GREECE: Implementation of NGO register leaves NGOs in legal vacuum

– By Dominika Spyratou, Common Ground, reported on 8 March 2021

Following a new Law in May 2020 and two Ministerial Decisions (March and September 2020 respectively) new rules were established for the registration of NGOs involved in Migration in Greece. The legislation was critised by NGOs and other stakeholders in Greece and internationally, including the Expert Council on NGO Law of the Council of Europe,  for not meeting EU standards and for creating difficulties with respect to freedom of association and the protection of civil society space. Nevertheless, the state disregarded criticism and recommendations and is restricting civil society’s ability to operate and to provide services and help to populations in need.

Implementation of the new legislation: Currently accordingly to the Ministry of Migration and Asylum official website only 27 NGOs have managed to successfully join the Registry ( to the Minister of Migration and Asylum approximately 200 NGOs have applied to join the Register. The majority of organisations working with migrants and refugees, including many whose role is crucial in the implementation of government programmes in refugee camps and other setting are not yet registered; in principle their operations should have seized as the deadline for their registration has passed. The Ministry is using the discretionary power that the new legislation provides, to allow several organisations to continue their operations in refugee camps and other setting, however this creates further uncertainty and confusion to organisations. At the same time other organisations were rejected and have claimed that authorities have used their discretionary power to exclude them from the registry which indicates that providing such a wide array of discretionary powers to authorities is problematic per se.

In addition, according to a report by Choose Love that was released in February 2021 ‘Of the 70 organisations surveyed, 20 noted that due to registration legislation they had already lost access to reception facilities or were faced with increasing difficulties with access. A further 40 anticipated problems with their ability to provide essential services, and 75 percent of the organisations foresaw problems with the ability of civil society to bear witness to the conditions facing refugees and displaced people.

The registration of the NGO under the name “Hopeland’ has raised further transparency concerns regarding the Registry. Until recently the NGO was unknown, had no record of providing services to refugees and no revenue. It became the second organisation to join the Registry and its registration was accepted a week after it was founded. Hopeland has since then become an implementing partner  for an accommodation programme for asylum seekers funded by the Ministry. A parliamentary inquiry about the selection criteria and suitability of the NGO for the specific prorgramme  has been also submitted; the Minister’s response was vague and did not address the three questions of the inquiry.

Furthermore, the Registry raises privacy and protection of private data concerns as authorities have access to personal data of employees and volunteers without adequate justification.

Annulment application against the Joint Ministerial Decision have been filed before the Council of State by at least two NGOs and some Association of NGO employees.


Read the report “Under pressure: How Greece is closing in on civil society organizations working with refugees” by Choose Love