The remedy provided under Article 118(1) (formerly introduced by the amended Article 24 L 4540/2018 in December 2018) remains illusory, since an individual cannot lodge an appeal pursuant to the Code of Administrative Procedure in the absence of an individual, enforceable administrative act. In addition, no tailored legal aid scheme is provided for challenging such decisions (see Regular Procedure: Legal Assistance). A fortiori, no legal remedy to challenge said restriction is provided by the new Asylum Code that replaced the IPA. As has been the case since 2021, data on the number of persons who had their geographical restriction lifted during 2025 is not published by the MoMA, nor was it provided fllowing GCR’s request for information. Based on available data published by the MoMA on the number of asylum applicants transferred from the islands to the mainland throughout 2025,970 it could be inferred that the geographical restriction might have been lifted in the case of up to 15,270 applicants.971 However, the specific data lacks significant information, such as on the legal status or potential vulnerabilities of the people transferred (or any more specific breakdown whatsoever), thus making it impossible to draw any safe conclusions. Since 1 January 2020, the new regulatory framework for the geographical restriction on the islands has significantly limited the categories of applicants for whom the restriction can be lifted. Thus, the implementation of this framework can further increase the number of applicants stuck on the Greek islands and serves as a constant risk for bottlenecks that can deteriorate conditions there. This was vividly showcased in the latter half of 2023 and 2024, and yet again in 2025, when, due to sustained increased arrivals, led to a drastic deterioration in the quality of reception in the CCACs —with residents, including unaccompanied minors, frequently forced to sleep on floors and in communal areas.972 In sum, the practice of indiscriminate imposition of the geographical restriction since the launch of the EUTürkiye Statement has for years been a risk factor, intrinsically linked with the EU’s ongoing externalisation approach, that fosters and maintains conditions of possibility for the constant (re)emergence of overcrowded, substandard reception conditions on the Greek islands. B. Housing 1. Types of accommodation Indicators: Types of Accommodation 1. Number of reception centres in 2025: 30 2. Total number of places in the reception system in 2025: 40,884(nominal)/33,423 (actual) 973 3. Total number of places in private accommodation in 2025: 0974 970 971 972 973 974 4. Type of accommodation most frequently used in a regular procedure: Reception centre Hotel or hostel Emergency shelter Private housing Other 5. Type of accommodation most frequently used in an accelerated procedure: Reception centre Hotel or hostel Emergency shelter Private housing Other MoMA, Statistics: Consolidated Reports – Overview, December 2025 - International Protection | Appendix A, available at: https://migration.gov.gr/statistika/, Table 2. The number is based on reported transfers during 2025 from the 5 island CCACs. It does not take into consideration what is reported as transfers from “other islands” by the MoMA. Inter alia see Amnesty International et.al., Samos: Unlawful detention and sub-standard conditions must not become a blueprint for the EU Migration Pact, 25 February 2025, available at: https://tinyurl.com/2cccrnmd; Solomon, “Unaccompanied Children Sleep on the Floor in Shifts in Greece's 'Model Camps'”, 31 March 2025, available at: https://tinyurl.com/ytfrvhs7. RSA, Reception & refugee camps in Greece in the first half of 2025, 11 September 2025, available at: https://tinyurl.com/yp6ar5fu. Concerns the previous ESTIA accommodation programme that was terminated in December 2022. 204