application for international protection was lodged (Article 7 par. 2 Dublin III Regulation) and that the humanitarian grounds of Article 17 (2) do not apply. They also sometimes argue that further consideration of such cases would undermine the meaning of the Regulation, which is to ‘prevent secondary movement’. However, in two cases dealt with in 2022, Germany accepted a “humanitarian clause” request for the reunification of parents with their two daughters in Germany, one of whom had arrived there after having submitted an asylum application in Greece,433 as well the reunification of two brothers in a case of a subsequent separation.434 In contrast, Belgium rejected a request based on Article 17(2) of the Regulation regarding a family with a minor son, on the basis that the mother’s departure from Greece after the family’s application had been submitted was not in the best interests of her child.435 GCR is not aware of similar cases in 2023. It is also difficult to establish a family relationship in cases of marriages by proxy, as they may not be recognised by the receiving State’s domestic law. GCR is aware of at least one such case of family reunification that was rejected by the German Authorities, because the applicant’s spouse was already present in the requested Member State’s territory when the marriage ceremony took place. Unaccompanied children On 22 July 2022, L 4960/2022 on the National Guardianship System and Framework of Accommodation of UAMs entered into force,436 replacing former law L4554/2018 on guardianship, which was never implemented in practice. New provisions on guardianship and accommodation were inserted in the third part of the Asylum Code regarding Reception. Under the new legislative provisions general competency was transferred from the National Centre for Social Solidarity of the Ministry of Labour and Social Affairs to the Special Secretary for the Protection of Unaccompanied Minors (SSPUAM) now General Secretariat for Vulnerable Persons and Institutional Protection. Under the new law, the provision of guardianship is relegated to a list of legal entities appointed by the Public Prosecutor (i.e., public entities, NGOs, international organizations) who collaborate with persons acting as guardians. The Public Prosecutor can also appoint a child’s family member or friend to be responsible for their everyday care. At the end of October 2023, the NGOs METAdrasi and Praksis were announced by the Ministry of Migration and Asylum as the finalist candidates entrusted with the implementation of the National Guardianship scheme, following a public procurement procedure. The project officially begun on 1st November 2023 and, according to its design, the first two months consisted of preparatory actions (trainings, prioritization of cases, etc.) while, at the time of writing, guardians are deployed and started work. (See D Guarantees for vulnerable groups 4. Legal representation of unaccompanied children) The number of applications for family reunification of unaccompanied minors before the Asylum Service in 2023 is not available. In August 2018, the Greek Dublin Unit introduced the Best Interests Assessment (BIA) Form to support unaccompanied minors claims under Dublin Regulation 604/2013. The BIA Form aims to gather and assess all necessary information required by Member States to assess the family reunification requests of unaccompanied minors and is an indispensable element of take-charge requests. UNHCR, UNICEF 433 434 435 436 Information provided by RSA. Information provided by European Expression. Information provided by RSA. L 4960/2022 National Guardianship System and Framework of Accommodation of UAMs and other provisions under the jurisdiction of the MoMA. 91