After the age assessment procedure is completed, the individual should be informed in a language he or she understands about the content of the age assessment decision, against which he or she has the right to appeal in accordance with the Code of Administrative Procedure. The appeal has to be submitted to the authority that issued the contested decision within 15 days from the notification of the decision on age assessment.639 In practice, the 15-day period may pose an insurmountable obstacle to receiving identification documents proving their age, as in many cases, persons under an age assessment procedure remain restricted in the RIC/CCACs. These appeals are in practice examined by the Central RIS. The number of appeals submitted against age assessment decisions in 2023 is not available, as at the time of writing the Greek authorities had not provided GCR with this information it requested. During regular parliamentary scrutiny procedures, though, the deputy minister for Migration and Asylum replied to the member of parliament who asked the relevant question that between 28/04/2021 and 29/03/2023 a total of 1,024 decisions were issued following an appeal against an initial age assessment decision.640 According to the findings of the Greek Ombudsman, following inspection visits in CCACs, RICs and CAFTAAS during the last semester of 2022 until December 2023, there is a number of problems, obstacles and malfunctions in the implementation of the age assessment process. Indicatively, according to the report, in Samos CCAC, it was found that the psychosocial assessment was not carried out at all due to the lack of training of the psychosocial team of the Unit and this stage was being skipped (contrary to the provision of the relevant JMD mentioned above), while the lack of a doctor in the facility of Samos had affected the age assessment, as well, before a doctor was sent from Leros to cover the gap.641 GCR’s findings in Lesvos indicate that in a great number of cases, the age assessment procedure is carried out by two doctors,642 with the one referring to the other in case of a doubt regarding the person’s minority, a practice not prescribed in law. Also, in Lesvos CCAC inadequate implementation of the domestic legislation has been observed,643 as lengthy delays in the age assessment procedures, unlawful use of X-rays, non-acceptance of identification documents, lack of specialised personnel and lack of information regarding the procedure, methods and potential consequences of the age assessment are all forming pieces of a puzzle that a child has to understand alone, given the lack of guardians for UASCs during the reporting period. In Kos, according to GCR’s field experience, the lack of sufficient medical personnel is reflected on this procedure as well. Persons who claim to be minors, contrary to the relevant JMD, have their age firstly assessed by psychosocial personnel (stage 2) and if the outcome is not conclusive, then any doctor working at the public hospital can offer his/her assessment regarding the age of the person (stage 1), as long as s/he is willing to participate in this procedure. In mainland RICs of Diavata and Malakasa, the Medical Control and Psychosocial Support Unit (NPHO or EODY as is mostly used) is conducting the age assessment procedures, although the lack of a paediatrician at the Malakasa RIC, as well as the more general lack of medical staff or EODY Units in some facilities may affect or cause delays in the age assessment process.644 As mentioned above, in practice, the age assessment of unaccompanied children is an extremely challenging process as the procedure is not followed in a significant number of cases, inter alia, due to the lack of qualified staff. In this regard, it must be noted that GCR provided legal aid for three cases of 639 640 641 642 643 644 See Art. 1(9) JMD 9889/2020. Response rot.no 472645, 20 October 2023, available in Greek at: https://tinyurl.com/yc4tut2x , p.4 Greek Ombudsman, The Challenge of Migratory Flows and Refugee Protection Reception Conditions and Procedures, April 2024, available in English and Greek at: https://tinyurl.com/546kmb76, see in particular pp. 150-152 One doctor being a general practitioner and the other a urologist. Fenix Humanitarian Legal Aid, Age Assessment Procedures on Lesvos: a Dead Letter, January 2024, available at: https://tinyurl.com/5ek48wfu. Greek Ombudsman, The Challenge of Migratory Flows and Refugee Protection Reception Conditions and Procedures, April 2024, available in English and Greek at: https://tinyurl.com/546kmb76, p. 151. 139