carried out by EODY within the RIC, by any public health institution, or otherwise, by a private practitioner under a relevant programme.466 The age assessment is conducted with the following successive methods: Initially, the assessment will be based on the macroscopic features (i.e. physical appearance) such as height, weight, body mass index, voice, and hair growth, following a clinical examination from properly trained healthcare professionals (physicians, paediatricians, etc) who will consider body-metric data.467 In case the person’s age cannot be adequately determined through the examination of macroscopic features, a psychosocial assessment is carried out by a psychologist and a social worker to evaluate the cognitive, behavioural and psychological development of the individual. If a psychologist is not available or there is no functioning social service in the nearest public health institution, this assessment can be conducted by a specially trained psychologist and a social worker available from a certified civil society organisation but it cannot be conducted by an organisation in charge of providing care or housing to the person whose age is in question. The outcome of the age assessment at this point is a combination of the psychosocial assessment and the examination of the development of macroscopic features.468 Whenever a conclusion cannot be reached after the conduct of the above procedures, the person will be subjected to the following medical examinations: either left wrist and hand X-rays for the assessment of the skeletal mass, or dental examination or panoramic dental X-rays or to any other appropriate means which can lead to a firm conclusion according to the international bibliography and practice. 469 According to Article 1(7) JMD 9889/2020 the opinions and evaluations are delivered to the person responsible for the referral, who issues a relevant act to adopt the abovementioned conclusions, registers the age in the database of Reception and Asylum, and notifies the act to the Special Secretariat for the Protection of Unaccompanied Minors. 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 assessment470. 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. These appeals are in practice examined by the Central RIS. The number of appeals submitted against age assessment decisions in 2022 is not available. The findings of a report published by several civil society organisations at the beginning of 2020 are still valid for the year 2022: ‘Medical methods for age assessment are systematically used, despite well-documented concerns as to their accuracy and reliability. The authorities do not systematically comply with the procedure set out in secondary legislation […] Persons are subjected to an X-ray examination at the First-Line National Health Network Centre (ΠΕΔΥ) or general hospital, without prior assessment by a psychologist and a social worker. Moreover, EODY does not perform a systematic process starting from less invasive methods, as established by JMD 9889/2020. The alleged minors go through a one-time appointment, which includes an age assessment interview and a medical and psychological evaluation. Many are only asked about aspects irrelevant to age 466 467 468 469 470 See Art 4 JMD 9889/2020. See Article 1(5)(a) JMD 9889/2020. See Art. 1(5)(b) JMD 9889/2020. See Art 1(5)(c) JMD 9889/2020. Contrary to MD 92490/2013 and JMD 1982/2016 which provided for left wrist, hand X-rays, dental examination and panoramic dental X- rays cumulatively and not alternatively. See Art1(9) JMD 9889/2020. 113