2. Access to NGOs and UNHCR Indicators: Access to NGOs and UNHCR 1. Do asylum seekers located at the border have effective access to NGOs and UNHCR if they wish so in practice? Yes With difficulty No 2. Do asylum seekers in detention centres have effective access to NGOs and UNHCR if they wish so in practice? Yes With difficulty No 3. Do asylum seekers accommodated in remote locations on the territory (excluding borders) have effective access to NGOs and UNHCR if they wish so in practice? Yes With difficulty No Access of NGOs to Reception and Identification Centres, camps on the mainland and pre-removal detention facilities is subject to prior permission by the competent authorities. Article 78 of the Asylum Code (Greek Law 4939/2022 ratifying the Code on reception, international protection of third-country nationals and stateless persons, and temporary protection in cases of mass influx of displaced persons) provides for the obligation of all Greek and International Organisations of Civil Society active in the field of refugee support and protection as well as their members to register in the established Registry of Greek and Foreign Non-Governmental Organisations (NGOs) in the Special Secretariat for the Coordination of Involved Agencies of the Ministry of Immigration and Asylum. NGOs that meet the minimum necessary conditions for participation as provided in the Asylum Code are registered by the competent service. Non-profit organisations, voluntary organisations and any corresponding organisation, Greek or international, that is not registered in the registry, may not participate in the implementation of international protection, immigration and social integration actions within the Greek territory, and in particular in the provision of legal, psychosocial and medical services. The Law also provides of an additional Registry of Members of Non-Governmental Organisations (NGOs) active in matters of international protection, immigration and social integration, in which the members, employees and partners of the above-described categories of organisations active in Greece are registered. The registration of these persons in the Registry and their certification is a necessary condition both for their activity within the Greek territory and for their cooperation with public bodies. In practice employees of NGOs and members whose name is not provided for in the registry are banned from entering places of detention and reception facilities under the Ministry’s responsibility. GCR is aware of several instances when access was refused to interpreters and on occasion lawyers or were obliged to wait for several hours before they were granted permission to enter. Concerning the lawfulness of these new registration requirements, ECRE’s Expert Opinion upon request from the ELENA Coordinator in Greece, published in December 2021,825 emphasizes that the registry has been heavily criticised by civil society organisations,826 the Council of Europe,827 and in the context of UN 825 826 827 ECRE, Expert Opinion upon request from the ELENA Coordinator in Greece concerning the lawfulness of Greek legislation regulating the registration of non-governmental organisations (NGOs) on the Registry of NGOs working with refugees and migrants in Greece, December 2021, available at: https://bit.ly/3yvt6xc. 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. 171