Ref. Ares(2015)2688180 - 26/06/2015
DIRECTORATE-GENERAL MIGRATION AND HOME AFFAIRS
Directorate E – Migration and Security Funds
Unit E1 – Programming
Observations on the second version of the multiannual national
programme under the Asylum, Migration and Integration Fund for
Thank you for the third version of the national programme under the Asylum, Migration
and Integration Fund for Greece,
submitted on 19 June 2015,
following the observations
made by the Commission on 29 May 2015 (uploaded in SFC on 18 June 2015).
Following the re-examination of the national programme by the Commission, we would
like to provide you with additional observations on this amended version, and invite you
to present us with a modified programme as soon as possible.
The period of six months set for the approval of the multiannual national programme by
the Commission, referred to in Article 14(7) of Regulation (EU) No 514/2014, is hereby
suspended until a revised version of the programme is submitted.
Head of Unit
Encl.: Annex: Observations on the proposed national programme
Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11.
Observations on Greece's draft NP for AMIF submitted on the 19 June 2015
The revised draft programme is substantially improved, taking in consideration most of the
Commission’s latest observations and the results of the discussions held in Athens on 10-11
June 2015. However, some information still needs to be provided and some corrections need to
be made in the programme before it can be considered ready for approval. Furthermore, in line
with our discussions, please provide also the required annexes with further information on the
functioning and monitoring of reception facilities for applicants of international protection
(centres, network of rented apartments).
Identification of the designated authorities
We take note that no formal designation of the Responsible Authority (RA) has taken
place yet (provisionally or fully). Please note that the RA shall be formally designated before
making payments eligible to the Funds. We would like to furthermore draw your attention to
Article 35 of Regulation n°514/2014 in which it is stipulated that the initial pre-financing
payments by the Commission following the approval of national programme shall be paid to the
Moreover, should the RA be provisionally designated, we invite you to inform us about
the duration of the provisional designation and, in line with article 31 of Regulation (EU)
N°514/2014 and to allow the Commission to have a clear view on the reasons leading to the
provisional designation as well as the content of the action plan, to transmit also the respective
audit reports (including the conclusions i.e. non-compliances, the timeframes to address these
As regards the Management and Control System (MCS), please complete fully the table
in the first page and explain in the respective section to what extent the system is different from
the one used for former SOLID funds. Please also note that the MCS must be finalised (and
checked by the audit authority) before the designation of the Responsible Authority (RA).
Section 2: Baseline situation in the Member State
The baseline situation still needs to be completed/updated with information on:
Data on financial resources, both national and EU funds, allocated to different policy
areas (asylum, legal migration/integration and return) and respective components (asylum
service, reception, backlog, unaccompanied minors, voluntary and forced returns, etc.) are still
We also note that the draft continues to refer to December 2016 as target date for
clearance of the “backlog” asylum cases to be funded by AMIF: as agreed in Athens on 18 June
2015, no target date should be mentioned in the national programme for the clearance of the
With regards to the reception of applicants for international protection, the draft
continues to refer to the Ministry of Labour and the First Reception Service as the competent
authorities for the establishment and operation of open reception facilities, while in our
understanding that competence lies now with the new body within the Ministry of Interior and
Administrative Reconstruction which will be one of the Delegated Authorities to be soon
designated. We also note that no reference is made to EKKA, the body that coordinates all
referrals of applicants for international protection to open reception facilities. To allow for a
better understanding of how the reception facilities operate as part of a coordinated and
sustainable system at national level, the role of EKKA should be clarified in the programme.
Please clarify these issues.
To our understanding the data provided in the asylum section does not reflect the
situation up to 03/2015 according to the official statistical data of the Asylum Service.
Section 3: Programme objectives
SO1 – Asylum
Please note that the main actions and funding priorities are not always clearly
Please note also that when presenting the national strategy in this area no reference is made to
contingency measures as regards reception capacity, even though such contingency measures
are referred under the respective national objective.
On National Objective 1 (Reception / Asylum
), as regards the clearance of the pending
appeals the draft continues to refer to December 2016 as target date for clearance of the
“backlog” asylum cases to be funded by AMIF: as agreed in Athens on 18 June 2015, no target
date should be mentioned in the national programme for the clearance of the “backlog”. We
understand that no funding is envisaged under the NP for the clearance of the backlog. We also
understand that the financial support of EUR 1 million to be granted for this purpose under
Union Actions would not be enough for the clearance of the backlog. Please confirm this
assumption and indicate the funding complementary sources to be used for this purpose, i.e.
On National Objective 3 (Resettlement),
we take note that Greece does not propose any
resettlement measures in the framework of its national programme. On the other hand, as the
resettlement pledging exercise for 2014/2015 does not depend on the results of the ongoing
discussions on the measures proposed in the European Agenda for Migration, we believe that
the explanation provided in the national programme is not relevant and invite therefore Greece
to withdraw it from the programme.
SO2 – Integration / Legal Migration
Please redraft the explanation on the complementarity of funding with ESIF, to make it
clearer, reading like this: “Considering the current financial situation in Greece and the limited
national resources, it is of utmost importance to prioritise funding from AMIF to cover Greece’s
pressing needs in the areas of asylum and return, address persistent systemic deficiencies and
comply with the EU acquis
. Therefore, the percentage of AMIF resources to be allocated to
integration / legal migration measures is lower than the 20% threshold (Article 15(1)(a) of the
AMIF Regulation). However, Greece plans to mobilise substantial complementary funding (at
least EUR 20 million) from ESIF to support integration measures, thus ensuring that in total an
amount equivalent to at least 20% of AMIF allocation for Greece would be used in support of
We also note that the draft continues to make reference in this section to UASC, instead
of Unaccompanied Minors (UAM). Unless there is a specific need to refer to unaccompanied
minors applicants for international protection, the term unaccompanied minors (UAMs) should
be used throughout the text. In addition, the national strategy for unaccompanied minors is
mentioned in this part, as well as in the asylum part. To our understanding this strategy is
considered to be an overall systematic procedure which will affect every unaccompanied minor
TCN in Greece.
In the paragraph on projects under National Objective 2 (Integration
), the reference to
"monthly allowance" should be clarified. Please explain what the allowance would be aimed for.
In addition, please move action (e) to National Objective 3 (Capacity
Reference to Specific Action 8 (Legal Migration
) led by Belgium should be deleted from
the programme since such Specific Action has not been approved for funding.
SO3 – Return
Returning people who do not or no longer have the right to stay in the EU needs to be
part of any comprehensive migration policy, an approach that is reflected in your national
program. Given the increasing number of irregular migrants coming to Greece we are pleased to
see that Greece’s objective is to increase the number of returnees, as keeping the numbers on
the average of previous years would seem too modest a target. While we would agree that the
first focus should be on increasing voluntary returns, we would like to underline that the
success of voluntary return is also depended on the efforts on forced return
SO4 – Solidarity
We take note of the fact that Greece does not present any national strategy nor
propose any actions under this specific objective.
Section 3: Indicative timetable
We note that some actions are foreseen to start in 2015. As no formal designation
(provisionally or fully) of the RA authority has taken place yet, we alert once again Greece for
the urgent need to formalise such designation, as without such designation no initial pre-
financing payments can be made by the Commission; any payments made by a non-designated
authority in 2015 to cover costs to be charged to the Fund are not eligible.
Section 6: Framework for preparation and implementation of the programme by the Member
On paragraph 6.7.2, reference should be made only to those situations where direct
awards are planned, and provide an explanation of the reasons for such decision. The current
draft refers instead to the direct implementation of actions, as executing body, by one of the
Delegated Authorities (Asylum Service), which are not relevant for the paragraph and should
therefore be deleted. On the other hand, as regards Return Policy the justification provided is
not satisfactory: the draft refers to a series of entities that will be involved in the
implementation of the programme without specifying if such actions will be implemented
through a "direct award" and providing the necessary justification. This paragraph needs to be