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Joint Statement on the Draft Bill of the Ministry of Migration and Asylum

Zusammenfassung

Proposed amendments to the Immigration Code criminalise actions of employees of NGOs who support refugees and migrants. Despite repeated international recommendations, the Ministry of Migration and Asylum continues to target civil society, using the NGO Registry as a tool of intimidation and silencing. 56 organisations have described the proposed provisions as illegal and are calling for their immediate withdrawal.
Refugee graffiti (Jeffrey Diamond)
Refugee graffiti (Jeffrey Diamond). Unsere Visual Policy

With the proposed amendments to Articles 24 and 25 of the Immigration Code, being an employee of an organisation registered in the “NGO Registry” of the Ministry of Migration and Asylum becomes a criminal offense.

After five years of continuous recommendations by the European Union, the Council of Europe, and the UN to lift arbitrary restrictions on the operation of civil society organisations supporting refugees and migrants, the Ministry continues to target organisations it considers troublesome for the sole reason that they are doing their job.

Simply being a member of an organisation registered in the NGO Registry upgrades misdemeanors such as facilitating illegal residence or refusing to hand over travel documents to felonies punishable by imprisonment of ten years and fines of tens of thousands of euros. In other words, the declared and approved exercise of the right of association is considered an aggravating circumstance capable of upgrading the offense to a felony, in defiance of fundamental principles of anti-crime policy and criminal legislation. Furthermore, the mere initiation of criminal proceedings is sufficient for the organisation to be removed from the Registry.

These provisions are intended to intimidate us. They are being introduced just a few months after the threats made by the Minister of Migration and Asylum against the legal representatives of people who arrived on Crete during the illegal three-month suspension of asylum and were protected from deportation by interim measures of the European Court of Human Rights, which were immediately condemned by international and national institutions but which the competent minister refuses to revoke. European Court of Human Rights, which were immediately condemned by international and national institutions but which the competent Minister refuses to revoke.

For the undersigned organisations, this effort is unjust, illegal, and unreasonable. We demand the immediate withdrawal of these provisions.

The joint statement will remain open for signatures until Friday, January 23, 2026, at 12:00 p.m. Contact details: Alkistis Agrafioti Hatzigianni (a.agrafioti@gcr.gr), Minos Mouzourakis (m.mouzourakis@rsaegean.org).

The undersigned organisations:

  1. BIOZO – Panhellenic Consumers Union
  2. Doctors of the World – Greek Delegation
  3. Médecins sans frontières – Greek Section 
  4. Women's Self-Defense Group
  5. Greek Housing Network
  6. Hellenic League for Human Rights (HLHR)
  7. Greek Helsinki Monitor
  8. Greek Forum of Migrants
  9. Greek Forum of Refugees
  10. Greek Counicl for Refugees (GCR)
  11. Civil Society Alliance Greece
  12. Diotima Centre
  13. Melissa Networks for Migrant and Refugee Women in Greece
  14. Copwatch GR
  15. Piraeus Association of Parents, Guardians & Friends of Persons with Disabilities (PEKAmeA)
  16. Symbiosis-School of Political Studies in Greece, affiliated to the Council of Europe Network of Schools
  17. Symplexis
  18. Association of Greek Conscientious Objectors
  19. Refugee Support Aegean (RSA)
  20. ART HUB Athens
  21. Boat Refugee Foundation
  22. Changemakers Lab
  23. Civil Society Alliance Greece
  24. Collective Aid
  25. Community Peacemaker Teams-Aegean Migrant Solidarity
  26. ECHO100PLUS
  27. Emfasis Non-Profit
  28. EmpowerVan
  29. Equal Legal Aid (ELA)
  30. Equal Rights Beyond Borders
  31. FemArtAct
  32. Fenix Humanitarian Legal Aid
  33. HIAS Ελλάδος
  34. HIGGS
  35. Human Rights Legal Project
  36. The HOME Project
  37. I Have Rights
  38. Inter Alia
  39. InterMediaKT
  40. Intereuropean Human Aid Association 
  41. INTERSOS HELLAS
  42. Irida Women’s Center
  43. iSea
  44. Legal Centre Lesvos
  45. Mazí Housing 
  46. Mobile Info Team
  47. Nimertis Action Art
  48. Northern Lights Aid
  49. PRAKSIS
  50. Project Armonia
  51. Reading to the Others
  52. Safe Passage International Greece
  53. Samos Volunteers
  54. SHE – Society for Help and Empowerment
  55. Velos Youth
  56. Vouliwatch
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Equal Rights Beyond Borders besteht aus zwei separaten juristischen Personen, die jeweils in Griechenland und Deutschland eingetragen sind.

Griechenland
Gemeinnütziges Unternehmen (ΑΜΚΕ)
Akadimias 84, 10678, Athens
+30 210 3803067, athens@equal-rights.org

Steuernummer: GR 996887928, Finanzamt: KEFODE Attikis
Registernummer (GEMI): 151850501000
NGO-Registernummer: ID 3058

Deutschland
Gemeinnütziger Verein (e.V.)
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info@equal-rights.org

Amtsgericht Berlin-Charlottenburg
VR 35583 B