According to Article 80 (3) of the Asylum Code regarding applications of UAMs: ‘In case of doubt, the
competent Receiving Authorities shall refer the unaccompanied minor to the age assessment procedures
as per the provisions in force. In cases the above-mentioned referral is considered necessary and until
the completion of the procedure, special attention should be paid to the particular characteristics of the
minor, especially those related to their gender or cultural peculiarities’ (see below).
Since the end of 2019, the authority competent for carrying out medical checks has been the National
Public Health Organisation (EODY), which was established by L 4633/2019 as the successor of
KEELPNO.
Based on data published by the MoMA in the first months of 2024, the number of those registered as
vulnerable by the RIS at the borders and in mainland RICs throughout 2023, based on the category of
vulnerability, stands as follows:598
Vulnerability category
Number of persons
Disabilities
246
UAMs
2,364
Pregnancy
519
Victims of Human Trafficking
114
Victims of Abuse
2,115
Single families (total number of persons)
2,569
Elderly (>65 years)
177
Total
8,104
During the same period (2023), EUAA staff identified 7,940 persons as presenting vulnerability indicators,
in the context of vulnerability assessments carried out in reception facilities, as part of the support provided
by the Agency to Greece’s first and second-line reception system,599 but the extent to which these
numbers overlap is not possible to assess.
The number of persons identified as vulnerable after conclusion of the reception and identification
procedures and the number of persons identified as vulnerable after re-examination were not provided by
the competent Ministry. Moreover, no information was provided regarding the competent authority to cover
the expenses in cases where transfer to another island was necessary for the vulnerability assessment.
The low quality of the process of medical and psychosocial screening, if any, has remained a source of
serious concern also in 2023. As stated in AIDA report for 2022,600 vulnerabilities are often missed, with
individuals going through the asylum procedure without having their vulnerability assessment completed
first. Equal Rights Beyond Borders, HIAS Greece and RSA have reported that “[s]evere delays persist
when it comes to conducting vulnerability assessments even after the reception and identification
procedure formally ends: The time delay ranges from ten days to longer than three months in some cases.
Yet, the Asylum Service and EUAA continue to process asylum claims before individuals have undergone
a vulnerability assessment, and routinely disregard or deny special procedural guarantees afforded by
EU law, even where they are specifically requested by the applicants in writing and/or orally prior to the
interview. They instead insist on completing the interview under the border procedure. The medical cards
issued to people undergoing reception and identification procedure do not clearly indicate whether and
when a vulnerability assessment was conducted”. 601 The organisations further report that, “[o]n the one
598
599
600
601
MoMA, Secretary General for the reception of Asylum Seekers / Reception and Identification Service /
Directorate of RICs & CCACs, Registrations 12 months 2023, available in Greek at:
https://tinyurl.com/ytfkhkfu, p.7 and Registrations 12 months mainland 2023, available at:
https://tinyurl.com/48jc9u7x, p.5.
Information provided by the EUAA, 26 February 2024.
ECRE, AIDA, Country Report: Greece, 2022 Update, June 2023, available at: https://bit.ly/3PUOVk9.
Equal Rights Beyond Borders, HIAS Greece & Refugee Support Aegean, Τhe state of the border procedure
on the greek islands, September 2022, available at: https://bit.ly/40VTZrM, p. 4.
130
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