❖ Detention of vulnerable asylum seekers: NGOs witnessed several cases of vulnerable persons in detention whose vulnerability had not been taken into account. 385 unaccompanied migrant children were detained in PRDCs throughout 2024. 9 This does not include unaccompanied children detained as adults, including during age assessment procedures in spite of the presumption of minority. Moreover, particularly during the second half of 2024, a significant number of UAMs remained in de facto detention in Malakasa RIC on the mainland and in CCACs on the islands for significant prolonged periods exceeding one, two or three months, awaiting their placement in a shelter for UAMs, raising strong concerns all-around, including by the Greek Ombudsperson. ❖ Insufficient information provision and legal advice: lack of information provision remained a structural and longstanding issue in Greece’s immigration detention, highlighted by the European Committee for the Prevention of Torture in its 2024 report on Greece. The Committee also highlighted concerns regarding access to legal aid. Free legal assistance for detained asylum seekers provided by NGOs, who have limited resources, cannot sufficiently address the existing needs. No free legal aid is provided in order for a detainee to challenge their detention decision before Courts, contrary to national and EU law. ❖ Lack of effective appeal mechanism: the ex officio judicial scrutiny mechanism suffers from many structural deficiencies and cannot be considered effective. During the first semester of 2024, out of the total number of 3,017 decisions of the administrative courts issued within the framework of the ex officio judicial review, only 0.43% rejected the prolongation of detention. The ‘objection against detention’ procedure is also marred by a lack of legal security and predictability. In an October 2024 judgement, the ECtHR again found a violation of Article 5(4) ECHR due to the lack of effective examination of detention by the domestic court following the “objections against detention” submitted by the applicant. Content of international protection ❖ Delay in renewal of residence permits: as in previous years, BIPs continued to face delays in the processing of their applications to renew their residence permits. In GCR’s experience, in 2024, renewal decisions were issued 3 to 6 months after the application was filed, which is nevertheless an improvement compared to previous years, where delays reached over 1 year. Pending the renewal decision and depending on its timing compared to the expiration of the current residence permit, beneficiaries have no access to the labour market, to social security, social welfare and sometimes healthcare for several months, thus facing increased risks of destitution and homelessness. The attestation of application status is generally not accepted by other Greek public authorities. ❖ Council of State: In 2024, an application for annulment of the revocation of refugee status for reasons of national security based solely on a confidential document was introduced before the Council of State under the pilot procedure and is still pending. 9 In the context of their right of reply, submitted on 10 September 2025, the Greek General Secretariat for Vulnerable Persons and Institutional Protection contested this figure, arguing it does not concur with the statistics extracted from the database of the National Emergency Response Mechanism (NERM), according to which the NERM has received a total of 195 unaccompanied minors’ referrals from PRDCs in 2024. This number includes unaccompanied minors who were initially detained as adults and were subsequently registered as minors, following an age assessment. Further, the Greek General Secretariat for Vulnerable Persons and Institutional Protection noted that following the abolition of the measure of protective custody by law in 2020, and since the establishment of NERM in 2021, unaccompanied minors are traced by the police and are not detained and are referred to NERM for emergency accommodation. Moreover, the Police Headquarters regularly inform NERM for the presence of unaccompanied minors in PRDCs or police departments and NERM follows-up the cases for placement in emergency accommodation. However, the authors of this report maintain the figure provided in the report unchanged, based on the reply provided on 16 January 2025 to them by the Headquarters of the Hellenic Police, through which it can clearly be interpreted that during 2024 a total of 385 unaccompanied minors have been detained in PRDCs, of which only one remained in a PRDC at year’s end. 24