The “Asylum Code”, i.e. Law 4939/2022 ‘ratifying the Code on reception, international protection of third-country nationals and stateless persons, and temporary protection in cases of mass influx of displaced persons’ in force since 10 June 2022 repealed the IPA (International Protection Act, i.e. Law 4636/2019) without making any amendments to the definition of vulnerable groups and persons in need of special procedural guarantees.
According to Article 1-λγ of the Asylum Code the following groups are considered as vulnerable groups:
‘children; unaccompanied children; direct relatives of victims of shipwrecks (parents, siblings, children, husbands/wives); disabled persons; elderly; pregnant women; single parents with minor children; victims of human trafficking; persons with serious illness; persons with cognitive or mental disability and victims of torture, rape or other serious forms of psychological, physical or sexual violence such as victims of female genital mutilation.’
According to Article 62(2) of the Asylum Code ‘The assessment of vulnerability shall take place during the identification process, the registration process and the medical screening of the Art. 41 without prejudice to the assessment of international protection needs’. According to Article 62(4) of the Asylum Code ‘Only the persons belonging to vulnerable groups are considered to have special reception needs and thus benefit from the special reception conditions’. Article 62(3) of the Asylum Code provides that ‘[…] the special condition of applicants, even if it becomes apparent at a later stage of the examination of the application for international protection, is taken into account throughout this procedure […]’.
According to Article 77(3) of the Asylum Code:
‘[…]Upon the completion of the medical and psychosocial assessment, the (Medical Screening and Psychosocial Support) Unit of the RIC […] shall inform the Head of the competent RAO. The above-mentioned assessment is also notified to the Manager of the RIC. That assessment shall have as only consequence the immediate provision of special reception conditions and special procedural guarantees to the applicant.’
According to Article 72 of the Asylum Code relating to special procedural guarantees:
‘The Receiving Authorities shall assess within a reasonable period of time after an application for international protection is submitted, or at any point of the procedure the relevant needs arise, whether the applicant requires special procedural guarantees, due to their age, gender, sexual orientation, gender identity, psychological disorder or because they are a victim of torture, rape or other serious forms of psychological, physical or sexual violence.’
The number of asylum seekers registered by the Asylum Service as vulnerable in 2022 was not provided. The number and type of decisions taken at first instance on cases of vulnerable applicants in 2022 was not provided. The number of first instance decisions granting refugee status or subsidiary protection to vulnerable applicants in 2022 was not provided.
In Greece in 2022, through vulnerability assessments for residents in the reception facilities in the context of support to first and second-line reception, EUAA staff identified 4,805 persons as presenting vulnerability indicators.
Screening of vulnerability
Vulnerability identification in the border regions
The identification of vulnerability of persons arriving at the border regions shall take place, according to the Asylum Code which repealed the IPA, either by the RIS before the registration of the asylum application or during the asylum procedure.
Vulnerability identification by the RIS
According to Article 41(d) of the Asylum Code, in the context of reception and identification procedures carried out by the RIS:
‘[…] The Manager of [RIC] or the Unit, acting on a motivated proposal of the competent medical staff of the Centre, shall refer persons belonging to vulnerable groups to the competent public institution of social support or protection as per case. A copy of the medical screening and psychosocial support file is transmitted to the Head of the institution where the person resides or is being referred. In all cases the continuity of the medical treatment followed shall be ensured, where necessary. The assessment that a person is vulnerable shall have as only consequence the immediate provision of special reception conditions.’
According to Article 80 (3) of the Asylum Code,
‘In case of doubt, the competent Receiving Authorities shall refer the unaccompanied minor to the age assessment procedures as per the provisions in force. In the case where the above-mentioned referral is considered necessary and until the completion of the procedure, special attention should be paid to the particular characteristics of the minor, especially those related to their gender or cultural peculiarities’ (see below).
Since the end of 2019, the authority competent for carrying out medical checks has been the National Public Health Organisation (EODY), which was established by L 4633/2019 as the successor of KEELPNO.
The number of asylum seekers identified as vulnerable by the Reception and Identification Service in the border regions in 2022 was not provided.
The average time between the completion of a 14-day quarantine period imposed upon arrival to all newcomers and the completion of the medical/psychosocial examination/ vulnerability assessment in the border regions in 2022 was not provided.
The low quality of the process of medical and psychosocial screening (if any) has remained a source of serious concern. Vulnerabilities are often missed, with individuals going through the asylum procedure without having their vulnerability assessment completed first. As RSA and other civil society organisations have recently reported “Severe delays persist when it comes to conducting vulnerability assessments even after the reception and identification procedure formally ends: The time delay ranges from ten days to longer than three months in some cases. Yet, the Asylum Service and EUAA continue to process asylum claims before individuals have undergone a vulnerability assessment, and routinely disregard or deny special procedural guarantees afforded by EU law, even where they are specifically requested by the applicants in writing and/or orally prior to the interview. They instead insist on completing the interview under the border procedure. The medical cards issued to people undergoing reception and identification procedure do not clearly indicate whether and when a vulnerability assessment was conducted”  At the same report, it is also mentioned that “On the one hand, the RIS consistently issues referrals of the individuals concerned to the competent authorities (i.e. the Asylum Service and Hellenic Police) stating that the reception and identification procedure has been completed without a finding of vulnerability. On the other hand, the exact date of the medical check and vulnerability assessment is not marked in the case file of the person. The Foreigner’s Medical Card (Κάρτα Υγείας Αλλοδαπού) issued on the day the reception and identification procedure takes place automatically carries that same date. The card may be amended following an assessment, in which case a re-issuance date is indicated. However, this is not necessarily the date on which the vulnerability assessment takes place. This means that asylum seekers are referred to the Asylum Service with a Medical Card which in most cases precedes the actual medical check and vulnerability assessment.”
Based on GCR’s information from the field, a lack or complete absence of psychosocial assessment, difficulties in carrying out referrals from RIS to public hospitals, the low quality of the medical screening and psycho-social support, the classification of vulnerability and non-vulnerability and the lack of information on the outcome of the procedure, were the main problems concerning the vulnerability assessment in the context of Reception and Identification procedures during 2022. As mentioned in the Regular procedure and Fast-track border procedure, many asylum seekers continue to be forced into the personal interview before the Asylum Service without prior assessment of their vulnerability, including pregnant women.
The number of healthcare professionals involved in the provision of medical and psychosocial services at different Reception and Identification Centres in the border regions in 2022 is not available.
Lesvos: According to GCR’s observations, on Lesvos the quarantine period imposed upon arrival could last up to about two months depending on several factors, such as the availability of EODY and RIS staff, the number of COVID-19 cases, etc. UNHCR Units had no access to the quarantine area where all new arrivals were being placed for as long as the quarantine lasted, thus depriving newcomers of the possibility to undergo a vulnerability assessment and access basic information regarding their rights, the procedures and their general status. Even after the completion of the quarantine period, only evident vulnerabilities were identified given the low quality of the medical screening. Psychosocial support was conducted mostly after the first instance interview. Due to these shortcomings, a considerable number of newcomers and asylum seekers were not properly assessed regarding potential vulnerabilities. RAO continued scheduling interviews before the completion of the vulnerability assessment, while there was no information exchange between RIS and RAO to ensure interviews were scheduled after the assessment had been completed. Indicatively, an applicant suffering from active tuberculosis at the time of her interview before RAO had not been identified by RIS during the medical screening and in any case the RAO’s caseworker was not aware of her health condition. Also, any reassessment of vulnerabilities only took place for active asylum cases – subsequent applications that had not yet received a positive decision on admissibility were not considered as such.
In most cases a vulnerability assessment was conducted only after the examination of the asylum claim and the results of the vulnerability assessment were often not communicated to the Asylum Service prior to the examination of the asylum claim. Shortcomings related to understaffing were also reported in the RIS of Kos, as there was no EODY doctor in 2022 and vulnerability assessments were signed in mass when a visitor doctor from EODY arrived at the RIS. Only obvious vulnerabilities were identified (e.g. pregnant women, elderly people); while victims of GBV or Female Genital Mutilation victims were often identified as vulnerable by RIS only after a first instance negative decision on their asylum application.
The lifting of the geographical restriction (see also Freedom of movement)
Under the IPA and the Asylum Code, the recognition of vulnerability of asylum seekers has no bearing on the asylum procedure under which their application is examined. Therefore, vulnerable groups, even when identified as such, are no longer referred to the Regular procedure, unless it is proven that no appropriate health care regarding their individual medical problem is available on the island where they reside (See below). In the latter cases, the geographical restriction imposed upon arrival is lifted and persons are transferred or allowed to travel to the mainland. In light of this, the exemption of vulnerable individuals from the Fast-Track Border procedure has become much more difficult.
More precisely, for asylum-seekers who entered Greece through the islands of Lesvos, Chios, Samos, Kos, Leros, and Rhodes during 2022, a restriction of movement within each island (‘geographical restriction’) was imposed as per the Ministerial Decision 1140/2.12.2019 (GG B’ 4736/20.12.2019) in force since 1 January 2020. Greek law transposes Article 7 RCD allowing Member States to impose a restriction of movement to asylum-seekers within a specific area assigned to them, provided that it does not affect the unalienable sphere of private life and that it allows sufficient scope for guaranteeing access to all benefits under the Directive. Until 31 December 2019, the geographical restriction could be lifted, inter alia, in respect of vulnerable persons. Following amendments to the law, after 1 January 2020, the geographical restriction may inter alia be lifted by a decision of the Manager of the RIC for vulnerable persons or persons in need of special reception conditions if appropriate support may not be provided within the area of restriction, without sufficiently describing what such appropriate support entails.
The number of decisions to lift geographical restrictions per RIC and per category of vulnerability (or other cases) in 2022 is not available.
Vulnerability identification in the asylum procedure
According to Article 77 (3) of the Asylum Code:
‘During the Reception and Identification procedure or the border procedure of art. 95 of this law, the Receiving Authorities or the Decision Authorities and especially the Regional Asylum Offices or the Autonomous Asylum Units shall refer the applicant for international protection to doctors of Public Hospitals or Public Mental Health Institutions or other contracted physicians or the Medical Screening and Psychosocial Support Unit of the RIC for the vulnerability assessment under the Article 41 of this law. Upon the completion of medical and psychosocial assessment, the Unit, acting on a written motivated proposal, shall inform the Head of the competent RAO. The above-mentioned proposal is also notified to the Manager of the RIC. That assessment shall have as only consequence the immediate provision of special reception conditions and special procedural guarantees to the applicant.’
According to Article 80 (3) of the Asylum Code ‘In case of doubt, the competent Receiving Authorities shall refer the unaccompanied minor to the age assessment procedures as per the provisions in force. In the case where the above-mentioned referral is considered necessary and until the completion of the procedure, special attention should be paid to the particular characteristics of the minor, especially those related to their gender or cultural peculiarities.’
Article 72(1) of the Asylum Code provides that ‘The Receiving Authorities shall assess within a reasonable time after the application for international protection is lodged or at any point of the procedure the relevant need arises, whether the applicant requires special procedural guarantees as a consequence, inter alia, of age, gender, sexual orientation, gender identity, mental disorders or as a consequence of torture, rape or other serious forms of psychological, physical or sexual violence’. According to Article 72(3) of the Asylum Code ‘When adequate support cannot be provided [to the applicants] within the framework of the accelerated procedure (art. 83 (9) IPA) and border procedure (art. 90 IPA), especially when the applicant needs to be provided with special procedural guarantees as a consequence of torture, rape or other forms of serious psychological, physical or sexual violence, the abovementioned procedures do not apply or cease to apply […]’.
Also, according to Article 62 (5) of the Asylum Code ‘In case the competent Authorities identify victims of human trafficking, they are obliged to inform as soon as possible the National System of Recognition and Referral of Victims of Human Trafficking in accordance with the Articles 76 and 79 L. 4781/2021’.
Despite these provisions, the shortage of medical and psychosocial care can make it extremely complicated and sometimes impossible for people seeking asylum to be (re-)assessed during that process. Following the medical and psychosocial assessment, the medical psychosocial unit of the RIC should inform the competent RAO or AAU of the Asylum Service.
As mentioned above, due to significant gaps in the provision of reception and identification procedures in 2022, owing to a significant understaffing of EODY units and other issues, GCR has found that for a considerable number of applicants the asylum procedure was initiated without a proper medical screening and/or a psychosocial assessment having been concluded.
Accordingly, where vulnerability is not identified before the asylum procedure the initiation of a vulnerability assessment and further referral for vulnerability identification lies to a great extent at the discretion of the caseworker. However, according to GCR’s observations, the referral for further medical/psychosocial screening by the caseworker after the first instance interview before the competent RAO is not common practice.
Also, according to GCR’s knowledge, the understaffing of state authorities in combination with the constant pressure to process more asylum applications more quickly, resulted in a serious undermining of procedural legal safeguards and thus to decisions of poor quality and unjustified rejections in many cases. GCR has documented many cases where the asylum interview took place before the medical examination of the asylum seeker, who was afterwards rejected as non-credible because of his/her inability to provide all the dates and details of certain events and narrate his/her story in a chronological order, although the person suffered from acute psychiatric problems (e.g. psychosis), as was later proved.
As far as GCR is aware, Article 72(3) of the Asylum Code (exemption from the fast-track border procedure and referral to the regular procedure due to vulnerability) was not applied by the Asylum Service to any case without a prior lifting of the geographical restriction during 2022. It was also noted that after the lifting of geographical restriction for reasons not related to vulnerability, Article 72(3) of the Asylum Code was applied in several cases by the Asylum Service and the case was referred to the regular procedure without the person being identified as vulnerable. If the interview of first instance had already been conducted before the decision to lift the geographical restriction and the referral to the regular procedure due to vulnerability, it was not conducted again in accordance with the guarantees provided by Article 72(2) of the Asylum Code.
Data for applications exempted from the fast-track border procedure and referred to the regular procedure on grounds of vulnerability was not provided.
Vulnerability identification in the mainland
On 22 November 2021, the Greek authorities issued a circular establishing that asylum seekers (except for unaccompanied minors) who have not been through the reception and identification process can submit their asylum applications only in the Reception and Identification Centres (RIC) on the Aegean island hotspots of Samos, Chios, Lesvos, Leros and in the Evros region. Following strong opposition in the parliament however, the government backed up and clarified that applicants will not be transferred from the mainland to the islands, without however providing further information on the competent authorities for the registration of said applications. According to the authorities, the island centres will exclusively process the cases of people arriving by sea. Furthermore, Skype is no longer used as a channel to access to the asylum procedure for new applicants. Consequently, vulnerable persons in the mainland (with the exception of unaccompanied minors) who have not been subjected to the reception and identification procedures were not able to have access to the asylum procedure via Skype. Moreover, even if a lawyer intervenes and requests the registration of the asylum application of a vulnerable person in the mainland, a medical document of vulnerability issued from a public entity is most of the times needed according to the competent Regional Asylum Offices.
On 13 July 2022, the new Asylum Service registration platform was launched and since that date any appointment for lodging an asylum application in the mainland, even for vulnerable asylum seekers, needs to be booked through the platform. According to the Ministry’s announcement, the registration of applicants staying in Southern Greece was to take place in the facility of Malakasa while the registration of applicants staying in Northern Greece would take place in the facility of Diavata. Appointments were available from 1 September 2022. However, in practice, appointments were available several months later, depending on the language of the applicant.
According to the law, when indications or claims of past persecution or serious harm arise, the Asylum Service should refer the applicant for a medical and/or psychosocial examination, which should be conducted free of charge and by qualified, specialised personnel. Otherwise, the applicant must be informed that they are eligible to such examinations at their own initiative and expense. However, Article 77(2) of the Asylum Code provides that ‘Any results and reports of such examinations are deemed as justified by the Asylum Service where it is established that the applicant’s allegations of persecution or serious harm are likely to be well-founded’.
Currently, there are no public health structures specialised in identifying or assisting torture survivors in their rehabilitation process. As a result, it is for the NGOs running relatively specialised programmes, to handle the identification and rehabilitation of victims of torture. This is rather problematic for reasons that concern the sustainability of the system, as NGOs’ funding is often interrupted. In Athens, torture survivors may be referred for identification purposes to Metadrasi in the context of the programme “VicTorious: Identification and Certification of Victims of Torture”. However, those referrals take place mostly by other NGOs.
Also, according to Article 62(5) of the Asylum Code “In case the competent Authorities identify victims of human trafficking, they are obliged to inform the National Referral Mechanism (NRM) for the identification and referral of victims of Human Trafficking as soon as possible  in accordance with Articles 76 and 79 L. 4781/2021”.
As far as GCR is aware, during 2022 the Asylum Service did not refer any case for further vulnerability assessment neither to EODY nor to any public entity.
Age assessment of unaccompanied children by the RIS and in the asylum procedure
On 13 August 2020 the Joint Ministerial Decision 9889/2020 entered into force, which sets out a common age assessment procedure both in the context of reception and identification procedures and the asylum procedure.
Article 41 (f) of the Asylum Code related to reception and identification procedures refers to the relevant legislation; i.e. JMD 9889/2020. According to Article 1(2) JMD 9889/2020, in case of doubt of the person’s age, i.e. when the authority’s initial assessment is not consistent with the person’s statements, the RIS or the Asylum Service or any authority/organisation competent for the protection of minors or the provision of healthcare or the Public Prosecutor should inform – at any point of the reception and identification procedures or the asylum procedure – the Manager of the RIC or the Facility of temporary reception/hospitality, where the individual resides, or the Head of RIS or the Asylum Service -if the doubt arises for the first time during the personal interview for the examination of the asylum application-, who, acting on a motivated decision, is obliged to refer the individual for age assessment. Age assessment is carried out by EODY within the RIC, by any public health institution, or otherwise, by a private practitioner under a relevant programme.
The age assessment is conducted with the following successive methods:
Initially, the assessment will be based on the macroscopic features (i.e. physical appearance) such as height, weight, body mass index, voice, and hair growth, following a clinical examination from properly trained healthcare professionals (physicians, paediatricians, etc) who will consider body-metric data.
In case the person’s age cannot be adequately determined through the examination of macroscopic features, a psychosocial assessment is carried out by a psychologist and a social worker to evaluate the cognitive, behavioural and psychological development of the individual. If a psychologist is not available or there is no functioning social service in the nearest public health institution, this assessment can be conducted by a specially trained psychologist and a social worker available from a certified civil society organisation but it cannot be conducted by an organisation in charge of providing care or housing to the person whose age is in question. The outcome of the age assessment at this point is a combination of the psychosocial assessment and the examination of the development of macroscopic features.
Whenever a conclusion cannot be reached after the conduct of the above procedures, the person will be subjected to the following medical examinations: either left wrist and hand X-rays for the assessment of the skeletal mass, or dental examination or panoramic dental X-rays or to any other appropriate means which can lead to a firm conclusion according to the international bibliography and practice.
According to Article 1(7) JMD 9889/2020 the opinions and evaluations are delivered to the person responsible for the referral, who issues a relevant act to adopt the abovementioned conclusions, registers the age in the database of Reception and Asylum, and notifies the act to the Special Secretariat for the Protection of Unaccompanied Minors.
After the age assessment procedure is completed, the individual should be informed in a language he or she understands about the content of the age assessment decision, against which he or she has the right to appeal in accordance with the Code of Administrative Procedure. The appeal has to be submitted to the authority that issued the contested decision within 15 days from the notification of the decision on age assessment.
In practice, the 15-day period may pose an insurmountable obstacle to receiving identification documents proving their age, as in many cases persons under an age assessment procedure remain restricted in the RIC. These appeals are in practice examined by the Central RIS. The number of appeals submitted against age assessment decisions in 2022 is not available.
The findings of a report published by several civil society organisations at the beginning of 2020 are still valid for the year 2022:
‘Medical methods for age assessment are systematically used, despite well-documented concerns as to their accuracy and reliability. The authorities do not systematically comply with the procedure set out in secondary legislation […] Persons are subjected to an X-ray examination at the First-Line National Health Network Centre (ΠΕΔΥ) or general hospital, without prior assessment by a psychologist and a social worker. Moreover, EODY does not perform a systematic process starting from less invasive methods, as established by JMD 9889/2020. The alleged minors go through a one-time appointment, which includes an age assessment interview and a medical and psychological evaluation. Many are only asked about aspects irrelevant to age assessment such as their family relationships, country of origin, and reasons for fleeing. The sessions take less than 15 minutes and involve no explanation of the procedure or its outcome.’
In the same report, it is mentioned that
‘Errors in the registration of personal details e.g. name, parents’ names, date of birth, are frequently reported in the different RICs. […]. Particularly as regards the date of birth, the RIS frequently sets artificial dates such as 1 January. This is especially relevant in the case of alleged minors. In several cases, documents held by individuals are disregarded on the ground that the authorities cannot assess the documents’ authenticity, and the authorities assign a new date of birth to the applicant. This practice is verified, for instance, vis-à-vis applicants from Afghanistan. [….] Complaints also relate to wrong registration of children as adults. Frontex officers are reported to systematically register declared minors as adults, without recording their declared age and without referring them to age assessment procedures’.
According to GCR’s findings, in practice, the age assessment of unaccompanied children is an extremely challenging process and the procedure prescribed is not followed in a significant number of cases, inter alia, due to the lack of qualified staff.
According to GCR’s findings, on Kos, minors were treated as adults unless their lawyer submitted a request for age assessment. It is also observed that, in case of doubt, the medical and psychosocial assessment in the scope of the RIS was skipped and the individuals were directly referred to the public hospital for X-rays. During 2022 there was no pediatrician at the Public Hospital of Kos. Also, the authenticity of children’s documents proving their age was controlled by FRONTEX which always concluded that the documents were forged.
On Chios, during the first semester of 2022, in case of minors lacking documents, both RIS and FRONTEX registered them as adults.
Concerning age assessment in the asylum procedure, the Asylum Code (Article 80(3)) includes procedural safeguards and refers explicitly to ‘applicable regulatory procedures’, i.e. to JMD 9889/2020. Also, ‘when such a referral for age determination examinations is considered necessary and throughout this procedure, attention shall be given to the respect of gender-related special characteristics and of cultural particularities.’
The provision also sets out guarantees during the procedure:
- A guardian for the child is appointed who shall undertake all necessary action in order to protect the rights and the best interests of the child, throughout the age determination procedure;
- Unaccompanied children are informed prior to the examination of their application and in a language which they understand, of the possibility and the procedures to determine their age, of the methods used, therefore, the possible consequences of the results of the above-mentioned age determination procedures for the examination of the application for international protection, as well as the consequences of their refusal to undergo this examination;
- Unaccompanied children or their guardians consent to carry out the procedure for the determination of the age of the children concerned;
- The decision to reject an application of an unaccompanied child who refused to undergo this age determination procedure shall not be based solely on that refusal; and
- Until the completion of the age determination procedure, the person who claims to be a minor shall be treated as such.
The law also states that ‘the year of birth can be modified after the age determination procedure under Article 80, unless during the interview it appears that the applicant who is registered as an adult is manifestly a minor; in such cases, a decision of the Head of the competent Receiving Authority, following a recommendation by the case-handler, shall suffice.’
The JMD was an anticipated legal instrument, filling the gap of dedicated age assessment procedures within the context of the Asylum Service and limiting the use of medical examinations to a last resort while prioritising alternative means of assessment. Multiple safeguards prescribed in both the IPA and JMD 9889/2020 regulate the context of the procedure sufficiently, while explicitly providing the possibility of remaining doubts and thus providing the applicant with the benefit of the doubt even after the conclusion of the procedure. However, the lack of an effective guardianship system also hinders the enjoyment of procedural rights guaranteed by national legislation (see Legal Representation of Unaccompanied Children).
In practice, the lack of qualified staff within the reception and identification procedure and shortcomings in the age assessment procedure in the RIC undoubtedly have a spill-over effect on the asylum procedure, as the issuance of an age determination act by the RIS precedes the registration of the asylum application with the Asylum Service. While registration of date of birth by the Hellenic Police could be corrected by merely stating the correct date before the Asylum Service, this is not the case for individuals whose age has been wrongly assessed by the RIS. In this case, in order for the personal data e.g. age of the person to be corrected, the original travel document, or identity card should be submitted. Additionally, a birth certificate or family status can be submitted, however, these two documents require an apostille stamp, which in practice is not always possible for an asylum seeker to obtain. In practice though, in a few cases the employees in the RAOs proceed to the correction of the age of the person, based on documents without apostille. Alternatively, according to the law, the caseworker of the Asylum Service can refer the applicant to the age assessment determination procedure in case that reasonable drought exists as to his or her age. In this case, referral to the age assessment procedure largely lies at the discretion of the Asylum Service caseworker.
The number of age assessments conducted within the framework of the asylum procedure in 2022 was not provided.
 ASYLUM CODE, Gov. Gazette A’ 111/10.06.2022
 L 4636/2019, Gov. Gazette A’ 169/01.11.2019
 Information provided by the EUAA, 28 February 2023.
 Equal Rights Beyond borders and others, see above, p. 15.
 For a detailed description of the issues that exacerbate the procedure of the vulnerability assessment see AIDA report on Greece 2021.
 This act is based on Article 45 L. 4636/2019. It is worth noting that the act mentions that the geographical restriction is necessary for the implementation of the EU-Türkiye statement.
 Except for the case of vulnerable persons and persons in need of special reception conditions the geographical restriction may be lifted in the case of: a. unaccompanied minors; b. persons falling under the family reunification provisions of Articles 8-11 of Dublin Regulation, only after the person is accepted by the concerned member state; and c. persons whose applications for international protection are reasonably considered to be founded.
 See Article 67 (2) L. 4636/2019 and Article 2 (d) of the Ministerial Decision 1140/2.12.2019.
 According to Article 67 (2) L. 4636/2019, ‘[w]here applicants have been identified as applicants in need of special procedural guarantees, they shall be provided with adequate support in order to allow them to benefit from the rights and comply with the obligations of this Part throughout the duration of the procedure. Forms of adequate support shall, in particular, consist of additional break times during the personal interview in accordance with Article 77, allowing the applicant to move during the personal interview if this is necessary because of his or her health condition, as well as showing leniency to non-major inaccuracies and contradictions, where these are related to his/her health condition.’
 MOMA, «Ξεκινά η λειτουργία της πλατφόρμας ηλεκτρονικής αίτησης για ραντεβού καταγραφής αιτούντων άσυλο», 2022, available at: https://bit.ly/3S76tJ6
 Article 77(3) Asylum Code
 Joint Ministerial Decision 9889/2020, Gov. Gazette 3390/Β/13-8-2020.
 See Article 1(3) JMD 9889/2020.
 See Art 4 JMD 9889/2020.
 See Article 1(5)(a) JMD 9889/2020.
 See Art. 1(5)(b) JMD 9889/2020.
 See Art 1(5)(c) JMD 9889/2020. Contrary to MD 92490/2013 and JMD 1982/2016 which provided for left wrist, hand X-rays, dental examination and panoramic dental X- rays cumulatively and not alternatively.
 See Art1(9) JMD 9889/2020.
 RSA, HIAS, GCR, Legal Center Lesvos, DRC, Fenix, ActionAid, Mobile Info Team, The Workings of the Screening Regulation. Juxtaposing proposed EU rules with the Greek reception and identification procedure, January 2021, available at: https://bit.ly/3fL8xFF, 21.
 Ibid, 10-11.
 Article 84(4) of the Asylum Code
 Decision of the Director of the Asylum Service No 3153, Gov. Gazette Β’ 310/02.02.2018.
 Article 80(3) Asylum Code.
 For a detailed description of the problems related with the age assessment on Lesvos island, see Fenix, A Child’s Best Interests? Rights Violations in the Absence of Presumption of Minority, 13 October 2022, available at : https://bit.ly/3ACqq2t