DECREASE IN ACCESS TO SERVICES, ASSISTANCE, AND MONITORING
Since the end of 2019, Greek authorities have imposed legislation that restricts the operations of civil society
organisations (CSOs) working with displaced people and people on the move. The Council of Europe Expert
Council on NGO Law;33 three UN Special Rapporteurs;34 a report commissioned by the European Parliament
Committee on Civil Liberties, Justice and Home Affairs (LIBE);35 and the European Commission’s 2021 Rule of Law
Report36 all warned that Greek legislation contradicts European and international standards and legislation on
the freedom of association.
Greek authorities have, on several occasions, stated that they will deny access to reception facilities to NGOs that
do not register with the State.37 They insist this is in the interest of communities’ safety. However, authorities have
broad discretion in authorizing NGOs’ registration and deciding which organisations stay registered,38 and the
various critiques of the process call into question the validity of authorities’ decisions about which NGOs receive
this authorization.39 Thus, the authorities’ statements serve not as reassurance, but as a warning about the future
of access to services inside reception facilities. Indeed, a survey of 70 CSOs published in February 2021 found
that 20 organisations had been denied access to several existing camps already and 40 organisations had faced
increased difficulties reaching the people they support due to registration requirements.40
The Greek NGO legislation has had, and will continue to have, a chilling effect on organisations’ ability to operate
and access the MPRICs on the islands and camps on the mainland. Civil society action continues to be regulated by legislation that has been deemed not in line with international and EU law and standards. In addition,
authorities have broad discretion in authorizing NGOs’ registration and which organisations stay registered.41
As such, the new rules will also hinder NGOs’ ability to carry out their critical watchdog function—independent
organisations have been vital in highlighting gaps in protection, human rights violations, and the dire circumstances in reception facilities.42
33. Expert Council on NGO Law NGO Law (Council of Europe) ‘Opinion on the Compatibility With European Standards of Recent and Planned Amendments
to Greek Legislation on NGO Registration’ (2 July 2020) CONF/EXP(2020)4 Para 106
34. UN DOC OL GRC 1/2021
35. LIBE Committee (EU Parliament) ‘Protecting Civil Society Space: Strengthening Freedom of Association, Assembly and Expression and the Right to
Defend Rights in the EU’ (October 2020)
36. EU Commission ‘2021 Rule of Law Report Country Chapter on the Rule Law Situation in Greece’ COM (2021) 709 final
37. E
πιχείρηση – τάξη στις ΜΚΟ με κατάθεση νομοσχεδίου (Kathimerini, 7 June 2020) <link> accessed 17 November 2020; Notis Mitarakis (Facebook, 31 July
2020) <link> accessed 17 November 2020; Notis Mitarakis ‘Ξεκινά η λειτουργία του Μητρώου ΜΚΟ και μελών ΜΚΟ στο Υπουργείο Μετανάστευσης και
Ασύλου’ (Official website, 14 April 20202) <link> accessed on 20 November 2020; Ενημέρωση Πολιτικών Συντακτών από τον Υπουργό Μετανάστευσης και
Ασύλου κ. Νότη Μηταράκη (Ministry of Migration and Asylum, 12 October 2020) <link> accessed 27 November 2020
38. Choosing Love and Justice Limited ‘Under Pressure – How Greece is Closing in on Civil Society Organisations Working with Refugees’ (27 February 2021),
page 17-20
39. LIBE Committee (EU Parliament) ‘Protecting Civil Society Space: Strengthening Freedom of Association, Assembly and Expression and the Right to
Defend Rights in the EU’ (October 2020)
40. Choosing Love and Justice Limited ‘Under Pressure – How Greece is Closing in on Civil Society Organisations Working with Refugees’ (27 February 2021),
page 17-20
41. Choosing Love and Justice Limited ‘Under Pressure – How Greece is Closing in on Civil Society Organisations Working with Refugees’ (27 February 2021),
page 17-20
42. Choosing Love and Justice Limited ‘Under Pressure – How Greece is Closing in on Civil Society Organisations Working with Refugees’ (27 February 2021),
page 17-20
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