(b) Accommodation centres, which can operate in properly customised public or private buildings, under the management of public or private non-profit entities or international organisations and guarantee a suitable standard of living; (c) Private houses, flats and hotels, rented in the context of accommodation programmes implemented by public or private non-profit entities or international organisations. In all cases, the provision of accommodation is under the supervision of the competent reception authority, in collaboration, where applicable, with other competent state bodies. The law provides that the specific situation of vulnerable persons, such as minors (accompanied and unaccompanied), people with disabilities, elderly people, single-parent households and pregnant women, should be taken into account in the provision of reception conditions.935 In practice, following the termination of the ESTIA accommodation programme in December 2022, 936 camp-based accommodation has become the only available accommodation provided under the Greek reception system. As of the end of 2025, facilities used for this purpose included 24 Controlled Temporary Accommodation camps, the RICs of Fylakio, Malakasa and Diavata on the mainland, and the Closed Control Access Centres (CCACs) operating –under EU funding– on the Eastern Aegean islands, where asylum applicants have continued being contained in prison-like conditions.937 The “detention-like nature” of island facilities was also noted by the EU Ombudsperson in the context of an own-initiative inquiry regarding the use of EU funds in the CCACs.938 To be noted, this new camp-based model of reception, which inter alia fosters conditions of social isolation for applicants, stands in stark contrast to the model promoted by the former ESTIA accommodation programme, the positive impact of which had been noted by local communities as well. 939 It also challenges Greece’s ability to comply with obligations arising vis-à-vis vulnerable applicants with special reception needs.940 In what concerns provision of material reception conditions in the form of financial aid, under the ESTIA II-CBI programme, the beneficiaries of such aid are: 941 ❖ Adult asylum applicants who have submitted or fully lodged an asylum application in accordance with Article 65 (1)(2) & (7) L. 4636/2019, as long as they reside in the centres and facilities provided under para. 4 Article 8 L. 4375/2016, in accommodation programmes of the MoMA, in shelters and hospitality centres operated by international organisations and legal entities governed by public law, local authorities, as well as civil society actors that are registered in the Registry of Greek and foreign NGOs of the MoMA. Applicants in detention are not entitled to the cash-based support. ❖ Beneficiaries of international protection who upon turning 18 reside in accommodation centres for UAM or in temporary accommodation spaces for UAM, for a period of three months following their placement to the aforementioned accommodation spaces. 935 936 937 938 939 940 941 Article 62(1) Asylum Code in connection with Article 1λγ΄ Asylum Code regarding the definition of ‘vulnerable persons’ in a non-exhaustive manner. For more, AIDA, Country Report Greece: 2022 Update, June 2023, available at: https://bit.ly/4cc0a07, p. 147ff. Greek Council for Refugees / OXFAM / Save the Children International, Greece: A two-tier refugee system, Bi-monthly bulletin, May 2022, available at: https://bit.ly/3OJOetv. EU Ombudsperson, Decision in strategic inquiry OI/3/2022/MHZ on how the European Commission ensures respect for fundamental rights in EU-funded migration management facilities in Greece, 11 July 2022, available at: https://tinyurl.com/yckyjef3. For instance, as noted in January 2023 by the President of the Developmental Agency (Anaptyxiaki) of Irakleio, Crete, and Mayor of Archanes Asterousia, Crete, ‘[t]he framework, the rules and the whole organisation of the hospitality [under ESTIA] was exemplary and gave no room to the xenophobia that was initially expressed’. Ekriti, Crete: An end to the hospitality program for refugees, 2 January 2023, available in Greek at: https://bit.ly/3IEwj4h. For the closure of ESTIA, see among others: RSA, A Step backwards for protection and integration: On the termination of the ESTIA II housing programme for asylum applicants, 22 December 2022, available at: https://bit.ly/43vr3Y5; GCR, Press Release, Εξώσεις, αστεγία και πισωγύρισμα στην ένταξη, 30 November 2022, available in Greek at: https://bit.ly/3oBev2B; FENIX, Closure of ESTIA II: thousands of extremely vulnerable asylum seekers to be left without humane and adequate accommodation and proper care, 31 October 2022, available at: https://bit.ly/43nPgzO. Article 1(d) Ministerial Decision 115202/2021, op.cit. 198