less than 25 days, newly arrived persons were released and the majority were referred by the RIS to open
reception facilities in the mainland, with the exception of UAMs who continued to remain in the RIC,
pending their placement and transfer to a shelter for minors. However, individuals who had been convicted
upon arrival by Greek Penal Courts (i.e. for illegal entry) or who had had penal charges brought against
them were not released, but referred to pre-removal facilities in the mainland (mostly in PRDF of Xanthi
and Paranesti), where they remain detained on alleged public order grounds. .
By the end of September 2022, 305 UAMs (279 boys and 26 girls) were registered by the RIS in Evros. 177
During 2022 the waiting period for the placement of UAMs in a ‘restriction of liberty status’ (namely in
protective custody or in the RIC) to shelters for minors remained short. According to official data available,
the average waiting time for the placement was 7.64 days. However, the average waiting time for the
placement of UAMs in protective custody was 2.25 days in 2022.178 Transfers to shelters for minors may
be conducted with delays of up to 2-3 months.
3. Registration of the asylum application
Indicators: Registration
1. Are specific time limits laid down in law for making an application?
❖ If so, what is the time limit for making an application?
Yes
No
2. Are specific time limits laid down in law for lodging an application?
❖ If so, what is the time limit for lodging an application?
Yes
No
3. Are making and lodging an application distinct stages in the law or in practice?
Yes
No
4. Is the authority with which the application is lodged also the authority responsible for its
examination?
Yes
No
5. Can an application for international protection for international protection be lodged at embassies,
consulates or other external representations?
Yes
No
3.1
Rules for the registration and lodging of applications
Article 69 of Asylum Code transposes Article 6 of the recast Asylum Procedures Directive relating to
access to the procedure.
As outlined below, Greek law refers to simple registration (απλή καταγραφή) to describe the notion of
“registration” and full registration (πλήρης καταγραφή) to describe the notion of “lodging” of an application
for international protection under the Directive.
Registration of applications for international protection (“Καταγραφή”)
Article 69(1) of the Asylum Code provides that any foreigner or stateless person has the right to “make”
an application for international protection. In this case, the application is submitted before the competent
receiving authorities, i.e. the Regional Asylum Offices (RAO), the Autonomous Asylum Units (AAU) or the
Mobile Asylum Units of the Asylum Service or the Regional Reception and Identification Services, 179
depending on their local jurisdiction, which shall immediately proceed with the “full registration” (πλήρης
καταγραφή) of the application.
Following the “full registration” of the asylum claim,180 the application for international protection is
considered to be lodged (κατατεθειμένη).181
177
178
179
180
181
https://bit.ly/40KHON5
Data available to GCR by the Special Secretariat for the Protection of Unaccompanied Minors of the MoMA,
as of 16-02-2023
Article of Asylum Code.
Article 69(1) of Asylum Code.
Article 69(3) of Asylum Code.
51
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