On 31 July 2023, the NTA published its annual report for 2022 which, as noted by the NTA, “provides objective and comprehensive information on all the activities of the Authority, which were carried out during 2022, as well as the actions included in its operational planning for the following year”. 106 In the Greek version of the report, the NTA notes that, in 2022, it received a total of 2,694 general complaints, 167 of which were forwarded to other audit services (mainly to the “AADE” and the Internal Affairs Service of the Security Services) due to lack of jurisdiction.107 This annual report does not mention any activity related to investigation on a complaint concerning pushbacks nor of any public service/authority against which allegations of being engaged in pushback operations has arisen in recent years. On 6 September 2024, the NTA published its annual report for year 2023.108 Apart from a reference to 8 audits carried out in Non-Governmental Organisations registered in the Registry of the Ministry of Immigration & Asylum, there is only one general reference that: ‘[…] NTA carried out audits and investigations on: […] - Residence permits – refoulements […]’. Furthermore, in the Greek version of the report, under the sub-title “Migration” it is only mentioned that a specialised control mechanism for migration flows has been developed in the context of which ‘the investigation and evaluation of 194 reports and publications concerning incidents that allegedly took place in the context of the management of migration flows and the country's borders by the competent institutions was completed. The inspection and investigation reports are confidential with a confidential annex attached and include personal data, which are protected by the provisions of national and EU data protection legislation. The above reports have been communicated to the relevant national and international judicial authorities, as appropriate’. No other information is provided e.g. as to the nature of the complaints, the status of the complainants and the denounced persons, or the status and/or outcome of the reported communications to the judicial authorities. The ECtHR’s judgement of 7 January 2025, in its A.R.E. v. Greece case,109 challenged the Government's claims that it does not carry out pushbacks and questioned the credibility of the NTA’s investigations. The Court explicitly notes that, on the contrary, reports from fully independent and credible authorities, such as the National Commission for Human Rights and the Ombudsperson, which provide credible and serious evidence that systematic pushbacks are taking place, must be taken into account in pushback complaints. On the same day, ruling on the G.R.J case which concerned pushback allegations from the island of Samos to Türkiye, the Court also concluded that there were strong indications to suggest that a systematic practice of “pushbacks” from the Greek islands to Türkiye had existed. The Court however could not find a violation of the Convention as it considered that the applicant had failed to provide prima facie evidence of his individual claim.110 It bears emphasising that the Court did not take into account any of the NTA’ findings, not only because the Greek government failed to address the applicant’s lawyers’ arguments to that end, but also because the Court considers that a complaint before the NTA is not considered as an effective remedy.111 In July 2022, a Fundamental Rights Officer (FRO) and a Special Committee on Fundamental Rights Compliance (Task Force for Fundamental Rights Compliance) was appointed within the Ministry of Migration and Asylum,112 and, in September 2023, the FRO activated an online complaint platform. 113 According to the platform’s instructions, the complaints must be submitted with a name and in writing by the victim-third country national, in Greek or English, and only about incidents that were not brought before judicial or prosecuting authorities. 106 107 108 109 110 111 112 113 NTA, 2022 Annual Report, 31 July 2023, available in Greek at: https://bit.ly/3TNGjMN, and English at: https://bit.ly/4amDMAl. Ibid., pp 43-44. NTA, 2023 Annual Report, 15 January 2025, available in English here and in Greek here. ECtHR, A.R.E. v. Greece (Application no. 15783/21), 7 January 2025, available in French here. ECtHR, G.R.J. v. Greece (Application no. 15067/21), available here. ECtHR, A.R.E. v. Greece (Application no. 15783/21), paras 200 and 228, 7 January 2025, available here. AIDA, Country report: Greece, 2023 Update, p. 37, June 2024 available here. The complaint form is available at: https://bit.ly/3VLxbL8. 44