(b)
(c)
(d)
(e)
Beneficiaries of International Protection, published on 26 April 2016,777 without taking into
consideration its critical amendments, based on emergency measures;778
the letters, dated 2016, exchanged between the European Commission and Turkish
authorities,779
the letters, dated 2016, exchanged between the European Commission and the Greek
authorities,780
the 2016 letters of UNHCR to the Greek Asylum Service, regarding the implementation of Turkish
law about temporary protection for Syrians returning from Greece to Türkiye and
sources, indicated only by title and link, without proceeding to any concrete reference and legal
analysis of the parts they base their conclusions.
Although a number of more recent sources have been added to the endnotes of some decisions issued
since late 2018 and up until today, their content is not at all assessed or taken into account and
applications continue to be rejected as inadmissible on the same reasoning as before.781 For instance,
sources cited in decisions delivered by different IAC (Independent Appeals Committees) in the course of
2023 refer inter alia to the 2019 and 2020 updates of the Asylum Information Database (AIDA) country
report on Türkiye, to other reports published in 2017 and 2018, and to two letters sent by the Permanent
Delegation of Türkiye to the EU to the European Commission in April 2016 in the context of the EU-Turkey
Statement.782
777
778
779
780
781
782
National Legislative Bodies / National Authorities, Türkiye: Regulation on Work Permit of International
Protection Applicants and International Protection Status Holders, 26 April 2016, available at:
https://bit.ly/3oTLij3.
Venice Commission, Opinion No. 865 / 2016, Opinion on the Emergency Decree Laws Nos. 667-676 adopted
following the failed coup of 15 July 2016, adopted at its 109th plenary session, 9-10 December 2016, Doc.
CDL-AD(2016)037, available at: https://bit.ly/3uQDa6h; International Commission of Jurists, Türkiye: Justice
suspended, Access to justice and the State of Emergency in Türkiye, 2018, available at: https://bit.ly/3DlcsTi,
p. 2.
Letters between the European Commission and the Turkish and Greek authorities between April and July
2016, available at: https://bit.ly/4bbi6Y2.
Ibid.
Indicatively, some of the sources used by the GAS to reject applications even to this day, include: USDOS –
US Department of State, 2019 Report on International Religious Freedom: Syria, 10 June 2020,
https://tinyurl.com/4h8pc3u4; GIZ, Civil Society and State Engagement in the Refugee Response in Turkey:
Law and Regulations, 2021, https://tinyurl.com/96t3bbpr; UNHCR, Key information for Syrians, Temporary
protection in Turkey, undated, https://tinyurl.com/mwy238c6; European Council on Refugees and Exiles
(ECRE), Country report: Turkey - 2018 update, 30 April 2019, https://tinyurl.com/ye2x92tf; ACCORD, Türkiye
COI Compilation, August 2020, available at: https://bit.ly/3iKTfRv; Syrian Observatory for Human Rights,
Türkiye’s involvement in Libya war | 150 Syrian children recruited and sent to fight in Libya, 16 killed, May 13,
2020, available at: https://bit.ly/3iIE2QT; UD Department Of State, 2019 Country Reports on Human Rights
Practices: Türkiye, available at: https://bit.ly/3wMJaM1; EASO, Syria: Internally displaced persons, returnees
and internal mobility, April 2020, available at: https://bit.ly/46Jxx77; ECRE, Country Report: Türkiye, 2019
Update, April 2020, available at: https://bit.ly/3wKv5i6; European Commission, European Civil Protection and
Humanitarian Aid Operations, ECHO Factsheet Türkiye: Refugee Crisis, Last consulted on 17/05/2021,
available at: https://bit.ly/3JJyaml; Republic of Türkiye, Regulation on Work Permit of International Protection
Applicants and International Protection Status Holders, 26 April 2016 (Unofficial translation by UNHCR
Türkiye), available at: https://bit.ly/3Ti1ZlK; US Department of State, Country Report on Human Rights
Practices: Türkiye, 30 March 2021, https://bit.ly/3xonaaJ; European Commission, Türkiye 2020 Report
[SWD(2020) 355 final], 6 October 2020, available at: https://bit.ly/38aSyyW; UNHCR, Key information for nonSyrians, Livelihoods, undated, available at: https://bit.ly/3Djkufi; AAN, Afghan Exodus: Migrant in Türkiye left
to fend for themselves, 22 December 2020, available at: https://bit.ly/3LptQZT; UNHCR, Key information for
non-Syrians, Medical and psychological assistance, undated, available at: https://bit.ly/3iPQ8Yk; UNHCR, Key
information for non-Syrians, Education, undated, available at: https://bit.ly/3iLI9eY; UNHCR, Türkiye
Education Sector Achievements as of March 2021, March 2021, available at: https://bit.ly/3wRJ3z3; Respond,
Susan Beth Rottmann - Özyeğin University, Türkiye Country Report, Integration Policies, Practices and
Experiences, Global Migration: Consequences and Responses, Paper 2020/50, June 2020, available at:
https://bit.ly/3qJOJXE.
See, e.g., 2nd IAC, IP/142459/2023, 25 September 2023; 4th IAC, 79499/2023, 8 February 2023; 5th IAC,
39744/2023, 20 January 2023; 6th IAC, IP/312088/2023, 28 November 2023; IP/291367/2023, 21 November
2023; 8th IAC, 103648/2023, 20 February 2023; 11th IAC, IP/578/2023, 28 June 2023; 12th IAC,
168365/2023, 22 March 2023; 13th IAC, IP/113682/2023, 13 September 2023; 22148/2023, 13 January 2023;
14th IAC, IP/335367/2023, 6 December 2023; 250567/2023, 3 May 2023; 211179/2023, 11 April 2023; 15th
IAC, 300763/2023, 12 June 2023; 16th IAC, 85916/2023, 10 February 2023; 17th IAC, 297832/2023, 9 June
2023; 20th IAC, 91410/2023, 14 February 2023; 21st IAC, 87590/2023, 13 February 2023, as cited in ProAsyl
and RSA, “The concept of “Safe third country”. Legal standards and Implementation in the Greek Asylum
System, February 2024, available at: https://bit.ly/44fR5jV, p. 10, note 29.
162
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