The PDMM are formally in charge of registering temporary protection beneficiaries. However, in 2018, PDMM in large provinces such as Istanbul, Hatay and Mardin de facto stopped registering and granting documents to newly arriving Syrian refugees, with the exception of vulnerable cases. Others such as Şanlıurfa continue to register temporary protection beneficiaries, although they have stopped registering international protection applicants.
The registration process of Syrians has not been smooth in 2019. Vulnerable groups had priority in registration procedures but the number of Syrians who did not receive ID documents increased in 2019. The main problem is the increase in the number of ‘closed cities’ and the problems in getting travel permit from PDMMs. Without valid travel permits, Syrian refugees are at risk of deportation or administrative detention.
After the July 2019 operation in Istanbul, all Syrians registered in Antakya were sent back to Antakya, which had repercussions for the situation there. Antakya is now closed for new registrations except vulnerable cases due to the high number of Syrian refugees. Even in these cases, registration takes a long time. If during the data verification process it is found that the person lied during the initial registration process that person is immediately deported due to a crime under Article 206 of the Turkish Criminal Code called ‘lying during the constitution of an official document’. The person is also banned from re-entering Turkey and a V-87 code is imposed. 
A lawyer provided a list of open and closed cities to temporary and international protection applications in 2019 (see The “satellite city” system).
According to another 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. However, the list changes according to capacity and if there is a health or education emergency, both group of protection holders can be directed to other cities. Istanbul is reportedly closed to registration of both non-Syrians and Syrians except for justified reasons such as education, health or employment. However, Istanbul PDMM is reportedly not accepting registrations due to educational needs as it would mean registering the whole family which leads to an increase in numbers.
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.
DGMM collects biometric data, including fingerprints, during registration and maintains electronic files for each beneficiary in the agency’s electronic file management system named “Göç-Net” – an internal database available to DGMM staff to facilitate registration procedures.
Security checks and pre-registration
As discussed in Eligibility, Article 8 TPR makes provisions for exclusion of persons from temporary protection, without however designating a procedure for the exclusion assessment. However, as Article 22 TPR instructs that persons who are determined to fall within the exclusion grounds shall not be issued a Temporary Protection Identification Card, it implies that the registration interview should also entail the exclusion screening of applicants.
In practice, this has been crystallised through a pre-registration phase prior to temporary protection registration introduced in March 2016. Pre-registration is conducted with a view to conducting security checks within a period of 30 days, the modalities of which are set out in an unpublished circular. Syrians readmitted to Turkey from Greece under the EU-Turkey statement are also channelled under pre-registration.
In many locations around Turkey, due to high numbers, lack of interpreters and the conduct of security checks, applicants are given pre-registration appointments and face substantial delays before registering, which may take several months and vary from one province to another. Applicants also face other practical impediments to registration such as errors on the part of DGMM officials, which may only be corrected following time-consuming legal intervention.
The delay in registration leads to problems in accessing health care and other services, which require the beneficiary to have a Temporary Protection Identification Card and a Foreigners Identification Number (YKN), which is listed on the card.
It should be noted, however, that certain categories of vulnerable groups are issued a Temporary Protection Identification Card without waiting for the 30-day period of pre-registration. This includes: (a) children aged 0-12; persons in need of urgent medical treatment; pregnant women; elderly persons; and unaccompanied children. In practice, people with special needs such as persons with health conditions or women in advanced stages of pregnancy benefit from prioritisation in the registration procedure.
Completing registration before the PDMM
After the completion of the pre-registration phase, the applicant is required to appear before the PDMM within 30 days in order to obtain the Temporary Protection Identification Card. Failure to appear before the PDMM 15 days after the expiry of that 30-day time limit without a valid reason leads to the activation of a “V71” code on “unknown location” (Semt-i meçhul). The “V71” code suspends the registration procedure and can only be lifted after the PDMM confirms the continuation of the procedure or after search and apprehension records are registered in the database.
 Information provided by a stakeholder, February 2019. See also Human Rights Watch, ‘Turkey Stops Registering Syrian Asylum Seekers’, 16 July 2018, available at: https://bit.ly/2uq5FWg; Hürriyet, ‘Turkish government stops relocating Syrians to Istanbul’, 9 February 2018, available at: https://bit.ly/2HPa9NL.
 Information provided by a lawyer of the Şanlıurfa Bar Association, February 2019.
 Information provided by a stakeholder, February 2020.
 Information provided by a stakeholder, February 2020.
 Information provided by a stakeholder, 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.
 Information provided by Izmir PDMM, December 2017.
 UNHCR Greece, ‘Response to query related to UNHCR’s observations on Syrians readmitted to Turkey’, 23 December 2016, available at: http://bit.ly/2B5IykY. See also Euractiv, ‘Turkey blocks UNHCR access to Syrian refugees’, 19 January 2017, available at: http://bit.ly/2BFsuYp.
 In Konya, for example, registration is reported to take 2 months at the time of writing: Information gathered following a visit to an NGO, February 2019.
 Information provided by Adana Bar Association, February 2018.
 On some occasions, courts have granted orders to allow vulnerable persons to access health care. See e.g. 2nd Children’s Court of Gaziantep, Decision of 18 July 2016.
 DGMM Circular 2017/10 of 29 November 2017 on principles and procedures for foreigners under temporary protection.