Special Procedures,828 and it has also been the subject of a question at the European Parliament.829 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 Ombudsman 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”.830 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.831 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, yet the request received no reply by the MoMA.832 UNHCR is present in Athens, Lesvos, Chios, Samos, Kos, Thessaloniki, covering through physical presence, field missions and ad hoc visits all sites in their area of responsibility.833 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 seekers 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 as well as a UNHCR WhatsApp automatic information system. and UNHCR Protection HelpDesk834 Helplines are also provided depending on the refugees whereabouts providing information and assistance.835 After the Covid pandemic several helplines and helpdesks were established by the majority of actors allowing asylum seekers and recognised refugees to access information and services remotely.836 828 829 830 831 832 833 834 835 836 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 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. UNHCR, Information on the road with you, available at: https://bit.ly/3BQAK7V. See UNHCR, Contact us, available at: https://bit.ly/3MvAsYT. i.e., National service map, available at: https://bit.ly/3QdLFQz; City of Athens, Targeted support and assistance to asylum seekers and beneficiaries of international protection with disabilities, available at: https://bit.ly/3ICrSpX, and Caritas ADAMA center, available at:: https://bit.ly/3BT7YDn; GCR Helpline, information available at: https://bit.ly/3WvGyNo; EPAPSY Psychosocial Support (PSS) Helpline, KEM Athens heldesk , Refugee.Info website - Facebook HelpLine, Lighthouse Relief Helpline & Information point, CARITAS Social Spot at Neos Kosmos. 172