Author
Under Greek law, any authority detecting the entry of an unaccompanied or separated child into the Greek territory shall take the appropriate measures to inform the closest Public Prosecutor’s office and the General Secretariat for Vulnerable Persons and Institutional Protection.[1]
On 22 July 2022, L 4960/2022 on the National Guardianship System and Framework of Accommodation of UAMs[2] entered into force, replacing former law L 4554/2018 on guardianship, which was never implemented in practice. New provisions on guardianship and accommodation were inserted in the third part of the Asylum Code regarding Reception (provisions on guardianship were incorporated in Chapter C / Part 3 in Articles 66A-66ΚΔ and provisions on accommodation in Chapter D / Part 3 in Articles 66ΚΕ–66ΛΔ). Under the new legislative provisions on guardianship, general competency was transferred from the National Centre for Social Solidarity of the Ministry of Labour and Social Affairs to the Special Secretary for the Protection of Unaccompanied Minors (SSPUAM) now General Secretariat for Vulnerable Persons and Institutional Protection (GSVPIP).
Under the new law, the provision of guardianship is delegated to a list of legal entities appointed by the Public Prosecutor (i.e., public entities, NGOs, international organisations) who employ persons acting as guardianship-mandated persons (henceforth referred to as “mandated guardians”). The Public Prosecutor can also appoint a child’s family member or friend to be responsible for their everyday care.
In late October 2023, METAdrasi and Praksis NGOs were identified by MoMA as the two entities entrusted with the execution of the National Guardianship scheme, following a public procurement process.[3] The project commenced officially on 1 November 2023, and as per its blueprint, the initial two months were dedicated to preparatory measures, such as trainings and prioritisation of cases. Subsequently, the first mandated guardians were deployed on the ground at the beginning of 2024, after obligatory trainings were concluded.
The total number of mandated guardians for UASC throughout the country on 22 January 2025 stood at 128,[4] significantly below the expected minimum number of 170[5] (with a project that provisioned a maximum of 180 mandated guardians). This team is responsible for addressing the needs of the 2,414 UASC registered in Greece as of December 2024.[6] With an average allocation of 15 children per professional, they can potentially cover up to 2,550 children.
At the time of writing, UAMs’ presence in Safe Areas or Zones inside RICs, both on the mainland and the islands, is much higher than the number of those registered (and thus recorded in the cited statistics), and exceeds the actual capacity of these arrangements (e.g., in Samos Safe Area, in January 2025, there were more than 500 children for a space that can accommodate 200 children).[7] In parallel, UASC are staying in such Areas for significantly longer periods of time compared to those foreseen by law (max. 25 days, while in practice, some UASC have stayed for more than three months). This concerning situation also surpasses the existing capacity of mandated guardians, creating a protection gap for children on the move, as flagged by NGOs in Greece.[8]
Although circulars have been issued to clarify the guardianship’s legal framework,[9] challenges identified in practice primarily stem from the novelty of the scheme and the emergence of mandated guardians as a new professional profile with roles and responsibilities previously associated with other field professionals (e.g. lawyers or social workers). Consequently, discrepancies have been observed concerning the level of involvement of guardians, lawyers, social workers and educators, some of which have affected UACS’ asylum procedure, such as Dublin II procedures and appeals, as lawyers and other professionals now require authorisations from the mandated guardian to support or follow up on a case.
With Joint Ministerial Decision no 539638/20.12.2023 of the Minister of Economy and the Minister of Migration and Asylum, a Mechanism for the submission and management of complaints of UAMs in the context of guardianship was set up,[10] as foreseen by Article 66KB Asylum Code. The coordinator of mandated guardians, which is appointed by each of the two NGOs that has undertaken the provision of guardianship services, is designated by law as the person responsible for the procedure of submission, examination and resolution of complaints of minors and is expected to cooperate with the Child Protection Policy Manager of the guardian, who is responsible for the general supervision of the complaints mechanism. In particular, the coordinator shall ensure: (a) Receiving the complaint, the immediate filing of the complaint, the weekly updating of the Institutional Protection Unit on all complaints submitted, and the keeping of a record of the complaints received, (b) investigating and collecting data on complaints, (c) the resolution of complaints, (d) regularly updating the minor and the authorities involved on the conduct of the procedure, (e) the inclusion of a report on the complaints in the reports referred to in paragraph (e). (2 of Article 66KA of the Act). 4939/2022. If the child’s complaint concerns the coordinator, the Child Protection Policy Officer is then responsible for the management of the complaint in question.[11] The Law also sets up the Board of Guardianship for Unaccompanied Minors within GSVPIP, consisting of five of its officials, which decides on complaints submitted by unaccompanied minors and brought before it, following a referral from the Institutional Protection Unit.
The establishment of a national guardianship system by Law 4960/2022, launched in January 2024, has been a welcome development, as previous legislation on the matter had never entered into force.
Since 2024 and up to the end of 2025,[12] a number of structural shortcomings, including the capacity of the system exist. A number of issues have already arisen, first and foremost, delays in appointment of Guardians and/or lack of Guardians in particular for newly arrived unaccompanied children and especially in the mainland[13]. Covering all unaccompanied children and appointing guardians in a timely manner are the main challenges identified in the assessment of the guardianship system by the main actors of the scheme.[14] As reported, as of January 2025, 120 guardians have been appointed by the Public Prosecutors,[15] 65 a non-sufficient number to cover the need of unaccompanied children present in the country. Also, instability persists due to resignations of appointed Guardians, coupled with delays in the timely disbursement of salaries for both Guardianship Officers and Coordinators by the competent Guardianship Service Providers have been identified as challenges within the system[16].
Additional gaps in the application of the provisions have been noted and criticized since the institution does not work yet in a unified manner for all children located in Greece.[17] According to Save and Children and GCR, despite the establishment of a national guardianship scheme, critical gaps persist, leaving many UASC without legal representation and support. As of early 2025, there are only 128 mandated guardians nationwide, falling short of the target of 170 (or up to 180 if needed)— a figure still far below what is required to meet actual needs. The guardianship programme is hampered by severe bureaucratic delays (e.g. in the Public Prosecutors’ offices) and structural weaknesses. Fluctuations in arrivals strain an already overstretched system, while high turnover rates and excessive caseloads undermine effective support. In some cases, children in CCACs/RICs are not being assigned a mandated guardian, delaying access to critical legal support and essential services such as healthcare, psychosocial support, clothing, and other basic needs[18].
The number of applications for international protection lodged by unaccompanied minors during 2025 was 3052 (of which 37 are subsequent applications) – a decrease in comparison to 2024 that reach 4136 (out of which 39 were subsequent applicants). In 2025, only 449 unaccompanied children received positive decisions [19] in striking contrast with the recognition rate of 2024, which was 1025.[20]
As some decisions spill over from previous years and the number of negative decisions is not publicly available, nor was this number shared by the Greek authorities despite GCR’s request, one cannot estimate the actual scale of children left with no protection status.
Since April 2021, the Ministry of Migration and Asylum and UNHCR, in collaboration with IOM and the NGOs Arsis, METAdrasi and the Network for Children’s Rights, launched a mechanism to rapidly identify unaccompanied children who are homeless or live in insecure conditions and transfer them to safe accommodation. The National Emergency Response Mechanism (NERM), which in accordance with L. 4939/2022,[21] is part of the General Secretariat for Vulnerable Persons and Institutional Protection, and includes a telephone hotline available Monday to Friday from 08:00 to 22:00 and Saturday from 11:00 to 19:00 (multiple languages available) for identifying and tracing children in need,[22] and Info Desks / Mobile Units in Athens and Thessaloniki, together with emergency accommodation facilities. It is, therefore, considered an integral part of UASCs protection in Greece.[23]
According to GCR’s observations, the new mechanism is very responsive to requests addressed both by NGOs and by UAMs themselves. According to the General Secretariat for Vulnerable Persons and Institutional Protection since the beginning of NERMs operation in 2021 until 31 August 2024, the NERM received 9,121 referrals of homeless unaccompanied children (UAC) and those in precarious living conditions from local authorities, citizens, and the children themselves. From its operationalisation until the end of 2023, 4,437 children were placed in age-appropriate accommodation.[24] According to MoMA’s answer in Parliament,[25] the Secretariat plans to expand NERM’s competence beyond UASCs, offering also support to vulnerable persons who are homeless or at risk -an already long-awaited development given the lack of state social support services even for the local population.
According to the latest information published, by the General Secreteriat, since 2021 and until the end of December 2025, the Mechanism received 16,763 calls, which concern 11,598 different cases of (UAMs), out of which 8,979 concern accommodation requests, 1,159 legal aid, and 1,060 other types of assistance. Since 2 March 2022, the line has received referrals for 4 unaccompanied*[26],10 orphans (with escorts) directly from an orphanage of Ukraine and 591 separated minors from Ukraine.[27]
[1] Article 64(1) of the Asylum Code as amended by Article 4 L.4960/2022.
[2] L 4960/2022 National Guardianship System and Framework of Accommodation of UAMs and other provisions under the jurisdiction of the MoMA.
[3] For administrative and funding purposes, the two NGOs operate under a Private Agreement Partnership, with
METAdrasi taking the lead with a 70%-30% split of responsibilities.
[4] In the context of their right of reply, submitted on 10 September 2025, the Greek General Secretariat for Vulnerable Persons and Institutional Protection, clarified that, while this number is accurate January 2025, it should be noted that the average number of guardians for 2024 was 127, due to the gradual implementation of the guardianship project, which included recruitments in three stages (60 guardians by the end of the first month, 120 by the end of the first trimester, and 170 by the end of May 2024). Since May 2024, until August 2025, the average number of guardians was 142 (reaching at a point 168 guardians, in June 2024).
[5] Information shared by the competent GSVPIP during a meeting of the Legal Aid Working Group operating in Greece dedicated to guardianship.
[6] See Ministry of Migration and Asylum, Situation Update: Unaccompanied Minors (UAM) in Greece, reference date: 01 December 2024, available here.
[7] Information shared within Child Rights Advocacy Network (CRAN) members at the meeting of 16 January 2025.
[8] See, among others, Joint Press Release of 12 Child Rights Advocacy Network (CRAN) members titled Hundreds of unaccompanied children in Unsafe Zones: Need for an Immediate Activation of Relocation, 5 December 2024, available here.
[9] Mainly GSVPIP Circular 1/2024 available in Greek here, and a document providing guidelines to shelters and other facilities for UAMs, 20 June 2024, available upon request.
[10] Government Gazette B 7143/20.12.2023.
[11] See Article 7 of the 539638/20.12.2023 JMD.
[12] Comments of the GCR and the AIRE Centre before the Committee of Ministers of the Council of Europe regarding the execution of the ECtHR judgments O.R. v Greece et al. –November 2025, available here and here
[13] Greek National Commission on Human Rights, Note on the 7th National Report to the Council of Europe in the context of the Revised European Social Charter , Follow-up to Collective Complaint No. 173/2018 International Commission of Jurists (ICJ) and the European Council for Refugees and Exiles (ECRE) v. Greece, April 2025; ERBB, ‘Suspended and Secluded: The State of Unaccompanied and Separated Children in Greece’, 2025 Report, https://directus.equalrights.org/assets/1bd72379-f47e-4aaa-8638-a431751e0eaa.
[14] GSVPIP, EUAA, UNICEF, and the implementing partners METAdrasi and PRAKSIS, Report on the Guardianship System Evaluation, 2025, https://tinyurl.com/3ue4ryp5
[15] European Commission, Communication on the status of migration management in mainland Greece, COM(2025) 170, 4 April 2025, p. 9.
[16] GSVPIP, EUAA, UNICEF, and the implementing partners METAdrasi and PRAKSIS, Report on the Guardianship System Evaluation, 2025, https://data.unhcr.org/en/documents/details/118708
[17] GCR-Save the Children, Children on the move, January 2025 – April 2025. https://resourcecentre.savethechildren.net/pdf/2025-Save-GCR-Joint-Briefing_Q1_ENGLISH.pdf
[18] Ibid
[19] MoMA, Statistics: Consolidated Reports – Overview, December 2025 – International Protection | Appendix A, available at: https://migration.gov.gr/statistika/, Table 11e
[20] MoMA, Statistics: Consolidated Reports – Overview, December 2024 – International Protection | Appendix A, available at: https://migration.gov.gr/statistika/, Table 11e
[21] Article 66ΛΓ.
[22] Ministry of Migration and Asylum, Σε λειτουργία ο εθνικός μηχανισμός για τον εντοπισμό και την προστασία ασυνόδευτων παιδιών σε επισφαλείς συνθήκες, 6 April 2021, available in Greek here.
[23] Ministry of Migration and Asylum, Special Secretariat for the Protection of UAMs, National Emergency Response Mechanism. A safety net for unaccompanied children identified in precarious living conditions, November 2022, available here.
[24] See more at Greece: National Emergency Response Mechanism (see here) and project’s annual report of 2023 here.
[25] See relative answer of deputy Minister Mrs Voultepsi, March 2024, available in Greek here.
[26] According to the announcement there there are cases of unaccompanied minors whose status changes from unaccompanied to separated and later on to adulthood.
[27] General Secretariat for Vulnerable Persons & Institutional Protection Situation Update: Unaccompanied Minors (UAM) in Greece Reference Date: 01.01.2026 https://tinyurl.com/p8bevuys