identification and referral of victims of Human Trafficking as soon as possible 685 in accordance with Articles 76 and 79 L. 4781/2021”. Challenges continued being identified in 2024 as well. According to UNHCR, RIC Malakasa maintained a very limited number of appointments on the platform, while RIC Diavata had less limitations. Yet in the case of Diavata, in GCR’s experience, the online platform would remain open for 15-16 appointments per day, following which it went down quickly again. SolidarityNow noted that the platform of RIC Malakasa opened on 2 December 2024 in the morning and closed again at the end of the same day. ELIL noted that Farsi speakers have managed to get appointments for Malakasa, while Arabic and Pashto speakers have not succeeded. In one case due to the platform being down, Equal Rights Beyond Borders wrote to the two RICs and RIC Diavata requested the person to come for registration. 686 The same issues remain during 2025. According to GCR, despite the Greek Government’s assurances in its 2025 Action Plan (para 13) that the platform is operational without interruption, complaints regarding the non-smooth operation of the online platform of the MoMA persist to date, including reports of complete inability to access the online platform, resulting in the ongoing risk of arbitrary arrest and detention of asylum seekers awaiting registration, and their non-access to reception conditions. The platform is often non-accessible or does not grant an appointment date for the registration of the request for international protection at the Malakasa and Diavata RICs. Failure to register an application for international protection means deprivation of the protection linked with the asylum seeker’s status (i.e. right to remain on the territory, enjoyment of reception conditions). Most recently, on 7 April 2025, the Greek Ombudsman, in its written intervention addressed to the Asylum Service, following a GCR complaint for the arrest and detention of an Afghan national, who was unable to access the platform, re-raised the issue of the impossibility of accessing the online platform of the Ministry. In that case, the applicant was arrested outside Malakasa, where he went to submit in person an asylum application due to the lack of access to the online platform, and he was consequently detained on the basis of a return decision. Moreover, and even in the event that an applicant has scheduled an appointment to Malakasa and Diavata RICs, while awaiting the day of the full registration of his/her asylum application, they are not protected from arrest and detention in view of deportation. 687 1.2. Age assessment of unaccompanied children by the RIS and in the asylum procedure Article 41 (f) Asylum Code refers to the Joint Ministerial Decision 9889/2020,688 which sets out a common age assessment procedure both in the context of reception and identification procedures and the asylum procedure. According to Article 1(2) JMD 9889/2020, in case of doubt as to the person’s age, i.e., when the authority’s initial assessment is not consistent with the person’s statements or storyline,689 the RIS or the Asylum Service or any authority/organisation competent for the protection of minors or the provision of healthcare or the Public Prosecutor should inform – at any point of the reception and identification procedures or the asylum procedure – the Manager of the RIC or the reception facility, where the individual resides, or the Head of RIS or the Asylum Service if the doubt arises for the first time during the personal interview for the examination of the asylum application, who, acting on a reasoned decision, is obliged to refer the individual for an age assessment procedure. The age assessment is, according to the law, conducted by the Medical and Psychosocial Support Unit of the Reception and Identification Centre or the Control Access Facilities Temporary Accommodation of Asylum Seekers (CAFTAAS) or the Mobile Reception and Identification Units or the nearest one to the 685 686 687 688 689 Office of The National Rapporteur on Trafficking in Human Beings, web page, available at: https://bit.ly/3T60ZRw. Information obtained during Legal Aid Working Group meeting of 4 December 2024 GCR Submission to the Committee of Ministers of τhe Council οf Europe concerning the execution of the M.S.S. v. Greece Group of cases - April 2025 available here Joint Ministerial Decision 9889/2020, Gov. Gazette 3390/Β/13-8-2020. See Article 1(3) JMD 9889/2020. 155