Asylum (EUAA) with support from interpreters of the Agency. These officials are
identified in lodging forms not by name but by handwritten staff codes; “REG
[number]” and “EUAA [number]” respectively. This practice has no basis in the Asylum
Code, given that EUAA-deployed personnel may “offer support” to the RIS in reception
and identification procedures39 but may support only the Asylum Service in the lodging
of asylum claims “where urgent needs arise”. 40 The Asylum Code therefore does not
foresee the possibility for EUAA support to the RIS in the lodging of asylum applications.
In cases supported by RSA, all lodging forms indicate as “date & place of entry into
Greece” the RIC of Malakasa and the date of lodging, not the actual date of entry
and the point of entry into the country. Nevertheless, the “International Protection
Application Information” section includes the question “Tell us your point of entry in
Greece”. This field is filled by the correct point of entry. Similar issues have been
documented in the lodging of asylum applications by the RIS on the islands.41
In addition, the “International Protection Application Information” section of the RIS
lodging form contains a specific field relating to the application of the “safe third
country” concept based on the national list of safe third countries,42 with the question
“Tell us the reasons for your departure from Turkey”. In cases supported by RSA,
however, the reasons for applicants’ departure from Türkiye are written down by the
RIS in a rudimentary manner and as a summary rather than a verbatim account of their
statements. For instance, relevant reasons for leaving Türkiye have been recorded in
lodging forms as “fear of police and deportation” in the case of Rohullah*, “fear of
deportation” in the case of Habibi* and Reza*, “fear for my safety” in the case of
Shabnam*, “I just passed” in the case of Naiem* and “I only passed” in the case of
Nooria*. As for Zarifa*, the field in the form is empty.
Furthermore, after lodging has been completed, elements of the applicants’ case files
e.g. lodging form and Foreigner’s Health Card are uploaded on the Asylum Service
database (“Alkyoni”) with delay, due to challenges faced by the RIC of Malakasa in
promptly handling cases. Delays reach up to ten days, as was the case for Shabnam*
in December 2022, or even two weeks in the cases of Raheel*, Habibi* and Reza* in
January 2023.
Finally, according to a Decision of the Independent Authority for Public Revenue
(Ανεξάρτητη Αρχή Δημοσίων Εσόδων, AADE) which entered into force at the end of
December 2020, asylum seekers automatically receive a Tax Identification Number
(Αριθμός Φορολογικού Μητρώου, AFM) upon completing the lodging of their asylum
application.43 An AFM is automatically issued together with the International Protection
Applicant Card (Δελτίο Αιτούντος Διεθνή Προστασία, DADP) after the Responsible
Registration Authorities conduct the process online, and an AFM issuance certificate is
handed to the applicant.44 Yet, whereas it issues DADP, the RIC of Malakasa does not
39
40
41
42
43
44
Article 45 Asylum Code.
Article 69(16) Asylum Code.
RSA et al., The state of the border procedure on the Greek islands, September 2022, 13.
JMD 42799/2021, Gov. Gazette Β΄ 2425/07.06.2021, as amended and in force.
Articles 1(3) and 8 AADE Decision A1270/2020, Gov. Gazette Β΄ 5508/14.12.2020.
Article 2(1) AADE Decision A1270/2020.
12
RSA REPORT │ 2023
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