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 2025,741 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 mainland742. 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.743 As reported, as of January 2025, 120 guardians have been appointed by the Public Prosecutors,744 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 745. 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. 746 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 needs747. 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 748 in striking contrast with the recognition rate of 2024, which was 1025.749 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. 741 742 743 744 745 746 747 748 749 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 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. GSVPIP, EUAA, UNICEF, and the implementing partners METAdrasi and PRAKSIS, Report on the Guardianship System Evaluation, 2025, https://tinyurl.com/3ue4ryp5 European Commission, Communication on the status of migration management in mainland Greece, COM(2025) 170, 4 April 2025, p. 9. 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 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 Ibid MoMA, Statistics: Consolidated Reports – Overview, December 2025 - International Protection | Appendix A, available at: https://migration.gov.gr/statistika/, Table 11e MoMA, Statistics: Consolidated Reports – Overview, December 2024 - International Protection | Appendix A, available at: https://migration.gov.gr/statistika/, Table 11e 166

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