The PDMM are formally in charge of registering temporary protection beneficiaries and referring them to cities.
However, the list of available cities changes according to capacity and if there is a health or education emergency, both groups of protection holders can be directed to other cities. İstanbul is closed to registration of both non-Syrians and Syrians except for justified reasons such as education, health or employment. However, İstanbul 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.[1] In Istanbul, ten districts, Kucukcemece, Bagcilar, Basaksehir, Avcilar, Bahcelievler, Sultangazi, Esenler, Zeytinburnu, Esenyurt and Faitih are closed to the new registration of foreigners.
As of 6 June 2022, a protection seeker can be referred to a temporary accommodation center for registration, or registered by PDMM if it falls under one of the following categories:
- If the applicant has a family member who is already registered under temporary protection and not obliged to stay at Temporary Accommodation Centers. This category would include the spouses with civil marriage, new-born babies, underage children and dependents of the individuals who are already registered under temporary protection and not obliged to stay at Temporary Accommodation Centers;
- If the applicant has travel restrictions due to medical conditions, and if the applicant has no self-care ability;
- If the applicant has a family member (spouses who can furnish a civil marriage certificate, children, dependents) of Turkish nationals and foreign nationals holding residence permit, work permit or registered under international protection;
- If the applicant is deemed not suitable to be accommodated in Temporary Accommodation Centers due to a specific need, and their spouses, children and dependents.
If the applicant has any substantiating document of the above-mentioned situations, they should provide the PDMM with the relevant supportive documents. The applicant is registered at the Temporary Accommodation Centers if they do not fall under these categories. At the Temporary Accommodation Center that they are referred to, the applicant is fingerprinted, and a security check is conducted. The applicant is required to stay at the Temporary Accommodation Centre during the procedure. The applicant is issued the Temporary Protection Identification Card after the security check. If the applicant cannot pass the security check, they are interviewed by the PDMM prior to any other action. PDMM issues a decision on an individual basis if the applicant is assessed to be excluded from temporary protection.[2]
In 2022, registration of temporary protection continued, although not in all cities. For some stakeholders, all registrations were stopped, including temporary protection registrations. At the end of the year there were 3,535,898 people registered under temporary protection.[3] This is a decrease of 201,471 compared to 2021. Registrations are closed in many cities. For example, due to the increase in population density in İstanbul and people’s concerns, registrations have been closed in İstanbul since 2019, except for some instances (family reunification, access to treatment, having a work permit, vulnerable groups). Another problem widely encountered is when the father of the family has temporary protection, but his wife and children come to Türkiye illegally, try to register in İstanbul but have difficulties in accessing registration.[4] The new 25% rule or ‘deconcentration policy’[5] will also affect cities with larger populations of Syrians such as Kilis where over 38% of the population is made up of Syrians under temporary protection.[6]
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.
PMM 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 PMM staff to facilitate registration procedures.[7]
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. It aims to conduct security checks within 30 days. Syrians readmitted to Türkiye from Greece under the EU-Türkiye statement were also channelled through pre-registration. However, due to the high numbers of applicants, the lack of interpreters, and lengthy security checks, applicants face delays and difficulties in registration. Delays can lead to difficulties accessing healthcare and services, which require a Temporary Protection Identification Card and Foreigners Identification Number.[8]
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.[9] 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.[10]
[1] Information provided by a stakeholder, May 2023.
[2] UNHCR, Registration with the Turkish authorities, available at: https://bit.ly/3PWiVMU.
[3] See PMM website, ‘Temporary Protection’, available in English at: https://bit.ly/3wKyP0K.
[4] Information provided by a stakeholder, April 2022.
[5] Turkish Government, Mahalle Kapatma Duyurusu Hk., available at: https://bit.ly/3PXaBfM.
[6] See PMM website, ‘Temporary Protection’, available in English at: https://bit.ly/3wKyP0K.
[7] Turkish Government, Mahalle Kapatma Duyurusu Hk., available at: https://bit.ly/3PXaBfM.
[8] Information provided by a stakeholder, May 2023.
[9] PMM Circular 2017/10 of 29 November 2017 on principles and procedures for foreigners under temporary protection.
[10] Ibid.