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) 2024/1348.702 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,703 that the new JMD: i. ii. iii. 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; 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. 2. Special procedural guarantees Indicators: Special Procedural Guarantees 1. Are there special procedural arrangements/guarantees for vulnerable people? Yes For certain categories No ❖ If for certain categories, specify which: Article 1-λγ of the Asylum Code: “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.” 702 703 Save the Children & GCR, Children on the move in Greece , September - December 2025 https://tinyurl.com/yck3jkzy 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. 158