A 2021 general regulation covering the operation of the island CCACs inter alia foresees the possibility
to terminate accommodation and withdraw material reception if applicants are unjustifiably not identified
during the regular census-verification of the resident population for two consecutive times,964 although no
separate procedure is foreseen. The same provision is maintained under Article 9 of a 2023 General
Regulation for the Operation of the CCACs.965
In practice
Between June and December 2020, reception conditions were withdrawn in the case of 4,957 people,
2,964 of whom were accommodated in camps, and 2.033 in the former ESTIA accommodation scheme
(2,033), following status recognition or after a second instance negative decision. Data on decisions
reducing or withdrawing material reception conditions have since not been provided by the MoMA, even
though GCR has requested it on a yearly basis. Instead, following the latest such request sent by GCR in
December 2024, the MoMA replied by referring GCR to the Ministry’s website “and in particular at the link
https://migration.gov.gr/statistika/ [where] the monthly newsletters are published, alongside relevant
annexes, which include summary and detailed statistical data on the work of the First Reception Service,
the Asylum Service and the Appeals Authority […]”966. Yet, a closer look at the public sources referred to
by the MoMA highlights that the specific data is not available.
Applicants have the right to lodge an appeal (προσφυγή) against decisions that reduce or withdraw
reception conditions before the Administrative Courts. In the case of appeal before the Courts, applicants
also have a right to free legal aid and representation. 967 However, as explained further below, the remedy
provided by this provision is not available in practice.
4. Freedom of movement
Indicators: Freedom of Movement
1. Is there a mechanism for the dispersal of applicants across the territory of the country?
Yes
2. Does the law provide for restrictions on freedom of movement?
Yes
No
No
Asylum applicants may move freely within the territory of Greece or an area (περιοχή) assigned by a
regulatory (κανονιστική) decision of the Minister of Migration and Asylum 968 (formerly, the Minister of
Citizen Protection). This geographical restriction of freedom movement within a particular area should not
affect the inalienable sphere of private life and should not hinder the exercise of rights provided by the
law.969
Following the entry into force of the IPA, on 1 January 2020, and subsequently the Asylum Code that
replaced it, asylum applicants’ freedom of movement can also be restricted through assignment to a
specific place (τόπος), only if this is necessary for the swift processing and effective monitoring of the
applications for international protection or for duly justified reasons of public interest or reasons of public
order. This restriction is imposed by the Head of the Asylum Service and is mentioned on the asylum
applicants’ cards.970 Applicants who are subject to this type of restriction are provided with material
reception conditions, as long as they reside within the place indicated and, in case of non-compliance,
the provision of material reception conditions is interrupted in accordance with Article 61 of the Asylum
Code971.
Applicants are required to immediately notify the competent authorities of any changes to their place of
residence for as long as the examination of their asylum application is pending. 972
964
965
966
967
968
969
970
971
972
Article 7 (2) Decision 25.0/118832 of the General Secretary of Reception of the MoMA, Gov. Gazette
3191/B/20.7.21, available in Greek at: https://bit.ly/3XwiTz8.
Article 9 (2) Decision 553695/2023 of the General Secretary of Reception of the MoMA, Gov. Gazette
7533/B/31.12.23, available in Greek at: https://bit.ly/4beC3fU.
MoMA, Analysis and Studies Office, Information provision for the preparation of the updated Annual Report
on Greece for 2024 in the framework of the Asylum Information Database (AIDA) project., 10 January 2025.
Article 118 (1) and (2) Asylum Code.
Article 49 (1) Asylum Code.
Ibid.
Article 49(2) Asylum Code.
Article 49(3) Asylum Code.
Article 49(6) Asylum Code.
184
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