Additionally, in July 2022 and following discussion45 between the EU Commission and the Greek Authorities on a ‘new proposal to mainstream fundamental rights’ within the Greek asylum system, a Fundamental Rights Officer (FRO)46 and a Special Commission on Fundamental Rights Compliance (Task Force for Fundamental Rights Compliance) were appointed 47 within the Ministry of Migration and Asylum. The Ministry of Migration and Asylum publicly announced the first meeting of the Commission in August 2022, even though no JMD had been adopted to define its exact responsibilities. 48 No further information has been made available by the Ministry on the work of the Commission to date. Both the Ombudsman49 and the National Commission for Human Rights (GNCHR) 50 have explicitly called upon the government to reconsider the above reform of a Commission underpinned by ‘majority participation of representatives of the Administration’,51 as incompatible with their mandates and independence. Furthermore, the Recording Mechanism of Informal Forced Returns that commenced operations in early 2022 under the supervision of the National Commission for Human Rights, presented its first Interim Report52 in January 2023. In the framework of this Mechanism, ten civil society organisations, 53 including GCR, recorded at least 50 incidents and 58 testimonies of informal forced returns which, according to testimonies of the alleged victims, occurred between April 2020 and October 2022. The total number of alleged victims in the report was approximately 2,157 third country nationals, including asylum seekers and recognised refugees in Greece. In 2022, the practice of refoulements continued to be used as a “front-line” tool of the country’s migration policy to halt the flow of refugees and to deter others from attempting to irregularly cross the borders. The practice is a permanent eventuality for people attempting to cross the borders according to testimonies, media coverage and reports. Serious incidents of alleged refoulements have been monitored regarding the arbitrary removal of people residing on the mainland (mainly Thessaloniki) or on the islands. In a statement from February 2022, the UN Special Rapporteur on the human rights of migrants mentioned that:54 ‘Violence, ill-treatment and pushbacks continue to be regularly reported at multiple entry points at land and sea borders, within and beyond the European Union (EU), despite repeated calls by UN agencies, including UNHCR, intergovernmental organisations and NGOs to end such practices. We are alarmed by recurrent and consistent reports coming from Greece’s land and sea borders with Türkiye, where UNHCR has recorded almost 540 reported incidents of informal 45 46 47 48 49 50 51 52 53 54 zero representatives of UN agencies, the Ombudsman or the National Commission for Human Rights. 29 interviewees were Greek officials’. DRC, Protecting Rights at Borders: Beaten, punished and pushed back, 27 January 2023, available at: https://bit.ly/3opeoXU. The Fundamental Rights Officer at the MoMA was appointed, 6 December 2022, MoMA, available at: https://bit.ly/3IwlEYK. Articles 49 and 50 of law 4960/2022 (GG A’145); DRC, Protecting Rights at Borders: Beaten, punished and pushed back, 27 January 2023, available at: https://bit.ly/3opeoXU. As it was described in art. 50 par 3 in L. 4960/2022. ‘The Ombudsman's work in this field is accompanied by the maximum guarantees of personal and functional independence according to the Constitution, thus constituting the ‘strong and timeless institution with increased guarantees of reliability and transparency in the examination of complaints,’ elements that I understand are sought after by the Ministry. Therefore, his parallel participation in a collective body of the administration with the same object raises concerns regarding the possibility of limiting his autonomous, independent role, his competences, or at least a blurring/overlap of competences’. Available at: https://www.synigoros.gr/en/category/nea/post/the-ombudsman's-reservations-regarding-his-participation-incommittees-of-the-ministry-of-migration-and-asylum GNCHR, letter on 21 October 2022, available in Greek at: https://bit.ly/43kpmMW. Rule of Law Backsliding Continues in Greece, Joint Civil Society Submission to the European Commission on the 2023 Rule of Law Report, January 2023, available at: https://bit.ly/45qfPpQ, 37. GNCHR, Recording Mechanism of Informal Forced Returns, Interim Report, January 2023, available at: https://bit.ly/3IUTyH5. Greek Council for Refugees (GCR), Hellenic League for Human Rights (HLHR), Network for Children’s Rights, Medical Intervention, METAdrasi – ACTION FOR MIGRATION AND DEVELOPMENT, Transgender Support Association, RSA, HIAS Greece, Legal Centre Lesvos, Danish Refugee Council Greece (DRC): see https://bit.ly/3Ix1jTl. UNHCR, News Comment: UNHCR warns of increasing violence and human rights violations at European borders, 21 February 2022, available at: https://bit.ly/42Vd0Ly. 31