procedures and at “responding to practical challenges in the implementation of the law”. The proposed amendment further weakens basic guarantees for persons in need of protection. Inter alia, the draft law increases the number of applications which can be rejected as manifestly unfounded and introduces a set of provisions that can lead to arbitrary detention of asylum seekers and third country nationals. 22 The draft law was adopted by the Parliament on 9 May 2020, 23 despite concerns from human rights bodies, including the Council of Europe Commissioner for Human Rights and civil society organizations. 24 Further amendments were introduced by L. 4825/2021 voted in in September 2021. On June 2022, L. 4939/2022 “Ratification of the Code on reception, international protection of thirdcountry nationals and stateless persons, and temporary protection in cases of mass influx of displaced persons” (hereinafter Asylum Code) was adopted by the parliament, mainly codifying amendments introduced after 2019 (i.e. IPA etc), in one piece of legislation. First instance procedure Since September 2022, Asylum applications need to be lodged in Malakasa and Diavata Reception and Identification Centres (RICs), in the south and north of Greece respectively. Subsequent applications are lodged before the Regional Asylum Offices (RAO) across the country. The Asylum Service is also competent for applying the Dublin procedure, with most requests and transfers concerning family reunification in other Member States. The Asylum Service may be assisted by EUAA staff in registration and interviews. Effective Access to the asylum procedure still remains an issue of concern. First instance decisions rejecting an asylum application also include a removal order or incorporate a previous removal decision if this has been already issued. Following the issuance of the Joint Ministerial Decision (JMD) on 7 June 2021, which designated Türkiye as a safe third country for applicants from Syria, Afghanistan, Somalia, Pakistan and Bangladesh, applications submitted by applicants of these nationalities on the islands and in the mainland, are examined under the safe third country concept. This was renewed by another Joint Ministerial Decision in February 2022.25 A fast-track border procedure is applied to applicants subject to the EU-Türkiye statement, i.e. applicants arriving on the islands of Eastern Aegean islands after 20 March 2016. This takes place in the Reception and Identification Centres (RIC) where hotspots are established (Lesvos, Chios, Samos, Leros, Kos) and before the Rhodes RAO. Appeal First instance decisions of the Asylum Service are appealed before the Independent Appeals Committees under the Appeals Authority. An appeal must be lodged within 30 days in the regular procedure, 20 days in the accelerated procedure, in case of an inadmissibility decision or where the applicant is detained, 15 days in the Dublin procedure, 10 days in the border procedure and in the fast-track border procedure and 5 days in the case of an inadmissibility decision on a subsequent application. Appeals submitted against decisions rejecting applications in the accelerated procedure or dismissed as inadmissible on certain grounds do not have an automatic suspensive effect. The procedure before the Appeals Committees is as a rule written. 22 23 24 25 Ibid; See also GCR, ‘GCR’s comments on the draft law amending asylum legislation’, 27 April 2020, available at: https://bit.ly/2ywIMWa; RSA, ‘Comments on the Reform of the International Protection Act’, 23 April 2020, available at: https://bit.ly/2WrMwQR. L. 4686/2020, Gov. Gazette A' 96 /12 May 2020; Amendments introduced by L. 4686/2020 in May 2020 are not included in the present report. Council of Europe, Commissioner for Human rights, 7 May 2020. JMD 734214 (Gazette Β' 6250/12-02-2022). 28