step forward, with the potential for bringing positive results for both third country nationals and locals. As noted by the Representative of UNHCR in Greece:1086 These measures are a step in the right direction. They respond in a pragmatic manner to workforce needs in Greece’s productive sectors that remain unfulfilled and promptly puts asylumapplicants on the path to self-reliance and inclusion, which in the end will yield significant socioeconomic returns for all […] The amendment is a positive example of political will to dismantle barriers that render people invisible and marginalised, contributing to the broader prosperity of the Greek economy and society. As long as they hold a valid asylum applicant card, Article 57(2) Asylum Code provides them access to paid employment or the provision of services or work throughout the period of validity of the card. Applicants are also under an obligation to inform the competent reception authority of any professional activity they engage in (commencement of a profession, contract of employment), and submit relevant documentation. Failure to comply with this obligation can lead to the reduction or withdrawal of material reception conditions in accordance with Article 61 Asylum Code.1087 Lastly, the right is automatically withdrawn upon issuance of a negative decision which is not subject to an automatically suspensive effect, and applicants lack the right to stay on the Greek territory.1088 Notwithstanding this, in 2024, the unemployment rate in Greece remained higher (9.4%) compared to the EU27 (6.3%), particularly for women (11.6% in Greece compared to 6.5% for women in the EU27). 1089 Given that women in situations of forced displacement face greater obstacles in accessing the labour market, amongst others, due to the language barrier and other adverse circumstances, this percentage is estimated to be even higher for women asylum seekers.1090 All the above are interlinked with access of the asylum applicants and beneficiaries of international protection to public social insurance coverage. A legislative change in late 2023 introduced a – in many cases unsurmountable - challenge for asylum applicants in Greece. By virtue of Joint Ministerial Decision no. Φ80320/109864/14.12.2023, the activation of the social security number (AMKA) for adult beneficiaries of international protection, requires, as proof of residence, a certificate of employment, an employment contract or a commencement of work, uploaded in the ERGANI system,1091 in addition to the already existing obligation to prove one’s residence by a lease contract or a solemn declaration of a third person hosting the asylum seeker. The above regulation raises concerns regarding the treatment of beneficiaries of international protection and the safeguarding of their social rights that have been collectively addressed by CSOs in Greece to the competent Ministries.1092 In so far as it establishes a differential approach vis-à-vis beneficiaries, compared to nationals –which is also in breach of Articles 29 and 30 Asylum Code– it also introduces an additional layer to be considered under relevant infringement proceedings triggered by the European Commission in January 2023, whose outcome remains yet unknown. Obstacles in practice Data collected through an ongoing survey conducted under the coordination of UNHCR, between February 2022 and March 2024,1093 helps provide some further contextualisation to the challenges faced by asylum seekers in order to effectively access and remain in the Greek labour market. Namely, based on a total of 107 surveys carried out during the reference period with the participation of households in 1086 1087 1088 1089 1090 1091 1092 1093 UNHCR & IOM, UNHCR and IOM welcome new amendment facilitating access to labour for migrants and asylum-seekers, 19 December 2023, available at: https://tinyurl.com/39m8xwtk. Article 57(4) Asylum Code. Article 57(3) Asylum Code. See Eurostat indicators dashboard for Greece, available here. See also SolidarityNow,The Reality of Employment for Migrant Women in Greece, 2024, available here, 26. Joint Ministerial Decision no. Φ80320/109864/14.12.2023 of the Ministers of National Economy and Finance, Foreign Affairs, National Defense, Interior, Health, Labour and Social Security, Citizen Protection, Immigration and Asylum, Maritime and Island Policy and Digital Governance regarding the conditions and the procedure for the issuance, activation, deactivation and inactivation of the Social Security Number (AMKA), for the activation of the AMKA for adult beneficiaries of international protection, Article 6 par. 5b, available in Greek here. A letter sent on 15 July 2024 by NGOs participating at the Legal Aid Working Group is in GCR’s files and available upon request See UNHCR, Inter-Agency Protection Monitoring for Refugees in Greece: Key findings, available at: https://tinyurl.com/3z6t3y9f. For the data presented in this paragraph filters have been used, in order to only include the data arising from the surveys carried out with households that were clearly still in the asylum procedure or were waiting for their application to be registered. 202