As far as GCR is aware, also in 2023, Article 72(3) of the Asylum Code (exemption from the fast-track border procedure and referral to the regular procedure due to vulnerability) was not applied by the Asylum Service without a prior lifting of the geographical restriction. It was also noted that after the lifting of the geographical restriction for reasons not related to vulnerability, Article 72(3) of the Asylum Code was applied in several cases by the Asylum Service and the case was referred to the regular procedure without the person being identified as vulnerable. If the interview of first instance had already been conducted before the decision to lift the geographical restriction and the referral to the regular procedure due to vulnerability, it was not conducted again in accordance with the guarantees provided by Article 72(2) of the Asylum Code. For further information on the geographical restriction, see chapter on Reception Conditions – Freedom of Movement. Data for applications exempted from the fast-track border procedure and referred to the regular procedure on grounds of vulnerability was not provided by MoMa despite GCR’s request. Throughout 2023, the various RAOs in the different islands followed different practices as regards the conduct of asylum interviews (see the Regular procedure and Fast-track border procedure). 1.1.2 Vulnerability identification in the mainland In November 2021, the Greek authorities issued a circular establishing that asylum seekers (except for unaccompanied minors) who have not been through the reception and identification process can submit their asylum applications only in the Reception and Identification Centres (RIC) on the Aegean island hotspots of Samos, Chios, Lesvos, Leros and in the Evros region. However, strong opposition in the parliament prompted the government to clarify622 that applicants will not be transferred from the mainland to the islands, without however providing further information on the competent authorities for the registration of their applications. According to the authorities, the island reception facilities will exclusively process the cases of people arriving by sea. Furthermore, Skype is no longer used as a channel to access the asylum procedure for new applicants.623 Consequently, vulnerable persons in the mainland (with the exception of unaccompanied minors) who have not been subjected to the reception and identification procedures were not able to have access the asylum procedure via Skype. Moreover, even if a lawyer intervenes and requests the registration of the asylum application of a vulnerable person in the mainland, a medical document of vulnerability issued from a public entity is most of the times needed according to the competent Regional Asylum Offices. On 13 July 2022, the new Asylum Service launched a new registration platform, through which any appointment for lodging an asylum application in the mainland, even for vulnerable asylum seekers, needs to be booked. According to the Ministry’s announcement,624 the registration of applicants staying in Southern Greece was to take place in the facility of Malakasa (Athens), while the registration of applicants staying in Northern Greece would take place in the facility of Diavata (Thessaloniki). Appointments were available from 1 September 2022. However, in practice, appointments were available several months later, depending on the language of the applicant. In the meantime, between November 2021 and September 2022, access to the asylum procedure on mainland Greece, Crete and Rhodes was suspended for the majority of third country nationals.625Access was suspended again between May 2023 and the beginning July 2023.626 622 623 624 625 626 Correct repetition of Circular 411695/2021, 24 November 2021, available at: MOMA, Press release: Procedure for Submitting Asylum Claims, available at: https://tinyurl.com/2kyervyc/. Efsyn, Μόνο σε νησιά και Έβρο τα νέα αιτήματα ασύλου, 24 November 2021, available in Greek at: https://bit.ly/3t5Y4h2. MOMA, Ξεκινά η λειτουργία της πλατφόρμας ηλεκτρονικής αίτησης για ραντεβού καταγραφής αιτούντων άσυλο, 13 July 2022, available in Greek at: https://bit.ly/3Rw9HXO. Mobile Info Team (MIT), Blocked from the System: Voices of People Excluded from the Asylum Procedure on Mainland Greece, Crete and Rhodes, May 2022, available at: https://bit.ly/45wetd3. GCR, Submission to the Committee of Ministers of the Council of Europe concerning the groups of cases of M.S.S. v. Greece (Application No. 30696/09) and Rahimi v. Greece (8687/08), July 2023, p. 3, available at: https://bit.ly/4b3Q3JR. 136