typical example of deficient registration is the fact that even though the number of new arrivals in Greece in 2015 was nearly elevenfold that of 2014, there was no corresponding increase in the number of requests for accommodation of unaccompanied minors, a fact that highlights the problems in identification and registration during 2015.39 Similar was the reaction of the Greek Ombudsman stressing the need to take measures due to the restriction or the total prohibition of the crossing at the Eidomeni area.40 The independent authority has noted since then the need for State coordination of the de facto refugee camp in Eidomeni, and for a contingency plan for dealing with possible restrictions in border crossing. The findings and recommendations of the independent authority were the outcome of a visit of a joint team of the Ombudsmen from Greece and FYROM on 17.11.2015 to the temporary refugee camps on the borders of the two neighbouring countries, in Eidomeni and in Vinojug, with the purpose of ascertaining the living conditions and the protection of the fundamental rights of the refugees. The Ombudsman had at the time also highlighted the State’s obligation to ensure their fundamental rights, and noted the need for special consideration for the protection of populations on the move, from smugglers, human trafficking rings or from existing phenomena of financial exploitation. In early 2016, to support the legislative endeavour for the better organisation of first reception procedures, the Greek Ombudsman submitted comments in the context of the consultation for Law 4375/2016 with regard to the Reception and Identification Service (RIS). Inter alia, the Greek Ombudsman had noted the need for a special provision for vulnerable groups.41 After the creation of the hotspots on 5 critical islands as Reception and Identification Centers42 according to Law 4375/2016 (Lesvos, Chios, Samos, Kos, Leros) and the EU-Turkey Statement of 18 March 2016, the identification 39 Introductory note of Service for the management of Accommodation Applications of Asylum Seekers and Unaccompanied Minors of the National Center of Social Solidarity (EKKA) http://www.ekka.org.gr/portal_docs/forceaccount/ picture/25_1072.pdf of vulnerable persons remains an issue of vital importance during the reception procedures within 25 days at the hotspots, however the universal implementation of first reception procedures remains the object to be reached. During an on-site inspection carried out on 26-27.7.2016 at the Samos hotspot, it was found that not all new arrivals undergo a medical check, as required by law. What actually takes place, is the registration of any vulnerability on the identification file (identification of person and citizenship) of the new arrivals, during their first interview by the Hellenic Police with the help of FRONTEX at the identification division of the hotspot during the initial three-day detention period. Despite the fact that this is an indicative registration (the Greek Ombudsman has asked that the indicative character should be mentioned on the Hellenic Police file), it was found that the medical and psychosocial required procedures upon first reception are not followed in practice for all new arrivals, in order to identify further vulnerable cases that might have been missed by the police’s registration, such as e.g. human trafficking victims. If other first reception procedures do not follow, the statistical data for vulnerable persons are based on the police’s registration at the hotspot identification division. The transport of asylum seekers from the islands to the mainland is allowed only after the asylum registration process has been completed, or in cases of particularly vulnerable individuals. The transportation delay is in part due to the slow pace of the asylum registration or identification of vulnerable persons, and in the past, the lack of any appropriate facilities on the mainland. Among other things, this delay has led to serious overcrowding of the facilities on the islands, which were created for far smaller numbers, and an increase of risks in the field of protection.43 In July 2015, at the very onset of the so-called refugee crisis, the Greek Ombudsman stressed the need to create FRCs on the islands, as required by law, and to screen all new arrivals in order to correctly identify any vulnerability they may have.44 However, even after the establishment of the hotspots with Law 4375/2016, the reinforcement of first reception ser- 2.3. Conclusions 40 Press Release in November 2015 (http://www.synigoros.gr/ resources/151119-dt.pdf) 41 See comments of the Greek Ombudsman on the special care required for families with toddlers or infants in the document dated 26 February 2016 (https://www.synigoros.gr/resources/paratiriseis_gia_sxedio_nomou_ tropop_3907_2011.pdf). 42 Hereinafter, hotspots. 43 See Press Release of the United Nations High Commissioner for Refugees of 5.1.2017. 44 Press release on 27.7.2015 “The Greek Ombudsman is requesting immediate measures for the reception of migrants and refugees on the Aegean Islands” http://www.synigoros.gr/?i=humanrights.el.danews.296571 23