Author
Pursuant to Article 30 Asylum Code, beneficiaries of international protection are to enjoy equal access to healthcare, under the same conditions as Greek nationals. Moreover, pursuant to Article 33 L. 4368/2016, uninsured and vulnerable social groups, which include BIPs and stateless persons, are to enjoy free access to public health facilities and are entitled to nursing and medical care, irrespective of whether they hold a valid residence permit or whether a decision is pending on an application for renewal of international protection status, or on an administrative appeal or judicial remedy against a decision rejecting the application for renewal, or at the time when there is a right to an administrative appeal or judicial remedy.[1]
Despite the favourable legal framework, actual access to health care services is hindered, in practice, by significant shortages of resources and capacity for both foreigners and the local population, as a result of years of austerity policies followed in Greece, as well as a lack of adequate cultural mediators. For BIPs subject to the “old procedure” under the competence of the Hellenic Police, another specific issue, in GCR’s experience, is that the residence permit they receive in the form of a “booklet”, poses added challenges in the issuance of AMKA, as this old residence permit contains a number written in a different format than the new residence permits. Hence, the civil servants did not know how to process the issuance of AMKA.
Meanwhile, administrative obstacles with regard to the issuance and in particular the activation of a Social Security Number (AMKA), promote an increasingly restrictive environment that impedes access to health care.
Since December 2023, pursuant to article 6 paragraph 5 point (bb) of JMD Φ80320/109864/14.12.2023, in order for third country nationals, including BIPs, to be able to activate their AMKA –without which activation they cannot have access to the rights attached to holding an AMKA– they need to cumulatively fulfil the following set of requirements: hold (a) a valid passport of a third country or a valid travel document, (b) a valid residence title in the country with the right of access to the labour market, and (c) proof of residence in the country.
As proof of residence in the country, it is mandatory to also submit a certificate of employment (βεβαίωση πρόσληψης) from an employer or an employment contract uploaded in the Information System of the Ministry of Employment (ERGANI) or a certificate of commencement of self – employment by the competent Tax Office, or a certificate of studies in Greece, with the latter being added as an alternative in Guidelines issued by the Ministry of Employment and Social Security on 1 April 2024.[2]
Notably this requirement does not apply to either Greek or EU citizens, introducing an impermissible division with regards to the treatment of BIPs, in breach of applicable law, and with concerning material manifestations, as BIPs who have not yet secured lawful employment are effectively barred from activating their AMKA, are in turn systemically excluded from public healthcare. The impact is particularly severe for beneficiaries unable to work due to health conditions and who are, in turn, also excluded from accessing the benefits of the Organisation of Welfare Benefits and Social Solidarity (OPEKA).[3]
As noted in a 21 November 2024 letter of the active Director-General of Migration and Home Affairs to competent Greek Ministers,[4] “the new provisions of the law on the AMKA activation set additional requirements (e.g., having an employment contract) for beneficiaries of international protection and legally residing third-country nationals in comparison to Greek citizens. This provision hinders the effective access to the healthcare system by beneficiaries of international protection and legally residing third country nationals, and is particularly worrying for persons with disabilities who are unable to work.”
Lastly, clarifications offered by the Ministry of Health via Circular 48556/2025 in November 2025 on access to public health facilities for the beneficiaries foreseen under Article 33 of L. 4368/2016, have further hindered access of uninsured BIPs to healthcare. Although the Circular clarifies that BIPs can enjoy these rights without an active AMKA, thus potentially providing for a means to resolve the aforementioned barriers to its activation, it substitutes the need for active AMKA with the need to submit a written confirmation of the decision to postpone their removal pursuant to the provisions of paragraph 4 of Article 24 of L. 3907/2011. Given BIPs have a regularised stay in Greece, and thus are not subject to either removal measures or their postponement, this is a practical impossibility, and in case the Hellenic Police, which would be the competent authority for issuing such as postponement decision, does not issue such decisions in cases of BIPs.
These systemic barriers have also been flagged in a recent (February 2026) case supported by RSA before the ECtHR regarding a young refugee woman from Syria facing a serious health condition and in need of vital medication, which she could not acquire on account of the impossibility of activating her AMKA. The Court ordered the Greek authorities to ensure the continuation of urgent medication and treatment necessary for her survival.[5] Nevertheless, despite this binding decision, the administration failed to comply, leaving the applicant at imminent risk for more than 20 days after the Strasbourg ruling.[6]Regarding beneficiaries of subsidiary protection, it should also be noted that they receive national passports from the Embassies/Consulates of their country of origin in Greece. However, there are cases where they are neither provided with a national passport nor with a certificate of objective impossibility to issue one, so that a travel document can be issued by the Greek authorities. Therefore, these beneficiaries of subsidiary protection are excluded from access to public health care, as the AMKA cannot be activated as described above.[7]
Furthermore, according to the aforementioned JMD, the issuance of AMKA is conditional upon possession of a “valid residence title in the country with labour market access”.[8] The requirement of a “valid” residence permit creates substantial obstacles, given that AMKA is deactivated upon (a) interruption of lawful residence in the country; or (b) interruption of access to the labour market; or (c) interruption of actual residence in the country, except for minor beneficiaries; or (d) deactivation of A.M.K.A. of the directly insured person, in the case of indirectly insured persons adults or minors[9]. “Specifically as regards deactivation due to non-legal residence in the country, [deactivation] shall automatically take place on the day following the expiry of validity of the residence title, in the absence of renewal, extension or withdrawal of the status of international or temporary protection”.[10]
According to Guidelines provided by the Registration Department of the Insurance Directorate of the General Directorate for Contributions, “the service of third country nationals for the issuance – activation – re-activation of AMKA will be provided by the Ministry of Migration and Asylum by 22.12.2024. Until this date, third country nationals will be served by e-EFKA and Citizens’ Service Centres” (Κέντρα Εξυπηρέτησης Πολιτών – KEPs).[11]
It should be noted that, in the Guidelines of the Ministry of Labour and Social Affairs, there are neither templates of residence permits of beneficiaries of international protection issued by the Headquarters of the Hellenic Police, nor templates of certificates of submission of renewal applications of residence permits for both beneficiaries of international protection granted international protection status either by the Asylum Service or the Headquarters of the Hellenic Police.[12]
The Ministerial Decision 12184/2022 that came into effect on 16 March 2022 provided that the prescription of medicines, therapeutic operations and diagnostic examinations for patients without health insurance will be possible, only by doctors of public hospitals and Primary Health Care structures.[13] This Ministerial Decision affected the vast majority of beneficiaries of international protection, since most of them do not have health insurance and will therefore no longer be able to visit private doctors.
As of 1 July 2022, it is impossible for private doctors to prescribe the uninsured patients under Article 38 Law 4865/2021,[14] in conjunction with Ministerial Decision (M.D) 30268/30-05-2022.[15] The exception from this provision are (a) uninsured people up to 18 years old; (b) uninsured patients with intellectual or mental disabilities, autism, down syndrome, bipolar disorder, depression with psychotic symptoms, cerebral palsy or severe and multiple disabilities, amputees who receive the extra-institutional allowance with a disability rate of 67% or more, as well as those who have a certified disability of 80% or more, for any condition; (c) uninsured patients with conditions included in the list of diseases for which medicinal products are administered with reduced or no contribution by the insured person, including patients suffering from AIDS; (d) the prescription of all vaccines without exception to all uninsured patients.[16] All the above apply to every person residing legally in Greece and there is no specific provision for beneficiaries of international protection.
As of March 2023, the “Evangelismos” General Hospital of Athens, the “Aiginitio” Hospital and “Dromokaitio” Psychiatric Hospital of Athens had no interpreters. Conversely, the “Dafni” Psychiatric Hospital of Athens only had interpretation for Arabic and the “Alexandra” General Hospital of Athens covered Arabic, Farsi, French and Lingala.[17] Thus, access to health care is extremely difficult is for beneficiaries of international protection.
According to a survey conducted by UNHCR from July 2022 until June 2023 with 424 beneficiaries of international protection “[t]wenty-nine per cent of respondents had difficulty accessing healthcare because of language barriers, challenges to securing appointments and lack of information on the national health care system”, while the number of households that have at least one member with specific needs is 36%. Chronic illnesses, mental health issues and physical disabilities are the top three reported vulnerabilities.[18]
[1] Article 33 par. 2 point ix of L. 4368/2016.
[2] Ministry of Employment and Social Security, Guidelines for the Issuance and Use of the Social Security Number – Annex B: Documents Required for the Issuance and Activation of an AMKA, prot. no.Φ80320/25192, available in Greek at: https://tinyurl.com/42pj3zft, p.23 of 59.
[3] Also see RSA and Stiftung Pro Asyl, Recognised refugees in Greece 2025, March 2025, available at: https://tinyurl.com/3emyk5w3, pp. 22-24.
[4] DG HOME, Implementation of new law on AMKA and its repercussion on Beneficiairies of International Protection and legally residing third-country nationals, 21 November 2024, Ref. Ares (2024)8316809 – 22/11/2024. The document was made available following a request for access to information made by RSA.
[5] RSA, “ECtHR interim measures secure access to medication for recognised refugee with serious health condition and inactive AMKA in Greece”, 2 February 2026, available at: https://rsaegean.org/en/ecthr-interim-measures-amka-refugee-greece/.
[6] RSA, “BREAKING: EFKA ignores binding ECtHR interim measures decision”, 26 February 2026, available at: https://rsaegean.org/en/breaking-efka-ignores-binding-ecthr-interim-measures-decision/.
[7] Intervention by 20 civil society organizations of the national Legal Working Group to the Minister and Vice Minister of the Ministry of Migration and Asylum and the Minister of Citizen Protection, Beneficiaries of International Protection, prot. no. β/139/24.10.2024. The same issues regarding AMKA have already been raised in the intervention No. 385/17-07-2024 addressed to the Ministry of Migration and Asylum and to all competent Authorities by 22 civil society organizations, without, however, receiving any response to date.
[8] Article 3(a) of JMD Φ80320/109864/14.12.2023. 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/3KT41TT, p. 20.
[9] Article 7(1) JMD Φ80320/109864/2023.
[10] Article 7(2) JMD Φ80320/109864/2023. 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/3KT41TT, p. 20.
[11] Registration Department of the Insurance Directorate of the General Directorate for Contributions, Παροχή Οδηγιών για την απόδοση και τη λειτουργία του Αριθμού Μητρώου; Κοινωνικής Ασφάλισης (ΑΜΚΑ), prot. no. 530132, 10 April 2024, available in Greek at: https://bit.ly/3xmJ3ts.
[12] Ministry of Labour and Social Affairs, Οδηγίες για την απόδοση και τη λειτουργία του Αριθμού Μητρώου Κοινωνικής Ασφάλισης (ΑΜΚΑ), prot. no. Φ80320/25192, 01 April 2024, available in Greek at: https://bit.ly/3RBmkRb.
[13] Ministerial Decision 12184/2022, Gov. Gazette 899/B/28.2.2022.
[14] Law 4865/2021, Gov. Gazette 238/A’/04-12-2021.
[15] Ministerial Decision 30268/30-05-2022, Gov. Gazette, B’, 2673/31.05.2022.
[16] Article 11(1) Ministerial Decision 30268/30-05-2022 Gov. Gazette 2673, Β’, 31-05-2022.
[17] 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/3KT41TT, p. 26.
[18] UNCHR, Key Findings: July 2022 – June 2023, Protection Monitoring of Refugees in Greece, August 2023, available at: https://bit.ly/4dgyE2l.