following objections before the Administrative Court of First Instance of Rhodes are accepted in the
CCAC, provided the decision accepting Objections is requesting the Administration to ensure their access
to RIS’ services.290
Actors present in the RIC and CCACI
In addition to civil society organisations, a number of official actors are present in the RIC facilities on the
islands, including RIS, Frontex, the Asylum Service, EUAA and the Hellenic Police.
Police: The Police is responsible for guarding the external area of the hotspot facilities, as well as for the
identification and verification of nationalities of newcomers. According to the IPA, the registration of the
applications for international protection, the notification of the decisions and other procedural documents,
as well as the registration of appeals may be carried out by police staff. 291 Moreover, in exceptional
circumstances, the interviews of the applicants under the “fast track border procedure” may be carried out
by police staff, provided that they have received the necessary basic training in the field of international
human rights law, the EU asylum acquis and interview techniques.292 However, during 2023 and 2024 all
the interviews, including those of the “fast track border procedure“, were exclusively conducted by EUAA
or Asylum Service staff. Finally, the decisions on applications for international protection are always taken
by the Asylum Service.
Frontex: Frontex staff also participates in the identification and verification of nationalities. Although
Frontex should have an assisting role, in practice, it conducts nationality screening almost exclusively, as
the Greek authorities lack relevant resources, such as interpreters. The conduct of these procedures by
Frontex is defined by an internal regulation. It should be noted that, even though the Greek authorities
may base their decision concerning the nationality of a newcomer exclusively on an assessment by
Frontex, documents issued by the latter are considered to be ‘non-paper’ and thereby inaccessible to
individuals. Assessments by Frontex are thus extremely difficult to challenge in practice.
UNHCR/IOM: provide information to newly arrived persons.
Asylum Service: According to IPA, the Asylum Service is present in the hotspots. Specifically:
‘(a) third-country national or stateless person wishing to seek international protection, shall be
referred to the competent Regional Asylum Office, a Task Force of which may operate in the RIC;
(b) both the receipt of applications and the interviews of applicants may take place within the
premises of the RIC, in a place where confidentiality is ensured’. 293
EUAA (previously EASO): EUAA also participates in the asylum procedure. EUAA experts have a rather
active role within the scope of the Fast-Track Border Procedure, as its officers conduct first instance
personal interviews, and they issue opinions regarding asylum applications. Following a legislative reform
in 2018, Greek-speaking EASO (now EUAA) personnel can also conduct any administrative action for
processing asylum applications, including in the Regular Procedure.294 Following a mission conducted in
Greece in 2019, ECRE published a report in November 2019 which provides a detailed overview on the
role of EASO in Greece.295
RIS: The RIS previously outsourced medical and psychosocial care provision to NGOs until mid-2017.
Since then, the provision of said services have been undertaken by the Ministry of Health, throughout
different entities under its supervision. At the end of 2019, the National Organisation for Public Health
(Εθνικός Οργανισμός Δημόσιας Υγείας, ΕΟΔΥ, also EODY), a private entity supervised and funded
directly by the Ministry of Health and Social Solidarity, 296 was the competent body for the provision of
medical and psychosocial services in CCACs. EODY had serious shortcomings in staffing and medical
supplies, resulting in poor provision of services, including vulnerability assessment procedures. As of 8
June 2024, EODY was replaced by ‘Ippocratis I’ project run by IOM. 297 Since then, the project has initiated
a recruiting process, however shortages in medical staff and supplies (i.e., no doctor in Samos, Leros,
290
291
292
293
294
295
296
297
Based on GCR observations on the field.
Article 90(2) IPA.
Article 90(3), b IPA.
Article 39(6) IPA
Article 65(16) and 90(3) b IPA. See also ECRE, The Role of EASO Operations in National Asylum Systems,
November 2019, available at: https://bit.ly/3cSt5rs.
ECRE, The Role of EASO Operations in national asylum systems, November 2019, available at:
https://bit.ly/3cSt5rs.
Established by L 4633/2019.
IOM, IPPOKRATIS I - Provision of medical and psychosocial services to residents of the accommodation
facilities under the responsibility of the Reception and Identification Service, available here.
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