been heavily criticised by civil society organisations,888 the Council of Europe,889 and in the context of UN Special Procedures,890 and it has also been the subject of a question at the European Parliament. 891 The criticism focuses on the lack of meaningful public consultation before the adoption of the framework, the excessive requirements for registration/certification, which serves as a precondition for NGOs to be able to operate in Greece in the field of international protection, migration and social inclusion, the introduction of seemingly unlimited discretion to deny registration or remove NGOs from the registry on the basis of vague criteria, and the absence of effective remedies. According to the reports, such a framework can interfere with the freedom of association by establishing a situation of legal uncertainty and restricted guarantees that could create significant obstacles in the free development of NGO activities in Greece. As of October 2021, at least three refugee-assisting organisations have been denied registration. The Greek Ombudsperson has since called for the re-examination of the rejection decision as it found that it resulted in violation of national, EU and international law”.892 An annulment application was lodged by Equal Rights Beyond Border and HIAS Greece before the Council of State against JMD 10616/2020 establishing the aforementioned NGO Registry and is still pending before the Council of State. 893 On 6 November 2023, RSA requested statistical data on the number of organisations and individuals approved, rejected and/or de-registered from the Registry since its establishment, but the request received no reply by the MoMA.894 UNHCR is present in Athens, Lesvos, Chios, Samos, Kos, Thessaloniki, and Evros covering through physical presence, field missions and ad hoc visits all sites in their area of responsibility. 895 UNHCR’s teams continue to assist new arrivals by helping them gain access to necessary services, and by providing them with information on procedures, rights and obligations. Asylum applicants can access UNHCR as well as other organisations through a variety of means. UNHCR has established the UNHCR HELP Website providing information on how to apply for asylum, cash assistance, family reunification, access to employment and other important elements. According to the announcement, the website is updated on a regular basis, including with a section of ‘Latest Announcements’ for all the recent news,896 events and opportunities relevant for refugees and asylum seekers in Greece. UNHCR maintains a WhatsApp automatic information system, a Facebook page and UNHCR Protection HelpDesk.897 Helplines are also provided depending on the refugees whereabouts providing information and assistance.898 After the Covid pandemic several helplines and helpdesks remain 888 889 890 891 892 893 894 895 896 897 898 Amnesty international, Greece: Regulation of NGOs working on migration and asylum threatens civic space, 31 July 2020, available at: https://bit.ly/3rsGjVW; RSA, Risk of Repression: New Rules on Civil Society Supporting Refugees and Migrants in Greece, available at: https://bit.ly/31dyTLH, p. 3; RSA, Repression Continued: Greece Further Restricts Civil Society Supporting Refugees and Migrants, September 2020, available at: https://bit.ly/3J0OL6N; HIAS Greece, Some thoughts on the new Joint Ministerial Decision, regulating the registration of migration-related NGOs in Greece, 8 May 2020, available at: https://bit.ly/3OYVm5E. CoE Commissionner for Human Rights, Letter of Commissioner for Human Rights, 3 May 2021, available at: https://bit.ly/3MSLWGb; Council of Europe, Expert Council on NGO Law of the Conference of INGOs, Opinion on the compatibility with European standards of recent and planned amendments to the Greek legislation on NGO registration, 6 July 2020, available at: https://bit.ly/3WP56RL and Addendum to that opinion, 23 November 2020, available at: https://bit.ly/3NcGpeU. OHCHR, Letter to Greece by the Special Rapporteur on the rights to freedom of peaceful assembly and of association; the Special Rapporteur on the situation of human rights defenders; and the Special Rapporteur on the human rights of migrants, 31 March 2021, available at: https://tinyurl.com/y5mnekua. European Parliament, Follow-up to the letter from the Committee on Civil Liberties, Justice and Home Affairs regarding Greece’s NGO registration law (JMD 10616/2020), 16 October 2020, available at: https://rb.gy/7kt7jr. RSA, Ombudsman calls for re-examination of rejection of RSA’s registration on the NGO Registry, 13 December 2021, available at: https://bit.ly/3MSpU7o. For more information, see HIAS Greece and RSA, Joint Civil Society Submission to the European Commission on the 2023 Rule of Law Report, Rule of Law Backsliding Continues in Greece, January 2023, available at: https://tinyurl.com/54h5wr88, paras 69-74. Vouliwatch et.al., Greece in Institutional Decline: Joint Civil Society Submission to the European Commission on the 2024 Rule of Law Report, January 2024, available at: https://tinyurl.com/29tusvpv, para. 121. UNHCR, About UNHCR in Greece, available at: https://bit.ly/428wpYa. Available here. UNHCR, Information on the road with you, available at: https://bit.ly/3BQAK7V. See UNHCR, Contact us, available at: https://bit.ly/3MvAsYT. 173