assurances on immediate uploading of ADET renewal applications on the “Alkyoni” database. 1280 However, in practice, and despite the letter of the Director of the Asylum Service explicitly stating that renewal applications are given a protocol number within 5 days from their submission via e-mail, this is not the case.1281 It is noted that the applicant beneficiary of international protection is not informed of the upload of their application in the system, so as to be able to submit a request for the issuance of attestation of application status. Nor are they informed of the protocol number assigned to their application, which they only become aware of upon receipt of the certificate, where it is indicated. In April 2023, there was a positive legal amendment of Greece’s Migration Code (L. 5038/2023). According to Article 9 (ι), in conjunction with Article 11(10) L. 5038/2023, a certificate similar to the one issued for immigrants who apply for the renewal of a residence permit must be issued to beneficiaries of international protection pending the issuance of their renewed residence permits. This provision has not yet been implemented in practice and beneficiaries of international protection still face the same obstacles in accessing their rights. It is worth noting that beneficiaries are never served their official renewal decision. They are simply notified by the Asylum Service via email that the renewal of their residence permit has been accepted. This notification also outlines the procedure that they ought to follow to submit the required documentation before the competent Alien’s Directorate for the issuance of their renewed residence permit. In practice, after the notification email is sent, beneficiaries need to follow the exact same procedure they followed for the initial issuance of their residence permit. For the delivery of their renewed residence permits, the Asylum Service does not notify the beneficiaries individually. It uploads on its website a list of case numbers for which the renewed ADET are ready for collection on an indicated day. Therefore, beneficiaries have to regularly consult the lists online, until they can find an entry corresponding to their individual case number. However, the lists of the renewed residence permits are announced on the same segment of the website of the Ministry as the residence permits that are issued for the first time. This creates an enormous confusion to beneficiaries considering that the residence permit guidelines of the Asylum Service advise them to consult the list of the renewed residence permits. Only the RAO of Chios uploads the lists of the renewed ADET on the specific platform created for this purpose, contrary to practice followed by other RAOs / AAUs.1282 Returnees from other countries who may have been granted status several years before the establishment of certain RAOs and AAUs face many obstacles upon their return to Greece. In particular, returnees arriving at the Athens International Airport do not receive clear and accurate information on the authorities they should approach in order to obtain or renew their documents and to access their legal rights.1283 In addition, they face long delays in the issuance of decisions on the renewal of residence permits, as specific checks are carried out, inter alia, on any possible criminal convictions in the country from which they have been sent back. As per data published by the MoMA,1284 a total of 148,036 applications for renewal were submitted throughout 2025, the majority of which (74.4%) were still pending at the end of the year. However, due to a lack of a relevant breakdown in the data, it is impossible to assess the percentage of these that specifically concerned beneficiaries of international protection. For beneficiaries of international protection who applied for international protection before 7 June 2013 (“old procedure”), the competent authority for the renewal procedure is the Headquarters of the Hellenic Police (Αρχηγείο Ελληνικής Αστυνομίας). Specifically, the renewal procedure is conducted through the 1280 1281 1282 1283 1284 RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece, Access to documents and socioeconomic rights, March 2023, available at: https://bit.ly/45y1CY1, p. 7. Letter of Director of the Asylum Service, Renewal of identity documents of beneficiaries of international protection, prot. no. 58515/16.02.2024. The original letter is available at GCR. MoMA, Initial Residence Permits that are Ready, available at: https://bit.ly/3QiENRL. The separate page for renewed residence permits is available at: https://bit.ly/4aOprgn. Also see RSA and Stiftung Pro Asyl, Recognised refugees in Greece 2025, March 2025, available at: https://tinyurl.com/3emyk5w3, p. 36 et seq. MoMA, Statistics: Consolidated Reports – Overview, December 2025 – Legal Migration | Appendix B, available in Greek at: https://migration.gov.gr/statistika/, Table 4a. 256

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