According to Article 80 (3) of the Asylum Code regarding applications of UAMs: ‘In case of doubt, the competent Receiving Authorities shall refer the unaccompanied minor to the age assessment procedures as per the provisions in force. In cases the above-mentioned referral is considered necessary and until the completion of the procedure, special attention should be paid to the particular characteristics of the minor, especially those related to their gender or cultural peculiarities’ (see below). Since the end of 2019, the authority competent for carrying out medical checks has been the National Public Health Organisation (EODY), which was established by L 4633/2019 as the successor of KEELPNO. Based on data published by the MoMA in the first months of 2024, the number of those registered as vulnerable by the RIS at the borders and in mainland RICs throughout 2023, based on the category of vulnerability, stands as follows:598 Vulnerability category Number of persons Disabilities 246 UAMs 2,364 Pregnancy 519 Victims of Human Trafficking 114 Victims of Abuse 2,115 Single families (total number of persons) 2,569 Elderly (>65 years) 177 Total 8,104 During the same period (2023), EUAA staff identified 7,940 persons as presenting vulnerability indicators, in the context of vulnerability assessments carried out in reception facilities, as part of the support provided by the Agency to Greece’s first and second-line reception system,599 but the extent to which these numbers overlap is not possible to assess. The number of persons identified as vulnerable after conclusion of the reception and identification procedures and the number of persons identified as vulnerable after re-examination were not provided by the competent Ministry. Moreover, no information was provided regarding the competent authority to cover the expenses in cases where transfer to another island was necessary for the vulnerability assessment. The low quality of the process of medical and psychosocial screening, if any, has remained a source of serious concern also in 2023. As stated in AIDA report for 2022,600 vulnerabilities are often missed, with individuals going through the asylum procedure without having their vulnerability assessment completed first. Equal Rights Beyond Borders, HIAS Greece and RSA have reported that “[s]evere delays persist when it comes to conducting vulnerability assessments even after the reception and identification procedure formally ends: The time delay ranges from ten days to longer than three months in some cases. Yet, the Asylum Service and EUAA continue to process asylum claims before individuals have undergone a vulnerability assessment, and routinely disregard or deny special procedural guarantees afforded by EU law, even where they are specifically requested by the applicants in writing and/or orally prior to the interview. They instead insist on completing the interview under the border procedure. The medical cards issued to people undergoing reception and identification procedure do not clearly indicate whether and when a vulnerability assessment was conducted”. 601 The organisations further report that, “[o]n the one 598 599 600 601 MoMA, Secretary General for the reception of Asylum Seekers / Reception and Identification Service / Directorate of RICs & CCACs, Registrations 12 months 2023, available in Greek at: https://tinyurl.com/ytfkhkfu, p.7 and Registrations 12 months mainland 2023, available at: https://tinyurl.com/48jc9u7x, p.5. Information provided by the EUAA, 26 February 2024. ECRE, AIDA, Country Report: Greece, 2022 Update, June 2023, available at: https://bit.ly/3PUOVk9. Equal Rights Beyond Borders, HIAS Greece & Refugee Support Aegean, Τhe state of the border procedure on the greek islands, September 2022, available at: https://bit.ly/40VTZrM, p. 4. 130

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