Joint Letter by 17 Civil Society Organisations

We join our fellow members of the Child Rights Advocacy Network (CRAN) in urging the Hellenic Parliament not to abolish the residence permit for young people who arrived in Greece as unaccompanied children and have successfully completed at least three years of formal education in Greek schools.

Introduced in 2023 and implemented in March 2024, this provision was a clear commitment by the Prime Minister and the Ministry of Migration and Asylum. It remains the only legal pathway protecting young people who grew up in Greece after arriving alone as children.

The permit supports a group already integrated into Greek society: refugee youth who attend school, speak the language, and are building their lives here. It keeps them engaged in education, reduces the risk of exploitation and delinquency, and allows them to contribute socially and economically as adults.

Abolishing this provision would be a serious setback for child protection, disrupt education pathways, and reverse years of public investment in inclusion, social cohesion, and safety.

We stand with our partners in calling for policies that protect children’s rights and support their safe transition into adulthood.

READ THE FULL JOINT LETTER BELLOW: 

Honourable Members of the Hellenic Parliament,
Ladies and Gentlemen,

Through this letter, the undersigned civil society organizations wish to draw your attention to the provisions included in Article 38 of the draft bill of the Ministry of Migration and Asylum entitled “Promotion of policies on legal migration, transposition of Directive (EU) 2024/1233 on a single application procedure for the issuance of a single permit for third-country nationals to reside and work in the territory of a Member State and on a common set of rights for third-country workers legally residing in a Member State, amendment of the Migration Code and other provisions”.

Article 38 of the draft bill repeals Article 161(1)(c) of the Migration Code, as currently in force, which provides for the possibility of granting a ten-year residence permit (type M.2) to young people who entered Greece as unaccompanied children and who successfully completed at least three (3) grades of secondary education in a Greek public school before reaching the age of twenty-three.

This repeal constitutes a serious step backwards in terms of child protection policy, while at the same time undermining a long-term investment by the Greek State in the social and economic integration of young people who arrived as unaccompanied children. Notably, this change is introduced without any reference or justification in the Regulatory Impact Assessment and without the submission of an Explanatory Memorandum during the public consultation process.

The provision in question was first introduced by Law 5038/2023, following the National Strategy for the Protection of Unaccompanied Children of the Ministry of Migration and Asylum, and represented an explicit commitment by the Prime Minister and the political leadership of the Ministry. Member organizations of the Child Rights Advocacy Network (CRAN), in close cooperation with the competent services of the Ministry, actively supported the adoption of this provision.

The existing provision is the only one offering targeted protection to young people who entered and were registered in Greece as unaccompanied children. It provides residence security to a group that is, by definition, already integrated and productive: young third-country nationals who completed a significant part of their schooling in Greece as unaccompanied children. It serves as a meaningful recognition of their efforts and incentivizes continued engagement with secondary education, facilitating their smooth integration and productive contribution to Greek society and the national economy after graduation, while simultaneously reducing their exposure to risks of exploitation and juvenile delinquency.

Furthermore, the provision only became operational in March 2024, following the issuance of the necessary implementing regulations. As such, insufficient time has elapsed to allow for a meaningful evaluation based on empirical evidence.

We also wish to emphasize that, to date, no empirical data supports claims that the provision has been misused or has functioned as a “pull factor,” as is sometimes asserted in public discourse. On the contrary, the number of applications submitted remains very low (159 applications), and only 13 residence permits under Article 161(1)(c) have been granted to date. It should be underlined that eligibility requires the successful completion of at least three (3) grades of secondary education; therefore, this provision does not apply to, nor does it grant residence rights to, individuals who have not successfully completed their studies.

At a time when migration policy increasingly recognizes the need for tailored treatment of former unaccompanied children and emphasizes gradual integration pathways, the repeal of Article 161(1)(c) raises serious concerns regarding policy coherence, legal certainty, and effectively nullifies the State’s long-standing investment in structures for the protection and support of unaccompanied children.

The framework of Article 161(1)(c) should be maintained and further strengthened through additional child-protection measures, several of which are already included in the National Strategy for the Protection of Unaccompanied Children. These include, inter alia, the establishment of a defined legal status for unaccompanied children regardless of the asylum procedure, transition-to-adulthood support mechanisms, and a protection network for young adults—drawing on best practices from other EU Member States—as well as avoiding the imposition of criminal sanctions under Article 83 of Law 3386/2005 (as amended by Article 27 of Law 5226/2025) for irregular stay, in cases involving children or young adults who are enrolled in Greek schools.

For all the above reasons, the undersigned organizations call upon the Hellenic Parliament not to adopt Article 38 of the draft bill of the Ministry of Migration and Asylum, while simultaneously ensuring the strengthening of child-protection measures in accordance with the best interests of the child, as enshrined in the Convention on the Rights of the Child.

The undersigned organizations – members of the Child Rights Advocacy Network (CRAN)

1. ΑΡΣΙΣ – Κοινωνική Οργάνωση Υποστήριξης Νέων
2. Δίκτυο για τα Δικαιώματα του Παιδιού
3. ΕΛΙΞ
4. Ελληνικό Συμβούλιο για τους Πρόσφυγες
5. ΜΕΤΑδραση
6. Σχεδία – Κέντρο Παιδαγωγικής και Καλλιτεχνικής Επιμόρφωσης
7. Better Days
8. Changemakers Lab
9. International Rescue Committee (IRC) Hellas
10. INTERSOS HELLAS
11. Safe Passage International – Greece
12. SolidarityNow
13. Terre des hommes Hellas
14. The HOME Project

And the civil society organizations

15. Γιατροί Χωρίς Σύνορα – Ελληνικό Τμήμα / Médecins Sans Frontières Greece
16. Ελληνικό Φόρουμ Προσφύγων
17. Υποστήριξη Προσφύγων στο Αιγαίο (RSA)