decision on their Applications of Suspension is issued.316 The examination/hearing of said legal remedies
(Applications for Annulment and for Suspension) had not been scheduled at the time of writing.
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. 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, 317 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, 318 the application for international protection is
considered to be lodged (κατατεθειμένη).319
The Asylum Code provides that such full registration shall take place no more than 15 working days from
the time of simple registration. More precisely, according to the Asylum Code, where “for whatever reason”
full registration is not possible, following a decision of the Director of the Asylum Service, the Receiving
Authorities may conduct a “simple registration” (απλή καταγραφή) of the asylum applicant’s necessary
details within 3 working days, and then proceed to the full registration by way of priority within a period of
not exceeding 15 working days from “simple registration”. 320 In such a case, upon “simple registration”,
the applicant receives a document indicating their personal details and a photograph, to be replaced by
the International Protection Applicant Card when their full registration is eventually carried out, i.e., upon
the lodging of the full application.321
According to the Asylum Code, if the application is submitted before a non-competent authority, that
authority is obliged to promptly notify the competent receiving authority and refer the applicant thereto. 322
An asylum application will not be considered properly lodged until it is fully registered by the Asylum
Service, as the competent authority.
For third-country nationals willing to apply for asylum while in detention, the competent Detention
Authorities shall ensure the immediate preparation and submission of a written declaration to that effect,
following which the detention authority must register (simple registration) the application on an electronic
network connected to the Asylum Service within three working days. 323
Moreover, according to the Asylum Code, the lodging of the application with the Receiving Authorities
must be carried out within seven working days after the “simple registration” by the detention authority or
the RIS.324 In order for the application to be fully registered, the detainee is transferred to the competent
RAO or AAU.325
Lodging of applications (“Κατάθεση”)
No time limit is set by law for lodging an asylum application. However, Article 83 of the Asylum Code
transposes Article 13 of the recast Asylum Procedures Directive that refers to applicants’ obligations and
foresees that applicants are required to appear before competent authorities in person, without delay, in
order to submit their application for international protection.
316
317
318
319
320
321
322
323
324
325
Greek Council for Refugees, Press Release, The Administrative Court of First Instance of Athens, as the
European Court of Human Rights had also ruled earlier, grants a suspension of removal from the country to
Sudanese refugees affected by the amendment imposing a 3-month suspension of access to asylum, 26-82025, available here; Refugee Support Aegean, Press Release, European Court of Human Rights blocks
deportation of refugees detained by Greece under unlawful asylum suspension, 18-8-2025, available here.
Article of Asylum Code.
Article 69(1) of Asylum Code.
Article 69(3) of Asylum Code.
Article 69(2) of Asylum Code.
Ibid.
Article 69(9) of Asylum Code.
Article 69(7) (b) of Asylum Code.
Ibid.
Ibid.
71
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