Author
Individuals recognised as refugees are granted a three-year residence permit (“ADET”), which can be renewed after a decision of the Head of the Regional Asylum Office.[1] Beneficiaries of subsidiary protection, however, obtain a one-year residence permit, which is renewable for a period of two years.[2]
Residence permits are usually delivered at least two to three months after the communication of the decision granting international protection and the submission of the required documents, which as per Article 6(1) of JMD 513542/2022 (Gazette B’ 4763) are:
- an ID photo,
- a valid asylum applicant card and
- a solemn declaration of Article 8 L. 1599/1986 stating the beneficiary’s address of residence.
Notwithstanding these, in GCR’s experience beneficiaries are also requested to submit a copy of the positive decision granting them international protection and of the decision granting them an ADET to the Aliens Police Directorate (‘Διεύθυνση Αλλοδαπών’) or the competent passport office. The asylum office responsible for issuing and delivering the ADET is determined on the basis of the residence address provided by the beneficiary[3].
The Asylum Service does not notify the beneficiaries individually, through e-mail or any other means of communication, of the issuance of their residence permit.[4] Rather, the Asylum Service uploads lists containing beneficiaries’ case numbers on the MoMA’s website, when their ADET is ready for collection. These lists include specific dates and hours for the collection of the ADET.[5] As a result, beneficiaries have to regularly consult these lists online, until they find an entry corresponding to their individual case number.[6] If they miss their appointment, they have to request for their case number to be re-entered in the lists.
Until the issuance of their residence permits, beneficiaries keep their asylum applicant card and are considered as asylum applicants by ERGANI (ΕΡΓΑΝΗ) –the Information System of the Ministry of Employment.[7] In practice, this means that pending the receipt of their ADET, beneficiaries do not enjoy full access to the labour market, as per their rights, but instead face the same limited access/restrictions faced by applicants of international protection (i.e. no possibility to engage in independent economic activity, and, if status recognition takes place in less than two months from the lodging of their asylum application, no access to the labour market until the two months have lapsed).[8]
After delivery of the residence permit (A.Δ.E.T), the Asylum Service notifies the Electronic Governance of Social Security S.A. (ΗΔΙΚΑ Α.Ε.) to deactivate the Provisional Foreigner’s Insurance and Health Care Number for asylum applicants (ΠΑΑΥΠΑ). Along with the delivery of the residence permit, the Asylum Service is obliged to inform beneficiaries of international protection that they are henceforth eligible to acquire a social security number (AMKA) and that they must take the legally required steps to issue it within one (1) month.[9] In practice, due to delays linked with the electronic system of ΗΔΙΚΑ, beneficiaries have no access to health care for many months until their AMKA number is activated.
Renewals
An application for renewal needs to be submitted no later than 30 calendar days before the expiry of the residence permit. The mere delay in an application for renewal, without any justification/reason, cannot lead to its rejection.[10] However, in case of delayed submission without due reasons, a EUR 100 fine is foreseen.[11] The authority responsible for imposing the fine is determined by Joint Ministerial Decision of the Ministers of Migration and Asylum, and of Finance.[12] In practice, this fine has never been imposed.
Since 2017, the application for renewal, together with a digital photo of the beneficiary, is submitted via email to the Asylum Service (Asylum Unit of International Protection Beneficiaries –Αυτοτελές Κλιμάκιο Ασύλου Δικαιούχων Διεθνούς Προστασίας) and the latter’s decision is notified to the applicant also via email. Bearing in mind that legal aid is not provided at this stage, technologically illiterate beneficiaries face obvious obstacles to apply for the renewal of their permit.
As in previous years, long waiting periods for the renewal of ADETs have continued being an issue of concern in 2025 as well, with average waiting times being officially reported at 4 months.[13] However, based GCR’s caseload experience, 4 months tends to be the minimum waiting period for an ADET renewal, with delays of even a year still reported in 2025.[14] To GCR’s knowledge, these delays are due to the high number of applications and the severe understaffing of the competent Asylum Unit of International Protection Beneficiaries (Αυτοτελές Κλιμάκιο Ασύλου Δικαιούχων Διεθνούς Προστασίας). Indicatively, as noted in a 16 February 2024 (prot. no. 58515) letter of the Director of the Asylum Service in response to the intervention of 16 NGOs of the national Legal Aid Working Group,[15] only 8 employees were then in charge of processing the total volume of renewal applications (including decisions on renewal) throughout Greece.[16]
During the renewal procedure, the Asylum Service conducts criminal record checks, which may lead to the withdrawal of protection status, as well as an assessment of whether the grounds on which international protection was granted continue to apply. Pending the renewal process, beneficiaries are provided with an attestation of application status (βεβαίωση κατάστασης αιτήματος)[17] which is valid for three or six months, depending on the RAO or AAU that is competent for issuing it. This attestation provides beneficiaries with access to less rights (e.g. no access to the labour market, social welfare or to public healthcare, with the exception of emergencies) than the attestation of Article 11(10) L. 5038/2023[18] issued for migrants. In fact, beneficiaries of international protection holding these attestations are only protected from detention and have no access to their rights pending the renewal of their residence permit.
As far as GCR is aware, a main reason for this is that public services, such as the Public Employment Service (Δημόσια Υπηρεσία Απασχόλησης/ΔΥΠΑ, formerly OAED), are reluctant to accept these attestations, since they lack security features and a photograph of the beneficiary. Given a photograph of each beneficiary is available in their file, which is held by the Asylum Service, this issue could be at least partially and easily resolved by obtaining the beneficiary’s photograph, either from the attached file of the electronically submitted application for renewal, or from the administrative file kept by the Asylum Service, which includes their “facial image”. Such a procedure has not been implemented to date.[19]
Furthermore, a day after the residence permit expires, beneficiaries’ Social Security Number (AMKA) is deactivated.[20] This creates an additional bureaucratic layer and delays, as, in order to re-activate it, beneficiaries need to submit the attestation of application status, along with other documents required under JMD Φ80320/109864/14.12.2023.[21] Yet the attestation can only be issued after the application for renewal has been first uploaded by the competent Asylum Unit for Beneficiaries of International Protection to the electronic system of “ALKYONI” (ΑΛΚΥΟΝΗ). In GCR’s experience, this can take even up to a month from the time beneficiaries have submitted their application for renewal. That being said GCR is aware that in 2025, in certain cases, the applications were uploaded within a maximum of 15 days. This is in spite of Article 12 of the Code of Administrative Procedure (L. 2690/1999), which requires public authorities to record any document received on the same day.
The Ombudsperson has flagged this obligation to the Asylum Service in the specific context of ADET renewal applications.[22] In response, the administration has provided the Ombudsperson with assurances on immediate uploading of ADET renewal applications on the “Alkyoni” database.[23] However, in practice, and despite the letter of the Director of the Asylum Service explicitly stating that renewal applications are given a protocol number within 5 days from their submission via e-mail, this is not the case.[24] It is noted that the applicant beneficiary of international protection is not informed of the upload of their application in the system, so as to be able to submit a request for the issuance of attestation of application status. Nor are they informed of the protocol number assigned to their application, which they only become aware of upon receipt of the certificate, where it is indicated.
In April 2023, there was a positive legal amendment of Greece’s Migration Code (L. 5038/2023). According to Article 9 (ι), in conjunction with Article 11(10) L. 5038/2023, a certificate similar to the one issued for immigrants who apply for the renewal of a residence permit must be issued to beneficiaries of international protection pending the issuance of their renewed residence permits. This provision has not yet been implemented in practice and beneficiaries of international protection still face the same obstacles in accessing their rights.
It is worth noting that beneficiaries are never served their official renewal decision. They are simply notified by the Asylum Service via email that the renewal of their residence permit has been accepted. This notification also outlines the procedure that they ought to follow to submit the required documentation before the competent Alien’s Directorate for the issuance of their renewed residence permit. In practice, after the notification email is sent, beneficiaries need to follow the exact same procedure they followed for the initial issuance of their residence permit. For the delivery of their renewed residence permits, the Asylum Service does not notify the beneficiaries individually. It uploads on its website a list of case numbers for which the renewed ADET are ready for collection on an indicated day. Therefore, beneficiaries have to regularly consult the lists online, until they can find an entry corresponding to their individual case number. However, the lists of the renewed residence permits are announced on the same segment of the website of the Ministry as the residence permits that are issued for the first time. This creates an enormous confusion to beneficiaries considering that the residence permit guidelines of the Asylum Service advise them to consult the list of the renewed residence permits. Only the RAO of Chios uploads the lists of the renewed ADET on the specific platform created for this purpose, contrary to practice followed by other RAOs / AAUs.[25]
Returnees from other countries who may have been granted status several years before the establishment of certain RAOs and AAUs face many obstacles upon their return to Greece. In particular, returnees arriving at the Athens International Airport do not receive clear and accurate information on the authorities they should approach in order to obtain or renew their documents and to access their legal rights.[26] In addition, they face long delays in the issuance of decisions on the renewal of residence permits, as specific checks are carried out, inter alia, on any possible criminal convictions in the country from which they have been sent back.
As per data published by the MoMA,[27] a total of 148,036 applications for renewal were submitted throughout 2025, the majority of which (74.4%) were still pending at the end of the year. However, due to a lack of a relevant breakdown in the data, it is impossible to assess the percentage of these that specifically concerned beneficiaries of international protection.
For beneficiaries of international protection who applied for international protection before 7 June 2013 (“old procedure”), the competent authority for the renewal procedure is the Headquarters of the Hellenic Police (Αρχηγείο Ελληνικής Αστυνομίας). Specifically, the renewal procedure is conducted through the Aliens Police Directorates (Διεύθυνσεις Αλλοδαπών) based on beneficiaries’ place of residence. Contrary to the electronic procedure followed by the Asylum Service, this procedure requires the drafting of a legal document for the renewal application. Based on available Country of Origin Information (COI), the renewal application must demonstrate that reasons of persecution / serious harm still exist. During the renewal stage, even for the procedure before the Headquarters of the Hellenic Police, GCR observed that, in the years 2025–2026, following the submission of a renewal application, the Headquarters of the Hellenic Police notifies applicants who are beneficiaries of international protection with a document requesting that, either through an interview or by way of written submissions, they present within 20 days the reasons why they continue to face persecution in their country of origin. This practice effectively initiates a re-examination procedure on the merits, which in several cases—particularly concerning beneficiaries of subsidiary protection, including individuals originating from countries facing an extremely dangerous security situation, such as Afghanistan—leads to the non-renewal of residence permits.
Throughout 2025, a total of 450 applications for renewal were submitted before the Headquarters of the Hellenic Police, 57.3% of which concerned refugee status holders (258), and the rest beneficiaries of subsidiary protection (192). Of these, 227 applications were accepted, 5 were rejected, while the majority (51.5%) were still pending at the end of the year,[28] highlighting ongoing challenges in the timely renewal of ADETs under the “old procedure” as well. Though waiting times for renewal continued to be reported at less than 6 months in most pending cases under this procedure, close to a third were reported as pending for more than 6 months or even a year.[29]
Pending the renewal decision, a large number of beneficiaries have no access to the labour market, to social security, social welfare and sometimes healthcare for several months. As a consequence, they also face an increased risk of destitution and homelessness. The attestation of application status (βεβαίωση κατάθεσης αίτησης ανανέωσης άδειας διαμονής) issued by the Aliens Directorates underwent a complete change in format in 2025. In contrast to the attestation previously provided by the Asylum Service, it now includes a photograph and an expiration date of six months (with a fixed validity date), and it contains an explicit reference to Article 31 of Law 5226/2025, stating that the holder resides legally in the country and enjoys all rights attached to the residence permit for which renewal has been requested. This, in principle, should allow the document to be accepted by other Greek public authorities. However, the attestation does not bear a unique identification number, and therefore cannot be processed through the ERGANI system, preventing access to the labour market and to social benefits. Moreover, although beneficiaries receive their renewed residence permits on the same day they are notified of a positive renewal decision, these permits are often not accepted by public services, as they are handwritten, issued in booklet form, and remain unfamiliar to the majority of administrative authorities.
As of December 2025, a total of 96,438 active residence permits for beneficiaries of international protection were reported by the MoMA,[30] the majority of which concerned nationals of Aghanistan (35.8%), Syria (20.2%), Palestine (11.5%), Iraq (8.1%) and Eritrea (4%). This represents 10.3% of the total number of active residence permits reported up to December 2025 (936,522) in Greece, the majority of which concerned other categories of legally residing third country nationals (56.2%), as well as expatriates (ομογενείς) and EU citizens (29.5%).
At the same time, 7,640 renewal applications were still pending before the Asylum Service at the end of 2025.[31]
[1] Article 23(1) Asylum Code.
[2] Ibid.
[3] Circular No. 68883/31.01.2023, “Εγκύκλιες οδηγίες σχετικά με την εφαρμογή της με αρ. 513542 Κοινής Υπουργικής Απόφασης (ΦΕΚ Β΄ 4763/12.09.2022) «Διαδικασία χορήγησης Άδειας Διαμονής Ενιαίου Τύπου στους δικαιούχους διεθνούς προστασίας».
[4] Contrary to what is applicable for immigrants, who can be informed individually for the issuance of their residence permit through here. Such platform does not exist for the individual information of beneficiaries of international protection regarding the issuance of their residence permits.
[5] Ministry of Migration, Initial Residence permits that are ready, available at: https://bit.ly/3QiENRL.
[6] RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece: Access to documents and socio-economic rights, March 2024, available at: https://bit.ly/3Vy9DYJ.pdf, p. 13.
[7] See website of the Ministry of Employment: https://bit.ly/3KZj7oE.
[8] Article 192 L. 5078/2023 (Gov. Gazette A 211/20.12.2023), amending Article 57(1) Asylum Code.
[9] Articles 10 & 11, JMD Φ80320/109864/14.12.2023, Gov. Gazette B 7280/22.12.2023.
[10] Article 23(1) Asylum Code, JMD 513551/2022, Gov. Gazette Β ́ 4763/12.09.2022
[11] Article 23(1)(7) Asylum Code. As inter alia noted in a 2023 Circular of the MoMA: “Delayed application for renewal of ADET without reason” should be interpreted as follows: “the mere submission of any reason for negligence on the part of the beneficiary in submitting the application in time shall not suffice. Reasons shall be given which in fact justify exceeding the deadline set by law on the basis of objective criteria or events, without mandatory written evidence. The reasons invoked by the applicant shall be accepted where they are in line with the conduct of the ordinary reasonable person”. Ministry of Migration and Asylum, Circular 69244/2023 – Εγκύκλιες Οδηγίες σχετικά με την εφαρμογή της με Αριθμ. 513551/05.09.2022 (Β ́ 4763) Κοινής Απόφασης των Υπουργών Οικονομικών και Μετανάστευσης και Ασύλου «Καθορισμός του αρμόδιου οργάνου επιβολής και της διαδικασίας βεβαίωσης του προστίμου του έβδομου εδαφίου της παρ. 1 του άρθρου 23 του ν. 4939/2022 (Α’ 111)», 1 February 2023, available at: https://tinyurl.com/mtbt72ux, p.4. Also see RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece, Access to documents and socio-economic rights, March 2024, available at: https://bit.ly/3Vy9DYJ, p. 8. See also RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece, Access to documents and socio-economic rights, March 2023, available at: https://bit.ly/45y1CY1, pp. 6-7.
[12] Article 17 L. 4825/2021. JMD 513551/05.09.2022, Gov. Gazette Β ́ 4763/12.09.2022.
[13] Hellenic Republic, National Registry of Administrative Procedures: Renewal of Uniform Format Residence Permits (ADET), in Greek: https://tinyurl.com/yhkrzbx7 [last updated on 9 April 2025].
[14] Also see RSA, Recognised Refugees 2025, March 2025, available at: https://tinyurl.com/3emyk5w3, p.14.
[15] Intervention by 16 civil society organizations of the national Legal Working Group to the Minister and Vice Minister of the Ministry of Migration and Asylum, Renewal of identification documents of beneficiaries of international protection, prot. no. β/117/15.02.2024. Said intervention raised the following issues: (a) Long delays in the processing of applications for renewal of ADETs and travel documents by the Asylum Service, (b) Non-acceptance of the Asylum Service’s “Certificates of beneficiaries of international protection”, (c) Obstacles in the communication of beneficiaries and legal representatives with the Asylum Unit of International Protection Beneficiaries, (d) Ineffective means and procedures for the service of the issued ADETs and travel documents by the Asylum Service.
[16] Letter of Director of the Asylum Service, Renewal of identity documents of beneficiaries of international protection, prot. no. 58515/16.02.2024.
[17] Article 13 JMD 513542/2022, Gov. Gazette Β ́ 4763/12.09.2022.
[18] L. 5038/2023 “Immigration Code”, Gazette 81/A/01-04-2023.
[19] On 16 February 2024, in response to the aforementioned intervention of the Legal Aid Working Group, the Director of the Asylum Service noted that the legislation would be amended so that renewal applications would be processed electronically, through a platform, from where certificates of pending renewal would also be issued. This legal framework would also define specific requirements for the certificate, that would make it possible to verify the validity of the data and the authenticity of the document, in line with the standards of the Immigration Code. Such certificates would also include provisions for their general acceptance by third parties. Yet the adoption of relevant legislation is pending.
[20] Article 7 JMD Φ80320/109864/14.12.2023, Gov. Gazette B 7280/22.12.2023.
[21] Article 8 in conjunction with Articles 5 and 6 of JMD Φ80320/109864/14.12.2023, Gov. Gazette B 7280/22.12.2023.
[22] RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece, Access to documents and socio-economic rights, March 2024, available at: https://bit.ly/3Vy9DYJ, p. 9.
[23] RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece, Access to documents and socio-economic rights, March 2023, available at: https://bit.ly/45y1CY1, p. 7.
[24] Letter of Director of the Asylum Service, Renewal of identity documents of beneficiaries of international protection, prot. no. 58515/16.02.2024. The original letter is available at GCR.
[25] MoMA, Initial Residence Permits that are Ready, available at: https://bit.ly/3QiENRL. The separate page for renewed residence permits is available at: https://bit.ly/4aOprgn.
[26] Also see RSA and Stiftung Pro Asyl, Recognised refugees in Greece 2025, March 2025, available at: https://tinyurl.com/3emyk5w3, p. 36 et seq.
[27] MoMA, Statistics: Consolidated Reports – Overview, December 2025 – Legal Migration | Appendix B, available in Greek at: https://migration.gov.gr/statistika/, Table 4a.
[28] Information provided by the Headquarters of the Hellenic Police on 28 February 2026.
[29] RSA, Recognised refugee statistics in Greece in 2025, March 2026, available at: https://tinyurl.com/435psr2v, p.3.
[30] MoMA, Statistics: Consolidated Reports – Overview, December 2025 – Legal Migration | Appendix B, available in Greek at: https://migration.gov.gr/statistika/, Tables 1 and 18.
[31] RSA, Recognised refugee statistics in Greece in 2025, March 2026, available at: https://tinyurl.com/435psr2v, p.3.