The “satellite city” system
Each applicant is assigned to a province, where he or she shall register with the PDMM, secure private accommodation by their own means and stay there as long as they are subject to international protection, including after obtaining status. This dispersal scheme is based on Article 71 LFIP, according to which the DGMM rarely refers an applicant to a Reception and Accommodation Centre but generally to take up private residence in an assigned province.
The RFIP elaborates the dispersal policy. It defines the concept of “satellite cities” as provinces designated by DGMM where applicants for international protection are required to reside. While new applicants for international protection can initiate their application in a province not listed in the list, and may remain there until they are assigned and referred to a satellite city.
According to the latest list, 62 provinces in Turkey are designated by DGMM as “satellite cities” for the referral of international protection applicants:
|Satellite cities for international protection applicants|
In practice, however, not all provinces are available to applicants. It is up to the individual PDMM to decide on the ‘opening’ or ‘closing’ of a “satellite city” and on referrals thereto depending on their capacity. When a PDMM is ‘closed’, it usually processes existing applications to issue International Protection Application Identification Cards and Temporary Protection Identification Cards. The ‘closure’ or ‘opening’ of a PDMM is not officially or publicly notified.
The regulation of the “satellite city” system is not based on publicly available criteria, nor is there an official decision taken in respect of each applicant. In general, metropoles and border cities do not usually figure among satellite cities.
Since there is only one fully operational Reception and Accommodation Centres with a capacity of 100 places, currently almost all international protection applicants are in self-financed private accommodation in their assigned provinces.
Prior to the changes in the Registration system, international protection applicants had to approach UNHCR / SGDD-ASAM in Ankara with a view to registering an application with UNHCR. During joint registration, they were able to choose their preferred province, provided that it was ‘open’ and had available places. Following that registration, they were given a Registration Document indicating the province in which they were required to reside and which they needed to reach in order to report to the PDMM.
Practice is now no longer standardised. The appointment of a “satellite city” is now done by the PDMM taking into account the existence of family members in other provinces, for instance, but it is not clear whether other criteria are also relied upon. The interpretation of family links is confined to first-degree members, meaning that siblings or cousins are not accepted.
Since DGMM took over the registration process there is no official list of open and closed cities for registration of Syrians and non-Syrians but stakeholders can receive information upon request from the PDMM. The situation also changes according to capacity.
According to one stakeholder, the following cities were closed to all non-Syrians and Syrians (except vulnerable cases) in early 2020: Istanbul, Edirne, Tekirdag, Kirklareli, Kocaeli, Canakkale, Bursa, Balikesir, Izmir, Aydin, Mugla, Antalya, Hatay and Yalova. Istanbul was reportedly closed to registration of both non-Syrians and Syrians except for justified reasons such as education, health or employment. However, Istanbul PDMM was reportedly not accepting registrations due to educational needs as it would mean registering the whole family which leads to an increase in numbers.
According to another stakeholder, this was the status of open and closed cities to Temporary (TP) and International Protection (IP) applicants in late 2019: Mardin: IP closed, TP open; Mersin: Both open but process is very long. For Iraqis for instance it takes more than 4 months; Urfa: Both open but TP takes 5 months; Maras: Both open; Hatay: Both closed as per a decision of the Governorate but open in emergency situations; Malatya: Both open; Osmaniye: Both closed except IP exemptions; Antep: Both closed but TP only in emergency situations. In Antep, even NGOs on the ground did not always know if the city was open or closed to applications. On the other hand, if there is a health or education emergency, both group of protection holders can be directed to other cities.
The situation in 2020 was complicated by COVID-19. It was often not clear if PDMMs were accepting applications or for how long and physical access was difficult for both lawyers and international protection applicants. This also delayed the registration process (see Registration of the asylum application).
After changes to the LFIP in December 2019 the law now foresees an administrative fine for those who provide accommodation to unregistered foreigners even unknowingly. In many provinces registration for Temporary Protection and International Protection is not taking place, foreigner citizens cannot complete registration even if they want to. This could lead to a rise in homelessness.
Travelling outside the “satellite city” and sanctions
The PDMM has the authority to impose an obligation on applicants to reside in a specific address, as well as reporting duties. In practice, applicants are not subject to strict reporting requirements, but their effective residence in the address declared to the PDMM is monitored if they do not appear before the PDMM for prolonged periods. In this case, the PDMM might conduct unannounced checks.
Any travel outside the assigned province is subject to written permission by the PDMM and may be permitted for a maximum of 30 days, which may be extended only once by a maximum of 30 more days.
As of November 2019, travel permits could be obtained through the online system (E-Devlet) through the e-accounts of refugees. Refugees are expected to get a password from National Postal Services. Some people still have language barriers and have difficulties in accessing the online system.  In 2020 during lock-down due to the COVID-19 pandemic, travel permits were not issued and many refugees and people seeking international protection were not able to travel to health services they were referred to, especially in urgent cases.
Failure to stay in an assigned province has very serious consequences for the applicant. International protection applicants who do not report to their assigned province in time or are not present in their registered address upon three consecutive checks by the authorities are considered to have implicitly withdrawn their international protection application. In practice, if the person is not found at his or her declared address, the DGMM may issue a “V71” code declaring that the applicant is in an “unknown location” (Semt-i meçhul) following a residence check.
Furthermore, applicants’ access to reception rights and benefits provided by the LFIP are strictly conditional upon their continued residence in their assigned province. The International Protection Applicant Identification Card is considered valid documentation only within the bounds of the province where the document was issued. They may also be subject to Reduction or Withdrawal of Reception Conditions if they fail to stay in their assigned satellite city.
In practice, however, applicants may be subject to even more severe – and arbitrary – sanctions such as administrative detention in a Removal Centre, with a view to their transfer to their assigned province (see Grounds for Detention). It seems, however, that the rigour of sanctions for non-compliance with the obligation to remain in the assigned province varies depending on the nationality, sexual orientation or gender identity or civil status of the applicant (e.g. single woman) or simply due to the working relationship of the applicant with the PDMM staff. Afghan applicants, for example, often face stricter treatment than other groups. Even where released from Removal Centres after being detained for non-compliance with the obligation to reside in their assigned province, asylum seekers are often required to regularly report to the Removal Centre or to a PDMM in a different province from the one where they reside. In 2019 the number of T6 forms issued increased because new detention centres opened. Ankara PDMM reportedly does not register people with T6 forms or those who illegally enter Turkey.
It is possible for applicants to request that DGMM assign them to another province on grounds of family, health or other reasons. Requests for a change in assigned province for other reasons may be granted by the DGMM Headquarters on an exceptional basis. Where an applicant is unhappy about his or her province of residence assignment and his or her request for reassignment is denied, he or she can appeal this denial by filing an administrative appeal with the IPEC within 10 days or filing a judicial appeal with the competent Administrative Court within 30 days.
 Article 2(hh) RFIP.
 Article 66(3) RFIP.
 Information provided by an NGO, February 2019.
 Information provided by a stakeholder, March 2020.
 Information provided by an NGO, February 2020.
 Information provided by an NGO, March 2020.
 Mülteci-Der, Joint Assessment: Proposed Amendments in the Law on Foreigners and International Protection of Turkey, 4 December 2019, available at: http://bit.ly/2IRYoVQ.
 Article 71(1) LFIP.
 Article 91(1)-(2) RFIP.
 Information from a stakeholder, Ankara, February 2020.
 Information provided by a stakeholder, March 2021.
 Article 77(1)(ç) LFIP.
 HRW, Turkey Stops Registering Syrian Asylum Seekers, July 2018, available at: https://bit.ly/2XM5t2V
 Information provided by a stakeholder, March 2020.
 Article 110(5) RFIP.