Affairs Service of the Security Services) due to lack of jurisdiction.60 This annual report does not mention any activity related to investigation on a complaint concerning pushbacks nor of any public service/authority against which allegations of being engaged in pushback operations has arisen in recent years. Additionally, in July 2022 and following discussion between the EU Commission and the Greek Authorities on a ‘new proposal to mainstream fundamental rights’ within the Greek asylum system,61 a Fundamental Rights Officer (FRO)62 and a Special Committee on Fundamental Rights Compliance (Task Force for Fundamental Rights Compliance) were appointed63 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 a Ministerial Decision, specifying the Committees responsibilities, pursuant to article 50 (3) L. 4960/2022? was only issued close to a year later, in June 2023.64 No further information has been made available by the Ministry on the work of the Commission to date. Both the Ombudsman65 and the National Commission for Human Rights (GNCHR)66 have explicitly called upon the government to reconsider the above reform of a Commission underpinned by ‘majority participation of representatives of the Administration’,67 as incompatible with their mandates and independence. In September 2023, the Fundamental Rights Officer of the Ministry of Migration and Asylum activated an online complaint platform.68 According to the platform’s instructions, the complaints must be submitted by name and in writing by the victim-third country national, in Greek or English and only about incidents that were not brought before judicial or prosecuting authorities. No possibility for a representative of the victimthird country national to submit a complaint on their behalf is provided. Furthermore, in January 2023, the National Commission for Human Rights published its Interim Report on its Recording Mechanism of Informal Forced Returns, which had been launched in early 2022.69 In the framework of this Mechanism, ten civil society organisations,70 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 December 2023, the “Recording Mechanism” published a follow-up report71 to the Interim Report of the Recording Mechanism of January 2023. In the period between February 2022 and December 2022, the Recording Mechanism has recorded testimonies through personal interviews with 60 61 62 63 64 65 66 67 68 69 70 71 Ibid., pages 43-44 DRC, Protecting Rights at Borders: Beaten, punished and pushed back, 27 January 2023, available at: https://bit.ly/3opeoXU. Greek Ministry of Migration and Asylum, 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); See also DRC, Protecting Rights at Borders: Beaten, punished and pushed back, 27 January 2023, available at: https://bit.ly/3opeoXU. MD 329937/2023 on the Responsibilities and operation of the Special Committee for Compliance with Fundamental Rights of the Ministry of Migration and Asylum. Greek Ombudsman, The Ombudsman’s reservations regarding his participation in committees of the Ministry of Migration and Asylum – Letter to the Ministry of Migration, 29 July 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’. See, Greek Ombudsman, The Ombudsman’s reservations regarding his participation in committees of the Ministry of Migration and Asylum, available at: https://bit.ly/47BW3by. 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, p. 37. Available at: https://bit.ly/3VLxbL8. 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. GNCHR, Full Annual Report of 2022, published in December 2023, available at: https://bit.ly/3PSoOtv. 37