themselves in one of the two registration facilities in Diavata (Thessaloniki) or Malakasa (Attica) to complete registration of their application. However, access to the online platform is not always possible, in some cases appointments for registration are assigned many months later, and applicants while waiting for the day of their appointment are not protected from detention and do not have access to reception conditions. Lastly, once they present themselves at the registration facilities, they may be subject to de facto detention for a period up to 25 days, contrary to the requirements of Art. 8 of the Reception Directive. Access to the asylum procedure for persons detained in pre-removal centres remains also a matter of concern. ❖ Subsequent applications: Subsequent applications after the first one are subject to a fee of EUR 100 per applicant and, in case of families, EUR 100 per family member. Greece is the only EU Member State which requires payment of a fee to lodge a subsequent application, thereby raising concerns as to access to the asylum procedure. An Application for Annulment of the relevant JMD has been filled by GCR and RSA before the Council of State and was still pending at time of publication of this report. ❖ Processing times: The number of the pending asylum applications decreased in 2022. Despite this, at the end of 2022, almost 1 out of 4 pending applications had been pending for over 12 months. Out of the total number of 17,249 applications pending at the end of 2022, 10,781 (62.50%) had been pending for under 6 months, 2,334 (13.53%) had been pending for over 6 months and 4,134 (23.74%) had been pending for over 12 months. ❖ Legal assistance: No state-funded free legal aid is provided at first instance, nor does the law establish an obligation to provide it. A state-funded legal aid scheme operates for the appeal procedure, on the basis of a registry of lawyers managed by the Asylum Service. However, obstacles in accessing free legal aid continued to be reported, inter alia because of the digitalisation of the procedure and the fictitious service of negative first instance decisions. Less than 1 out of 2 appellants received legal assistance under the free legal aid scheme in 2022. Out of the 16,830 appeals lodged against Asylum Service decisions in 2022, legal assistance in the appeals procedure was provided in 7,925 (47.08%) cases. ❖ Second instance procedure: Most appeals are rejected at second instance. Out of the total inmerit second instance decisions issued in 2022 (8,939), 7.4% resulted in the granting of refugee protection, 4.4% resulted in the granting of subsidiary protection and 88.19% resulted in a negative decision. During 2022, 1,790 appeals were rejected as “manifestly unfounded” without an in-merit examination, due to the fact that the appellants did not comply with the obligation of an in-person appearance of the appellant or their appointed lawyer before the Committee, or to present a certification of residence to the Committee, which constitutes a disproportionate administrative burden imposed to the appellants. Appeals against decisions rejecting the application in the accelerated procedure or as inadmissible under certain grounds do not have automatic suspensive effect, despite the fact that these decisions also incorporate a return decision with immediate effect. ❖ Dublin: Additional obstacles to family reunification under Dublin continued to occur in 2022 due to restrictive practices (requirements for official translations of documents proving family links, sometimes unnecessary DNA tests, age assessments of unaccompanied children to be conducted according to the requested state’s methods) adopted by a number of receiving Member States, which may undermine the right to family life. A total of 1,077 Dublin transfers were implemented in 2022, compared to 2,133 in 2021. By the end of 2022, 5,164 individuals in total, including 1,333 unaccompanied children had been relocated to another EU Member States under the voluntary relocation scheme, launched by the EU Commission in March 2020. ❖ Safe third country inadmissibility: In 2021, by a JMD Greece designated Türkiye as a “safe third country” for asylum seekers originating from Syria, Afghanistan, Pakistan, Bangladesh and Somalia, despite the fact that no readmissions to Türkiye have taken place since March 2020. As a result, applications for international protection lodged by persons of said nationalities throughout 20

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