Author
Rules for the registration and lodging of applications
Article 69 of the Asylum Code transposes Article 6 of the recast Asylum Procedures Directive on access to the procedure.
As outlined below, Greek law refers to simple registration (απλή καταγραφή) to describe the notion of “registration” and full registration (πλήρης καταγραφή) to describe the notion of “lodging” of an application for international protection under the Directive.
On Friday 11 July 2025, the Hellenic Parliament adopted a legislative provision introduced by the Ministry of Migration and Asylum (Article 79 of Law 5218/2025, Government Gazette Issue 125/A/14.07.2025[1]), which came into force on 14 July 2025. The provision imposes a three-month suspension (from 14-07-2025 to 14-10-2025) on the “making”/registration of asylum applications by people arriving in Greece illegally by any watercraft from North Africa and provides for their return to the country of origin or departure, without registration of their asylum applications. Among others, the Greek Ombudsman,[2] the Greek National Commission for Human Rights,[3], the Association of Administrative Judges,[4] the Council of Europe Commissioner for Human Rights,[5] the UN High Commissioner for Refugees,[6] as well as 109 human rights organizations,[7] have stressed that the amendment suspending access to asylum for three months is incompatible with international refugee law, international human rights law, and EU law, all of which are binding on Greece and allow no derogation from their application.
The Greek Council for Refugees[8] and other organizations visited the Pre-Departure Detention Center (PROKEKA) in Amygdaleza, where third-country nationals, subject to the provision on the suspension of asylum, who arrived in Gavdos (island south of Greece) from Libya, on 18 July 2025, have been transferred and are being held. Return decisions have been issued against them and they remain in immigration detention in view of the implementation of their removal. With support from GCR lawyers, Sudanese detaines submitted to the PROKEKA officer on duty statements of intent to apply for asylum so that the competent Asylum Service could be officially informed. Greek Authorities have refused to register their asylum applications by invoking the legislative amendment suspending access to asylum. On 12 August 2025, GCR lawyers representing 4 Sudanese asylum seekers submitted Applications for Annulment and for Suspension,[9] with a request for a temporary order, before the Administrative Court of Athens against the return decisions as well as the administration’s refusal/omission to register their asylum applications. Said legal remedies do not have an automatic suspensive effect. On 13 August 2025, GCR lawyers representing the same Sudanese asylum seekers and RSA lawyers representing other asylum seekers from Sudan submitted requests for interim measures (R39) before the European Court of Human Rights (ECtHR). On 14 August 2025, the ECtHR granted interim measures under Rule 39, indicating to the Greek Government not to remove them from the country until a decision on their Applications of Suspension is issued by the Administrative Court of Athens. On 25 August 2025, the Judge on duty of the Administrative Court of Athens accepted the request of temporary order of the Sudanese asylum seekers, represented by GCR, and granted a suspension of removal from the country until a decision on their Applications of Suspension is issued.[10] The examination/hearing of said legal remedies (Applications for Annulment and for Suspension) had not been scheduled – apart from 1 to take place early 2026, – at the time of writing.
Registration of applications for international protection (“Καταγραφή”)
Article 69(1) of the Asylum Code provides that any foreigner or stateless person has the right to “make” an application for international protection. The application is submitted before the competent receiving authorities, i.e., the Regional Asylum Offices (RAO), the Autonomous Asylum Units (AAU) or the Mobile Asylum Units of the Asylum Service or the Regional Reception and Identification Services,[11] depending on their local jurisdiction, which shall immediately proceed with the “full registration” (πλήρης καταγραφή) of the application.
Following the “full registration” of the asylum claim,[12] the application for international protection is considered to be lodged (κατατεθειμένη).[13]
The Asylum Code provides that such full registration shall take place no more than 15 working days from the time of simple registration. More precisely, according to the Asylum Code, where “for whatever reason” full registration is not possible, following a decision of the Director of the Asylum Service, the Receiving Authorities may conduct a “simple registration” (απλή καταγραφή) of the asylum applicant’s necessary details within 3 working days, and then proceed to the full registration by way of priority within a period of not exceeding 15 working days from “simple registration”.[14] In such a case, upon “simple registration”, the applicant receives a document indicating their personal details and a photograph, to be replaced by the International Protection Applicant Card when their full registration is eventually carried out, i.e., upon the lodging of the full application.[15]
According to the Asylum Code, if the application is submitted before a non-competent authority, that authority is obliged to promptly notify the competent receiving authority and refer the applicant thereto.[16] An asylum application will not be considered properly lodged until it is fully registered by the Asylum Service, as the competent authority.
For third-country nationals willing to apply for asylum while in detention, the competent Detention Authorities shall ensure the immediate preparation and submission of a written declaration to that effect, following which the detention authority must register (simple registration) the application on an electronic network connected to the Asylum Service within three working days.[17]
Moreover, according to the Asylum Code, the lodging of the application with the Receiving Authorities must be carried out within seven working days after the “simple registration” by the detention authority or the RIS.[18] In order for the application to be fully registered, the detainee is transferred to the competent RAO or AAU.[19]
Lodging of applications (“Κατάθεση”)
No time limit is set by law for lodging an asylum application. However, Article 83 of the Asylum Code transposes Article 13 of the recast Asylum Procedures Directive that refers to applicants’ obligations and foresees that applicants are required to appear before competent authorities in person, without delay, in order to submit their application for international protection.
Applications must be lodged in person,[20] except under force majeure conditions.[21] According to the Asylum Code, the lodging of the application must contain inter alia the personal details of the applicant and the full reasons for seeking international protection.[22]
As a general rule, the Asylum Code provides that the asylum applicant’s card, which is provided to all persons who have been fully registered, i.e., lodged their application, is valid for 1 year, which can be renewed as long as the examination is pending.[23] However, the Asylum Code provides for a number of cases where the asylum applicant’s card can be valid for shorter periods. Thus, the validity of an asylum applicant’s card can be set for a period:
- No longer than 3 months, where the applicant belongs to a nationality with a recognition rate lower than 35% in accordance with the official EU statistics and by taking into consideration the period for the issuance of a first instance decision expected;[24]
- No longer than 30 days, where the communication of a decision or a transfer on the basis of the Dublin Regulation is imminent;[25]
- No longer than 30 days, where the application is examined “under absolute priority” or “under priority”, under the accelerated procedure, under Article 89 (inadmissible) or under the border procedure.[26]
In 2025, the Asylum Service registered a total of 61,629 applications for international protection, including 6,248 subsequent applications, primarily by nationals of Afghanistan (15,296), Egypt (9,548), Sudan (8,179), Syria (3,511) and Bangladesh (3,132).[27]
Role of the EUAA in registration[28]
In 2025, the number of lodged asylum applications registered with the support of EUAA personnel in Greece decreased to 34,023 applications for international protection (46,701 in 2024).
Of these, 83% related to the same 10 citizenships, in particular Afghans (8,601), Egyptians (5,699), Sudanese (4,982), Syrians (1,843), Bangladeshis (1,837), Somalis (1,278), Nepalis (1,087), Eritreans (1,028), Pakistanis (954) and Yemenis (946).[29]
EUAA deployed personnel did not carry out TPD registrations in Greece in 2025.
Access to the procedure on the mainland
Access to the asylum procedure has remained a structural and endemic problem in Greece for many years, both during the period when the police authorities[30] were competent for the asylum procedure and even after the start of the operation of the Asylum Service in 2013 (for more information see the ΑIDA reports for 2023 and previous years).
On 13 July 2022, the Ministry of Migration and Asylum operationalised a new online platform for booking of appointments for lodging an initial asylum application in person for asylum applicants in Greece, which, as noted in several national Court decisions in cases represented by GCR,[31] is tantamount to confirming a person’s will to apply for asylum and therefore that that person has the status of an asylum applicant. The procedure applies to all third country nationals who have not been through reception and identification procedures. The platform is available in twelve languages (Greek, Kurmanji, Albanian, Georgian, Arabic, Bengali, Dari, English, Farsi, Pashto, Turkish and Urdu), and after applicants have provided their personal information, they are asked to choose one of two registration facilities: Diavata RIC (Thessaloniki) or Malakasa RIC (Attica). Once the electronic form is completed, a registration appointment would be assigned to the applicant and communicated via email.
Upon appearance at the above RICs at the pre-arranged appointment, asylum seekers are subject to de facto detention period of maximum 25 days in order for the procedure to be completed, despite the Directive’s provision “not to hold a person in detention for the sole reason that he or she is an applicant for international protection”.[32] During this de facto detention period, asylum applicants complete their asylum interview and wait for the first instance decision on their case.
The Asylum Service does not publish specific data on the pre-registration of applications through the platform.
As of 15 May 2024, there was a discontinuation of the provision of interpretation services which until then was exclusively provided by the organisation METAdrasi, due to the expiration of its contract with the Ministry of Immigration and Asylum and also due to months of delayed payments. Previously, as of 29 April 2024, for the same reasons, the provision of services to the Asylum Service had also been discontinued. The interpretation services are funded by European funds, from the Asylum, Migration and Integration Fund (AMIF) for the period 2021-2027.
As a result, Asylum Service in almost the entire territory stopped carrying out all procedures related to the applications for international protection (indicatively: registration of both initial and subsequent asylum applications, conducting interviews, service of decisions, etc.).
Although the law requires that interpretation services be provided by the state in a language understood by applicants throughout the entire reception and identification and asylum process, in many cases, the gaps in interpretation have been attempted to be filled in questionable -and not provided by law- ways. Illustratively, asylum seekers are often requested to state their consent to the proceedings being carried out in Greek by signing solemn declarations confirming that they understand the language; asylum seekers are requested to sign declarations that they accept third parties who are not certified interpreters to assist them during the proceedings; on the recommendation of the Asylum Service, the asylum seeker is accompanied by a lawyer, who is required to sign the act of lodging an appeal and, thus, assume responsibility of informing on the document and interpreting for the asylum seeker.[33]
Due to these deficiencies, in 2024, access to the asylum procedure was extremely limited, exposing third country nationals wishing to file an application for international protection to the risk of arrest and administrative detention, in a legal limbo without any official documentation or legal status, unsupported by appropriate structures to provide for their essential needs, creating at the same time huge delays in the processing of already registered asylum applications.[34] Despite the resuming of interpretation services, significant delays in both registering and examining international protection claims continued throughout 2025. On several occasions the registering platforms had exhausted capacity informing applicants that no appointment is available. Continuing postponement of interviews and thus delays in examination and decision issuance continued too, particularly among the Arabic-speaking population.
Access to the procedure from administrative detention
Access to the asylum procedure for individuals detained for the purpose of removal remains problematic. The application of a detained person having expressed the wish to apply for asylum is registered with delay. The person remains detained between the expression of the intention to apply for asylum and the registration of the application, by virtue of a removal order. The person is deprived of any of the procedural guarantees provided to asylum applicants, despite the fact that according to Greek law, any individual who expresses the intention to lodge an application for international protection is an asylum applicant. Since the waiting period between expression of intention and registration is not counted in the duration of detention, asylum applicants may be detained for a total period exceeding the maximum detention time limit for asylum applicants.
In practice, the lack of adequate information to persons in detention, the lack of free legal aid scheme and the lack of interpretation services in pre-removal detention centres and other police facilities, as recently found by the CPT, significantly hinder access to asylum for those in detention.[35]
The time period between the expression of intention to apply for asylum and the registration varies depending on the circumstances of each case, and in particular, the capacity of the competent authority, the availability of interpretation, and the number of people wishing to apply for asylum from detention.
Τhe discontinuation of interpretation services in asylum procedures from mid-2024 onwards, as mentioned above, has inevitably led to an increase in the length of detention of administrative detainees who wished to apply for international protection. Despite the resuming of interpretation services during 2025, delays continued.
[2] Greek Ombudsman, Statement, Υπόμνημα | Αναστολή υποβολής αιτημάτων ασύλου και αφίξεις πολιτών τρίτων χωρών στην Κρήτη, 10-7-2025, available in Greek here.
[3] Greek National Commission for Human Rights, Statement, Δήλωση της ΕΕΔΑ: Η αναστολή της υποβολής αιτήσεων ασύλου και η παραβίαση του διεθνούς δικαίου, 11-7-2025, available in Greek here.
[4] Association of Administrative Judges, Press Release, Για την τροπολογία περί αναστολής για 3 μήνες της δυνατότητας υποβολής αιτήσεων χορήγησης ασύλου από άτομα που εισέρχονται στη χώρα παράνομα με οποιοδήποτε πλωτό μέσο που προέρχεται από τη Βόρεια Αφρική, καθώς και της επιστροφής των ατόμων αυτών, χωρίς καταγραφή, στη χώρα προέλευσης ή καταγωγής, 11-7-2025, available in Greek here.
[5] Council of Europe Commissioner for Human Rights, Statement, The Commissioner urges the Greek parliament to refrain from suspending the registration of asylum applications, 11-7-2025, available here.
[6] UNHCR, Press release, UNHCR deeply concerned by Greece’s suspension of asylum applications, 10-7-2025, available here.
[7] 109 organisations call for the unlawful suspension of access to asylum in Greece to be immediately withdrawn, Joint Statement, 16-7-2025, available here.
[8] Greek Council for Refugees, Press Release, No right to asylum and living in appalling conditions: GCR visit to Pre-departure Detention Center in Amygdaleza for those recently arrived in Gavdos from Libya, 30-7-2025, available here.
[9] Greek Council for Refugees, Press Release, GCR files legal remedies for refugees subject to the recent amendment by the Ministry of Migration and Asylum on the suspension of asylum, 13-8-2025, available here.
[10] Greek Council for Refugees, Press Release, The Administrative Court of First Instance of Athens, as the European Court of Human Rights had also ruled earlier, grants a suspension of removal from the country to Sudanese refugees affected by the amendment imposing a 3-month suspension of access to asylum, 26-8-2025, available here; Refugee Support Aegean, Press Release, European Court of Human Rights blocks deportation of refugees detained by Greece under unlawful asylum suspension, 18-8-2025, available here.
[11] Article of Asylum Code.
[12] Article 69(1) of Asylum Code.
[13] Article 69(3) of Asylum Code.
[14] Article 69(2) of Asylum Code.
[15] Ibid.
[16] Article 69(9) of Asylum Code.
[17] Article 69(7) (b) of Asylum Code.
[18] Ibid.
[19] Ibid.
[20] Article 83(3) of Asylum Code.
[21] Article 83(4) of Asylum Code.
[22] Article 69(1) of Asylum Code.
[23] Article 75 (1) of Asylum Code.
[24] Article 75 (2) of Asylum Code.
[25] Article 75 (3) of Asylum Code.
[26] Article 75 (4) of Asylum Code.
[27] MoMA, Statistics: Consolidated Reports – Overview, December 2025 – International Protection | Appendix A, available at: https://migration.gov.gr/statistika/, Table 7c and 7d.
[28] It should be noted that Regulation 2021/2023 entered into force on 19 January 2022, transforming EASO into the EU Agency for Asylum (EUAA).
[29] Information provided by the EUAA, 05 March 2026.
[30] Greek Ombudsperson, “Problems in the reception and examination of asylum applications at the Athens Aliens Department”, 2005, available in Greek here. ; see also GCR, Asylum campaign invitation to a press conference, 12 October 2012, available here.
[31] Indicatively, ΔΠρΚαβ. 164/2023, ΜΠρΑθ 1524/2023 and ΔΠρΚομ ΑΠ163/2023.
[32] Article 8 (1) RCD
[33] RSA, Major deficiencies in the provision of interpretation services in Greece, Even asylum interviews are no longer being conducted”, 5 November 2024, available here.
[34] For this situation, individualized interventions were made by organizations to the Ministry of Migration and Asylum, as well as questions raised within the framework of Parliamentary Control by Members of Parliament from opposition parties. See, Ελληνικό Κοινοβούλιο, Μέσα Κοινοβουλευτικού Ελέγχου, 20 january 2025, available here.
[35] CPT, Report to the Greek Government on the visit to Greece carried out by the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) from 20 November to 1 December 2023, 12 July 2024, CPT/Inf (2024) 21, available here, paras. 33-37.