The same article also provides for the operation of distinct spaces, within the perimeter of the aforementioned types of accommodation, that should fulfil specifications appropriate for the accommodation of third country nationals or stateless persons belonging to the vulnerable groups prescribed by law. Overall, the Greek reception system has been long criticised as inadequate, not least in the M.S.S. v. Belgium and Greece ruling of the ECtHR. Subsequent jurisprudence of the ECtHR has also found violations of Article 3 ECHR due to the failure of national authorities to provide asylum seekers with adequate living conditions.932 From mid-2015, when Greece was facing large-scale arrivals of refugees, those shortcomings became increasingly apparent. The imposition of border restrictions and the subsequent closure of the Western Balkan route in March 2016 resulted in trapping about 50,000 third-country nationals in Greece. This created inter alia an unprecedented burden on the Greek reception system.933 Since then, the number of reception places has increased mainly through camps and the former ESTIA accommodation programme initially implemented by UNHCR, until the latter was terminated at the end of 2022. Despite this increase, destitution and homelessness remain a risk, which has continued affecting asylum seekers and refugees,934 particularly following the Greek government’s decision to link eligibility for the cash-based support provided in the context of material reception with residence in Greece’s reception system, coupled with the termination of ESTIA –which severely disrupted applicants’ access to their rights while compounding barriers to integration935– and systematic application of the “safe third country” concept even to cases where the provisions of article 38 Directive 2013/32/EU are not fulfilled in practice. The Reception and Identification Service (RIS), operating under the General Secretariat for the Reception of Asylum Applicants of the MoMA, is the responsible authority for the reception of asylum seekers,936 including of unaccompanied minors.937 Following the full handover of “ESTIA” to the MoMA in May 2021,938 the RIS has also been responsible for managing the accommodation programme, in collaboration with implementing partners,939 until the programme was terminated in December 2022. Yet as far as GCR is aware, the RIS had stopped receiving new referrals for accommodation to ESTIA, even for highly vulnerable cases, several months before the programme’s termination. Following the entry into force of the Asylum Code and relevant amendments by L. 4960/2022, the Special Secretary for Unaccompanied Minors (SSUM) of the MoMA remained the competent authority for the protection of UAM, including for the referral and accompaniment of UAM to dedicated accommodation facilities for UAM and the implementation of Guardianship,940 until the transfer of its responsibilities (under article 39 pf P.D. 106/2020) to the new General Secretariat for Vulnerable Persons & Institutional Protection establishedwith article 6(1) of P.D. 77/2023 (A' 130/ 27.6.2023). 932 933 934 935 936 937 938 939 940 ECtHR, F.H. v. Greece, Application No 78456/11, Judgment of 31 July 2014; Al.K. v. Greece, Application No 63542/11, Judgment of 11 March 2015; Amadou v. Greece, Application No 37991/11, Judgment of 4 February 2016; S.G. v. Greece, Application No 46558/12, Judgment of 18 May 2017, A.D. v Greece, Application no. 55363/19, Judgement of 4 April 2023. See also AIRE Centre and ECRE, With Greece: Recommendations for refugee protection, July 2016, available at: https://bit.ly/3WRDBXE, pp. 7-8. See, inter alia, Katimerini, Thousands of refugees back out in the cold, 20 January 2023, available at: https://bit.ly/3mWTzm3; The Guardian, Destitution is almost inevitable: Afghan refugees in Greece left homeless by failed system, 30 November 2022, available at: https://bit.ly/3HbNicW; GCR, Diotima Centre & IRC, Homeless & Hopeless: An assessment of the housing situation of asylum applicants and beneficiaries of international protection in Greece, January 2022, available at: https://bit.ly/3uwZ2zC; Joint Announcement of 74 civils society organisations, Refugees in Greece: Risk of Homelessness and Destitution for Thousands during Winter, 22 December 2020, available at: https://bit.ly/3nIBofT. For more, see AIDA, Country Report Greece: 2022 Update, June 2023, available at: https://bit.ly/45vXAir, pp. 161-164. Article 1(ιστ) Αsylum Code. Article 64 (2) Asylum Code as amended. ECRE, Greece: Hearing Reveals Hostile Environment for Human Rights Defenders, Strategy of Deflection and Denials on Pushbacks Continue, ESTIA Cash Scheme Unravels as Government Takes Over, 15 October 2021, available at: https://bit.ly/3LmNohy. MoMA, ESTIA Programme, see: https://bit.ly/439SeIj. Article 64 Asylum Code. 189