of the “First Reception Area “for more than 16 days. Individuals are held in this area without access to
legal or other information, healthcare and without undergoing vulnerability assessments. The period that
the asylum seekers are held in the ‘waiting area’ is not included in the 25-day movement restriction
imposed after the RIS registration in Kos, Samos and Leros CCAC.
Actors present in the RIC
As well as civil society organisations, a number of official actors are present in the RIC facilities on the
islands, including RIS, Frontex, the Asylum Service, EUAA and the Hellenic Police.
Police: The Police is responsible for guarding the external area of the hotspot facilities, as well as for the
identification and verification of nationalities of newcomers. According to the IPA, the registration of the
applications of international protection, the notification of the decisions and other procedural documents,
as well as the registration of appeals, may be carried out by police staff. 168 Moreover, in exceptional
circumstances, the interviews of the applicants under the “fast track border procedure” may be carried out
by police staff, provided that they have received the necessary basic training in the field of international
human rights law, the EU asylum acquis and interview techniques.169 However, decisions on applications
for international protection are always taken by the Asylum Service.
Frontex: Frontex staff is also engaged in the identification and verification of nationalities. Although
Frontex should have an assisting role, in practice, it conducts nationality screening almost exclusively, as
the Greek authorities lack relevant resources such as interpreters. The conduct of said procedures by
Frontex is defined by an internal regulation. It should be noted that, even though the Greek authorities
may base their decision concerning the nationality of a newcomer exclusively on an assessment by
Frontex, documents issued by the latter are considered to be ‘non-paper’ and thereby inaccessible to
individuals. Assessments by Frontex are thus extremely difficult to challenge in practice.
UNHCR/IOM: provide information to newly arrived persons.
Asylum Service: According to IPA, the Asylum Service has a presence in the hotspots. Specifically:
‘(a) third-country national or stateless person wishing to seek international protection, shall be
referred to the competent Regional Asylum Office, Unit of which may operate in the RIC;
(b) both the receipt of applications and the interviews of applicants may take place within the
premises of the RIC, in a place where confidentiality is ensured’.170
EUAA (previously EASO): EUAA is also engaged in the asylum procedure. EUAA experts have a rather
active role within the scope of the Fast-Track Border Procedure, as they conduct first instance personal
interviews, and they issue opinions regarding asylum applications. Following a legislative reform in 2018,
Greek-speaking EASO (now EUAA) personnel can also conduct any administrative action for processing
asylum applications, including in the Regular Procedure.171 Following a mission conducted in Greece in
2019, ECRE published a report in November 2019 which provides a detailed overview on the role of
EASO in Greece.172
RIS: The RIS previously outsourced medical and psychosocial care provision to NGOs until mid-2017.
Since then, the provision of said services have been undertaken by the Ministry of Health, throughout
different entities under its supervision. At the end of 2019, the National Organisation for Public Health
(Εθνικός Οργανισμός Δημόσιας Υγείας, ΕΟΔΥ), a private entity supervised and funded directly by the
Ministry of Health and Social Solidarity, 173 was the competent body for the provision of medical and
168
169
170
171
172
173
Article 90(2) IPA.
Article 90(3), b IPA.
Article 39(6) IPA
Article 65(16) and 90(3) b IPA; ECRE Report, The Role of EASO Operations in National Asylum Systems,
November 2019, available at: https://bit.ly/39JFEDI.
ECRE, The Role of EASO Operations in national asylum systems, November 2019, available at:
https://bit.ly/3cSt5rs.
Established by L 4633/2019.
49
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