GCR replies to questions posed by a foreign public authority

17/10/2017: GCR replies to questions posed by a foreign public authority, regarding the actual conditions pertaining to the access to basic social rights for beneficiaries of international protection in Greece, including persons with disabilities.

RE: Request for information about the actual conditions for aliens granted Convention status or subsidiary protection in Greece, including physically disabled aliens.

According to Art. 29 and 30 of Presidential Decree 141/2013[1], in general, beneficiaries of international protection should enjoy the same rights as Greek Citizens and receive the necessary social assistance according to the terms that apply for Greek citizens. However, not all of them have access to economic and social rights and welfare benefits. What has been recorded is either the difficult access of rights (bureaucracy and basically no provision for the inability of refugees to submit certain documents, i.e. family status, birth certificates, diplomas etc) or sometimes the refusal from civil servants to grant them the benefits provided, thus violating Greek or European law and the principle of equal treatment (Law 3304/2005).



(1)    Regarding the matter of whether aliens granted Convention status or subsidiary protection in Greece, including physically disabled aliens, have access to the healthcare services needed, please bear in mind the following information:

All Greek citizens are entitled to access healthcare free in Greece. Authorized residents in Greece are entitled to the same access to healthcare as Greek citizens. Formal access to the free services of the National Health System is dependent on registered employment and regular status, unless one is part of one of the groups defined by the 4368/2016 law of February 2016.

Law 4368/2016[1] implemented by the joint ministerial decision n° A3(c)/GP/oik.25132/2016 on 4 April 2016[2], opened access to the public health system to uninsured and vulnerable people and minimized the bureaucratic procedures. Pursuant to Article 33 of the 4368/2016 law, uninsured people and vulnerable social groups have free access to public health facilities, nursing and medical services. Asylum seekers and refugees are considered as vulnerable groups and thus have access to the public healthcare system for free, same as destitute Greek nationals, according to article 33 par.2 of the 4368/2016 law.

However, to access free healthcare, one must have a Social Security Number (AMKA)[3], pursuant to article 33 par. 3 of Law 4368/2016 ("For the provision of services of this arrangement to the beneficiaries, they must have a Social Security Number (AMKA), with the exception of the categories of case c’ in the paragraph 2 of this article, for whom the access to public health structures is determined by the joint ministerial decision as described in paragraph 5 of this article”). The granting of the AMKA is made by the KEPs [Kentro Eksipiretisis Pelaton (KEP) - Citizens' Service Centre] under the responsibility of the General Secretariat for Social Insurance[4]. However, in practice applicants are often confronted with problems by the KEP employees who do not provide them with AMKA numbers despite the fact that they meet the legal requirements. This refusal is accompanied by various reasons - most often unfortunate - which often lead to the administration's refusal to apply the current legislation[5].

In cases where beneficiaries of international protection cannot obtain an AMKA, for access to public health structures as determined by the joint ministerial decision, they must hold and display a special Foreigner Healthcare Card (K.Y.P.A.). However, the process of issuing a K.Y.P.A. is still inactive and despite the 31/05/2016 Circular of the Ministry of Health (A3g / G.P. oik.39364)[6], the persons concerned face ongoing problems in accessing health services.

Moreover, there are no translators or cultural mediators in public or private hospitals and health centers, which means that the access is becoming from hard to impossible for people that do not speak English or Greek.

In conclusion, in principle, beneficiaries of international protection, including physically disabled aliens, have free access to hospitals and medical care. However, given that Greece is witnessing an unprecedented increase in the inflow of refugees and migrants to its territory, the ability of the Greek health system to provide adequate health care to refugees upon entry is severely stretched. Thus, beneficiaries of international protection still encounter difficulties in gaining access to healthcare.


(2)  Regarding the matter of whether aliens granted Convention status or subsidiary protection in Greece, including physically disabled aliens, have access to housing, education and social welfare, please bear in mind the following information:

(2.1) Typically, beneficiaries of international protection have access to accommodation with the conditions and limitations applicable to third country nationals residing legally in the country, according to Article 33 of P.D. 141/2013[7] (Art. 32 of the Directive 2011/95/EU). In practice no state-run accommodation places are earmarked for beneficiaries of international protection, not even for vulnerable individuals, and no rent subsidies, loans or other forms of financial support for accommodation are provided. In the limited accommodation places reserved for homeless people in Greece, beneficiaries of international protection are not easily admitted. Those in need of shelter, who lack the financial resources to continue to rent a house, remain homeless or reside in abandoned houses, informal hotels, squats or unsuitable and overcrowded apartments, which are on many occasions sublet, often without access to electricity, toilets or running water. Some end up living in the streets, others are in constant danger of eviction. No alternatives are provided to them and no prospects for the future. Many survive only due to the help and support of others[8].

Moreover, there has been noticed in practice that beneficiaries of international protection who had been accommodated in the temporary camps or via the UNHCR scheme while they were applicants, are informally tolerated to stay on in these camps after their recognition for a further period of a maximum of six months[9]. Additionally, there is no provision for financial support for living costs. In an official information document distributed by the Greek Asylum Service beneficiaries of international protection are informed that the state cannot offer them shelter, nor can it guarantee social benefits or access to the labor market.[10] In other words, there are no shelters, exclusively for recognized refugees, where they could be part of integration activities.

Finally, it is worth mentioning that beneficiaries of international protection are required to prove their residence in the country in order to enjoy almost every social right in Greece, i.e. in obtaining a Tax Registration Number (AFM)[11], a Social Security Number (AMKA) and for the registration of unemployed persons in OAED (Manpower Employment Organization)[12]. According to the circulars regulating the above mentioned, the residence of the beneficiary of international protection must be proven by documents such as: (a) for residence in owner-occupied property, it is required to present a contract evidencing ownership and bills for state-owned enterprises; (b) for residence in rented property, it is required to present a copy of the electronic lease agreement, plus utility bills; (c) for residence in a property based on free concession, it is required to present the concession agreement and bills for state-owned enterprises.

(2.2) Furthermore, there are no free courses for Greek language by the State. The only program organized by the University of Athens charges a fee for participation in Greek Language courses, ranging from 500 to 670 Euros per academic year for immigrants.[13]

According to Article 28 par.1 of the PD 141/2013 (see also Article 27 par.1 of Directive 2011/95/EU)[14], minor beneficiaries of international protection have the same right to access to education as Greek nationals. According to Article 28 par. 2 (Article 27 par.2 of Directive 2011/95/EU), adult beneficiaries are also entitled to the educational system as well as to training programs under the same preconditions with third country nationals living in Greece. Free Greek language courses are offered at the moment by non­governmental organizations, but recognized Greek language certificates are issued only by the above mentioned program.

In an attempt to strengthen the educational system for the refugee children in Greece, the Ministry of Education adopted an educational program for refugee children. The basic new legal framework regulates the registration into schools with the circular 108457/Δ204/07/2016 “Reception Classes of Educational Priority Zones” (ΖΕΠ) and the “Facilities for the Reception and Education of Refugees” (DYEP) by the Ministerial Decision no 131024/Δ1 dated 08.08.2016) [15] and additionally the common ministerial decisions on DYEP 152360/ΓΔ4/2016 – (national gazette 3049/Β/23.09.2016) and 180647/ΓΔ4/2016 (national gazette 3502/Β/31.10.2016). Still, access to education is not guaranteed for all the minor beneficiaries of international protection. These classes are limited, created only  children aged 6 to 15 years old and they are insufficient to ensure integration of the children, as long as DYEP operate as separate preparatory classes, with no connection to the typical educational system. Also they do not include children over 15 years old; In secondary education the situation is even more challenging as the existing intercultural schools are not sufficient enough and there is no prediction for “Reception Classes of Educational Priority Zones” (ΖΕΠ.)

The governmental educational program for refugee kids has been mainly criticized for the lack of integration measures, keeping the refugee kids separate from the others and for the inadequate training and experiences of the teachers employed there[16]. Extra teachers employed for the special reception classes in the afternoons were recruited from a pool of state-registered supply teachers who have not been trained in intercultural education or teaching Greek as a second language. At the same time, the 13 nationwide existing intercultural schools lack the capacity to host more pupils. Given the fact that refugee children differ in their educational background and needs and the rising tensions in public schools in some local communities against refugee children’s attendance any systematic educational program is still absent.

(2.3) According to Article 30 of PD 141/2013 (Article 29 of the 2011/95/EU Directive, par. 1 and 256), it is ensured that beneficiaries of international protection shall receive the necessary social assistance as provided to Greek nationals[17]. However, austerity measures directly affected the social welfare legislation in Greece.

Family allowances are provided to families, who can show a 10 years permanent and continuous stay in Greece. As a result, the majority of beneficiaries of international protection are excluded from this benefit. Allowance to single mothers is provided to those who can provide proof (divorce, death certificate, birth certificates etc.) of their family situation. With no access to any authority of their country and no provision in law or in practice from the Greek State many of them are excluded because they cannot provide the necessary documents. The single child support allowance introduced by article 1, par. IA, subpar. IA.2 Law 4093/2012 as amended by article 6 of Law 4472/2017,  replaced the existed family allowances[18] .

Furthermore, beneficiaries of international protection are excluded by law from the social allowance to students, which amounts to € 1,000 annually. According to article 10 of law 3220/2004, this allowance is provided only to Greek nationals and EU nationals[19].

Beneficiaries of international protection with disabilities also face great difficulties in their efforts to access welfare benefits. First they have to be examined by the Disability Accreditation Centre to assess if their disability is at a level above 67%, so that they can be granted the Severe Disability Allowance[20]. Even so, there are often still significant delays in the procedure.

Since February 2017, the Social Solidarity Income (Κοινωνικό Επίδομα Αλληλεγγύης - K.E.A) is provided, a new welfare program regulated by Law 4389/2016[21].  This income of €200 per month for each household, plus €100 per month for each additional adult of the household and €50 per month for each additional minor member of the household, was designed in the current humanitarian crisis to temporarily support people who live below the poverty line, including beneficiaries of international protection. Provision is based on the following criteria: family status and family members, income and assets. It is described as a solidarity program and connected to supplementary services, such as access to social services that may provide cheaper electricity or water. 

However, the preconditions are difficult to meet. In order to receive this income, each member of the household must obtain a Tax Registration Number (AFM), a Social Security Number (AMKA), and a bank account. Also, each household must legally and permanently reside in Greece and the following documents are required to prove their residence: (a) for residence in owner-occupied property, it is required to present a contract evidencing ownership and bills for state-owned enterprises; (b) for residence in rented property, it is required to present a copy of the electronic lease agreement, plus utility bills; (c) for residence in a property based on free concession, it is required to present the concession agreement and bills for state-owned enterprises. In case of homelessness, homeless applicants are required to submit a homelessness certificate issued by the municipality or by shelter or a day-center. It is obvious, that it is almost impossible for homeless beneficiaries to provide all of these documents and hence they cannot apply for the allowance.

Unfortunately, except of K.E.A., there are no other effective allowances in practice. There is no provision of social support for vulnerable refugee cases, such as victims of torture, by the State. The only psychosocial and legal support addressed on the identification and rehabilitation of torture victims in Greece is offered by three NGOs GCR, Day Centre Babel and Doctors without Borders, which means that the continuity of the program depends on funding.

Finally, retirees beneficiaries of international protection, in principle have the right to the Social Solidarity Benefit of Uninsured Retirees, according to article 93 of Law 4387/2016 [22]. However, the requirement of 15 years of permanent residence in Greece in practice excludes seniors who are newly recognized refugees from this benefit. The period while they were applicants of international protection in Greece is not calculated, since legally the application for international protection is not considered as a residence permit.


(3)  Regarding the matter of whether aliens granted Convention status or subsidiary protection in Greece, including physically disabled aliens, have access to integration programs in Greece, please bear in mind the following information:

According to law 4375/2016 articles 69 and 71[23], beneficiaries of international protection in Greece have complete and automatic access to the labor market. In practice unemployment rates are so high (which currently run at over 23,5 %[24]), and competition from workers who speak Greek is so intense, that it is specifically extremely difficult for newly recognized refugees who do not speak Greek to find employment. Additionally, beneficiaries of international protection in Greece face obstacles in enrolling in vocational training programs as the majority of them cannot provide evidence (high school degrees, diplomas e.tc.) of their educational background, which are prerequisites for participating.

In accordance with the provisions of article 31 of Law 2515/1997[25], a Tax Registration Number (AFM) is mandatory for all persons and companies who have their domicile or professional housing or carry out taxation transactions within the Greek Territory. Along with AFM, submitting tax declarations is also an obligation for all residents and a precondition for entering employment and accessing social benefits and allowances. Τhe declaration of an address and the submission of a tenancy agreement or a hosting declaration as well as the homelessness certificate are necessary for the registration by the competent tax service. Additionally, a family certificate or marriage certificate is necessary for the registration of family status with the tax services. Beneficiaries face barriers to proper registration with the tax authorities due to the lack of documents required for proving accommodation or homelessness.

The acquisition of Greek citizenship by refugees or beneficiaries of subsidiary protection is regulated be the Code of Greek Citizenship[26] as amended by law 4332/2015. Specifically, a refugee can apply for the acquisition of Greek citizenship 3 years after recognition, and a beneficiary of subsidiary protection 7 years after recognition. Applicants for the acquisition of Greek citizenship must be integrated in the economic and social life of the country and be able to actively participate in the political life, according to the criteria set out in the article 5A of the Code of Greek Citizenship (general knowledge of history-geography-politics). Furthermore, one must undergo a lasting, complex and demanding interview procedure, that involves deep knowledge of the Greek history, culture, politics and literature etc. Also, there are huge delays in the procedure until the acquisition of Greek citizenship; the average time now stands at 3-5 years after the initial application.

In conclusion, there are many problems in the field of integration today. The administrative procedures for the granting of Social Security Number, Tax Registration Number, unemployment cards, bank accounts, etc. remain extremely problematic, while Greek language learning and labor market links remain fragmented and inadequate, making the integration of the population more difficult.


(4)    Regarding the matter of how the Greek authorities consider inquiries from aliens granted Convention status or subsidiary protection in Greece concerning criminal offences committed against them and whether the Greek authorities in actual fact offer protection in such situations.

During 2016/17, allegations of torture or other ill-treatment of individuals, including refugees, asylum-seekers and migrants during arrest or in immigration detention where reported. Hate-motivated attacks continued to be documented against people belonging to vulnerable groups including refugees, asylum-seekers and migrants. In December 2016, Parliament adopted a law designating the Greek Ombudsperson as a national police complaints mechanism. The mechanism has the power to conduct its own investigations but its recommendations to the disciplinary bodies of law enforcement agencies are non-binding.[27]

In 2015, the Racist Violence Recording Network[28] – developed by UNHCR and civil society organisations – documented 75 racist crimes against migrants or refugees. In a majority of these crimes, the victim suffered personal injuries. Severe attacks were also documented. However, impunity runs high in Greece. Positively, refugees and migrants who may be victims of hate crimes are excluded from the return procedure and may be granted humanitarian permits. Possible victims of hate crimes are also exempted from paying a deposit when they sue the perpetrators[29]


In light of the above mentioned, on April 19th, 2017, the Administrative Court in Hannover (Verwaltungsgericht Hannover) granted a suspension on the transfer of a recognized refugee to Greece in an appeals case. [30] The Court considered his transfer to Greece a breach of the ECHR. On May 8th, 2017, the Federal Constitutional Court (Bundesverfassungsgericht) stopped the removal of a recognized refugee from Syria to Greece and highlighted the need of examination of “how access to shelter, food and sanitary facilities would be safeguarded for recognized refugees returned to Greece at least in the first period after their arrival there”[31].

In general, integration for refugees in Greece was primarily the responsibility of the Ministry of Interior, responsible for the management of the European Integration Fund.  Since the funds transformation to AMIF, there was a newly appointed state authority responsible for managing it. In the last two years almost nothing has happened regarding integration matters, except of the formal educational program for minors beneficiaries of international protection and a small pilot program concerning vocational training in the agriculture sector[32].

In the absence of State sponsored integration programs, NGO's are struggling to assist refugees. Yet, given the current situation in Greece where over 50000 people have been added to those who were recognized as refugees and to those who are in the process being recognized (asylum seekers)[33], the emphasis of even the NGO's is placed upon meeting the needs of the newly arrived. in essence the assistance in terms of integrating refugees in Greece could be rated from extremely limited to non­existent. Consequently, newly recognized refugees have not much to expect for and most likely will continue to face living conditions which do not facilitate their integration but on the contrary have basic characteristics of social exclusion. (No housing is foreseen based on Refugees status, nor is there a financial support envisioned until someone manages to find employment. Moreover, UNHCR can fund an extremely limited number of projects for providing information, counseling, legal and social assistance to refugees. According to our experience, the possibility for direct financial assistance to beneficiaries of international protection arising from such projects is extremely limited and framed within the duration of each project. Therefore, such financial assistance can only have an extremely limited effect.

To conclude, GCR notes that the recognition of asylum seekers as beneficiaries of international protection does not result in any improvement of their social status. Instead, many of them continue to be homeless and unemployed with no future possibility of improvement. The majority of beneficiaries of international protection have never received adequate reception facilities, like housing and financial support. As a result, they keep facing serious welfare problems (poverty, homelessness, unemployment etc) and most of the times they cannot cover their basic needs. The lack of national integration policy for beneficiaries of international protection combined with the strong economic and social crisis in Greece creates an environment for refugees, non-conducive to integration but rather to social exclusion.

Yours sincerely,

Greek Council for Refugees (GCR) Legal Unit Coordinator

Vassileios Papadopoulos

 and lawyers at GCR’s Legal Unit

Eleni Kagiou

 Natalia-Rafaella Kafkoutsou




                        [1] Law 4368/2016 https://www.minedu.gov.gr/publications/docs2016/%CE%A6%CE%95%CE%9A.pdf

                        [2]Joint ministerial decision implementing law 4368/2016 http://www.opengov.gr/yyka/wp-content/uploads/downloads/2015/04/sxedio-kya-anasfalistwn.pdf

                        [3] AMKA Number, article 153 of Law 3655/2008 http://www.etaa.gr/files/N.3655-08.pdf

                        [4] Paragraph 3 of the article 153 of Law 3655/2008

                        [5] For more information about this matter please refer to our website http://www.gcr.gr/index.php/el/news/press-releases-announcements/item/689-koini-anafora-25-organoseon-gia-peristatika-paraviasis-dikaiomaton-ton-aitounton-asylo

                        [6] “Clarifications on how to ensure access to uninsured and socially vulnerable groups in the public health system”  https://www.gni-hatzikosta.gr/files/%CE%A9%CE%951%CE%91465%CE%A6%CE%A5%CE%9F-6%CE%A6%CE%9D.pdf

                        [7] See above mentioned note 1.

                        [8] AIDA 2017: Country report Greece (2016). Source: http://www.asylumineurope.org/reports/country/greece (page 142)

                        [9]LEGAL NOTE On the living conditions of beneficiaries of international protection in Greece,  https://www.proasyl.de/wp-content/uploads/2015/12/2017-06-23-Legal-note-RSA-beneficiaries-of-international-protection-in-Greece.pdf

                        [10] Please refer to the Greek Asylum Service 2017: Rights and obligations / Rights for beneficiaries of international protection, http://asylo.gov.gr/en/?page_id=471  http://asylo.gov.gr/en/wp-content/uploads/2017/02/Rights-of-beneficiaries-of-international-protection-2.2017.jpg , Frequently asked questions http://asylo.gov.gr/en/wp-content/uploads/2016/11/FINAL-QA_EN_06_2016.pdf

                        [12] Circular B102129/17.01.2012/23.01.2012 (ΑΔΑ: ΒΟΧ44691Ω2- Τ3Ψ) as amended by circular 102295/28.11.2014    ΕΙΝΑΙ ΛΑΘΟΣ

                        [13] http://en.greekcourses.uoa.gr/

                        [14] See above mentioned note 1.

                        [15]  Reception Classes of Educational Priority Zones - Facilities for the Reception and Education of Refugees (Ρυθμίσεις Ζωνών Εκπαιδευτικής Προτεραιότητας (ΖΕΠ) - Ίδρυση Τάξεων Υποδοχής ΖΕΠ, Ενισχυτικών Φροντιστηριακών Τμημάτων ΖΕΠ και Δομών Υποδοχής για την Εκπαίδευση των Προσφύγων ΖΕΠ (Δ.Y.Ε.Π. ΖΕΠ) σε σχολικές μονάδες Π.Ε) https://www.esos.gr/sites/default/files/articles-legacy/fek_zep.pdf

                        [16] Circular No. 108457/Δ2 dated 4.7.2016 (Circular related to the enrolment of students from third countries with incomplete documentation in Secondary Education school units of the country) http://dide-a-ath.att.sch.gr/1/images/data/ekp_data/egkl_eggr-allod-math_el-dik_5-9-16.pdf

                        [17] See above mentioned note 1.

                        [18]  Law 4093/2012 http://www.dsanet.gr/Epikairothta/Nomothesia/N4093_12.htm , Law 4472/2017 https://www.forin.gr/laws/law/3581/nomos-4472-2017#!/?article=26874

                        [19] article 10 of law 3220/2004, https://www.fle.gr/index.php/nomoi-p-d/101-nomoi-p-d-2004/293--322004-

                        [20] See Severe disability allowance http://www.synigoros-solidarity.gr/solidarity/assets/uploads/2015/11/YA-Epidoma-varias-anapirias.pdf

                        [21] Social solidarity allowance  article 235 Law 4389/2016, http://www.et.gr/index.php/82-2013-01-30-08-00-00/340-n4389-2016 , https://keaprogram.gr/pubnr/Home/Contact

                        [22] Social Solidarity Benefit of Uninsured Retirees  http://www.eea.gr/system/uploads/asset/data/11639/N.4387-16__FEK_ASFALISTIKO.pdf

                        [23] Law 4375/2016 https://www.synigoros.gr/?i=foreigner.el.politikoi-nomoi.359552

                        [27]GREECE 2016/2017

                        [28]  Racist Violence Recording Network  http://rvrn.org/2017/04/%CE%B5%CF%84%CE%AE%CF%83%CE%B9%CE%B1-%CE%AD%CE%BA%CE%B8%CE%B5%CF%83%CE%B7-2016/

                        [29] Current migration situation in the EU: hate crime http://fra.europa.eu/sites/default/files/fra_uploads/fra-2016-november-monthly-focus-hate-crime_en.pdf



A list of actions is mentioned here, unfortunately only in Greek:  http://www.amifisf.gr/prosklisi_cat/tame/

                        [33] Apart from the 570,000 third country nationals legally residing in the country and the high stock of undocumented migrants.

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