The total number of mandated guardians for UASC throughout the country on 22 January 2025 stood at 128,733 significantly below the expected minimum number of 170 734 (with a project that provisioned a maximum of 180 mandated guardians). This team is responsible for addressing the needs of the 2,414 UASC registered in Greece as of December 2024.735 With an average allocation of 15 children per professional, they can potentially cover up to 2,550 children. At the time of writing, UAMs’ presence in Safe Areas or Zones inside RICs, both on the mainland and the islands, is much higher than the number of those registered (and thus recorded in the cited statistics), and exceeds the actual capacity of these arrangements (e.g., in Samos Safe Area, in January 2025, there were more than 500 children for a space that can accommodate 200 children). 736 In parallel, UASC are staying in such Areas for significantly longer periods of time compared to those foreseen by law (max. 25 days, while in practice, some UASC have stayed for more than three months). This concerning situation also surpasses the existing capacity of mandated guardians, creating a protection gap for children on the move, as flagged by NGOs in Greece.737 Although circulars have been issued to clarify the guardianship’s legal framework, 738 challenges identified in practice primarily stem from the novelty of the scheme and the emergence of mandated guardians as a new professional profile with roles and responsibilities previously associated with other field professionals (e.g. lawyers or social workers). Consequently, discrepancies have been observed concerning the level of involvement of guardians, lawyers, social workers and educators, some of which have affected UACS’ asylum procedure, such as Dublin II procedures and appeals, as lawyers and other professionals now require authorisations from the mandated guardian to support or follow up on a case. With Joint Ministerial Decision no 539638/20.12.2023 of the Minister of Economy and the Minister of Migration and Asylum, a Mechanism for the submission and management of complaints of UAMs in the context of guardianship was set up,739 as foreseen by Article 66KB Asylum Code. The coordinator of mandated guardians, which is appointed by each of the two NGOs that has undertaken the provision of guardianship services, is designated by law as the person responsible for the procedure of submission, examination and resolution of complaints of minors and is expected to cooperate with the Child Protection Policy Manager of the guardian, who is responsible for the general supervision of the complaints mechanism. In particular, the coordinator shall ensure: (a) Receiving the complaint, the immediate filing of the complaint, the weekly updating of the Institutional Protection Unit on all complaints submitted, and the keeping of a record of the complaints received, (b) investigating and collecting data on complaints, (c) the resolution of complaints, (d) regularly updating the minor and the authorities involved on the conduct of the procedure, (e) the inclusion of a report on the complaints in the reports referred to in paragraph (e). (2 of Article 66KA of the Act). 4939/2022. If the child’s complaint concerns the coordinator, the Child Protection Policy Officer is then responsible for the management of the complaint in question. 740 The Law also sets up the Board of Guardianship for Unaccompanied Minors within GSVPIP, consisting of five of its officials, which decides on complaints submitted by unaccompanied minors and brought before it, following a referral from the Institutional Protection Unit. 733 734 735 736 737 738 739 740 In the context of their right of reply, submitted on 10 September 2025, the Greek General Secretariat for Vulnerable Persons and Institutional Protection, clarified that, while this number is accurate January 2025, it should be noted that the average number of guardians for 2024 was 127, due to the gradual implementation of the guardianship project, which included recruitments in three stages (60 guardians by the end of the first month, 120 by the end of the first trimester, and 170 by the end of May 2024). Since May 2024, until August 2025, the average number of guardians was 142 (reaching at a point 168 guardians, in June 2024). Information shared by the competent GSVPIP during a meeting of the Legal Aid Working Group operating in Greece dedicated to guardianship. See Ministry of Migration and Asylum, Situation Update: Unaccompanied Minors (UAM) in Greece, reference date: 01 December 2024, available here. Information shared within Child Rights Advocacy Network (CRAN) members at the meeting of 16 January 2025. See, among others, Joint Press Release of 12 Child Rights Advocacy Network (CRAN) members titled Hundreds of unaccompanied children in Unsafe Zones: Need for an Immediate Activation of Relocation, 5 December 2024, available here. Mainly GSVPIP Circular 1/2024 available in Greek here, and a document providing guidelines to shelters and other facilities for UAMs, 20 June 2024, available upon request. Government Gazette B 7143/20.12.2023. See Article 7 of the 539638/20.12.2023 JMD. 165