3: BARRIERS TO ACCESSING THE PROCEDURE
This chapter covers the challenges people face obtaining and attending asylum registration appointments
at the RICs of Diavata and Malakasa. Respondents reported a number of barriers to accessing the
procedure, including lack of information on how to apply, frequent technical issues or unavailability of the
online platform for booking appointments, and the remote location of the RICs, leading to challenges
relating to the time and cost of travel, and well-founded fears of apprehension and detention. Vulnerable
people were impacted by the lack of a standard procedure for identifying and prioritising the registration
of their cases.
(A) Lack of information on the procedure
Respondents reported a lack of information and guidance on the procedure for applying for
asylum in Greece. Despite the provisions of Greek law (Art. 39 and Art. 47, 4939/2022), no
respondents reported receiving information from Greek authorities regarding how to apply for
asylum and their rights and obligations in the procedure. Rather, most applicants received this
information from CSOs and their social networks. This finding is corroborated by data collected
by UNHCR in 2022-2023,⁴⁹ which evidenced that beneficiaries of international protection
primarily received information on their rights in the Greek asylum system from other refugees
(43% of respondents), the internet (34%) and CSOs (27%). Chronic lack of information provided
by the authorities is a persistent and long-standing issue in the Greek asylum system, reported on
by CSOs for several years.⁵⁰
The frequent changes in Greece’s asylum system in recent years was an additional factor
contributing to people’s confusion regarding how to access the new procedure. Greek lawyers
additionally reported that, for applicants who have been living in Greece for some years,
constant changes to the system and persistent dysfunction has eroded trust and motivation to
apply.
(B) Appointment delays and unavailability
50% of respondents who successfully booked an appointment at a mainland RIC reported a
waiting time of two months or more for their registration appointment.
Rulings by Greek courts have established that booking an appointment amounts to “making” an
asylum application.⁵¹ Consequently, waiting times well exceeded the deadlines laid out in Greek
law, which states that the authorities must register claims immediately or at least pre-register
within three working days after making (Art. 69(1-2), 4939/2022).
The inability to meet deadlines set out in the law for the registration of both first instance and
subsequent asylum applications has been a chronic issue in Greece for years. The absolute
maximum deadline of 15 days for full registration has been consistently exceeded, including in
20
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