Author
Article 24 Asylum Code and Joint Ministerial Decision 10302/2020,[1] regulate the procedures for the issuance of travel documents for beneficiaries of international protection.
Recognised refugees, upon a request submitted to the competent authority,[2] are entitled to a travel document (titre de voyage),[3] in accordance with the model set out in Annex to the 1951 Refugee Convention. This travel document allows beneficiaries of refugee status to travel abroad, except their country of origin, unless compelling reasons of national security or public order exist or where the person concerned is subject to proceedings for suspension, exclusion, revocation or cessation of the status granted.[4]
In 2024, the Council of State ruled on a case of a Turkish recognised refugee, whose application for the issuance of travel document was refused. In particular, the Court observed that Article 25(1) IPA (and the similar provision of Article 24(1) Asylum Code) introduced a prohibition on the issue of a travel document to a recognised refugee, either when a procedure for the application of a suspension, exclusion, revocation or cessation of the status granted is pending against him, or when there are compelling reasons of national security or public order, while with Article 25(2)(b) L. 4636/2019 an authorisation is granted to establish, by joint ministerial decision, the procedure for issuing, renewing and replacing the travel document, the supporting documents required, its type, content of the indications and its period of validity. However, the Court held that the authorisation granted, in the above context, does not include the specification of the vague legal concepts of ‘compelling reasons of national security or public order’ and thus the decision of non-issuance of travel document to a recognised refugee is not lawful.[5]
The abovementioned travel document is issued by the competent Passport Directorate of the Hellenic Police.[6] It is subject to an administrative fee of approximately 84 € for persons over 14 years old and 73 € for those up to 14 years of age, where the beneficiaries had applied for international protection after the operationalisation of the GAS in June 2023, and a fee of 58 € for all beneficiaires irrespective of age, for those that had applied for international protection under the old procedure. These travel documents are valid for 5 years for adults, as well as for children over 14 years old, and 3 years for children under 14 years old, and can be renewed.[7]
The same applies to beneficiaries of subsidiary protection or family members of beneficiaries of international protection, if they are unable to obtain a national passport, unless compelling reasons of national security or public order exist.[8] In practice, beneficiaries of subsidiary protection must submit to the Greek authorities a verification from the diplomatic authorities of their country of origin, certifying their inability to obtain a national passport. This prerequisite is extremely onerous, as beneficiaries of subsidiary protection may also fear persecution or ill-treatment from their country of origin. Furthermore, the issuance of this verification is at the discretion of the diplomatic authorities of their country of origin and depends on the policy of each country. The travel documents issued for beneficiaries of subsidiary protection are valid for 3 years and can be renewed.[9]
JMD 10302/2020 provides that the Passport Directorates of the Hellenic Police are the only competent authority for the issuance of travel documents.[10] In practice, after their recognition, beneficiaries of international protection must scan all the required documents (including the electronic administrative fee) and send them by email to the competent Alien’s Directorate in order to book an appointment for the submission of their applications in person. Travel documents are issued by the Passport Offices of the Hellenic Police. Beneficiaries of international protection are required to book an appointment, similar to the one for their residence permit (ADET). In case of travel documents, however, the payment of a fee is a prerequisite to obtaining such an appointment.[11] After the travel document is issued, they must regularly check the website of the Asylum Service for their scheduled appointment.[12] If they miss that appointment, they must book another one through the electronic platform of the Ministry of Migration and Asylum, which may be scheduled months after the missed one. Travel documents may only be collected at the RAOs of Attica, Thessaloniki and Crete. This means that beneficiaries of international protection on the islands have to travel either to Athens or to Thessaloniki to collect their document.[13]
The same Ministerial Decision regulates the issuance of travel documents for children accompanied by one of their parents who de facto exercises on their own the sole custody of the child, but does not possess documents establishing the sole custody of the child (e.g., divorce, court order on sole custody, death certificate). More precisely travel documents for children can be issued upon submission to the competent Passport Office of a declaration on oath before a Lawyer or a Notary[14] when the following conditions are met:
- the child is granted refugee status and is present in Greece with one of their parents;
- this parent is also exercising the sole custody due to facts or legal acts that have occurred in the country of origin (e.g., death of a spouse. divorce), and
- this parent does not possess documents proving that they are exclusively exercising the sole custody.
However, Article 1(6) of JMD 10302/2020 does not apply to cases where the parent is exercising sole custody due to facts or legal acts that have occurred in a country other than the country of their origin. In this case, if no supporting documents can be provided, travel documents for children can be granted only by a court order, pursuant to which the sole custody is assigned to the single parent.[15] The waiting period for the initial issuance of travel documents is not as lengthy as it used to be, as far as GCR is aware.
As regards the renewal of travel documents, beneficiaries of international protection have to follow a five-step procedure. In particular, the beneficiary has to:
-
- submit a renewal application and a photo via email to the Asylum Service,
- send to the Asylum Service a signed solemn declaration with a certified signature stating that they have not been convicted of several offences restrictively mentioned in the JMD 10302/2020 (see below), following which
- the Asylum Service sends to the beneficiary’s personal email the reply to their application, and
- the beneficiary submits supporting documents to the competent Passport Office of the Police or the Passport Office of the Aliens Directorate and subsequently
- the beneficiary receives their travel document from the competent Regional Asylum Office.[16]
The first step of the procedure often causes problems to beneficiaries of international protection who are technologically illiterate, as they have to fill in the application form electronically and send it correctly via their personal email. GCR has observed that many beneficiaries of international protection, despite knowing how to use social media applications, do not know how to use an email properly and often do not even know if they have an email address. Thus, in many cases, beneficiaries seek assistance, often paying huge fees in various photocopying centres in the centre of Athens or accounting offices, which, in many cases, do not send correctly said renewal applications.
The second step of this procedure is also vital for the travel document renewal procedure since:
‘A travel document shall not be granted to a person who: a) has been convicted by final decision for forgery, forgery of certificates, embezzlement of documents, false deposition without oath or false declaration (Articles 216, 217, 222 and 225 of the Criminal Code and Article 22(6) L 1599/1986) where commission is related to the issuance, use, loss or theft of a passport, an identification document or any other document that may be used as a travel document or for criminal organisation, terrorist acts, abduction, slave trade, trafficking in human beings, child abduction, involuntary kidnapping, trafficking (Articles 187, 187A, 322, 323, 323A, 324, 327, 351 of the Criminal Code) as well as the offences of Article 29(5), (6) and (7) and of Article 30(1) and (2) of [the Immigration Code]. The prohibition shall apply from the final convicting judgment for five years (5) as regards commission of the above misdemeanours and for ten (10) years as regards commission of a felony respectively, on condition that the sentence imposed has been commuted; b) has been the subject of a criminal charge for a felony or an offence of point (a) for the duration of proceedings (…).’[17]
The aforementioned condition also applies to the initial issuance of travel documents.
During the travel document renewal procedure, beneficiaries of international protection are asked to submit a solemn declaration pursuant to which they certify that they have not committed any of the above-mentioned criminal offences. This stage is vital because beneficiaries of international protection who have been convicted of travel document-related offences cannot renew or issue travel documents. In addition, any false statements made in the solemn declaration constitutes a criminal offence.[18]
Decisions of RAO and AAU refusing to grant a travel document may be appealed before the Director of the Asylum Service, who takes a decision based on a recommendation of a three-member panel.[19]
All renewal applications are being processed by the Asylum Unit of International Protection of Beneficiaries (Αυτοτελές Κλιμάκιο Ασύλου Δικαιούχων Διεθνούς Προστασίας), which is extremely understaffed. As noted by the Director of the Asylum Service, in a response of 16 February 2024 (prot. no. 58515) to an intervention by 16 NGOs of the Legal Working Group,[20] only two employees are in charge of processing all the travel document renewal applications throughout Greece.[21] According to the National Register of Procedures, the travel document renewal procedure may last up to two months.[22] However, in GCR’s experience, the procedure may last up to six months.
Contrary to the above, the beneficiaries of international protection for whom the competent authority is the Headquarters of the Hellenic Police,[23] have to appear in person before the competent Aliens Directorate both for the initial issuance and the renewal of their travel documents in order to submit their relevant applications. GCR has noticed that, despite the provisions of JMD 10302/2020 for beneficiaries of subsidiary protection, according to which travel documents are valid for three years, the travel documents of beneficiaries of subsidiary protection are renewed for two years.
As per information provided by the Headquarters of the Hellenic Police on 28 February 2026, during 2025, a total of 25 new travel documents were issued and 333 were renewed by the Headquarters of the Hellenic Police.
By the end of 2025, a total of 1,515 applications for renewal of travel documents were pending before the GAS, and in particular the competent AAU for Beneficiaries of International Protection, a significant majority (70.6%) of which were pending for more than 6 months.[24]
According to an ongoing survey conducted by UNHCR, from 1 January 2025 to 20 November 2025, out of 99 beneficiaries surveyed, 48% had applied for a travel document and had received it, 41% were waiting, while 10% had not yet applied.[25]
It must be stressed that travel documents are a prerequisite for opening a bank account in Greece, as banks do not accept ADET as valid identification documents for beneficiaries of international protection who wish to open a bank account. The issue of the link between possession of travel documents and the ability to open a bank account was already highlighted in a survey conducted by UNHCR from July 2022 – June 2023 with 424 beneficiaries of international protection. 43% of those interviewed reported that they had travel documents and only 42% had bank accounts.[26]
Possession of a travel document is also needed for access to employment, since the Unified Social Security Fund (Ενιαίος Φορέας Κοινωνικής Ασφάλισης, EFKA) does not accept ADET as a valid documentation.[27]
Furthermore, travel documents are in practice a prerequisite to access the platform of the Ministry of Finance (AADE). Specifically,
‘the AFM provides access to the online system TAXISnet. […] After an AFM has been issued, the applicant receives an account and TAXISnet codes, which are needed in order to access the systems of the tax authority and other public administrative services online […] Access codes (TAXISnet codes) are requested online through the AADE platform. […] The platform accepts only a travel document as a valid identity document; ADET or DADP documents are not accepted.79 In addition, the AADE platform is accessible only in Greek.’[28]
[1] Joint Ministerial Decision 10302/2020, Gov. Gazette B; 2036/30.05.2020, available in Greek at: https://bit.ly/2P71hc8.
[2] The territorially competent Aliens Police Directorate of the Hellenic Police is responsible for the submission of travel document applications and service of travel documents to the recognised refugees who have applied for international protection before the start of Asylum Service’s operation. The territorially competent Passport Offices of the Hellenic Police are responsible for the submission of travel document applications of the recognised refugees who have applied/apply for international protection after the operation of the Asylum Service. However, the competent authority for the service of these travel documents is the Asylum Service.
[3] Article 24 Asylum Code.
[4] Article 24(1) Asylum Code.
[5] Council of State, Decision 1107/2024.
[6] Article 24(2) Asylum Code.
[7] Article 6(1) JMD 10302/2020 (in force since 30.05.2020).
[8] Article 24(3) Asylum Code.
[9] Article 6(2) JMD 10302/2020.
[10] Article 3 JMD 10302.
[11] 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/3xsmCTB, p. 18.
[12] MoMA, Travel documents, available at: https://bit.ly/2Pd4kQe.
[13] RSA and Stiftung Pro Asyl, Beneficiaries of international protection in Greece: Access to documents and socio-economic rights, March 2022, available at: https://bit.ly/3lRUB1C para. 33.
[14] Article 1(5) JMD 10302/2020 (The District Courts in Greece do no longer exist), Article 421 Civil Procedure Code as in force.
[15] Articles 1(6) and 1(7) JMD 10302/2020.
[16] Ministry of Migration and Asylum, How to renew your travel documents, available at: https://bit.ly/3UyZTOl.
[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/45y1CY1, p. 16 see also Article 1(2) JMD 10302/2020.
[18] Article 8 L.1599/1986 “Whoever knowingly states false facts or denies or conceals the true facts with a written solemn declaration of Article 8 shall be punished with imprisonment of at least three months. If the person responsible for these acts intended to obtain pecuniary advantage harming others or intended to harm others, is punishable by imprisonment of up to 10 years.”
[19] 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. 18 . See also Article 4(3) JMD 10302/2020.
[20] Letter of Director of the Asylum Service, Renewal of identity documents of beneficiaries of international protection, prot. no. 58515/16.02.2024.
[21] Ibid.
[22] National Register of Procedures, Travel Documents Renewal for Beneficiaries of International Protection available in Greek at: https://tinyurl.com/28w6h893.
[23] Headquarters of the Hellenic Police is the competent authority for beneficiaries of international protection who have applied for international protection before the Asylum Service started its operation.
[24] RSA, Recognised refugee statistics in Greece in 2025, March 2026, available at: https://tinyurl.com/435psr2v, p.4.
[25] UNHCR, Greece Inter-Agency Protection Monitoring of refugees in Greece, Key Findings, 01 February 2022 – 20 November 2025, available at: https://tinyurl.com/k9vtxdwy.
[26] UNHCR, Key Findings: July 2022 – June 2023, Protection Monitoring of Refugees in Greece, August 2023, available at: https://bit.ly/4dgyE2l.
[27] 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. 17.
[28] Ministerie van Buitenlandse Zaken, Report on the fact-finding mission concerning beneficiaries of international protection in Greece, 3 September 2024, p. 19, received by GCR on 13 january 2025 by the Dutch Embassy in Greece.