14 March 2022

First refugees from Ukraine arrive in Greece: Our concerns on the management of the issue by the Greek authorities

A total 6,488 refugees from Ukraine have crossed Greek borders since the Russian invasion in Ukraine. There are no official data on the composition of the population that enters the country, but it is estimated that over 2,100 are minors, many among them being unaccompanied. The main entry point to Greece is the Bulgarian-Greek border crossing of Promachonas. The total number of refugees from Ukraine has tripled in the last week and the Ministry of Migration and Asylum estimates that the number will soon rise to 30,000.

First reactions in public sphere

Various government officials have made statements to the media on the issue. Minister Mitarachi described Ukrainians who come into Greece as “real refugees”, and further supported his view in parliament, in response to a relevant question from the representative of the parliamentary opposition. Tourism Minister Kikilias ironically wondered in his tweet if the NGOs operating on Greek islands would now go to assist in the humanitarian crisis in Ukraine. PM Mitsotakis reiterated this statement in parliament, calling the NGOs in Greece to also support the crisis in Ukraine, in a rather toned-down version. Several aid groups have been set up through social media platforms and prepare material support to be sent to Ukraine.

The notorious “Kleidi” camp

It is unclear how Greece will receive, accommodate and allocate refugees from Ukraine. The Ministry has announced that “Kleidi” camp in Serres will be used as a first reception center. Apart from the fact that the facility was set up during the shameful March 2020, when asylum seekers were placed in Kleidi and Malakasa camps to be further deported without their asylum claim being examined, during the tense events at the Greek-Turkish border of Evros, the camp is totally inappropriate to host persons in need of protection. The camp, geographically located in a canyon, is exposed to bad weather conditions, and the provision of food and supplies is often interrupted due to the overflow of Strymonas riverbanks, located a few dozen meters from the camp’s gate.

Temporary protection – Also in Greece

Greece too activated the Temporary Protection Directive.

Persons permanently residing in Ukraine who fled the country after 24 February 2022 may be entitled temporary protection in EU. A 90-days visa will be provided upon entrance. In Greece, the Presidential Decree 80/2006 on the temporary protection has been activated by the recently issued Ministerial Decision (Protocol No. 131035). The wording of the decision of the Council of the EU and of the Ministerial Decision leave a loophole as regards persons who were not in Ukraine on February 24, and de facto cannot return. As a matter of fact, there are some hundreds of Ukrainian students in Greece who fall in this category. Therefore, our position is that the Decision must be amended to also include persons, for who Ukraine was their center of vital interests.

Concerns on the Registration System

Beyond living conditions, our concerns extend to the registration process for temporary protection applications, access to health care, material reception conditions and access of school-age children to education.

Until now, the Ministry hasn’t provided information on the registration system of relevant applications, which is expected to be launched at the beginning of April. We welcome the immediate creation of an information webpage; the Ministry seems to be acting with unusual speed in providing information to refugees of this crisis.

The Regional Asylum Offices across Greece don’t seem to have capacity to deal with an overflow of applications for temporary protection. Therefore, it won’t be a surprise to see the creation of another Autonomous (Asylum) Unit, only for these applications. Should persons from Ukraine decide to submit an asylum application, for example in cases who fall outside the temporary protection’s eligibility criteria, they will face another paradox. Ukraine remains in the national list of safe countries of origin, in clear contradiction to the provisions of Art. 87 L 4636/2019. For these cases, the applications will be rejected as unfounded, under art. 88 L 4636/2019.

“Outsourcing” Protection?

However, the set-up of a webform for the provision of material assistance in refugee camps by individuals and NGOs might signals the externalization and outsourcing of the protection regime. It is to be seen whether this support is to be provided in a volunteer-basis to actually substitute again the State’s obligation to provide decent reception conditions. It is worrying, also, that the Ministry distributed all relevant information only to NGOs that are included in the NGO Registry.

The well-known inadequate system for providing decent reception conditions: What we expect to see

According to the current announcements, persons who flee Ukraine and enter into Greece are temporarily hosted in the camp of Kleidi in Serres. The Ministry gives oral guarantees that persons who ask for accommodation will further be transferred to other facilities in mainland. Greece’s misleading statistics on past accommodation referrals leave no doubt that we won’t be able to depict the actual accommodation situation again. Inevitably, refugees will rely upon the support of their own community. The Ministry rushed to close major reception facilities in mainland and recently announced the downsize and then closure of ESTIA accommodation scheme by the end of the year. At the same time, a significant portion of places are not vacant, but host recognized refugees who overstay, in lack of integration alternatives.

Temporary protection holders are entitled to housing and social welfare rights. Greece’s ministerial decision specified the provisions (Art. 2,3), by referring to the material reception conditions of the Greek Asylum Law 4636/2019.

This means, that beneficiaries of international protection are entitled to financial assistance. If they will not be provided with cash in reality – which is in view of the past very possible – we will exhaust legal remedies accordingly.

Furthermore, the termination of reception conditions, namely Cash and accommodation, is not foreseen in Law for persons with temporary protection.

We expect that the Ministry will attempt to regulate the issue by providing for the cessation of the assistance in case of employment or after a certain period of time. This has been the case for other recognized refugees as well, as we have shown in several occasions.

Access to healthcare and working rights

Persons with temporary protection status are allowed to work and access healthcare (Art. 2 MD).

Given that a tax registration number (AFM) is a pre-requisite for entering the labor force in Greece, it is unclear if and when refugees from Ukraine will be able to enjoy the respective rights. We have experienced significant delays in the past in the issuance of the AFM number. In this case, the acquisition system has to be adjusted and Circulars have to be issued for the guidance of tax offices, which will inevitably take time.

The same applies to AMKA, the national social security number. Although persons residing in Greece have in theory access to emergency healthcare, according to Law 4368/2016, this system is heavily depended on the assistance of NGOs for interpretation and coverage of extra medical costs. For instance, Metadrasi NGO is contracted to support with interpretation at hospitals. This support is scarce, in that interpretation only in Arabic and Farsi is provided, whereas the organization covers only some major hospitals. At the same time, the system of consumer’s participation for medicines is for many unaffordable, reaching in many cases 20% of the market price. This had prompted UNHCR to set strict criteria for the eligibility of costs under the ESTIA programme in the past.

The asylum service’s indifference to solve miscommunication issues with IDIKA, the Greek e-governance system had left thousand asylum-seekers without healthcare in 2020 and jeopardized the lives of two client of ours. Following a complaint we submitted to the Greek Ombudsman, the problem was solved after the intervention of the independent authority.

Besides, there is no provision for the period until the registration of the application or the acquisition of temporary protection status. Even though the Ministry has happily announced that both AFM and AMKA numbers will be granted upon registration, vulnerable applicants are expected to face struggles with emergency medical requests and with medicine supply until their registration, meaning for up to three months.

Access to education

Children from Ukraine that fled from their country in the middle of the schooling year have started to ask of a possibility to enroll in Greek schools. The Ministry of Education gives assurances that special classes will be prepared, with the active support of Greek teachers who came back from Ukraine after the invasion. As there are several formalities to be completed prior to a pupil’s enrolment in school in Greece, children from Ukraine will risk losing the schooling year, if no other solution is found with regards to mandatory vaccination and pupil’s medical card.

Unaccompanied children – the fear of a return of the protective custody practice

Greece has recently abolished -at least orally- the practice of holding unaccompanied children in cells at police stations, until a better solution is found. We believe that this was a result of Greece’s severe condemnation from international organizations and civil society but foremost, from our efforts to hold the country liable and ask the European Court of Human Rights to order compensation of non-pecuniary damages, as a result of violations of the Convention’s article 5. The abolition of this system and the placement of the -undoubtedly successful- tracing system came to a very favorable time for Greece – arrivals of asylum-seeking children were at their lowest since 2015 and the -voluntary- relocation system had just been completed. However, Greece’s reception capacity of unaccompanied children does not seem to have changed. Greece hosts almost 2,500 unaccompanied minors, as also in 2020. We fear that Greece will inevitably return to the unlawful practice again in case of a mass influx of arrivals.

Needed Action

We will continue to monitor the adherence of Greece to international protection standards. We intent to send a team of experts to the first reception point, the camp of Kleidi in Serres, at the end of March, to monitor the progress of the implementation of the recent Ministerial Decision.

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