“The Ministry’s of Migration and Asylum new draft law comes within less than 4 months since the entry into force (January 1, 2020) of L. 4636/2019 “On International Protection”, i.e. the law that entailed extensive changes of the Greek asylum law, which in itself is not an example of good law-making, and which in practice invalidates the invoked purpose of systematizing and codifying the relevant legislation (see explanatory memorandum law 4636/2019).
In addition, despite the fact that L. 4636/2019 has been consistently and substantively criticized by all national and international bodies and civil society organisations, due its numerous problematic regulations having led to deregulating the Greek asylum system, weakening the safeguards of refugee protection in Greece and “placing people in need of international protection in danger”,[2] the proposed amendments do not, in any part, restore the extremely problematic provisions of L. 4636/2019.
On the contrary, the introduced amendments are once more and in many respects contrary to the EU acquis in the field of asylum, and in this sense constitute a direct violation of EU law and of the Asylum and Return Directives, weakening basic guarantees for persons in need of protection, introducing additional procedural obstacles and reflecting, at the legislative level, the repeatedly stated intention to generalize detention and to increase returns, by preventing actual access to international protection. Accordingly, the draft law’s title “Improving Legislation on Migration, etc.” can only be considered as a euphemism.”