Access to NGOs and UNHCR


Country Report: Access to NGOs and UNHCR Last updated: 05/06/24


Teresa Fachinger, Paula Hoffmeyer-Zlotnik and Marlene Stiller

Welfare organisations and other NGOs offer free advice services which include basic legal advice.[1] However, access to NGOs is highly dependent on the place of residence. In some reception centres, welfare organisations or refugee councils have regular office hours or are located close to the centres so asylum seekers can easily access the offices of such organisations. However, offices of NGOs do not exist in all relevant locations and in any case, access to such services is not systematically ensured. As of 2023, there is no mechanism at the federal level which ensures that asylum seekers are getting access to legal advice from an independent institution before the interview. In contrast, the Federal Administrative Court decided in 2023 that there is no obligation to provide regular access to reception centres for welfare associations. Only in cases where counselling was explicitly requested by the asylum applicant and the respective welfare association received a mandate to counsel this individual applicant, access needs to be granted.[2] It is uncertain how the legal reforms of 2023 to the independent counselling will affect the implementation of the court ruling (see: Provision of information on the procedure).

In AnkER centres in Bavaria, access of NGOs depends on the management of the centre. In the AnKER Regensburg for example, Caritas, Amnesty International, the Refugee law clinic Regensburg and Campus Asyl have access to the facility, while in Manching/Ingolstadt, only Caritas has established presence. In the experience of certain NGOs, asylum seekers are not systematically re-directed to NGOs for further information. In centres such as Manching/Ingolstadt and Regensburg, NGOs have further no way of ensuring systematic counselling sessions with every new arrival, since they do not receive the registration list of residents in the AnKER centre.[3]

In other arrival or AnkER centres established since 2016, access to NGOs is made even more difficult as these do not have offices in the town or region where the new centres are located. A positive example is the arrival centre at Heidelberg where the Federal State of Baden-Württemberg has established an independent ‘qualified social and procedural advisory service’ in cooperation with welfare organisations.[4] Within this model, a social worker from an independent organisation functions as contact person for 100 asylum seekers and is explicitly commissioned to offer advice on the asylum procedure (while in many other reception centres social workers are not necessarily independent and/or they often are neither qualified nor entitled to offer counselling services on the asylum procedure).[5] Even here, in the past it has proven difficult for the social workers to effectively prepare asylum seekers for the interview in the asylum procedure since they are often approached with other urgent matters such as social support, family reunification etc.[6]

Furthermore, despite an attempt at a progressive approach in Heidelberg interviews have been scheduled at very short notice in the arrival centres, at a time when asylum seekers have to come to terms with other administrative regulations and with their new surroundings in general. In this situation, it has proven difficult to create an adequate setting for the preparation for the interview.[7] In the light of these problems being described in the context of the ‘arrival centre’ at Heidelberg, it can be concluded that access to NGOs is even more limited or may be excluded in many other locations where no similar structures exist. This is particularly the case for the possibilities to access NGOs before the interview, since fast-tracking of procedures is taking place at a growing number of ‘arrival centres’ and AnkER-centres.

Following an initial period in a reception centre, asylum seekers are usually referred to accommodation centres or apartments in other places of residence (see Types of accommodation). Some of these accommodation centres are located in remote areas without proper access by means of public transport. If the place of residence is located far away from the next town, travel costs to get there may also pose a serious problem in practice, since these costs would only be covered by public funds in exceptional cases. Accordingly, access to NGOs can be severely restricted under such circumstances.

The so-called ‘geographical restriction’ or ‘residence obligation’ (Residenzpflicht) also poses a legal obstacle for many asylum seekers who wanted to contact an NGO or lawyer. Beyond the obligation to stay in initial reception centres, a general residence obligation is imposed for asylum seekers from safe countries of origin for the whole duration of their procedures (see Freedom of movement).[8] Therefore the ‘residence obligation’ and the obligation to remain in a particular reception centre pose serious obstacles for access to NGOs and UNHCR in many cases.

For information on access to NGOs during the airport procedure, see Border procedure (border and transit zones).




[1] A database of advice services for asylum seekers is available at:

[2] Federal Administrative Court, Decision 1 C 40.21, 28 March 2023, available in German at:, para. 27f.

[3] ECRE, The AnkER centres Implications for asylum procedures, reception and return, April 2019, available at:       

[4] Friedrich-Ebert-Stiftung, Das Ankunftszentrum Heidelberg als ‚Pate‘ für Ankerzentren?, 8 August 2018, available in German at:

[5] Ibid.

[6] Ibid.

[7] Johannes Moll, ‘Das verkürzte Asylverfahren im Ankunftszentrum Heidelberg. Ein Modell im Spannungsfeld von effizientem Verfahren und effektiven Rechtsschutz’, Asylmagazin 12/2016, available in German at:, 412, 415-416.

[8] Section 47(1a) Asylum Act.

Table of contents

  • Statistics
  • Overview of the legal framework
  • Overview of the main changes since the previous report update
  • Asylum Procedure
  • Reception Conditions
  • Detention of Asylum Seekers
  • Content of International Protection
  • ANNEX I – Transposition of the CEAS in national legislation