In the context of our project on legal assistance to asylum seekers, we deal with hundreds of cases of asylum seekers who are in Greece and have applied for family reunification under the Dublin III Regulation.

During the last months we have noted that there is a serious problem concerning the completion of the family reunification cases in Germany. More specifically we have found that in cases of asylum seekers for which Germany has accepted responsibility, the transfer to Germany has not been carried out despite the fact that the six-month time-limit provided by the Regulation has expired. So far our organization is aware of 21 such cases of asylum seekers, including particularly vulnerable people such as an eight-member family waiting to be reunited with the seriously ill father as well as unaccompanied minors.

In early June our organization asked for the opinion of the Asylum Service on this and on 15.06.2017 the Asylum Service gave us the following written position (in our translation from the Greek document):

The German Dublin Unit requested from our department that the transfer of asylum seekers per month is controlled by number, irrespective of the six-month deadline for the completion of the transfer as provided by art. 29 of the EU Regulation 604/2013.

For the cases in which the six-month deadline has expired or is to expire, we have received extension of the deadline for their transfer according to an understanding with the German Dublin Unit (BAMF).

The completion of the transfers you mention in your letters will be scheduled in cooperation with the German Authorities from July 2017 onwards.


We would like to stress that arrangements such as the one described in the Asylum Service’s answer are not provided by the Dublin III Regulation and therefore this arrangement is against the Regulation. Moreover it hinders the enjoyment of the right to family life, which is a basic right under EU law.

Given that there are hundreds of family reunification cases of asylum seekers in Germany and that every month a big number of cases in which the six-month time-limit for their transfer expires is added, this arrangement has caused a serious problem which is expected to become more acute in the coming months, if the situation remains the same.