persons or persons in need of special reception conditions if appropriate support may not be provided within the area of restriction,676 without sufficiently describing what such appropriate support entails. 677 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. 678 676 677 678 See Article 67 (2) L. 4636/2019 and Article 2 (d) of the Ministerial Decision 1140/2.12.2019. According to Article 67 (2) L. 4636/2019, ‘[w]here applicants have been identified as applicants in need of special procedural guarantees, they shall be provided with adequate support in order to allow them to benefit from the rights and comply with the obligations of this Part throughout the duration of the procedure. Forms of adequate support shall, in particular, consist of additional break times during the personal interview in accordance with Article 77, allowing the applicant to move during the personal interview if this is necessary because of his or her health condition, as well as showing leniency to non-major inaccuracies and contradictions, where these are related to his/her health condition.’ 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. 152