needs,876 despite the reported willingness of the European Commission to continue the programme’s funding in the context of supporting alternative modes of accommodation to camps.877 In what concerns provision of material reception conditions in the form of financial aid, under the ESTIA II-CBI programme, the beneficiaries of such aid are:878 v Adult asylum seekers who have submitted or fully lodged an asylum application in accordance with article 65 (1)(2) & (7) L. 4636/2019, as long as they reside in the centres and facilities provided under para. 4 article 8 L. 4375/2016, in accommodation programmes of the MoMA, in shelters and hospitality centres operated by international organisations and legal entities governed by public law, local authorities, as well as civil society actors that are registered in the Registry of Greek and foreign NGOs of the MoMA. Applicants in detention are not entitled to the cash-based support. v Beneficiaries of international protection who upon turning 18 reside in accommodation centres for UAM or in temporary accommodation spaces for UAM, for a period of three months following their placement to the aforementioned accommodation spaces. In both cases, the new residency requirement as a pre-condition for receiving financial aid took effect on 1 July 2021, after first being announced through Press Releases issued by the MoMA in April and May 2021,879 and subsequently introduced in ministerial decisions in July and September.880 As per the new framework, financial aid is provided to those eligible at the end of each month, as long as it can be certified that they continue to reside in facilities operating under the MoMA (i.e., facilities of the reception system). Applicants who are not accommodated in these facilities need to first apply, then be referred to and lastly placed in such accommodation, before the procedure for accessing financial aid can (re)start.881 The decision to interrupt cash assistance to asylum applicants not accommodated in the reception system raised significant concerns, inter alia because it amounted to the withdrawal of material reception conditions for an estimated 25,000 asylum applicants,882 without any personalised assessment or reasoned decision, thus potentially also amounting to a violation of article 20 of Directive 2013/33/EU (as transposed by article 57 IPA, which was afterwards replaced by article 61 Asylum Code). Furthermore, as highlighted by 30 civil society organisations in a joint statement published in June 2021,883 the decision came at the detriment of integration. In practice, many of those affected were called to abandon a place of residence of their own choice –which they were able to sustain with the cash-based support– and to abandon their communities and friends, in order to return to camps, where they would have to be in isolation from society. The decision also failed to take into consideration the protection risks that could arise at least for some in the context of suddenly having to share accommodation in a camp. As observed,884 applicants from some communities ended up preferring losing the financial support out of fear that residence in a camp would expose them to risks connected with their fear of persecution. It lastly 876 877 878 879 880 881 882 883 884 For the closure of ESTIA, see among others: RSA, A Step backwards for protection and integration: On the termination of the ESTIA II housing programme for asylum applicants, 22 December 2022, available at: https://bit.ly/43vr3Y5; GCR, Press Release, Εξώσεις, αστεγία και πισωγύρισμα στην ένταξη, 30 November 2022, available in Greek at: https://bit.ly/3oBev2B; FENIX, Closure of ESTIA II: thousands of extremely vulnerable asylum seekers to be left without humane and adequate accommodation and proper care, 31 October 2022, available at: https://bit.ly/43nPgzO. Fenix, Closure of ESTIA II: a political choice behind its closure, December 2022, available at: https://bit.ly/3VbYagQ. Article 1(d) Ministerial Decision 115202/2021, op.cit. MoMA, The financial assistance to international protection applicants that are not accommodated in facilities under the responsibility of the MoMA or MoMA partners is abolished from 1/7/21, 15 April 2021, available in Greek at: https://bit.ly/3IEvEgx and Pre-requisites for the disbursement of financial assistance to international protection applicants, 25 May 2021, available at: https://bit.ly/3IDe5xx. Ministerial Decision 115202/2021 op.cit and JMD 2857/2021 Amending JMD 2089/16-07-2021 on a ‘Common Framework for Managing Programmes that are assigned to the Special Secretariat for the Coordination and Management of Programmes under the Asylum, Migration and Integration Fund and the Internal Security Fund and other resources and are nor financed through National Programmes’ (Β’ 3120), Gov. Gazette 4496/2909-2021. Annex III, JMD 2089/16.7.2021 as amended by JMD 2857/29.9.2021. Estimates provided by UNHCR in the protection working group of 7 June 2021. Joint Statement, A big setback in integration: The cut in aid to asylum seekers, 24 June 2021, available at: https://bit.ly/3qMKIBV. As per information shared in the national protection working group of 7 June 2021. 179