lower protection standards and create unwarranted procedural and substantive hurdles for people seeking international protection. As noted by UNHCR, the new Law reduces safeguards for people seeking international protection and creates additional pressure on the overstretched capacity of administrative and judicial authorities. The agency stated inter alia that “as a result, asylum seekers may be easily excluded from the process without having their international protection needs adequately assessed. This may expose them to the risk of refoulement”.25 On 10 April 2020, four months after the entry into force of the new law, the Ministry of Migration and Asylum submitted a bill entitled “Improvement of migration legislation”, aiming at speeding up asylum procedures and at “responding to practical challenges in the implementation of the law”. The proposed amendment further weakens basic guarantees for persons in need of protection. Inter alia, the draft law increases the number of applications which can be rejected as manifestly unfounded and introduces a set of provisions that can lead to arbitrary detention of asylum seekers and third country nationals.26 The draft law was adopted by the Parliament on 9 May 2020,27 despite concerns from human rights bodies, including the Council of Europe Commissioner for Human Rights and civil society organisations.28 Further amendments were introduced by L. 4825/2021 and adopted in September 2021. In June 2022, L. 4939/2022 “Ratification of the Code on reception, international protection of third-country nationals and stateless persons, and temporary protection in cases of mass influx of displaced persons” (hereinafter Asylum Code) was adopted by the parliament, mainly codifying amendments introduced after 2019 (i.e., IPA, etc.), in one piece of legislation. First instance procedure Since September 2022, Asylum applications need to be lodged in Malakasa and Diavata Reception and Identification Centres (RICs), in the south and north of Greece respectively. Subsequent applications are lodged before the Regional Asylum Offices (RAO) and Asylum Units (AU) across the country. The Asylum Service is also competent for applying the Dublin procedure, with most requests and transfers concerning family reunification in other Member States. The Asylum Service may be assisted by EUAA staff in registration and interviews. Effective access to the asylum procedure still remains an issue of concern. First instance decisions rejecting an asylum application also include a removal order or incorporate a previous removal decision if one had already been issued. Following the issuance of the Joint Ministerial Decision (JMD) on 7 June 2021, which designated Türkiye as a safe third country for applicants from Syria, Afghanistan, Somalia, Pakistan and Bangladesh,29 applications submitted by applicants of these nationalities on the islands and in the mainland, are examined under the safe third country concept. In December 2021, the JMD was amended to include Albania and North Macedonia in the list of safe third countries, covering applicants arriving form the respective territories.30 Since then, application of the safe third country concept in the specific cases has 25 26 27 28 29 30 in Greek at: https://bit.ly/3dWduqV, RSA, RSA Comments on the International Protection Bill, 21 October 2019, available at: https://bit.ly/2LCfJU7; Actionaid Greece et al, 15 civil society organisations call upon the Government to organise a substantial public consultation prior of voting the draft law on asylum, 31 October 2019, available in Greek at: https://bit.ly/2Zf4tFe; Amnesty International et al., Joint press conference regarding the draft law on asylum, 30 October 2019, available at: https://bit.ly/3bDUgVr. UNHCR, ‘UNHCR’s Intervention at the hearing for actors to the Standing Committee of Public Administration, Public Order and Justice of the Hellenic Parliament regarding the Draft Law on the Improvement of Migration Legislation’, 9 May 2020, available at: https://bit.ly/3dJEB8H. Ibid.; See also GCR, GCR’s comments on the draft law amending asylum legislation, 27 April 2020, available at: https://bit.ly/2ywIMWa; RSA, RSAComments on the Reform of the International Protection Act, 23 April 2020, available at: https://bit.ly/2WrMwQR. L. 4686/2020, Gov. Gazette A' 96 /12 May 2020; Amendments introduced by L. 4686/2020 in May 2020 are not included in the present report. Council of Europe, Commissioner for Human rights, 7 May 2020, available at: https://bit.ly/3PLbmYf. Article 1 JMD 42799/2021 on the Determination of third countries designated as safe and establishment of a national list, as defined in Article 86 L. 4636/2019, available in Greek at: https://bit.ly/4aGni5U. Article 1 (B) and (C) JMD 458568/2021, available in Greek at: https://bit.ly/4aGnnGK. 32