As outlined below, Greek law refers to simple registration (απλή καταγραφή) to describe the notion of
“registration” and full registration (πλήρης καταγραφή) to describe the notion of “lodging” of an application
for international protection under the Directive.
On Friday 11 July 2025, the Hellenic Parliament adopted a legislative provision introduced by the Ministry
of Migration and Asylum (Article 79 of Law 5218/2025, Government Gazette Issue 125/A/14.07.2025312),
which came into force on 14 July 2025. The provision imposes a three-month suspension (from 14-072025 to 14-10-2025) on the “making”/registration of asylum applications by people arriving in Greece
illegally by any watercraft from North Africa and provides for their return to the country of origin or
departure, without registration of their asylum applications. Among others, the Greek Ombudsman,313 the
Greek National Commission for Human Rights,314, the Association of Administrative Judges,315 the
Council of Europe Commissioner for Human Rights,316 the UN High Commissioner for Refugees,317 as
well as 109 human rights organizations,318 have stressed that the amendment suspending access to
asylum for three months is incompatible with international refugee law, international human rights law,
and EU law, all of which are binding on Greece and allow no derogation from their application.
The Greek Council for Refugees 319 and other organizations visited the Pre-Departure Detention Center
(PROKEKA) in Amygdaleza, where third-country nationals, subject to the provision on the suspension of
asylum, who arrived in Gavdos (island south of Greece) from Libya, on 18 July 2025, have been
transferred and are being held. Return decisions have been issued against them and they remain in
immigration detention in view of the implementation of their removal. With support from GCR lawyers,
Sudanese detaines submitted to the PROKEKA officer on duty statements of intent to apply for asylum
so that the competent Asylum Service could be officially informed. Greek Authorities have refused to
register their asylum applications by invoking the legislative amendment suspending access to asylum.
On 12 August 2025, GCR lawyers representing 4 Sudanese asylum seekers submitted Applications for
Annulment and for Suspension,320 with a request for a temporary order, before the Administrative Court
of Athens against the return decisions as well as the administration’s refusal/omission to register their
asylum applications. Said legal remedies do not have an automatic suspensive effect. On 13 August 2025,
GCR lawyers representing the same Sudanese asylum seekers and RSA lawyers representing other
asylum seekers from Sudan submitted requests for interim measures (R39) before the European Court
of Human Rights (ECtHR). On 14 August 2025, the ECtHR granted interim measures under Rule 39,
indicating to the Greek Government not to remove them from the country until a decision on their
Applications of Suspension is issued by the Administrative Court of Athens. On 25 August 2025, the Judge
on duty of the Administrative Court of Athens accepted the request of temporary order of the Sudanese
asylum seekers, represented by GCR, and granted a suspension of removal from the country until a
decision on their Applications of Suspension is issued.321 The examination/hearing of said legal remedies
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Available in Greek here.
Greek Ombudsman, Statement, Υπόμνημα | Αναστολή υποβολής αιτημάτων ασύλου και αφίξεις πολιτών
τρίτων χωρών στην Κρήτη, 10-7-2025, available in Greek here.
Greek National Commission for Human Rights, Statement, Δήλωση της ΕΕΔΑ: Η αναστολή της υποβολής
αιτήσεων ασύλου και η παραβίαση του διεθνούς δικαίου, 11-7-2025, available in Greek here.
Association of Administrative Judges, Press Release, Για την τροπολογία περί αναστολής για 3 μήνες της
δυνατότητας υποβολής αιτήσεων χορήγησης ασύλου από άτομα που εισέρχονται στη χώρα παράνομα με
οποιοδήποτε πλωτό μέσο που προέρχεται από τη Βόρεια Αφρική, καθώς και της επιστροφής των ατόμων
αυτών, χωρίς καταγραφή, στη χώρα προέλευσης ή καταγωγής, 11-7-2025, available in Greek here.
Council of Europe Commissioner for Human Rights, Statement, The Commissioner urges the Greek
parliament to refrain from suspending the registration of asylum applications, 11-7-2025, available here.
UNHCR, Press release, UNHCR deeply concerned by Greece’s suspension of asylum applications, 10-72025, available here.
109 organisations call for the unlawful suspension of access to asylum in Greece to be immediately withdrawn,
Joint Statement, 16-7-2025, available here.
Greek Council for Refugees, Press Release, No right to asylum and living in appalling conditions: GCR visit
to Pre-departure Detention Center in Amygdaleza for those recently arrived in Gavdos from Libya, 30-7-2025,
available here.
Greek Council for Refugees, Press Release, GCR files legal remedies for refugees subject to the recent
amendment by the Ministry of Migration and Asylum on the suspension of asylum, 13-8-2025, available here.
Greek Council for Refugees, Press Release, The Administrative Court of First Instance of Athens, as the
European Court of Human Rights had also ruled earlier, grants a suspension of removal from the country to
Sudanese refugees affected by the amendment imposing a 3-month suspension of access to asylum, 26-8-
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