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,102 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.103 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.104 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,105 and, in September 2023, the FRO activated an online complaint platform. 106 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. On 10 January 2025, the FRO published its first report, 107 covering the period between September 2023 and December 2024. In the report, the FRO noted that from the start date of the Complaints Mechanism on 26.09.2023 until 31.12.2024, a total of one hundred nineteen (119) complaints had been submitted to the Mechanism. Of these, twenty-seven (27) were submitted between 26.09.2023 and 31.12.2023, while the remaining ninety-two (92) were submitted within the year 2024. Ten of these complaints (nine related to reception conditions and one related to international protection procedures) were forwarded or partly forwarded to the competent authorities (General Secretariat of Reception of Asylum seekers of the Ministry, NTA and Asylum Service) while nine others since 2023 appeared to be ending at a preliminary stage. The rest of the complaints were dismissed. The report does not mention how many complaints were specifically submitted concerning pushback allegations nor does it specify how many complaints were dismissed as inadmissible and what violation they alleged. The one complaint that was forwarded to the NTA merely refers to “unofficial detention”. Except from the numbers and statistics, the report does not present preliminary findings, nor details the number of cases in which the FRO requested additional information from the complainants or in which the latter were called for a hearing or even information on the measures taken by the FRO to ensure an effective investigation of the complaints. Approximately 90% of the complaints have been dismissed as inadmissible and not further forwarded (87% in 2023 and 93% in2024), as the online platform and the complainant form continues to be only in Greek and English. In 2023, the Greek National Commission for Human Rights (GNCHR) published a report on its Recording Mechanism of Informal Forced Returns, which had been launched in early 2022, 108 and to which ten civil 102 103 104 105 106 107 108 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. Ministry of Asylum and Migration, FRO report, Το Υπουργείο Μετανάστευσης και Ασύλου ενισχύει τη διαφάνεια και την προστασία των θεμελιωδών δικαιωμάτων, 10 January 2025, available in Greek here. GNCHR, Recording Mechanism of Informal Forced Returns, Interim Report, January 2023, available at: https://bit.ly/3IUTyH5. 42