Reception and Identification Centres and Mobile Reception and Identification Units (Γενικός Κανονισμός
Λειτουργίας Κέντρων Υποδοχής και Ταυτοποίησης και Κινητών Μονάδων Υποδοχής και Ταυτοποίησης).
In the first case, the procedure foresees: (a) a written warning and (b) a reasoned decision reducing or
withdrawing material reception conditions, while in the second case a three-step procedure is foreseen,
consisting of (a) an oral recommendation, (b) a written warning and (c) the interruption of accommodation
as long as reception and identification procedures have been completed. 694
Lastly, a new regulation covering the newly established Closed-Controlled Facilities on the islands was
issued in 2021. This regulation inter alia foresees the possibility to terminate accommodation and
withdraw material reception if applicants are unjustifiably not identified during the regular censusverification of the resident population for two consecutive times, 695 albeit no separate procedure is
foreseen.
Between June and December 2020, reception conditions were withdrawn in the case of 4,957 people,
2,964 of whom were accommodated in camps, and 2.033 in the ESTIA accommodation scheme (2,033),
following status recognition or after a second instance negative decision. Data on decisions reducing or
withdrawing material reception conditions have since not been provided by the MoMA, even though GCR
has requested it.
Applicants have the right to lodge an appeal (προσφυγή) against decisions that reduce or withdraw
reception conditions before the Administrative Courts. In the case of appeal before the Courts, applicants
also have a right to free legal aid and representation. 696 However, as explained further below, the remedy
provided by this provision is not available in practice.
4. Freedom of movement
Indicators: Freedom of Movement
1. Is there a mechanism for the dispersal of applicants across the territory of the country?
Yes
2. Does the law provide for restrictions on freedom of movement?
Yes
No
No
Asylum seekers may move freely within the territory of Greece or an area (περιοχή) assigned by a
regulatory (κανονιστική) decision of the Minister of Migration and Asylum697 (formerly, the Minister of
Citizen Protection). This geographical restriction of freedom movement within a particular area should not
affect the inalienable sphere of private life and should not hinder the exercise of rights provided by the
law.698
Following the entry into force of the IPA, on 1 January 2020, and subsequently the Asylum Code that
replaced it, asylum seekers’ freedom of movement can also be restricted through assignment to a specific
place (τόπος), only if this is necessary for the swift processing and effective monitoring of the applications
for international protection or for duly justified reasons of public interest or reasons of public order. This
restriction is imposed by the Head of the Asylum Service and is mentioned on the asylum seekers’
cards.699 Applicants who are subject to this type of restriction are provided with material reception
conditions, as long as they reside within the place indicated and, in case of non-compliance, the provision
of material reception conditions is interrupted in accordance with article 61 of the Asylum Code 700.
694
695
696
697
698
699
700
Article 18 (1) Ministerial Decision 23/13532/2020, Gov. Gazette, 5272/Β’/30.11.2020 and article 10(1) Joint
Ministerial Decision 1/7433/10-6-2019, Gov. Gazette 2219/B/10.6.2019.
Article 7 (2) Decision 25.0/118832 of the General Secretary of Reception of the MoMA, Gov. Gazette 3191/B/
20.7.21.
Article 118 (1) and (2) Asylum Code.
Article 49 (1) Asylum Code.
Ibid.
Article 49(2) Asylum Code.
Article 49(3) of L 4939/2022.
152
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