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Kelemenis & Co.: Advice to Ukrainians in Greece

Kelemenis & Co.: Advice to Ukrainians in Greece

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This review was prepared for Ukrainian refugees by the law firm Kelemenis & Co. upon request and in coordination with the international legal network Multilaw and Ukrainian law firm Arzinger. The review is as of March 11, 2022. The review is not a legal advice and is for informational purposes only. For updates, please follow www.multilaw.com and/or www.arzinger.ua

Entering the country

1.1. Is any mandatory quarantine applied for UA citizens? If yes, please provide details (duration, where to stay, who pays for the stay, any exceptions)?]

No quarantine is required. Ukrainian citizens are exempted from the Passenger Locator Form submission requirement. A vaccination certificate for those who have completed vaccination for COVID-19 at least fourteen (14) days before arrival is required or proof of recovery from SARS-CoV-2 issued 14 days after the first positive COVID-19 test, or certificate of negative test result, namely, negative molecular test result (PCR) performed up to 72 hours before the scheduled arrival or negative Rapid Antigen test result performed up to 24 hours before the scheduled arrival.

1.2. Is any visa required for UA citizen to enter the country? If yes, how UA citizen may obtain it under the circumstances?

Holders of a Ukrainian passport with or without biometric features can enter Greece from all entry points (land and air) with a maximum stay of 90 days. The National Police will stamp the passport with the date of entry.

1.3. Is entry without passport allowed?

Ukrainian citizens who do not have a valid passport can only enter Greece through the Passport Control Department in Promachonas (at the Greek-Bulgarian border) where the staff of the Ukrainian Embassy in Greece will be issue an entrance document. This procedure allows Ukrainians to stay for a maximum period of 90 days in the country.

In the event that they do have a valid passport but they are accompanying minors who do not have a valid passport themselves, the National Police Officers will note under the entry stamp on their passport the number of minor children they are accompanying. In this case they will have to provide certification with regard to the minors such as a certificate of marital status or a birth certificate of the children. If they do not have the documentation required, they will be asked to fill in a solemn declaration stating the number of the children, their first name, surname, sex and date of birth.

1.4. Shall UA citizen apply for any special status (refugee etc.) right after entering the country, or this can be done later? If yes, what is the further deadline to apply for special status?

After entering the country Ukrainian citizens can stay in Greece for three months. Within these three months they will have to apply for an asylum, as they are not allowed to remain in the country after the 3-month deadline.

The Greek Ministry of Migration and Asylum has advised that they will be launching a new application named “temporary protection”, which will be available by the end of March and will provide the Ukrainian Citizens with a right to a one year residence permit, a right to work and a right to access public health care.

(2) Stay in the country

2.1. For how long UA citizen may stay in the country if entered based on visa-free regime without any additional formalities?

Three months from the day of entrance. The day of entrance will be stamped on their passport or provided with an official document at the point of entrance.

2.2. Are temporary residency permits available for UA citizens?

A temporary protection scheme is to be launched by the end of March by the Ministry of Migration and Asylum as mentioned in par. 1.4.

2.3. Are permanent residency permits available for UA citizens?

See par. 5.1.

2.4. Is refugee status available for UA citizens?

Yes. See par. 5.22.

2.5. Is there any other status except tourism, temporary/permanent residency permit, refugee available for UA citizens? If yes, please briefly describe the options.

No.

(3) If UA citizen entered the country based on no visa regime, or based on tourist visa

3.1. What is the maximum allowed duration of stay in the country?

A no visa regime grants a 3-month period of stay in Greece (see par. 2.1.). A type of a tourist-type visa is the type C visa, which is valid for the entire territory of the Member States of the European Union and its duration does not exceed ninety (90) days in any period of one hundred and eighty (180) days.

3.2. Are any formal procedures (registration etc.) required for the stay?

If the visit is under a Visa regime (type C visa), such visa must be granted by a local Greek Embassy.

3.3. Is employment allowed?

No.

3.4. Is healthcare covered by the hosting state?

No.

3.5. What are main taxes, which shall be paid by UA citizen during the stay?

No taxes are required to be paid.

3.6. What is the tax regime and relevant formalities if UA citizen works remotely for businesses in other countries and gets payments from there?

If he becomes a permanent Greek resident (i.e. resides for more than 183 days a year), then a foreigner becomes a permanent tax resident of Greece and is subject to taxation as any permanent (tax) resident of the country, Greek or else.

3.7. Is it possible to open and use banking account?

No

3.8. What is the upper limit of cash which can be put on a banking account without confirmation of the cash source?

On the assumption that a UA citizen can open a bank account, he/she may be required to provide for some supporting documentation (as any other Greek) for amounts exceeding €10,000. This primarily for the bank’s internal auditing procedures and relates to anti-money-laundering regulations.

3.9. Is UA driving license accepted? If yes, for how long?

See below

3.10. What and when is required to use a car brought from Ukraine (insurance, certification etc.)?

See below

3.11. What is required to sell a car brought from Ukraine in your country?

The car needs to be formally imported into Greece, be customs cleared and have all the required supporting documentation as any car outside the EU>

3.12. Are there any special regulations applied to kids under 5yo? At what terms kindergartens are available?

No

3.13. Are there any special regulations applied to kids 6 to 18yo? At what terms schools are available?

No

3.14. Are there any special regulations applied to juniors 19 to 22yo? At what terms universities are available?

No

3.15. Are there any special regulations applied to elderly people at 60+ age?

No

3.16. Are there any special regulations applied to disabled persons?

No

3.17. Is there any state program available suggesting accommodation, language courses, local integration? If yes, please briefly describe.

The Greek Ministry of Migration and Asylum has advised that Ukrainians in need for accommodation may email This email address is being protected from spambots. You need JavaScript enabled to view it.. There will be housing facilities provided by the Ministry.

Is there any state program suggesting support cash payments to UA citizens? If yes, please give rough numbers.

3.18. Any other important information.

No.

(4) If UA citizen entered the country aiming to get temporary residency permit

4.1. When and where UA citizen shall apply to obtain a temporary residency permit? Please briefly describe main steps required and respective timelines.

Ukrainian citizens have access to the international protection process. In order to acquire the refugee status a filing of an application for international protection before the Regional Offices or Independent Asylum Offices or at Offices of the Asylum Service located in Reception and Identification Centers is required. The applicant can also apply for the family members. They are also required to accompany the applicant in person to the Asylum Service. In total, the examination of the application may take from twenty (20) days to six (6) months, depending on the case. Upon completing the filing of the application, the applicant will receive the International Protection Applicant Form, which may last from thirty (30) days to one (1) year, depending on the procedure under consideration of the application. The International Protection Application allows an applicant to stay in Greece until the completion of the examination of your application. This form is a temporary title that provides specific rights and obligations and does not equate to a residence permit. If the application is rejected, the International Protection form expires.

Assuming the temporary residency permit is granted:

4.2. What is the maximum allowed duration of stay in the country?

The International Protection Application allows the applicant to stay in Greece until the completion of the examination of your application. This form is a temporary title that provides specific rights and obligations and does not equate to a residence permit.

4.3. Are any formal procedures (registration etc.) required for the stay?

See answer to question 4.1

4.4. Is employment allowed?

The International Protection Application form provides specific rights for the applicants during its duration. The applicants have the right to work under the conditions set by the Greek legislation, after the lapse of six (6) months from the date of submission of the application for international protection, and only if they have an International Protection Application form. Ukrainian citizens, as applicants of asylum, have the same social security rights and obligations, as Greek citizens. If the applicants are not employed and the financial resources are not enough to cover daily needs, they are entitled to benefits. They can also apply for accommodation in a Hospitality Center or other accommodation (accommodation programs in private homes or hotels). The request will be accepted, if there is availability.

4.5. Is healthcare covered by the hosting state? Is it covered for kids and other dependent relatives?

In order to have access to medical and hospital care, the applicant must obtain a Temporary Insurance and Health Care Number. The Temporary Insurance and Health Care Number (T.I.H.C.N) is issued with the application form for international protection by the Asylum Service and ensures the provision of health care to immigrants. The rejection of the asylum application implies the automatic deactivation of the T.I.H.C.N. On the contrary, in case of acceptance of the application, T.I.H.C.N becomes a permanent Social Security Registration Number (Α.Μ.Κ.Α).

4.6. What are main taxes, which shall be paid by UA citizen during the stay?

For a start, there are no taxes to be paid. To acquire a Greek tax number requires proof of residence (i.e. certificate of residence in a hosting structure, utility bill or copy of lease agreement). Applicants of international protection who do not have a residence certificate and/or are homeless, cannot obtain a tax number. When registering an asylum application, the procedure of acquiring a tax number will begin automatically. The tax number application process will be sent electronically by the asylum authorities at the registration stage and a tax number certificate will be issued to the applicant. Asylum seekers still need to retrieve their tax number upon completion of the procedure in person from the Tax Office.

4.7. What is the tax regime and relevant formalities if UA citizen works remotely for businesses in other countries and gets payments from there?

See par. 3.6

4.8. Is it possible to open and use banking account?

Ukrainian citizen can open a bank account in Greece by submitting the following documents to a Greek bank:

  • The originals and a copy of the valid "International Protection Application" or "Asylum Application",
  • A document proving their current address of stay,
  • An employment certificate issued by the employer and a copy of the employment contract,
  • A copy of the tax number issuance document,
  • Tax return or an official declaration that an income tax return has not been submitted in Greece.

4.9. What is the upper limit of cash which can be put on a banking account without confirmation of the cash source?

See 3.8

4.10. Is UA driving license accepted? If yes, for how long?

Since Ukraine is a party to the Vienna Convention, Ukrainian citizens can drive on Greek territory with their national driving license until they obtain a Greek residence permit. As a prerequisite, the details of the license must be in Latin characters and the holder of this license must not have his/her usual residence in Greece.

4.11. What and when is required to use a car brought from Ukraine (insurance, certification etc.)?

Immigrants can use a car with foreign license plates in Greek territory, only for the purpose of customs clearance and for a period of one (1) month provided that this period does not exceed the deadline within which the vehicle must be cleared. The car must be insured and and have a valid car registration.

4.12. What is required to sell a car brought from Ukraine in your country?

See 3.11.

4.13. Are there any special regulations applied to kids under 5yo whose parent obtained the temporary residency permit? At what terms kindergartens are available?

The children of the applicant, regardless of age, have access to free public education throughout the duration of the International Protection Application. For enrollment in a Greek school, the applicant must provide the same supporting documents that are required from Greek citizens. The children can be registered even if the applicant does not have a birth or marital status certificate. However, the following documents are required:

  • The "International Protection Application" or the "Asylum Application" or a valid residence permit,
  • a health or vaccine booklet,
  • proof of residence.

If the child is between 2 ½ and 5 years old, the parents can apply for a place at a public or private daycare center. From the age of 4, children can enroll in nursery, which is mandatory after the age of 5. The parents will need to complete an application, submit a document as proof of an address of stay, and present the child's "health booklet" proving that he or she has been vaccinated. The registration takes place every year from the 1st to the 15th of June; however, the applications are accepted even after these dates, if there are available places.

4.14. Are there any special regulations applied to kids 6 to 18yo whose parent obtained the temporary residency permit? At what terms schools are available?

If the child is six years old, then he or she can enroll in the first grade of primary school. For children over the age of six, the applicant will need to present a relevant certificate or state how many years the child has attended school so far and in which country. If the applicant lives in an apartment, a hotel or a building in a city, the applicant can enroll children from six to fifteen years old in a school class. In primary schools. there are morning classes and in secondary schools there is a program called "Educational Priority Zones" under the auspices of the Ministry of Education. The children attend the school that the Greek citizens also attend. Reception classes will be set up to provide additional support, especially for understanding the Greek language. The parents should go to the nearest school and state that they wish to enroll the children in school. The most important document they need to bring is proof that the child has been vaccinated.

4.15. Are there any special regulations applied to juniors 19 to 22yo whose parent obtained the temporary residency permit? At what terms universities are available?

There are several educational programs for adults organized by the State or private bodies, NGOs and other organizations. The General Secretariat for Lifelong Learning of the Ministry of Education is the responsible authority for most adult education programs.

4.16. Are there any special regulations applied to elderly people at 60+ age?

No.

4.17. Are there any special regulations applied to disabled persons?

To receive the disability benefit one should take the following steps.

Step 1: Submit the application to the nearest Centre of Disability Accreditation (KE.P.A.) With the application, one must also submit:

a) A complete file from a doctor, signed and stamped, as well as with the certification of the doctor’s signature.

b) The residence permit

c) The health booklet, if the UA citizen is insured

d) The social security number (AMKA)

Step 2: After one or two months, the UA citizen will be informed about the final decision and the disability ‘rating’. A rating of 67% is required for persons with disabilities and 50% for HIV positive persons in order to qualify for an allowance. If he/she does not agree with the assessment and rating, he/she has the right to submit an objection within 10 days of notification.

Step 3: The final step of the process is to submit an application to the municipal services in his/her location, along with the following:

a) The decision of KE.P.A

b) A valid residence permit

c) The tax clearance note

d) Proof of residence

e) Bank account details

National Confederation of Disabled People: +30 210 9949837 or e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it..

Some primary schools have specialized personnel and teachers for students with disabilities (serious hearing impairment or intellectual or learning impediments). For enrolment in special schools, the Centres for Diagnosis, Evaluation and Support for Persons with Special Needs (KE.D.D.Y.) issues the relevant recommendation and makes the referral.

4.18. Is there any state program available suggesting accommodation, language courses, local integration? If yes, please briefly describe.

The Greek Ministry of Migration and Asylum has advised that Ukrainians in need for accommodation may email This email address is being protected from spambots. You need JavaScript enabled to view it.. There will be housing facilities provided by the Ministry.

4.19. Is there any state program suggesting support cash payments to UA citizens? If yes, please give rough numbers.

As of October 2021, the Greek authorities are responsible for providing assistance to asylum seekers to cover basic needs. For the time being, the exact amount of the financial assistance has not been announced.

4.20. Are there any restrictions to leave the country?

When granted a residence permit, there are no restrictions to leave the country.

4.21. Any other important information.

No.

(5) If UA citizen entered the country aiming to get permanent residency permit

5.1. When and where UA citizen shall apply to obtain a permanent residency permit? Please briefly describe main steps required and respective timelines.

Ukrainians are considered third country nationals. According to Greek Immigration Law, a third country national who has resided in Greece, legally and continuously, for five (5) years may be granted a permanent residency permit, which has a duration of (5) five years with an option to renew. For beneficiaries of international protection, the term is 2 ½ years.

Assuming the permanent residency permit is granted:

5.2. What is the maximum allowed duration of stay in the country?

Following the process set out in 5.1, there can be 5-year renewals.

5.3. Are any formal procedures (registration etc.) required for the stay?

Beneficiaries of asylum can acquire from the Hellenic Republic a residence permit that is valid for three (3) years. After they receive asylum from the Regional Asylum Office, they must submit an application to the Passport Office.

5.4. Is employment allowed?

Yes.

5.5. Is healthcare covered by the hosting state? Is it covered for kids and other dependent relatives?

Once they obtain a social security number (AMKA), UA citizens will gain access to social welfare benefits and medical care under the same rules that apply to Greek citizens. Children and other dependent relatives do have access to the healthcare system when applying for the refugee status ant obtain a social security number.

5.6. What are main taxes, which shall be paid by UA citizen during the stay?

See above

5.7. What is the tax regime and relevant formalities if UA citizen works remotely for businesses in other countries and gets payments from there?

See above

5.8. Is it possible to open and use banking account?

See above

5.9. What is the upper limit of cash which can be put on a banking account without confirmation of the cash source?

See above (3.8)

5.10. Is UA driving license accepted? If yes, for how long?

See above

5.11. What and when is required to use a car brought from Ukraine (insurance, certification etc.)?

See above

5.12. What is required to sell a car brought from Ukraine in your country?

See above

5.13. Are there any special regulations applied to kids under 5yo whose parent obtained the permanent residency permit? At what terms kindergartens are available?

See above 4.13.

5.14. Are there any special regulations applied to kids 6 to 18yo whose parent obtained the permanent residency permit? At what terms schools are available?

See above 4.14.

5.15. Are there any special regulations applied to juniors 19 to 22yo whose parent obtained the permanent residency permit? At what terms universities are available?

See above 4.16.

5.16. Are there any special regulations applied to elderly people at 60+ age?

A recognised refugee that meets the following criteria has the right to a pension for uninsured elderly. The requirements are the following:

a) 67 years old or more

b) A valid residence permit;

c) Uninsured

d) Not entitled to a pension from another country

e) Not entitled to any other allowance in Greece

f) Stayed legally in Greece for 15 continuous years.

5.17. Are there any special regulations applied to disabled persons?

See above

5.18. Is there any state program available suggesting accommodation, language courses, local integration? If yes, please briefly describe.

The Greek Ministry of Migration and Asylum has advised that Ukrainians in need for accommodation may email This email address is being protected from spambots. You need JavaScript enabled to view it.. There will be housing facilities provided by the Ministry.

5.19. Is there any state program suggesting support cash payments to UA citizens? If yes, please give rough numbers.

See above 4.19.

5.20. Are there any restrictions to leave the country?

No.

5.21. Any other important information.

No.

6) If UA citizen entered the country aiming to get refugee status

5.22. When and where UA citizen shall apply to obtain a refugee status? Please briefly describe main steps required and respective timelines.

Access to the international protection procedure is unrestricted and free of charge. Any third country citizen or stateless person has the right to apply for international protection. The application is submitted to the Receiving Authorities, which immediately perform a full registration. The authorities that are competent for receiving applications are the Regional Asylum Offices, the Autonomous Asylum Service Units and the Mobile Units of the Asylum Service. The International Protection Application is lodged by the applicant in person. However, the application may now be lodged online through the self-registration application. The applicant may also apply for his/her family members, provided that they are with him/her in Greece. They should also come along with the applicant to the Asylum Service.

In case the applicant has entered the country without going through the legal formalities or staying in Greece without meeting the legal requirements, he/she will be transferred to a Reception and Identification Centre and in case the applicant does not possess any document issued by an official authority that proves his/her identity and nationality, he/she will undergo reception and identification procedures. In that case, in order to submit an international protection application, the applicant will be referred to the local competent Regional Asylum Service Office, an Asylum Unit of which may be operating within the Reception and Identification Centre where the applicant is staying. It will be compulsory for him/she to stay within the premises of the centre for the whole duration of the examination of the application, provided that the duration of this time period does not exceed twenty five (25) days.

On the date appointed by the Asylum Service, the applicant will give an interview to an Asylum Service staff member. The interview is being conducted by a competent member of the Receiving Authority staff (case-handler). An interpreter will also be present during the interview. Interpretation is provided free of charge.

Assuming the refugee status is granted:

6.1 What is the maximum allowed duration of stay in the country?

As a beneficiary of Refugee status by the Hellenic Republic, UA citizens are entitled to a three-year residence permit (ADET), which will be valid for three (3) years. The permit is renewable, unless compelling reasons of national security or public order otherwise require (EU Regulation 95/2011).

6.2 Are any formal procedures (registration etc.) required for the stay?

Yes, the beneficiary must obtain a three year residence permit (ADET).

6.3 Is employment allowed?

Yes.

6.4 Is healthcare covered by the hosting state? Is it covered for kids and other dependent relatives?

When obtaining a social security number (AMKA), UA citizens gain access to social welfare benefits and medical care, under the same rules that apply to Greek citizens. Kids and other dependent relatives do have access to the healthcare system when applying for the Refugee status and obtain a social security number.

6.5 What are main taxes, which shall be paid by UA citizen during the stay?

See above

6.6 What is the tax regime and relevant formalities if UA citizen works remotely for businesses in other countries and gets payments from there?

See above. Also note that, according to the Double Tax Avoidance Agreement (DTTA) that has been signed between Greece and Ukraine (ARTICLE 15-Dependent Personal Services):

Subject to the provisions of Articles 16, 18, 19 and 20 salaries, wages, and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.

Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:

a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned; and

b) the remuneration is paid by or on behalf of, an employer who is not a resident of the other Contracting State, and

c) the remuneration is not borne by a permanent establishment or a fixed base, which the employer has in the other Contracting State.

6.7 Is it possible to open and use banking account?

Yes, see above

6.8 What is the upper limit of cash which can be put on a banking account without confirmation of the cash source?

See above

6.9 Is UA driving license accepted? If yes, for how long?

See above

6.10 What and when is required to use a car brought from Ukraine (insurance, certification etc.)?

See above

6.11 What is required to sell a car brought from Ukraine in your country?

See above

6.12 Are there any special regulations applied to kids under 5yo? At what terms kindergartens are available?

See above

6.13 Are there any special regulations applied to kids 6 to 18yo? At what terms schools are available?

See above

6.14 Are there any special regulations applied to juniors 19 to 22yo? At what terms universities are available?

See above

6.15 Are there any special regulations applied to elderly people at 60+ age?

See above

6.16 Are there any special regulations applied to disabled persons?

See above

6.17 Is there any state program available suggesting accommodation, language courses, local integration? If yes, please briefly describe.

UN Refugee Agency Greece (UNHCR)

6.18 Is there any state program suggesting support cash payments to UA citizens? If yes, please give rough numbers.

As of October 2021, the Greek authorities are responsible for providing assistance to asylum-seekers to cover their basic needs. For the time being, the exact amount of the financial assistance has not been announced.

6.19 Are there any limitations to leave the country?

When granted a residence permit, there are no limitations to leave the country.

6.20 Any other important information.

7 Language issues

7.1. What languages can be used for communication in your country?

Greek and English

8 Upcoming or expected legislative changes

8.1. Do you expect any major changes to the relevant legislation?

The Ministry of Migration has confirmed that law 80/2006 (compliance with the EU directive 55/2001 will apply to all UA citizens arriving to Greece) by the end of March. The law provides a temporary 12-month residence permit which will allow UA citizens to live and work in Greece.

9 Local help resources

9.1. Please provide links and brief descriptions to any local helpful resources.

https://migration.gov.gr/

https://help.unhcr.org/greece/ukraine/

Unlike any other news items in CEELM, these are published as received with no other edits than outlined in this editorial note.