INTRODUCTION To assist the Committee of Ministers supervision of the implementation of the M.S.S. v. Belgium and Greece and Rahimi v. Greece cases, we present evidence on access to asylum procedures and legal assistance, living conditions of asylum seekers, safeguards for vulnerable individuals, and the conditions of detention facilities. Our evidence is obtained through our work providing legal aid to asylum seekers, refugees and migrants in Greece. 1. ASYLUM PROCEDURES a) Length of asylum procedures The authorities remain systemically noncompliant with deadlines in Greek law for the registration of 8 both first instance and subsequent asylum applications. Statistics published by the Government show that at the end of December 2023 there were over 32,000 pending asylum applications at both first and second instance.9 As a consequence of waiting for registration, applicants are undocumented and 10 unable to access their legal right to full material reception conditions and healthcare. _________(1) Samos As noted in our previous Rule 9.2 submission, vulnerability assessments in the asylum procedure are 11 inadequate on Samos. For over two years, the Closed Controlled Access Center (CCAC) has not had 12 a permanent state doctor to undertake vulnerability assessments. Instead, vulnerability assessments 13 are reliant on an ad hoc volunteer doctor and a single psychologist. For example, in 2023, I Have Rights (IHR) analysed the client data of 53 survivors of trafficking between March 2022 and June 2023 and determined that only 13% were identified during vulnerability assessments.14 _________ (2) Mainland Delays in processing asylum claims are routine due to several factors. In 2024, interruptions to 15 interpretation services have exacerbated existing delays in the processing of asylum claims. During times of high arrivals the authorities have struggled to conduct timely registrations in the mainland Reception and Identification Centres (RICs), particularly Malakasa: an analysis of data collected _________________________________ 8. Article 69(1-2), Article 88, Greek Law 4939/2022 (Gov Gazette A 111/10.06.2022). 9. Hellenic Republic Ministry of Migration and Asylum (HRMoMA). 2024. Reply to the Greek Parliament. Available at: https://www.hellenicparliament.gr/UserFiles/67715b2c-ec81-4f0c-ad6a-476a34d732bd/12507130.pdf. 10. Access to services is permitted after the registration of their application, according to Articles 1(c), 59(1), and 73(1), Greek Law 4939/2022; Articles 2(c) and 9(1), 2013/32/EU; Articles 2(b) and 17(1), 2013/33/EU of the European Parliament and of the Council of 26 June 2013 laying down standards for the reception of applicants for international protection (recast). Available at: https://eurlex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32013L0033. 11. Article 21, Directive 2013/33/EU. 12. Article 41(d), Article 77 International Protection Act, Greek Law 4939/2022. 13. International Rescue Committee and I Have Rights. 2023. Contribution to the European Ombudsman’s strategic inquiry into how the European Commission ensures respect for fundamental rights in EU-funded migration management facilities in Greece. Available at: https://ihaverights.eu/wp-content/uploads/2023/02/EU-Ombudsman_Submission_IRC_IHR_Jan-2023_final.pdf; I Have Rights. 2023. I Have Rights’ Second Communication to the UN Special Rapporteur on Trafficking in Persons regarding Greece’s Failures towards Survivors of Trafficking accommodated in the Closed Controlled Access Center of Samos, Greece. Available at: https://ihaverights.eu/wp-content/uploads/2024/05/Trafficking-Letter.docx.pdf. 14. I Have Rights. 2023. Unidentified, unrecognised and denied support Survivors of human trafficking in the Samos Closed Controlled Access Centre. Available at: https://ihaverights.eu/wp-content/uploads/2023/09/Unidentified-unrecognised-and-denied-supportsurvivors-of-human-trafficking-in-the-Samos-Closed-Controlled-Access-Centre.pdf. 15. Mobile Info Team, Equal Legal Aid, Refugee Legal Support, Avocats Sans Frontières, I Have Rights, and Legal Centre Lesvos. 2024. Lack of interpretation services lengthens existing delays to access asylum and leaves people without protection. Available at: https://www.mobileinfoteam.org/statement-lack-interpretation. 02