Following the conclusion of the Reception and Identification Procedures, newly arrived persons were released and the vast majority were referred by the RIS to open reception facilities in the mainland, with the exception of UAMs who remained in the RIC, pending their placement and transfer to a shelter for minors. During 2024, depending on the capacity of the second line reception facilities, 308 and ensuing delays in official transfers of applicants from the Fylakio RIC to other facilities in the mainland, according to GCR observation, in certain cases registered applicants who had initially expressed their wish to be referred to such facilities as part of their right to reception conditions, have been given the option to be released and leave the RIC on their own. However, in order to do so, applicants are first required to sign a solemn declaration, stating an address, as well as their willingness to no longer be included in official transfers to other facilities on the mainland, and for their right to reception conditions to be waived. Accordingly, this practice, aimed at decongesting the Fylakio RIC, needs to be checked, at least, with respect to the extent to which applicants are effectively informed of the consequences of singing this form, particularly given the link between residence in the Greek reception system and access to a set of provisions, both under material reception conditions (receipt of financial aid), and in the context of limited support to integration (enrolment to Helios) for those that may end up being granted international protection in Greece. By the end of December 2024, 343 UAMs (308 boys and 35 girls) were registered by the RIS in Evros.309 During 2025, 322 unaccompanied minors were registered ( 310 boys and 12 girls). 310 During 2023, the waiting period for the placement of UAMs in a ‘restriction of liberty status’ (namely in protective custody or in the RIC) to shelters for minors remained short. According to official data available, the average waiting time for the placement was 8.8 days.311 Transfers from the RIC in Fylakio to shelters for minors were conducted with delays of up to 2-3 weeks. By exception, according to GCR observations, certain transfers were carried out after a period that exceeded one month. 3. Registration of the asylum application Indicators: Registration 1. Are specific time limits laid down in law for making an application? ❖ If so, what is the time limit for making an application? 2. Are specific time limits laid down in law for lodging an application? ❖ If so, what is the time limit for lodging an application? Yes No Yes No 3. Are making and lodging an application distinct stages in the law or in practice? Yes No 4. Is the authority with which the application is lodged also the authority responsible for its examination? Yes No It depends. RIS personnel may also fully register asylum applications. 5. Can an application for international protection for international protection be lodged at embassies, consulates or other external representations? Yes No 3.1. Rules for the registration and lodging of applications Article 69 of the Asylum Code transposes Article 6 of the recast Asylum Procedures Directive on access to the procedure. 308 309 310 311 GCR, Reception of asylum seekers in Greece: the demand for humane conditions remains, 9 November 2023, https://tinyurl.com/5d789w58. As per the latest available data (time of writing) published at the MoMA’s website, under Statistics. See also Reception and Identification Service, 2024, nine months of 2024, registrations of TCNs/stateless persons per location of registration, available in Greek here. Ibid Data received from the General Secretariat for Vulnerable Persons & Institutional Protection of the MoMA, on 7 January 2025. 74

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