issued a Fourth Recommendation on 8 December 2016 in favour of the resumption of Dublin returns to Greece, starting from 15 March 2017, without retroactive effect and only regarding asylum applicants who have entered Greece from 15 March 2017 onwards or for whom Greece is responsible from 15 March 2017 onwards under other Dublin criteria.512 Persons belonging to vulnerable groups such as unaccompanied children are to be excluded from Dublin transfers, according to the Recommendation. 513 The National Commission for Human Rights in a Statement dated 19 December 2016, expressed its “grave concern” with regard to the Commission Recommendation and noted that: 514 it should be recalled that all refugee reception and protection mechanisms in Greece are undergoing tremendous pressure... the GNCHR reiterates its established positions, insisting that the only possible and effective solution is the immediate modification of the EU migration policy and in particular the Dublin system, which was proven to be inconsistent with the current needs and incompatible with the effective protection of human rights as well as the principles of solidarity and burden-sharing among the EU Member-States. However, the situation remains contrasted across Dublin countries. For example, the Belgian Immigration Office confirmed that as of January 2025, no Dublin transfer decisions were taken for Greece; a limited number of requests were sent to Greece but all were refused. 515 Similarly, following the 2019 Council of State ruling that a Dublin transfer to Greece would result in a violation of Article 3 ECHR unless the asylum applicant is guaranteed legal assistance during the asylum procedure by the Greek authorities, Dublin transfer decisions to Greece are not issued by the Dutch authorities as of March 2025. 516 Spain has also suspended Dublin transfers to Greece since 2014.517 In France, there is no specific policy in place, nor any precedent-setting caselaw.518 Ireland also sends Dublin requests to Greece, with 235 outgoing “take back” requests made to Greece in 2024, although no transfers were implemented.519 Although Sweden continues to submit requests for Dublin transfers to Greece (347 in 2024), it does not transfer applicants to Greece unless individual guarantees have been obtained by Greek authorities. As this is very rare, in practice Sweden does not transfer asylum applicants to Greece.520 Switzerland has issued several Dublin decisions to Greece in 2024, all concerns healthy men who were Turkish nationals, for which the Greek authorities issued ‘guarantees’. However, a decision by the Federal Administrative Court is pending following appeals.521 Germany sent 15,453 Dublin transfer requests to Greece in 2024, making for. 20% of Germany’s outgoing requests. Nevertheless, only 22 transfers were actually carried out. Courts had contrasted opinions as to the feasibility of transfers given the conditions in Greece, with some halting the transfers but others approving them. 522 512 513 514 515 516 517 518 519 520 521 522 Commission Recommendation of 8 December 2016 addressed to the Member States on the resumption of transfers to Greece under Regulation (EU) No. 604/2013, C(2016) 8525. For a critique, see OnMed, Doctors of the World Greece: The return of refugees to Greece in 2017 is disastrous, 17 December 2016, available in Greek at: https://tinyurl.com/mtuwxupm; Amnesty International, EU pressure on Greece for Dublin returns is ‘hypocritical’, 8 December 2016, available at: http://bit.ly/2kG8Dzf; Human Rights Watch, EU: Returns to Greece Put Refugees at Risk, 10 December 2016, available at: http://bit.ly/2hgVaNi; ECRE, GCR, Aitima and SolidarityNow, Letter to the President of the European Commission and the Greek Minister of Migration Policy ‘Re: Joint Action Plan on EU-Türkiye Statement and resumption of Dublin transfers to Greece’, 15 December 2016, available at: http://bit.ly/2kGcc8P; National Commission for Human Rights, Statement in response to the recommendation of the European Commission to reactivate the refugee return mechanism under the Dublin system, 19 December 2016, available at: http://bit.ly/2kGi7us. Commission Recommendation C(2016) 8525, para 9. National Commission for Human Rights, Statement in response to the recommendation of the European Commission to reactivate the refugee return mechanism under the Dublin system, 19 December 2016, available at: http://bit.ly/2kGi7us. AIDA, Country report: Belgium – Update on the year 2024, June 2025, available here, 69. AIDA, Country report: Netherlands – Update on the year 2024, May 2025, available here, 70. AIDA, Country report : Spain – Update on the year 2024, April 2025, available here, 66. AIDA, Country report: France – Update on the year 2024, June 2025, available here. AIDA, Country report: Ireland – Update on the year 2024, May 2025, available here. AIDA, Country report: Sweden – Update on the year 2024, May 2025, available here, 51. AIDA, Country report: Switzerland – Update on the year 2024, May 2025, available here, 47 and 51. AIDA, Country report: Germany – Update on the year 2024, June 2025, available here, 77. 101