and whether the date of entry has been recorded in any document other than said decisions of the Director.33 Furthermore, concerns arise around the legality of the process for the period prior to the establishment of Malakasa and Diavata as RIC. We recall that the uniform registration procedure on the mainland started on 1 September 2022, when the camps were still “reception facilities”. Only in mid-November 2022 were they relaunched as RIC where a “restriction of liberty” may be imposed under the Asylum Code. Accordingly, the Ombudsman has also requested clarifications from the RIS “on the status of stay and legal basis of restrictions of liberty for the period prior to the issuance of the aforementioned decisions by the Director and prior to the establishment of the RIC.”34 Vulnerability assessments Screening of new arrivals for vulnerability based on the indicative categories set out in Article 1(zg) of the Asylum Code is a core stage of the reception and identification procedure, conducted by the Medical Check and Psychosocial Support Unit for vulnerability.35 Prompt identification of vulnerability is a prerequisite for the provision not only of special reception conditions – as incorrectly stated in Article 41(d) of the Asylum Code – but also of special procedural guarantees needed for an adequate examination of the asylum application by the Asylum Service.36 In a sign of positive practice at the RIC of Malakasa, upon completion of reception and identification procedure and of the lodging of the asylum claim, the applicant’s classification in a vulnerability category is explicitly noted in the initial version of their Foreigner’s Health Card, signed by a National Public Health Organisation (Εθνικός Οργανισμός Δημόσιας Υγείας, EODY) doctor.37 Vulnerability categories are marked by a special code e.g. “2A” for persons with serious illnesses, “6A” for single-parent families, “10A” for victims of torture or violence, “C” for non-vulnerable persons. Lodging of asylum applications The lodging of asylum applications at the RIC of Malakasa and Diavata is carried out by the RIS based on form “ΥΠΥ.01 Additional personal data registration form”. The same form is used in the RIC of Fylakio at the Evros land border and in the Closed Controlled Access Centres (CCAC) of Lesvos, Chios, Samos, Leros and Kos. 38 Observations from certain cases supported by RSA even in 2023 indicate that lodging in the RIC of Malakasa is done by staff deployed by the European Union Agency for 33 34 35 36 37 38 Ombudsman, ‘Επιβολή περιορισμού ελευθερίας στο Κέντρο Υποδοχής και Ταυτοποίησης Μαλακάσας’, 327045/328337/67645, 12 December 2022. Ibid. Article 41(d) Asylum Code; Articles 12(2) and 16 JMD 1/7433/2019, Gov. Gazette B’ 2219/10.06.2019. See further RSA, Ειδικές διαδικαστικές εγγυήσεις στη διαδικασία ασύλου: Παρατηρήσεις επί της νομολογίας, June 2022, available at: https://bit.ly/3HixkNc. On different practice on the islands, RSA et al., The state of the border procedure on the Greek islands, September 2022, 15-16, available: https://bit.ly/3PC2Nhb. Ibid, 12-13. 11 RSA REPORT │ 2023