Material reception conditions may be provided in kind or in the form of financial allowances. According to Article 60(1) of the Asylum Code, where housing is provided in kind, it should take one or a combination of the following forms:
- Premises used for the purpose of housing applicants during the examination of an application for international protection made at the border or in transit zones;
- Accommodation centres, which can operate in properly customised public or private buildings, under the management of public or private non-profit entities or international organisations and guarantee a suitable standard of living;
- Private houses, flats and hotels, rented for the purposes of accommodation programmes implemented by public or private non-profit entities or international organisations.
In all cases, the provision of housing is under the supervision of the competent reception authority, in collaboration, where appropriate, with other competent state bodies. The law provides that the specific situation of vulnerable persons, such as minors (accompanied and unaccompanied), people with disabilities, elderly people, single-parent households and pregnant women, should be taken into account in the provision of reception conditions.
In practice, a variety of accommodation schemes remained in place as of the end of 2022. These included mainly large-scale camps, initially designed as emergency accommodation facilities on the mainland, Closed Control Access Centres (CCACs) operated –under EU funding– on the Eastern Aegean islands, where asylum seekers are contained in prison-like conditions, and to a significantly lesser degree apartments and NGO-run facilities (see Types of Accommodation).
The end of 2022 marked the termination of the “Emergency Support to Integration and Accommodation” (ESTIA) programme for vulnerable asylum seekers. The positive impact of this accommodation scheme on local communities has been recognised by the municipalities that hosted it. For instance, as noted in January 2023 by the President of the Developmental Agency (Anaptyxiaki) of Irakleio, Crete, and Mayor of Archanes Asterousia, Crete while commenting on the termination of ESTIA, ‘[t]he framework, the rules and the whole organisation of the hospitality [under ESTIA] was exemplary and gave no room to the xenophobia that was initially expressed’.
The Ministry of Migration & Asylum had surprisingly announced in February 2022 that the programme would be terminated by the end of the year, by quoting the ‘improved management of Migration’. At the time, no information was provided on what would happen with the programme’s beneficiaries or if any provisions would be in place to address the needs of vulnerable asylum seekers. From 16 April ESTIA’s accommodation places were decreased to 10,000, less than half than those available in 2021 (27,000) and the programme was officially terminated at the end of the year. Its termination undermines the legal obligation of the State to provide specific support for the special reception needs of vulnerable persons throughout the asylum procedure. It also marks the complete transformation of the Greek Reception system into a system of social isolation of those seeking international protection in Greece, including of those most vulnerable among them. This is despite the reported willingness of the European Commission to continue the programme’s funding in the context of supporting alternative modes of accommodation to camps.
Up to the end of September 2021, UNHCR, in collaboration with the Catholic Relief Services (CRS), the International Federation of Red Cross and Red Crescent Societies (IFRC), and METAdrasi, also continued to provide cash assistance in Greece, in the context of the “ESTIA II-CBI” programme, financed through AMIF with the aim to partly cover material reception conditions by addressing beneficiaries’ basic needs (e.g. clothing, medication). The cash card assistance programme is being implemented throughout Greece. As of October 2021, the programme was fully handed over to the Greek state, and has since been implemented under the MoMA. A serious gap in the distribution of the assistance was identified as part of this transition, which remained unresolved until December 2021. In January 2022, overdue payments for October and November 2021 were made. However, significant numbers of eligible asylum seekers ended up not receiving cash, or backdated payments, as a result of changes in their legal status. Disbursements resumed at the beginning of March 2022.
Under the ESTIA II-CBI programme, the beneficiaries of the cash-based assistance are:
- Adult asylum seekers who have submitted or fully lodged an asylum application in accordance with article 65 (1)(2)&(7) L. 4636/2019, as long as they reside in the centres and facilities provided under para. 4 article 8 L. 4375/2016, in accommodation programmes of the MoMA, in shelters and hospitality centres operated by international organisations and legal entities governed by public law, local authorities, as well as civil society actors that are registered in the Registry of Greek and foreign NGOs of the MoMA. Applicants in detention are not entitled to the cash-based support.
- Beneficiaries of international protection who upon turning 18 reside in accommodation centres for UAM or in temporary accommodation spaces for UAM, for a period of three months following their placement to the aforementioned accommodation spaces.
In both cases, the new residency requirement as a pre-condition for receiving cash assistance, took effect on 1 July 2021, after first being announced through Press Releases issued by the MoMA in April and May 2021, and subsequently introduced in ministerial decisions in July and September. As per the new framework, cash assistance is provided to those eligible at the end of each month, as long as it can be certified that they continue to reside in the facilities designated by the MoMA (i.e. facilities of the reception system). Applicants who are not accommodated in these facilities need to first apply, then be referred to and lastly placed to such accommodation, before the procedure for accessing the cash assistance can (re)start. In these cases, the application can only be made through actors that are registered on the special referral platform of the ESTIA program (e.g. NGOs), while referrals can only take place under the responsibility of the RIS.
The decision to interrupt cash assistance to asylum applicants not accommodated in the reception system raised significant concerns, inter alia because it amounted to the withdrawal of material reception conditions to an estimated 25,000 asylum applicants, without any personalised assessment or reasoned decision, thus potentially also amounting to a violation of article 20 of Directive 2013/33/EU (as transposed by article 57 L 4636/2019 which was afterwards replaced by article 61 of L. 4939/2022). Furthermore, as highlighted by 30 civil society organisations in a joint statement published in June 2021, the decision came at the detriment of integration. In practice, many of those affected were called to abandon a place of residence of their own choice –which they were able to sustain with the cash-based support– and to abandon their communities and friends, in order to return to camps, where they would have to be in isolation from society. The decision also failed to take into consideration the protection risks that could arise at least for some in the context of suddenly having to share accommodation in a camp. As observed, applicants from some communities ended up preferring losing the financial support out of fear (e.g. of being identified by authorities of their countries). It lastly also failed to take into consideration the severely limited capacity of NGOs, which were in practice called to implement the decision, to support their beneficiaries as part of the transition.
With regard to distribution, in December 2022, a total of 4,728 asylum applicants (3,008 households) received cash assistance throughout Greece, primarily in the region of North Aegean (22%), Epirus (17%) and Central Macedonia (15%). This amounts to less than a third of the 15,785 asylum seekers reported by the MoMA as residing in Greece’s reception system during the same month, and to less than a fifth of total (22,170) asylum applications reported by the MoMA as pending decisions at 1st and 2nd instance in the same month. It also helps to a degree to better contextualise observations made by GCR in the field.
Namely, as observed in Kos, since the cash support programme was handed over to the MoMA, nearly all applicants on the island have stopped receiving this type of material reception support and, importantly, are no longer informed by the RIS of their right to receive it. Amidst changing practices, a further hindering factor observed is that applicants are required to hold a Greek phone number to be able to request cash support, meaning they must first have their asylum application registered, in order to then be able to exit the CCAC –where they frequently remain in conditions of de facto detention for up to 25 days– to procure such a number. Yet fast registration and processing times lead to situations where, within very few days (e.g. 4 in November) , applicants have already received a negative decision and are thus excluded from cash support before they even had the opportunity to apply for it. Whether similar practices apply to other applicants who did not receive cash needs to be further assessed, yet lack of access to cash was also reported in Lesvos, and affects all those who for (inter alia) reasons of dignity or fear have “opted out” of being accommodated in Greece’s camp-based reception system.
Of the 4,728 applicants who received cash in December 2022, the majority were from Afghanistan (23%), followed by Syrians (10%), nationals of the DRC (10%), Somalia (9%), Sierra Leone and Iraq (8% each). The vast majority of beneficiaries (58%) were between 18-34, 17% between 35-64, 21% were between 0-13, 4% between 14-17 and less than 2% were 65 years of age or older as per the MoMA’s data. No disaggregated data on the family situation of the applicants was published.
The amount distributed to each household s proportionate to the size of each household and differs depending on whether the accommodation is catered or not. The financial sums in 2022 remained the same as the ones distributed in 2021, ranging from € 75 for single adults in catered accommodation to € 420 for a family of four or more in self-catered accommodation. In general terms, the sum provided is lower than what is provided under the Minimum Guaranteed Income, which foresees € 200 support for a single-member household that is increased by € 100 for each additional adult member of the household and by € 50 for each minor member, up to a € 900 ceiling, albeit variations may arise depending on each household.
In addition to the fact that cash assistance preserves refugees’ dignity and facilitates the process of regaining an autonomous life, by allowing them to choose what they need most, the programme has also had a significant, positive impact on local communities, as this assistance is eventually injected into the local economy, family shops and service providers. In proportion to programme’s beneficiaries, approximately € 7.4 million in cash assistance was expected to be injected into the local economy in December 2020. No relevant data has been reported since the MoMA started issuing reports on the implementation of the cash programme.
 Article 59(1) Asylum Code.
 Article 62(1) Asylum Code in connection with article 1λγ΄ Asylum Code regarding the definition of ‘vulnerable persons’ in a non-exhaustive manner.
 For the closure of ESTIA, see among others: RSA, A Step backwards for protection and integration: On the termination of the ESTIA II housing programme for asylum applicants, 22 December 2022, available at: https://bit.ly/43vr3Y5, GCR, Press Release, «Εξώσεις, αστεγία και πισωγύρισμα στην ένταξη», 30 November 2022, available at: https://bit.ly/3oBev2B; FENIX, Closure of ESTIA II: thousands of extremely vulnerable asylum seekers to be left without humane and adequate accommodation and proper care, 31 October 2022, available at: https://bit.ly/43nPgzO.
 See among others: Greek Council for Refugees, Press release: Εξώσεις, αστεγία και πισωγύρισμα στην ένταξη, 30 November 2022, available in Greek: https://bit.ly/43JHgsN. See also: FENIX, ‘Closure of ESTIA II: A Political choice behind its closure’, 6 December 2022, available at: https://bit.ly/3N3jJhb.
 Ministerial Decision 115202/2021 on the Terms of provision of material reception conditions in the form of financial assistance to applicants for international protection, Gov. Gazette 3322/Β/26-7-2021. See also: Article 4 of Ministerial Decision 2857/29.9.2021 that adds Annexe III to JDM 2089/16.7.2021 regarding the provision of cash assistance as material reception condition to international protection applicants.
 For more, inter alia, Joint advocacy letter by 14 NGOs in Greece, ‘NGOs welcome the resumption of cash assistance for asylum seekers in Greece, call for gaps to be urgently filled’, 8 March 2022, https://bit.ly/3WKzHQw; Joint Statement by 26 NGOs in Greece, ‘Are you eligible to eat?’, 18 October 2021, available at: https://bit.ly/3ipbE6a; GCR/Save the Children, Greece: Children on the move, January-March 2022, available at: https://bit.ly/3OJ66Vm, 5.
 Article 1(d) Ministerial Decision 115202/2021, op.cit.
 MoMA, ‘The financial assistance to international protection applicants that are not accommodated in facilities under the responsibility of the MoMA or MoMA partners is abolished from 1/7/21’, 15 April 2021, available at: https://bit.ly/3IEvEgx and ‘Pre-requisites for the disbursement of financial assistance to international protection applicants’, 25 May 2021, available at: https://bit.ly/3IDe5xx.
 Ministerial Decision 115202/2021 op.cit and JMD 2857/2021 Amending JMD 2089/16-07-2021 on a ‘Common Framework for Managing Programmes that are assigned to the Special Secretariat for the Coordination and Management of Programmes under the Asylum, Migration and Integration Fund and the Internal Security Fund and other resources and are nor financed through National Programmes’ (Β’ 3120), Gov. Gazette 4496/29-09-2021.
 Estimates provided by UNHCR in the protection working group of 7 June 2021.
 As per information shared in the protection working group of 7 June 2021.
 Feedback from GCR team on Kos in January 2023.
 Information from the 11 January 2023 protection working group operating under UNHCR on Lesvos.
 MoMA, Factsheet December 2022, op.cit.
 Article 3 Ministerial Decision 115202/2021 on the ‘Terms of material reception conditions in the form of financial assistance to applicants for international protection’, Gov. Gazette 3322/B/26-7-2021. See also: Ministerial Decision 2857/29.9.2021 regulating the cash assistance program.
 Article 2 (7) JMD 3359/2021,