themselves in one of the two registration facilities in Diavata (Thessaloniki) or Malakasa (Attica)
to complete registration of their application. However, access to the online platform is not always
possible, in some cases appointments for registration are assigned many months later, and
applicants while waiting for the day of their appointment are not protected from detention and do
not have access to reception conditions. Lastly, once they present themselves at the registration
facilities, they may be subject to de facto detention for a period up to 25 days, contrary to the
requirements of Art. 8 of the Reception Directive. Access to the asylum procedure for persons
detained in pre-removal centres remains also a matter of concern.
❖ Subsequent applications: Subsequent applications after the first one are subject to a fee of
EUR 100 per applicant and, in case of families, EUR 100 per family member. Greece is the only
EU Member State which requires payment of a fee to lodge a subsequent application, thereby
raising concerns as to access to the asylum procedure. An Application for Annulment of the
relevant JMD has been filled by GCR and RSA before the Council of State and was still pending
at time of publication of this report.
❖ Processing times: The number of the pending asylum applications decreased in 2022. Despite
this, at the end of 2022, almost 1 out of 4 pending applications had been pending for over 12
months. Out of the total number of 17,249 applications pending at the end of 2022, 10,781
(62.50%) had been pending for under 6 months, 2,334 (13.53%) had been pending for over 6
months and 4,134 (23.74%) had been pending for over 12 months.
❖ Legal assistance: No state-funded free legal aid is provided at first instance, nor does the law
establish an obligation to provide it. A state-funded legal aid scheme operates for the appeal
procedure, on the basis of a registry of lawyers managed by the Asylum Service. However,
obstacles in accessing free legal aid continued to be reported, inter alia because of the
digitalisation of the procedure and the fictitious service of negative first instance decisions. Less
than 1 out of 2 appellants received legal assistance under the free legal aid scheme in 2022. Out
of the 16,830 appeals lodged against Asylum Service decisions in 2022, legal assistance in the
appeals procedure was provided in 7,925 (47.08%) cases.
❖ Second instance procedure: Most appeals are rejected at second instance. Out of the total inmerit second instance decisions issued in 2022 (8,939), 7.4% resulted in the granting of refugee
protection, 4.4% resulted in the granting of subsidiary protection and 88.19% resulted in a
negative decision. During 2022, 1,790 appeals were rejected as “manifestly unfounded” without
an in-merit examination, due to the fact that the appellants did not comply with the obligation of
an in-person appearance of the appellant or their appointed lawyer before the Committee, or to
present a certification of residence to the Committee, which constitutes a disproportionate
administrative burden imposed to the appellants. Appeals against decisions rejecting the
application in the accelerated procedure or as inadmissible under certain grounds do not have
automatic suspensive effect, despite the fact that these decisions also incorporate a return
decision with immediate effect.
❖ Dublin: Additional obstacles to family reunification under Dublin continued to occur in 2022 due
to restrictive practices (requirements for official translations of documents proving family links,
sometimes unnecessary DNA tests, age assessments of unaccompanied children to be
conducted according to the requested state’s methods) adopted by a number of receiving
Member States, which may undermine the right to family life. A total of 1,077 Dublin transfers
were implemented in 2022, compared to 2,133 in 2021. By the end of 2022, 5,164 individuals in
total, including 1,333 unaccompanied children had been relocated to another EU Member States
under the voluntary relocation scheme, launched by the EU Commission in March 2020.
❖ Safe third country inadmissibility: In 2021, by a JMD Greece designated Türkiye as a “safe
third country” for asylum seekers originating from Syria, Afghanistan, Pakistan, Bangladesh and
Somalia, despite the fact that no readmissions to Türkiye have taken place since March 2020. As
a result, applications for international protection lodged by persons of said nationalities throughout
20
Select target paragraph3
Connect to a paragraph
Connect to an entity
Disable highlights
Add to table of contents