Identification

Author

Greek Council for Refugees Visit Website

According to Article 1(λγ) Asylum Code, the following non-exhaustive groups are considered as vulnerable:

‘children; unaccompanied children; direct relatives of victims of shipwrecks (parents, siblings, children, spouses); 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) Asylum Code, ‘[t]he assessment of vulnerability shall take place during the identification process, the registration process and the medical screening of the Article 41 without prejudice to the assessment of international protection needs’. According to Article 62(4) of the Asylum Code ‘[o]nly 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) Asylum Code:

[…] Upon 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(1) 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 –among others- 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.

A new General Secretariat for Vulnerable Persons and Institutional Protection (GSVPIP) falling under the responsibilities of the Deputy Minister of Migration and Asylum was established with Article 6(1) of P.D. 77/2023 (A’ 130/ 27-06-2023) to which the services of the Special Secretariat for the Protection of Unaccompanied Minors of Article 39 of the P.D. 106/2020 were transferred.^[1]

The number of vulnerable persons registered by the RIS during the 12 months of 2025 throughout the country stood as follows:

Source: MoMA, Registered Third-country nationals/stateless persons in Regional Units (CCAC / RIC) of Islands and Fylakio of the RIS for January – December 2025 and Registered and Third-country nationals/stateless persons in Regional Units (RIC/MURCT) in Mainland of the RIS for January – December 2025, both available at: https://migration.gov.gr/en/statistika/.

In what concerns children in particular:

• The number of children registered by the RIS in 2025 amounted to 10.498. The majority were registered at border RICs/CCACs (70,2%) 7.693 and the rest on the mainland. ( 29,8%) 2805 ^[2]
• The number of unaccompanied children registered by the RIS during the same period stood at 2.713, meaning 1 in 4 children arrived in Greece unaccompanied during the time.^[3]
• The number of first and second instance decisions granting refugee status and subsidiary protection to children throughout the year amounted to 8,640 (8,088 granting refugee status and 552 subsidiary protection).^[4]
• The number of first instance decisions granting refugee status and subsidiary protection to UAMs throughout the year stood at 449 (402 granting refugee status and 47 granting subsidiary protection), of which 352 concerned male UAMs and 97 female UAMs.^[5]

Screening of vulnerability

Vulnerability identification in the border regions

According to the law, the identification of vulnerability of individuals arriving at the border regions shall be carried out either by the RIS before the registration of the asylum application or during the asylum procedure.^[6]

Vulnerability identification by the RIS

According to Article 41 Asylum Code regarding registration and medical examination, in the context of reception and identification procedures carried out by the RIS:

’The third stage of the reception and identification procedure regarding “Registration and Medical Examination” includes: […] d) the care for those who belong to vulnerable groups, so that they are provided with specialized care and protection. In particular, the Manager of the Reception and Identification Centre (RIC) or the Closed Controlled Access Centre (CCAC) or Unit, acting on a reasoned proposal of the competent medical staff of the Reception and Identification Centre or the Closed Controlled Access Centres, shall refer persons belonging to vulnerable groups to the competent, based on each case, public institution of social support or protection. 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 regarding applications of UAMs: ‘In case of doubt, the competent Receiving Authorities shall refer the unaccompanied minor to age assessment procedures as per the provisions in force. In cases 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).

Based on data published by the MoMA, the number of those registered as vulnerable by the RIS at the borders during 2025 stood as follows:^[7]

The number of persons identified as vulnerable after conclusion of the reception and identification procedures and the number of persons identified as vulnerable after re-examination was not available. Moreover, no information was provided regarding the competent authority to cover the expenses in cases where transfer to another island was necessary for the vulnerability assessment.

The low quality of the process of medical and psychosocial screening, if any, has remained a source of serious concern also in 2025, since no positive developments occurred.

As stated in AIDA report for 2022,^[8] vulnerabilities are often missed, with individuals going through the asylum procedure without having their vulnerability assessment completed first. Equal Rights Beyond Borders, HIAS Greece and RSA have reported that:

[s]evere 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.^[9]

The organisations further report that:

[o]n 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 applicants are referred to the Asylum Service with a Medical Card which in most cases precedes the actual medical check and vulnerability assessment.^[10]

Based on GCR’s information from the field, in 2024 and 2025, the main problems arising in the context of Reception and Identification procedures continued and included the lack or complete absence of psychosocial assessment, the 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.^[11] As mentioned in the Regular procedure and Fast-track border procedure, many asylum applicants continue being forced to attend their personal interview with the Asylum Service without a prior assessment of their vulnerability, including pregnant women.

RSA reported that according to information obtained by the RIS, as of 11 November 2024 in the CCAC of Kos, Leros, Lesvos, Samos and Chios, there were only 2 doctors in Lesvos (a general doctor and a gynecologist), 6 psychologists except in the CCAC of Kos, 9 social workers, 25 nurses, 2 midwifes and 2 radiologists in Lesvos and Samos.[12]

As per the same report:

Critical gaps in medical personnel in the Medical Control and Psychosocial Support Units in the CCAC therefore persist even after the completion of the PHILOS programme at the end of June 2024 – at that time there were only two doctors on Lesvos and two on Leros for first-line health care and psychosocial support. The HIPPOCRATES programme implemented by the International Organisation for Migration (IOM) was launched in September, however, serious gaps remain in staffing of positions in the CCAC. Staff would not suffice to cover the population in the facilities even if all advertised positions were filled. […] The absence of doctors entails more than an inability of the state to deliver absolutely necessary medical care to the thousands of people living in the island facilities. It also poses a serious barrier to screening procedures which by law include a medical check and vulnerability assessment prior to the registration of an asylum application. The lack of medical staff is particularly critical for vulnerable cases with chronic and serious illnesses, such as diabetic patients. Furthermore, it renders connection with and referral to second- and third-line health care impossible, while all the islands hosting a CCAC suffer from seriously understaffed hospitals.

Chios: In Chios CCAC (Vial camp), the Medical Unit has no doctor since March 2021. As noted by RSA[13]: as of 11 November 2024, “the facility employs six nurses, two midwives, three social workers, and two psychologists. Nurses handle medical documentation and forward it to a doctor who signs the medical records. Primary healthcare services are unavailable in the afternoons and on weekends, so even minor emergencies must be referred to the understaffed Chios hospital by police or emergency medical services. Psychosocial evaluations are nearly impossible due to the severe shortage of interpreters, who must focus on urgent needs (e.g. interpretation for the custody of minors)”. According to information provided by UNHCR in December 2024, a part-time pediatrician was also active in the camp.[14]

Samos: Serious shortcomings in identifying vulnerabilities continued in 2024. As noted by RSA:

Our meetings with refugees confirmed severe deficiencies in identifying, supporting and further assessing vulnerable populations, a clear consequence of the medical staff shortages. Asylum seekers attend their asylum interviews without prior vulnerability assessments. Often, this process is postponed until later stages, after first registration, either upon referral by NGO lawyers who happen to represent vulnerable asylum seekers or during the asylum interview by the Asylum Service. Among those we met, only one survivor of a shipwreck, whose pregnant partner drowned, was referred to a psychologist. A heavily pregnant woman who had been hospitalised upon arrival was not identified as vulnerable. Similarly, a single male survivor of torture requested to speak with a psychologist from the CCAC but had not received assistance as of our visit date.[15]

As further reported by the organisation I Have Rights, “[t]he camp, with a 3,600-place capacity, had 4,600 people in mid-Nov 2024 and is expected to exceed 5,000 by the end of the year. As of 7 Nov 2024 the CCAC had 1,433 unregistered persons. This results in severe delays in registration and in people waiting at least one month to receive an asylum seeker’s card. […]. The camp has no doctor, only a pediatrician from the Red Cross.” [16]

Kos: RSA reports insufficient medical care and inadequate vulnerability assessments during 2024.

For the past two years, no permanent doctor has been stationed in the CCAC. Medical needs are covered sporadically by visiting doctors from other areas and a military doctor. The Reception and Identification Service’ response to us (as of 11/11/2024) confirmed that the CCAC employs only three nurses and two social workers, but no doctors. At the General Hospital-Health Centre of Kos “Hippocrates,” located 15 km from the CCAC, there are significant long-standing shortages in key medical specialties – for instance, no permanent pathologist or cardiologist is available. Only one hospital ambulance is staffed and operational. The hospital faces additional pressure during the summer months due to increased tourist activity. Since August 2024, Médecins Sans Frontières (MSF) has been active outside the CCAC, as well as once weekly outside the hospital, providing medical services to both refugees and locals. Additionally, the island hosts a mobile volunteer medical team from Medical Volunteers International (MVI), offering basic emergency care. Due to the lack of medical staff, the mandated medical screening processes and vulnerability assessments are not conducted. For instance, an asylum seeker with diabetes remained in the centre for about two months without receiving proper medication to manage his condition. In one case legally represented by RSA, no vulnerability assessment was performed for a survivor of torture, even after a formal request by our lawyers.[17]

Leros: As reported by RSA, during 2024:

[t]he provision of medical services in the Leros CCAC is severely inadequate. The response we received from the Reception and Identification Service (RIS) (on 11/11/2024) confirms that the facility has no doctor. The medical staff comprises only six nurses, one midwife, one psychologist, and one social worker. Medical screening is carried out by the RIS medical unit, involving nurses and periodic visits by doctors to the island. This arrangement means that medical assessments for newly arrived individuals are essentially unavailable, making it impossible to identify potential vulnerabilities. Furthermore, due to the lack of personnel, accessing medical assistance for residents is extremely challenging.

The staffing shortages render diagnosis, monitoring, and assistance for individuals with serious or chronic health conditions unfeasible. For example, in two cases of individuals with medical issues, RSA lawyers formally requested medical assessments and vulnerability evaluations. Although the CCAC administration referred these individuals to the Medical Control and Psychosocial Support Unit, no such assessments have taken place to date. One of these cases involved an individual blind in one eye and experiencing vision problems in the other, who had not been examined by a doctor since arriving in Greece in late July, with their health issues remaining unaddressed. When the individual sought help independently at the hospital, they were informed that medical examinations require a referral from the CCAC.

Refugees reported to us that hospital referrals, even for unaccompanied minors, are made only in very severe cases. Meanwhile, the Leros hospital itself faces significant staff shortages.[18]

In December 2024 METAdrasi and Equal Rights Beyond Borders noted that there were 750 unregistered persons beyond the 25-day time limit in CCAC of Leros. Numbers were higher and had reached 1,000 previously. People are allowed to exit after the 25-day period but without any rights, health care etc. The CCAC has no doctor to perform medical checks and is serviced by a doctor performing three-day missions, mainly to sign health cards and occasionally to offer care to urgent cases.[19]

Lesvos: Shortages in Medical and Psychological Support have continued during 2024. As reported by RSA:

[s]erious shortages in medical and healthcare staff are evident in the Lesvos CCAC. According to the Reception and Identification Service’ s response to us (as of 11 November 2024), there is only one general practitioner, one gynaecologist, two midwives, six nurses, one laboratory technician, two psychologists, and one social worker in the CCAC. Newly arrived individuals undergo a basic medical check-up, while no psychosocial evaluation is conducted. Even individuals with obvious vulnerabilities are not identified. Furthermore, medical staff only work during business hours, leaving the facility without a doctor at night or on weekends. NGOs attempt to fill this gap, but this complicates prescriptions and referrals, as only certified Greek doctors can issue them. The Vostanio Hospital in Lesvos is also severely understaffed. There is currently no active child psychiatrist on the island, making it impossible to identify minors with mental health vulnerabilities.[20]

Summing up, according to the data provided by the MoMA to the Greek Parliament, druring 2024 only 29 doctors were employed across all camps managed by the RIS, averaging just one doctor per 635 people among the 18,412 residents. Furthermore, 13 of the 32 camps, including some housing hundreds or even thousands of residents on 30 June 2024, such as Samos (2,255 residents), Kos (1,263 residents) and Katsikas (789 residents), have no doctors at all. Camps without doctors at all include Samos, Kos, Chios, Corinth, Kyllini, Pyrgos, Volos, Serres, Katsikas, Filippiada, Alexandria, Vagiochori, and Sintiki.[21] In the islands’ CCACs, only 2 doctors were employed in Lesvos CCAC, while Samos, Kos, Leros and Chios CCACs have no doctors at all.[22]

During 2025,[23] in a report concerning the first half of 2025, RSA reported that “at  the end of June 2025, 19,065 people resided in camps (“facilities”) managed by the Reception and Identification Service (RIS) of the Ministry of Migration and Asylum throughout Greece. This includes five Closed Controlled Access Centres (CCAC) on the islands, three Reception and Identification Centres (RIC) and 22 Controlled Temporary Reception Centres for asylum seekers (CTRC) on the mainland. At the end of 2024, the RIS reception system counted 27,100 residents. (…)  Figures made available in Parliament confirm persisting gaps in the staffing of medical and psychosocial services in camps, within the framework of the “Hippocrates” programme, despite a slight increase from the end of last year. A total of 60 doctors were deployed throughout the RIS camps, compared to 54 at the end of 2024. This corresponds to one doctor per 317 residents, in view of the total population of 19,065 residents. Camps such as Filippiada, Veria, Kyllini and Pyrgos had no doctor at all”.

Additionaly, RSA reported that the number of interpreters deployed in RIS camps was 128 as of 30 June 2025. Since then, however, interpretation services in camps have been halted indefinitely yet again. The absence of interpretation inevitably means a lack of access to necessary services such as health care[24].

Based on GCR’s and partners’ observations, asylum claims are frequently examined before vulnerability assessments are carried out, and, in any case, the outcome of the latter are often not communicated to the Asylum Service before it issues its decision on the application.

The lifting of the geographical restriction (see also Reception Conditions – Freedom of Movement).

Under the Asylum Code (and previously the IPA), the recognition of vulnerability of asylum applicants 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 such cases, the geographical restriction imposed upon arrival is lifted and the applicant is transferred or allowed to travel to the mainland. Therefore, the exemption of vulnerable individuals from the Fast-Track Border procedure has become much more difficult.

In particular, the movement of asylum-applicants who entered Greece through the islands of Lesvos, Chios, Samos, Kos, Leros, and Rhodes during 2023 is limited to within their respective island (‘geographical restriction’), as per Ministerial Decision 1140/2.12.2019 (GG B’ 4736/20.12.2019) in force since 1 January 2020.^[25] Greek law transposes Article 7 RCD, allowing Member States to impose a restriction of movement to asylum-applicants within a specific area, provided that it does not affect their unalienable sphere of private life and that it allows sufficient scope for guaranteeing access to all the benefits granted 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, since 1 January 2020, the geographical restriction may inter alia^[26] 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,^[27] without sufficiently describing what such appropriate support entails.^[28]

The number of decisions to lift geographical restrictions per RIC and per category of vulnerability (or other cases) in 2024 is not publicly available, nor was it provided by the MoMA following GCR’s relevant request.

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 Article 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 ‘[i]n case of doubt, the competent Receiving Authorities shall refer the unaccompanied minor to the age assessment procedures as per the provisions in force. In case 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:

‘[t]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 (Article 83 (9) IPA) and border procedure (Article 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 ‘[i]n 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’. Greece is not fully aligned with the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, in particular regarding the issue of consent, as highlighted by CEDAW.[29]

Despite these provisions, the shortage of medical and psychosocial care makes 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 2024 and 2025 owing to a significant understaffing of medical 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 depends to a great extent on 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, from reports from the field, many cases in which the asylum interview took place before the medical examination of the asylum applicant, thus impacted negatively on the outcome of the asylum cases.

As far as GCR is aware, also in 2025 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 without a prior lifting of the geographical restriction. It was also noted that after the lifting of the 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. For further information on the geographical restriction, see chapter on Reception Conditions – Freedom of Movement.

Data for applications exempted from the fast-track border procedure and referred to the regular procedure on grounds of vulnerability was not provided by MoMa despite GCR’s request.

Throughout 2025, the various RAOs in the different islands followed different practices as regards the conduct of asylum interviews (see the Regular procedure and Fast-track border procedure).

Vulnerability identification in the mainland

On 13 July 2022, the MoMA launched a new registration platform, through which persons wishing to apply for asylum while on the Greek mainland, including vulnerable ones, need to first book an appointment for lodging their application. The registration of applicants staying in Southern Greece takes place in the facility of Malakasa (Athens), while the registration of applicants staying in Northern Greece takes place in the facility of Diavata (Thessaloniki).

Since its operationalisation, the platform has been marked by deficiencies restricting applicants’ access to the procedure and in turn a prompt vulnerability assessment. For instance, as noted in a joint RLS and MIT report in November 2023,^[30] “out of 19 persons interviewed between May and October 2023, 69% of respondents who used the online platform to book an appointment at a RIC reported issues accessing or using the platform […and] 23% respondents said they paid a private lawyer to apply via the online platform for them […]”. Meanwhile, access to the platform was yet again suspended between May 2023 and the beginning of July 2023.^[31]

As further noted in the aforementioned 2023 report by RLS & MIT:

‘Under the new procedure […] at one of two RICs on the Greek mainland, […] applicants are unable to exit the facility for a maximum of 25 days while they undergo screening consisting of a police interview, medical check, vulnerability assessment, and the registration of an asylum claim […]. Restriction of movement is applied as a blanket measure […] including (to) vulnerable persons […] meaning that people with a disability, pregnant women, victims of human trafficking, people with serious illnesses and torture survivors, among others, are subjected to de facto detention within the RICs for periods up to 25 days (and in practice possibly longer). […] assessment of vulnerability within the screening procedure is inadequate […].’^[32]

According to the law, when indications or claims of past persecution or serious harm arise (i.e., torture survivors), the Asylum Service has to refer the applicant to a medical and/or psychosocial examination, which should be conducted free of charge and by qualified, specialised personnel. Alternatively, the applicant must be informed that they can undergo such examinations at their own initiative and expense.^[33] Article 77(2) of the Asylum Code provides that ‘[a]ny 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’.

However, there are still 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 were referred for identification purposes to the NGO METAdrasi in the context of its programme “Hope and Memory: Identification and Certification of Victims of Torture”^[34]. However, the programme ended at the end of 2023.

According to a report of FENIX of April 2023 regarding identification and certification of victims of torture:

‘practice over the years has demonstrated serious deficiencies in the identification and certification of victims of torture of applicants in Greece […]. Additionally, structural deficiencies are also observed in the specific process to certify VoTs, namely due to restrictive legislation limiting only public authorities to provide certification for VoTs in accordance with the Istanbul Protocol, whilst national authorities and bodies do not have the qualification or training and lack of interpretation to proceed with this certification. At the same time, non-governmental organisations, namely Metadrasi, hold the appropriate expertise to provide certification for VoTs according to the Istanbul Protocol […] Nonetheless, […] the VoT certification provided by NGOs may be taken into consideration by asylum authorities for the purposes of the asylum procedure, but it is at the discretion of each decision maker […].’^[35]

Also, according to Article 62(5) of the Asylum Code “[i]n 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^[36] in accordance with Articles 76 and 79 L. 4781/2021”.

Challenges continued being identified in 2024 as well. According to UNHCR, RIC Malakasa maintained a very limited number of appointments on the platform, while RIC Diavata had less limitations. Yet in the case of Diavata, in GCR’s experience, the online platform would remain open for 15-16 appointments per day, following which it went down quickly again. SolidarityNow noted that the platform of RIC Malakasa opened on 2 December 2024 in the morning and closed again at the end of the same day. ELIL noted that Farsi speakers have managed to get appointments for Malakasa, while Arabic and Pashto speakers have not succeeded. In one case due to the platform being down, Equal Rights Beyond Borders wrote to the two RICs and RIC Diavata requested the person to come for registration.[37]

The same issues remain during 2025. According to GCR, despite the Greek Government’s assurances in its 2025 Action Plan (para 13) that the platform is operational without interruption, complaints regarding the non-smooth operation of the online platform of the MoMA persist to date, including reports of complete inability to access the online platform, resulting in the ongoing risk of arbitrary arrest and detention of asylum seekers awaiting registration, and their non-access to reception conditions. The  platform is often non-accessible or does not grant an appointment date for the registration of the request for international protection at the Malakasa and Diavata RICs. Failure to register an application for international protection means deprivation of the protection linked with the asylum seeker’s status (i.e. right to remain on the territory, enjoyment of reception conditions). Most recently, on 7 April 2025, the Greek Ombudsman, in its written intervention addressed to the Asylum Service, following a GCR complaint for the arrest and detention of an Afghan national, who was unable to access the platform, re-raised the issue of the impossibility of accessing the online platform of the Ministry. In that case, the applicant was arrested outside Malakasa, where he went to submit in person an asylum application due to the lack of access to the online platform, and he was consequently detained on the basis of a return decision. Moreover, and even in the event that an applicant has scheduled an appointment to Malakasa and Diavata RICs, while awaiting the day of the full registration of his/her asylum application, they are not protected from arrest and detention in view of deportation.[38]

Age assessment of unaccompanied children by the RIS and in the asylum procedure

Article 41 (f) Asylum Code refers to the Joint Ministerial Decision 9889/2020,^[39] which sets out a common age assessment procedure both in the context of reception and identification procedures and the asylum procedure.

According to Article 1(2) JMD 9889/2020, in case of doubt as to the person’s age, i.e., when the authority’s initial assessment is not consistent with the person’s statements or storyline,^[40] 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 reception facility, 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 reasoned decision, is obliged to refer the individual for an age assessment procedure.

The age assessment is, according to the law, conducted by the Medical and Psychosocial Support Unit of the Reception and Identification Centre or the Control Access Facilities Temporary Accommodation of Asylum Seekers (CAFTAAS) or the Mobile Reception and Identification Units or the nearest one to the residence of the referred person, a competent structure of the public health system or, in case the aforementioned are not available, by a private qualified doctor, such as a paediatrician or pathologist and a private trained psychologist and social worker, under a relevant programme.^[41] According to same clause, the referral shall be made on the basis of the easiest, most accurate and fastest age determination.

The age assessment is conducted following three successive steps, unless a safe conclusion can be drawn already at the first or second examination stage:

• Initially, the assessment is based on the individual’s macroscopic features (e., physical appearance) such as height, weight, body mass index, voice, and hair growth, following a clinical examination from properly trained healthcare professionals (i.e., physicians, paediatricians, etc.) who will consider body-metric data.^[42]
• 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 (second step). 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.^[43]
• If a conclusion cannot be reached after the conduct of the above procedures, the person will be subjected to the following medical examinations (last step): either left wrist and hand X-rays for the assessment of the skeletal mass, or dental examination or panoramic dental X-rays or any other appropriate means which can lead to a firm conclusion according to the international bibliography and practice.^[44]

According to Article 1(7) JMD 9889/2020, the opinions and evaluations are delivered to the entity responsible for the referral, which then issues a relevant act to adopt the abovementioned conclusions, registers the age in the database of Reception and Asylum, and notifies accordingly the General Secretariat for Vulnerable Persons and Institutional Protection (former Special Secretary for UAMs).^[45]

After the age assessment procedure is completed, the individual should be informed in a language they understand about the content of the age assessment decision, against which they have 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.^[46] Also, as long as an age assessment procedure is pending, the person is considered a child (presumption of minority).[47]

Concerning age assessment in the asylum procedure, Article 80(3) Asylum Code provides for procedural safeguards and refers explicitly to ‘applicable regulatory procedures’, i.e., JMD 9889/2020. According to the aforementioned provision, ‘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:

1. 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;
2. 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;
3. Unaccompanied children or their guardians consent to carry out the procedure for the determination of the age of the children concerned;
4. 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
5. 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.’^[48]

The JMD 9889/2020 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.^[49] The above is corroborated by the World Medical Association (WMA) which clarifies that there is “conflicting evidence about the accuracy and reliability of the available methods of age assessment, which may generate significant margins of error”.[50]

The persisting administrative contra legem treatment of persons in a pending age assessment procedure as adults was noted over 2025, with a court decision clarifying that this is a malpractice in contrast to what the law stipulates. In a case supported by GCR, a child had been detained for three months in a Pre-Removal Detention Centre together with adults unknown to him, under conditions completely unsuitable for children and with no access to a guardian, given that he was treated as an adult.[51]

In its 2022 Concluding Observation, the UNCRC already noted its serious concern regarding the generalized and inappropriate determination procedures and urged the state to “[e]nsure that the age determination procedure is multidisciplinary, scientifically based, respectful of children’s rights, harmonized across the country, and used only in cases of serious doubt about the claimed age, and takes into consideration CRC/C/GRC/CO/4-6 14 documentary or other forms of evidence available, and ensure access to effective appeal mechanisms”.[52]

Nonetheless, in August 2025, the procedure was reformed once again  by the Joint Ministerial Decision 147627/22-8-2025 by the Ministries of Migration & Asylum and Health. Competent authorities —including the Reception and Identification Service, the Asylum Service, and child protection agencies—initiate the procedure. It is conducted in a single session including a medical examination of physical development, a psychosocial assessment by a qualified specialist, and a wrist/hand X-ray for bone age estimation. In case of conflicting results, radiological findings prevail. Written consent from the individual or their guardian is mandatory; refusal results in a presumption of adulthood without affecting the asylum claim. The process requires all steps to be completed within the same day.

With a joint letter to the Minister of Migration and Asylum in October 2025, 25 organizations expressed serious concerns that the new Ministerial Decision (JMD) violates fundamental safeguards as enshrined in the Convention on the Rights of the Child, EU law, and the European Convention on Human Rights. They point out that the procedure should prioritize non-medical methods as mandated by Regulation (EU) 2024/1348.^[53]

In November 2025, the GCR and the AIRE Centre filed a submission to the Committee of Ministers of the Council οf Europe concerning the execution of the O.R. v Greece judgment, emphasizing, regarding the new procedure,[54] that the new JMD:

1. provides that all stages (including X-Rays) to occur cumulatively and on the same day, with priority given to the results of medical examinations (X-rays), contrary to the obligation to conduct age assessments using the least intrusive method and use medical examinations only as a measure of last resort and against the fact that guarantees put in place by EU and international law to ensure a holistic and multidisciplinary age-assessment procedure (a development welcomed by the ECtHR). Moreover, increased weight on the result of the X-Ray examinations as provided by the JMD, means that even where all previous results indicated that the applicant is a child the results of the X-Rays take precedence, contrary to the presumption of minority;
2. reduces the appeal deadline from 15 to 5 days, without suspensive effect, hindering access to an appeal procedure in practice; and

• introduces a presumption of majority upon refusal to undergo medical testing.

The provisions above entail the risk that unaccompanied children are not properly identified and are excluded from any protection foreseen by Law for UASC, including guardianship, reception conditions, protection from detention, etc.

In addition, the new JMD provides that the presumption of minority during the procedure applies only to individuals registered as minors, excluding those unaccompanied children wrongly registered as adults. Those wrongfully identified as adults are not appointed with a guardian to provide support during the age assessment procedure, remain in accommodation facilities with unrelated adults, are not protected from detention and might be detained with unrelated adults, and are excluded from any guarantees provided for unaccompanied minors. However, as the Court has already found, the principle of presumption of minor age, is an inherent element of the protection of the right to respect for private life of a foreign unaccompanied individual declaring himself or herself to be a minor.

[1] For more information, see MoMA’s General Secretariat for Vulnerable Persons and Institutional Protection, home webpage, available at: https://tinyurl.com/2u63bw7y.

[2] MoMA, Registered Third-country nationals/stateless persons in Regional Units (CCAC / RIC) of Islands and Fylakio of the RIS for January – December  2025 and Registered Third-country nationals/stateless persons in Regional Units (RIC/MURCT) in Mainland of the RIS for January – December 2025, both available at: https://migration.gov.gr/en/statistika/.

[3] Ibid.

[4] MoMA, Statistics: Consolidated Reports – Overview, December 2025 – International Protection | Appendix A, available at: https://migration.gov.gr/statistika/, Table 11d.

[5] Ibid Table 11f.

[6] Articles 41 & 80(3) of the Asylum Code for vulnerability identification by RIS and Articles 62(5), 72(1, 3), 77(3) and 80(3) for vulnerability identification in the asylum procedure.

[7] MoMA, Registered Third-country nationals/stateless persons in Regional Units (CCAC / RIC) of Islands and Fylakio of the RIS for January – September, available at: https://migration.gov.gr/en/statistika/.

[8] ECRE, AIDA, Country Report: Greece, 2022 Update, June 2023, available at: https://bit.ly/3PUOVk9.

[9]Equal Rights Beyond Borders, HIAS Greece & Refugee Support Aegean, Τhe state of the border procedure on the greek islands, September 2022, available at: https://bit.ly/40VTZrM, p. 4.

[10]Ibid., p. 15.

[11] For a detailed description of the issues during the procedure of the vulnerability assessment, See ECRE, AIDA, Country Report: Greece, 2021 Update, May 2022, available at: https://bit.ly/3MRVkLf.

[12] RSA, Refugee facilities on the Aegean islands, 10 December 2024, available at: https://tinyurl.com/s9r9nzaj.

[13] RSA, Chios, 10 December 2024, available at: https://rsaegean.org/en/chios-2024/.

[14] Information obtained during Legal Aid Working Group meeting, 4 December 2024.

[15] RSA, Samos, 10 December 2024, available at: https://rsaegean.org/en/samos-2024/.

[16] Information obtained during Legal Aid Working Group meeting 4 December 2024.

[17] RSA, Kos, 10 December 2024, available at: https://rsaegean.org/en/kos-2024/.

[18] RSA, Leros, 10 December 2024, available at: https://rsaegean.org/en/leros-2024/.

[19] Information obtained during Legal Aid Working Group meeting of 4 December 2024.

[20] RSA, Lesvos, 10 December 2024, available at: https://rsaegean.org/en/lesvos-2024/.

[21] RSA, Persisting severe reception deficiencies in understaffed camps, 5 September 2024, https://rsaegean.org/en/stats-reception-of-asylum-seekers-jun-24/

[22] GCR Submission to the Committee of Ministers of τhe Council οf Europe concerning the execution of the M.S.S. v. Greece Group of cases – April 2025 available  here pp 61 –

[23] RSA, Reception & refugee camps in Greece in the first half of 2025, available at: https://tinyurl.com/4932a2uz

[24] RSA, Reception & refugee camps in Greece in the first half of 2025, available at: https://tinyurl.com/4932a2uz

[25] 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.

[26] 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.

[27] See Article 67 (2) L. 4636/2019 and Article 2 (d) of the Ministerial Decision 1140/2.12.2019.

[28]  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.’

[29] Committee on the Elimination of Discrimination against Women, Concluding observations on the combined eighth and ninth periodic reports of Greece ​(29 January–16 February 2024), United Nations CEDAW/C/GRC/CO/8-9, available here.

[30]         Refugee Legal Support (RLS) & Mobile Info Team (MIT), Protection Unavailable: Dysfunctional Practices and Restrictions on the Right to Asylum, November 2023, available at: https://tinyurl.com/4zf673xu, p.22.

[31]         GCR, Submission to the Committee of Ministers of the Council of Europe concerning the groups of cases of M.S.S. v. Greece (Application No. 30696/09) and Rahimi v. Greece (8687/08), July 2023, p. 3, available at: https://bit.ly/4b3Q3JR.

[32]         Refugee Legal Support / Mobile Info Team, Protection Unavailable: Dysfunctional Practices and Restrictions on the Right to Asylum Assessing the implementation of reception and identification procedures on mainland Greece, November 2023, p. 32 et al., available at: https://tinyurl.com/yrsjp5xa.

[33]         Article 77(3) Asylum Code.

[34]         METAdrasi, Hope and Memory: Identification and certification of victims of torture, available at: https://bit.ly/3JQEFFP.

[35]         FENIX – Humanitarian Legal Aid, Unrecognised Vulnerability- Greece’s systematic failure to identify and certify Victims of Torture, pp. 6-7, available at: https://tinyurl.com/mwpxajcv.

[36]         Office of The National Rapporteur on Trafficking in Human Beings, web page, available at: https://bit.ly/3T60ZRw.

[37]         Information obtained during Legal Aid Working Group meeting of 4 December 2024

[38]         GCR Submission to the Committee of Ministers of τhe Council οf Europe concerning the execution of the M.S.S. v. Greece Group of cases – April 2025 available here

[39]         Joint Ministerial Decision 9889/2020, Gov. Gazette 3390/Β/13-8-2020.

[40]         See Article 1(3) JMD 9889/2020.

[41]         See Art 4 JMD 9889/2020.

[42]         See Article 1(5)(a) JMD 9889/2020.

[43]         See Article 1(5)(b) JMD 9889/2020.

[44]         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.

[45]         See Presidential Decision 77/2023 (Government Gazette A’ 130/ 27-06-2023), available in Greek at: https://bit.ly/4b7MkL8.

[46]         See Article 1(9) of JMD 9889/2020.

[47]         Article 1(11) of JMD 9889/2020.

[48]         Article 84(4) of the Asylum Code.

[49]         See also GCR, Without papers, there’s no life: Legal barriers in access to protection for unaccompanied children in Greece, July 2023, available at: https://tinyurl.com/y6fb7zh5 ,p. 7.

[50]         See, inter alia, World Medical Association, WMA Statement on Medical Age Assessment of Unaccompanied Minor Asylum Seekers, October 2019, available here.

[51]         For more information, see GCR’s Press Release, Children, even alleged ones, are not to be detained. A recent decision of the Administrative Court of Athens safeguards the rights of children and persons under age assessment procedure in Greece”, 2 May 2024, available here.

[52]         UNCRC Concluding Observations on Greece (2022), § 39(c) and 40(c) cited by GCR/AIRE Submission to the Committee of Ministers of The Council of Europe concerning the execution of the O.R. v Greece etc. Judgments of the Court  – November 2025 available here.

[53]       Save the Children & GCR, Children on the move in Greece , September – December 2025

https://tinyurl.com/yck3jkzy

[54]         GCR, the AIRE Centre, Submission to the Committee of Ministers of The Council of Europe concerning the execution of the O.R. v Greece etc. Judgments of the Court  – November 2025 available here.