On 27 September 2023, after many years, the launch of a complaints mechanism operating under the responsibility of the fundamental rights officer (FRO) of the MoMA was announced. 999 As per the relevant announcement and guidance published by the MoMA, the mechanism is accessible to any third-country national who considers they have been “directly affected by state actions or omissions and […] that one or more of his/her fundamental rights have been violated due to those actions or omissions, during access to territory and/or reception and/or asylum procedures in Greece”. 1000 Complaints need to be submitted in writing and by name, and can either be filled online, in a relevant section established on the MoMA’s website, or sent by email or post to the MoMA’s FRO. Though in principle a positive development, the requirement for complainants to submit a complaint in writing, which can currently only be done either in Greek or English, 1001 and by name, seems to a priori hinder applicant’s potential for accessing this mechanism on their own, either on account of language barriers or due to potential fear of disclosing their name in a document that may attribute fundamental rights violations to actions or omissions of the Greek administration while their asylum applications are still pending. Therefore, the effectiveness of this mechanism remains to be seen. As far as GCR is aware, during 2025 and up to September, the complaints mechanism under the MoMA FRO received a total of 84 new complaints, 75% of which (total of 63) were deemed inadmissible on account of lacking essential formal elements or not meeting the admissibility requirements, particularly related to the FRO’s mandate. The remainder (21) were referred to services of the Ministry or the National Transparency Authority (NTA) or were pending at the end of September. The majority of admissible complaints concerned substandard and/or lack of special reception conditions, including the prolonged de facto detention of a minor applicant pending registration of their asylum claim. 1002 A total of 58 doctors were deployed throughout the RIS camps, compared to 54 at the end of 2024. Doctors and other medical staff profiles are deployed in camps under the EU-funded “Hippocrates” programme. This number corresponds to one doctor per 390 people, given the total number of 22,622 residents. The rate of doctors to residents is significantly lower in the largest RIS camps that hosted over 1,000 people. At least five camps had no doctor at all at the end of 2025. This includes Leros, Filippiada, Veria, Kyllini and Pyrgos. 168 interpreters were deployed in RIS camps at the end of 2025, exclusively through emergency provision of staff by the European Union Agency for Asylum (EUAA) 1003 2.1. Conditions in RICs and temporary accommodation facilities on the mainland Living conditions in the mainland camps vary depending on the facilities, as different types of accommodation and services are offered at each site. Therefore, although camps are never suitable for long-term accommodation, compliance with the standards of the recast Reception Conditions Directive should be assessed against the situation prevailing in each camp. Nevertheless, living conditions continued to be cause for concern throughout 2025, characterised by critical gaps in essential provisions and services, such as interpretation, and isolation. An August 2025 parliamentary response by the Ministry of Migration and Asylum, referring to data up to 30 June 2025, revealed that out of 12,863 camp residents, 11,959 were active asylum seekers entitled to reception conditions. None, however, were receiving the monthly financial allowance foreseen in the context of material reception provisions following the programme’s complete halt in March 2025,1004 resulting in most asylum seekers being unable to cover basic living expenses, including medicine and transportation. 1005 999 1000 1001 1002 1003 1004 1005 MoMA, Launch of the Complaints Mechanism, 27 September 2023, available in Greek at: https://tinyurl.com/8wyzzk2r. MoMA, Complaint Form, general guidance, available at: https://tinyurl.com/3nhnsumz, p.1. Ibid. Information received in the context of GCR’s participation in the Greek Monitoring Committee for Migration and Home Affair Funds. RSA, Asylum procedure and reception statistics in Greece in 2025, 26 March 2026 https://tinyurl.com/392ftj58 RSA, Reception & refugee camps in Greece in the first half of 2025, 11 September 2025, available at: https://tinyurl.com/yp6ar5fu. As per information inter alia received during the 9 July 2025 National Protection Working Group. 209

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