Author
The law provides that, when applying the provisions on reception conditions, the competent authorities shall take into account the specific situation of vulnerable persons such as minors, unaccompanied or not, direct relatives of victims of shipwrecks (parents and siblings), disabled people, elderly people, pregnant women, single parents with minor children, persons with serious illnesses, persons with a cognitive or mental disability and persons who have been subjected to torture, rape or other serious forms of psychological, physical or sexual violence, victims of female genital mutilation and victims of human trafficking.[1]
Since the entry into force of the IPA on 1 January 2020 and subsequent law 4939/2022 which replaced Articles 1-112 and 114 of the IPA, the assessment of the vulnerability of persons entering irregularly into the territory takes place within the framework of the Reception and Identification Procedure and is no longer connected to the assessment of the asylum application.[2] Under the reception and identification procedure, upon arrival, the Head of the RIC or of the Closed Control Centre shall refer persons belonging to vulnerable groups to the competent social support and protection institution.’[3]
However, shortcomings in the identification of vulnerabilities (see Identification), together with a critical lack of suitable reception places for vulnerable applicants on the islands (see Types of Accommodation) prevents vulnerable persons from enjoying special reception conditions. A report published by MSF highlights alarming levels of mental health problems among asylum applicants on the Greek islands, including self-harming and suicidal acts among children. According to MSF, the indefinite detention, sense of limbo and systematic violence further traumatised people seeking protection[4]. Also, according to an MSF announcement on the provision of health care on Lesvos island, there are still significant gaps in asylum applicants ‘s access to health services due to delays in the registration process, with the example of “a patient with a chronic heart problem and a history of heart attack, who lost his medication during the trip, (and who) was not registered at the camp for about 4 weeks and did not have access to the necessary support […]””.[5]
Moreover, in a recent joint statement of twenty civil society organisations on the living conditions and vulnerability assessment in Samos CCAC: “Any person who resides in the CCAC and especially those who are de facto detained, have insufficient and inconsistent access to medical care. Additionally, due to the absence of healthcare and individual vulnerability assessments, asylum applicants with communicable diseases risk remain undetected or unable to seek medical treatment for several weeks after arrival which causes a serious risk of contagion”.[6]
Testimonies of asylum applicants accommodated in Samos CCAC – gathered in a report of NGO I Have Rights highlight the inhuman living conditions in the structure:[7]
‘Our container is not locked, it is not safe. I don’t feel safe in this environment. They can always enter the containers when they want. no privacy. Of course it’s bad, especially we ladies need privacy. of course it stresses you, but there is nowhere you can go and complain.’[8]
‘Sometimes I use some sleeping tablets. MSF [Médecins Sans Frontières] gave them to me and I use them, but otherwise I cannot sleep because of the camp stress. If there was no MSF in the camp for us, some people would die there. Because the camp doctor makes no effort. You tell them you are feeling bad, they simply tell you to go out. The workers in the camp are very, very wicked. Sometimes I feel like harming myself because of the stress of being in the camp.’[9]
The ESTIA scheme on Samos, which had offered safe apartments to vulnerable applicants in the past, including victims of sexual and gender-based violence, was discontinued. Due to a lack of alternative accommodation, even sexually abused persons stayed in tents in a separate section of Vathy camp, where the alleged perpetrators also stayed. On Lesvos, following the closure of the Kara Tepe site, a model facility offering dignified accommodation in prefabricated containers, vulnerable persons were transferred to tents in Mavrovouni camp. Owing to the reduced numbers of alternatives to camps on both islands, there are significant difficulties in finding dignified accommodation even for persons with serious health issues, as reported by MSF.[10] In Chios CCAC (Vial camp), no separate accommodation is foreseen for vulnerable persons, and rub halls with single room and no beds (only mattresses on the floor) are used for the accommodation of monoparental families, together with single men and nuclear families.[11]
In its judgement in the case of A.D. v. Greece (Application no. 55363/19), published on 4 April 2023, the ECtHR “for the first time condemned the living conditions of a pregnant woman in Samos hotspot as unanimously found that Greece had violated Article 3 of the ECHR by forcing the applicant to live in unbearable conditions”.[12] The case was supported by Refugee Law Clinic Berlin (Germany), I Have Rights (Samos) and PRO ASYL.
Reception of unaccompanied children
Following the establishment of the Special Secretary for the Protection of Unaccompanied Minors (SSPUM) under the MoMA in February 2020,[13] the SSPUM has become the competent authority for the protection of UAM, including for their accommodation. In June 2023, the SSPUM was abolished and its responsibilities (under Article 39 of P.D. 106/2020) were transferred to the new General Secretariat for Vulnerable Persons and Institutional Protection (GSVPIP) established with Article 6(1) of P.D. 77/2023 (A’ 130/ 27.6.2023) and falling under the competency of the Deputy Minister of Migration and Asylum.[14] The newly established General Secretariat is also competent for the National Referral Mechanism, according to Article 66ΛΓ of L. 4939/2022 added with Article 39 of L. 4960/2022.
As of 1 January 2025, there were at least 2,408 unaccompanied and separated children in Greece and a total of 1,775 dedicated accommodation places in shelters and Semi-Independent Living (SILs) facilities, plus 155 places in urgent accommodation facilities.[15] The latter are located in a total of 4 Emergency Accommodation Structures operating under the responsibility of the International Organisation of Migration (IOM), all of them located in the mainland (3 in Attika region and 1 in Central Macedonia).[16] From the abovementioned estimated population, 1,434 unaccompanied children were residing in Shelters, 215 in Semi Independent Living facilities (SILs) and 129 in urgent accommodation facilities. At the same time, there were a total of 448 unaccompanied minors residing in Reception and Identification Centers and Closed Controlled Access Centers of islands, while other 182 unaccompanied minors were Controlled Accommodation Facilities for Asylum Seekers, having not accept yet the proper reception treatment.
The National Emergency Response Mechanism (NERM), initially designed by the Special Secretariat for the Protection of Unaccompanied Minors (now the General Secretariat for Vulnerable Citizens and Institutional Protection) and the UNHCR in 2020, was implemented in Greece in 2021 and institutionalised in 2022. Its primary goal is to identify and provide immediate housing in emergency accommodation structures for unaccompanied minors (UAMs) living in homelessness or precarious conditions.
NERM is dedicated to the protection and integration of unaccompanied minors in Greece and has recently expanded its services to vulnerable adults. The goal of NERM is to identify promptly children in immediate need of protection and shelter, transfer them to appropriate accommodation and provide them with the necessary services.
NERM is supported by UNHCR (expert support), EUAA, IOM and the European Commission Its operation on the ground is carried out through NGOs Arsis, METAdrasi and the Network for Children’s Rights.[17] The Mechanism also includes a 24/7 telephone hotline for identifying and tracing children in need, which is available in six languages. The hotline provides guidance to children, citizens, local and public authorities on steps and actions to be taken from the point of identification of an unaccompanied child until their timey inclusion in emergency accommodation.[18]
The total number of referrals of unaccompanied children received by the SGVP in 2025 was reported at 4,440, while the number of those resolved, either through placement in a dedicated shelter or cancelation after verification stood at 4,846.[19] At the same time, the number of accommodation in spaces, specifically designated for unaccompanied minors remained stable, reaching a total of 1,900 places by the end 2025.[20] Of those, almost 91.8% (1,745) were long-term accommodation (including SILs), while the rest (155) were temporary/emergency accommodation under the relevant mechanism established by the MoMA in April 2021.[21]
Nevertheless, challenges remained regarding the proper identification of UAM upon arrival, and consequently, cases where UAM have been accommodated alongside the adult population continued to be observed in 2024, at least on the islands, currently [22] For the situation of UAMs see also the chapter on Guarantees for Vulnerable Groups.
The lack of appropriate care, including accommodation for unaccompanied children, in Greece has been repeatedly raised by human rights bodies.[23]
Moreover, in the case of T.K. v. Greece (Application no. 16112/20) of 18 January 2024 represented by Refugee Law Clinic Berlin (Germany) and supported by I Have Rights (Samos), the ECtHR held that there has been a violation of Articles 3 and 8 of the ECHR in the case of an unaccompanied child on Samos, whose wrong registration as an adult and the failure to correct his age violated his right to respect for private and family life (Article 8 ECHR). Moreover, according to the Court, the living conditions of the applicant amounted to inhumane and degrading treatment, in violation of Article 3 of the ECHR.[24]
On 3 October 2024, the ECtHR convicted Greece for violation of Articles 3 (prohibition of inhuman and degrading treatment) , 5(1) (right to liberty and security) and 5(4) (right to apply to a court) of the European Convention on Human Rights (ECHR), for the violations suffered in 2019 by two unaccompanied minor sisters from Afghanistan, who were found, despite their apparent vulnerability as minor girls, homeless and subsequently detained in an adult women’s cell under “protective custody” at the Pre-removal Detention Centre of Taurus.[25] The unaccompanied minors were represented before the ECtHR by the Legal Unit of the Greek Council for Refugees (GCR). In their application, the minors complained, inter alia, of inhuman and degrading living conditions, their confinement and their placement in ‘protective custody’ in a detention centre resulting in their de facto detention, and their inability to challenge this decision. The Court, inter alia, stressed that the Greek authorities had failed to take prompt action to accommodate them emphasising that the large number of pending applications for accommodation for unaccompanied minors does not relieve the authorities of their positive obligations to protect them. Furthermore, specifically with regard to the placement of minors in “protective custody”, the Court accepted the minors’ arguments that this constituted an unlawful deprivation of their liberty and that there was no legal remedy available to the applicants to challenge the decision being an oral order of Prosecutorial Authorities. The Court further found a violation of Article 3 of the ECHR regarding the conditions to which the minors were exposed during their confinement at the Tavros Pre-removal detention centre.
Types of accommodation for unaccompanied children
During 2024 the accommodation capacity in total was 1,930 out of which 1,775 places in Accommodation Facilities (Accommodation Centers/SIL apartments) and 155 places in Emergency Accommodation Facilities.[26]
According to the data published by the General Secretariat for Vulnerable Persons & Institutional Protection regarding the period 1 January to 1 December 2024, the total number of placement’s requests of UAMs that NERM received was 2005 while the Secretariat received a total of 5,716. During the same period Secreteriat processed 5,333 referrals which resulted in placement or a cancel of the referral. According to the same information 151 minors were placed in emergency accommodation facilities, 209 in SIL Apartments, 1372 in long term accommodation places, 176 in controlled accommodation facilities for asylum seekers and 506 in R.I.C/ C.C.A.C, a total of 2414. Of them, 89% were boys and 11% girls. 15% were below the age of 15 years old. Regarding nationality, 45% were from Egypt, 16% Somalia, 16% Syria, 10% Afghanistan, 3% Pakistan and a 9% other various nationalities.[27]
Regarding 2025, according to the data published by the General Secretariat for Vulnerable Persons & Institutional Protection regarding the period 1 January to 1 December 2025, the total number of placement’s requests of UAMs that NERM received was 1,354 while the Secretariat received a total of 4,440. During the same period the Secreteriat processed 4,846 referrals which resulted in placement or a cancel of the referral. According to the same information 87 minors were placed in emergency accommodation facilities, 205 in SIL Apartments, 1,243 in long-term accommodation places, 38 in controlled accommodation facilities for asylum seekers and 143 in R.I.C/ C.C.A.C, a total of 1.716. Of them 92% were boys and 8% girls. 13.1% were below the age of 15 years old. Regarding nationality, 53% were from Egypt, 12% Afghanistan, 8% Somalia, 8% Syria, 6% Sudan, and a 13 % other various nationalities. [28]
During 2025 the accommodation capacity in total was 1,900 out of which 145 places in Accommodation Facilities (Accommodation Centers/SIL apartments) and 155 places in Emergency Accommodation Facilities.
Evidently there remains a large number of UAMs that have to remain in R.I.C, CCAC and in other unsuitable sheltering arrangements, with this trend expected to continue, following the MoMA’s reported plans to scale back the protection framework for UAM.
Namely, in a joint statement issued on 21 May 2026, twelve civil society organisations-members of the Child Rights Advocacy Network (CRAN), expressed serious concern over the systematic defunding and operational rollbacks targeting the domestic protection infrastructure for unaccompanied and separated refugee children in Greece. The coalition detailed immediate structural threats to specialized reception networks, noting that the Ministry of Migration and Asylum is actively shutting down vital Emergency Accommodation Facilities, alongside the planned phased termination of Supervised Apartments for Semi-Independent Living (SILs). Furthermore, chronic state funding delays and the non-renewal of essential operational contracts have forced key implementing partners to suspend auxiliary child protection actions within the National Emergency Response Mechanism (Ε.Μ.Ε.Α.) in Athens. The signatory organisations argue that downscaling these networks flagrantly violates international obligations under the UN Convention on the Rights of the Child –specifically the best interests of the child (Article 3), non-discrimination (Article 2), and General Comment No. 6 regarding standard of living requirements– and they urge the Greek government to ensure immediate, unhindered funding, emphasising that child protection is a permanent state duty that cannot be treated as a temporary mechanism dependent on border arrival fluctuations.[29]
Shelters for unaccompanied children: long-term accommodation facilities for unaccompanied children (shelters) are managed primarily by civil society entities and charities.
Supported Independent Living (SIL): “Supported Independent Living for unaccompanied minors” is an alternative housing arrangement for unaccompanied children aged 16 to 18 launched in 2018. The programme includes housing and a series of services (education, health etc.) and aims to enable the smooth coming of age and integration to Greek society.[30]
Emergency Accommodation Facilities: Emergency accommodation facilities are temporary accommodation places, for unaccompanied children who are traced living homeless or in precarious living conditions, operating under the National Emergency Response Mechanism (NERM) and run by IOM. The Emergency Accommodation Facilities provide an immediate assessment of the best interest of UAMs and a comprehensive protection, including the provision of psychosocial, legal and medical support and the referral to long-term accommodation shelters[31].
[1] Article 62 (1) Asylum Code in combination with Article 1 i) and λγ) of the same law.
[2] Article 62 (2) Asylum Code, citing Article 41 of the same law.
[3] Article 40 Asylum Code.
[4] MSF, Constructing Crisis at Europe’s Borders: The EU plan to intensify its dangerous hotspot approach on Greek islands, June 2021, available at: https://bit.ly/3WfEpY5.
[5] MSF, Ελλάδα: Εν μέσω αυξημένων αφίξεων, οι Γιατροί Χωρίς Σύνορα καταγράφουν σημαντικά κενά στην πρόσβαση των αιτούντων άσυλο σε υπηρεσίες υγείας στη Λέσβο, 1 September 2023, available in Greek at: https://tinyurl.com/44hwvunn.
[6] Joint Statement of 20 civil society organisations, NOT AGAIN IN 2024 – Call for upholdinghuman rightsin the Samos Closed Controlled Access Centre, 31 January 2024, p. 1-4, available at: https://tinyurl.com/3dxhybnk; for more information regarding health and vulnerabilities witnessed on Samos and Lesvos arrivals see: MSF, In plain sight – The Human Cost of Migration Policies and Violent Practices at Greek Sea Borders, 2 November 2023, pp. 12-13, available at: https://tinyurl.com/m63dcr7d.
[7] I Have Rights, They are killing minds – Life in the Samos Closed Controlled Access Centre, 20 June 2023, available at: https://tinyurl.com/565hmbzb.
[8] Ibid., p. 5.
[9] Ibid., p. 10.
[10] MSF, Constructing Crisis at Europe’s Borders: The EU plan to intensify its dangerous hotspot approach on Greek islands, June 2021, available at: https://bit.ly/3tVzwFg; FRA, Migration: Key fundamental rights concerns – Bulletin 2 – 2021, September 2021, available at: https://bit.ly/3LopAcY.
[11] Information shared by Chios UNCHR Field Office during GCR mission (January 2024).
[12] I have Rights, Press Release, Young mother successfully sues the Greek Government for the treatment she suffered as a pregnant woman in the ‘hotspot’ on Samos, available at: https://bit.ly/3Wdfpkc; see also judgements of the ECtHR published on 23 November 2023 on cases M.L. v. Greece (Application no 8386/20) and M.B. v. Greece (Application no 8389/20) where the Court found again a violation of Article 3 of the ECHR on account of the conditions in the Samos hotspot, which amounted to inhumane and degrading treatment. These cases were also supported by Refugee Law Clinic Berlin (Germany), I Have Rights (Samos) and PRO ASYL Foundation: I Have Rights, Press Release, The European Court of Human Rights again condemns the living conditions of asylum seekers on Samos, 11 January 2024, available at: https://tinyurl.com/s8ce44mk.
[13] Article 1(3) P.D.18/2020, Gov. Gazette 34/Α/19-2-2020.
[14] MoMA, General Secretariat for Vulnerable Persons & Institutional Protection, available at:
[15] MoMA / General Secretariat for Vulnerable Persons & Institutional Protection, Situation Update: Unaccompanied Children (UAC) in Greece, 1 January 2025, p. 1, available in Greek at: https://tinyurl.com/2s3nmkvh
[16] Ibid., p. 2.
[17] Interreg Europe, National Emergency Response Mechanism (NERM) in Greece, 16 November 2023, available at: https://tinyurl.com/2ryp53cs; see also, European Crime Prevention Network (EUCPN), National Emergency Response Mechanism¸available at: https://tinyurl.com/mvv8ntvp.
[18] See European Commission: Greece: National Emergency Response Mechanism | European Website on Integration,available at: https://tinyurl.com/bd8aa8ys, see also, UNHCR, Greece launches national tracing and protection mechanism for unaccompanied children in precarious conditions, 6 April 2021, available at: https://bit.ly/3uBRICI.
[19] SG for Vulnerable Persons & Institutional Protection, Status updated: Unaccompanied Minors (UM) in Greece, 1 December 2025, available in Greek at: https://tinyurl.com/mus9dfbz.
[20] Ibid.
[21] Data provided by the General Secretariat for Vulnerable Persons & Institutional Protection on 1 January 2025.
[22] GCR & Oxfam, Lesbos Bulletin: Update on Lesbos and the Aegean Islands, by the Greek Council for Refugees & Oxfam, March 2022, available at: https://bit.ly/3YEXp0H, p. 5.
[23] Indicatively see: UNHCR, Lone children face insecurity on the Greek islands, 14 October 2019, available at: https://bit.ly/36XQ6pf. In 2019, in the context of his visit to the Lesvos, the UN High Commissioner for Refugees stated he was ‘very worried about children, especially children travelling alone…[who] are the most exposed to violence and exploitation”, while Human Rights Watch inter alia noted that “the lack of prompt transfers [from the islands] put vulnerable people, including people with invisible disabilities and children, at higher risk of abuse and violation of their rights”, UN Committee on the Rights of the Child, Concluding observations on the combined fourth to sixth reports of Greece, 28 June 2022, available at: https://bit.ly/3xTHfYR, and UN Human Rights Office, Council of Europe, New complaint registered concerning Greece, 21 December 2018, available at: https://bit.ly/2SG0FpF European Committee of Social Rights, Decision on admissibility and on immediate measures in the case International Commission of Jurists (ICJ) and European Council for Refugees and Exiles (ECRE) v. Greece, Complaint No. 173/2018, 23 May 2019, available at: https://bit.ly/39clrGj.,
[24] I Have Rights, European Court of Human Rights Condemns Greece’s Treatment of an Unaccompanied Child on Samos, 18 January 2024, available at: https://bit.ly/44dJNNg.
[25] ECtHR case of T.S. and M.S. v. Greece, judgement of 3 October 2024, application no 15008/19.
[26] General Secretariat for Vulnerable Persons & Institutional Protection, Situation Update: Unaccompanied Minors (UAM) in Greece January 2024 – December 2024 https://tinyurl.com/2jsz7b3e
[27] Ibid
[28] General Secretariat for Vulnerable Persons & Institutional Protection, Situation Update: Unaccompanied Minors (UAM) in Greece January 2025 – December 2025 https://tinyurl.com/39tb9kh3
[29] CRAN, Joint Statement by the Child Rights Advocacy Network, 21 May 2026, available in Greek at: https://tinyurl.com/ms92bd23.
[30] Metadrasi, Supported Independent Living for unaccompanied minors, available at: https://bit.ly/2tPEljv.
[31] MoMA / 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 at: https://tinyurl.com/2msh79hc.