UAM reports December 2024 - Feb 2025
Dear European Union Agency for Asylum,
Under the right of access to documents as established in the EU treaties and Regulation 1049/2001, I am requesting the following documents from the European Union Agency for Asylum (EUAA) related to migrant camps on the Greek islands of Kos, Lesbos, Samos, Leros, and Chios.
For the period from 01 December 2024 to present:
1 ) The following two documents: "Situational Update - Unaccompanied Children in First Line Reception" for the months of December 2024 and January 2025 (if the latter is available)
2) All documents (including briefings, notes, meeting minutes, papers, non-papers, reports, PowerPoints, or informal input) related to reception conditions for unaccompanied and separated minors (also referred to as UAMs, UAC, UASC)
Under Regulation 1049/2001, public access to documents is a fundamental right, and I emphasize the significant public interest in ensuring transparency regarding key numerical data related to asylum procedures and reception conditions on the Greek islands.
This includes not only the number of asylum seekers, including unaccompanied minors, present on the islands but also figures related to reception capacity, occupancy rates, case processing times, average waiting periods for registration and asylum interviews, and other statistical data that reflect the functioning of the asylum system.
Such data has been disclosed in previous reports by EU institutions, national authorities, and international organizations. Redacting or withholding these figures would be inconsistent with the EU’s commitments to transparency, accountability, and evidence-based policymaking.
Moreover, numerical data of this nature does not constitute sensitive personal information nor does its disclosure pose a risk to individuals' safety or privacy. Instead, it plays a crucial role in assessing compliance with EU and international asylum standards, evaluating the efficiency of asylum procedures, and informing the public, researchers, and policymakers about the realities on the ground.
Any decision to redact this information should be justified with a clear and specific legal basis, in line with the principle of proportionality and the case law of the Court of Justice of the European Union, which has repeatedly affirmed that restrictions on access to documents must be narrowly interpreted.
For these reasons, I respectfully request that all numerical data—including figures on the number of asylum seekers, reception capacity, average waiting times, processing durations, and other statistical indicators—be disclosed in full.
Yours faithfully,
Lydia Emmanouilidou
Dear Ms Emmanouilidou,
Reference is made to your request (dated 5 February 2025) for public
access to documents under Regulation (EC) No 1049/2001.
In particular, under point 2 of your request, you request access to "All
documents (including briefings, notes, meeting minutes, papers,
non-papers, reports, PowerPoints, or informal input) related to reception
conditions for unaccompanied and separated minors (also referred to as
UAMs, UAC, UASC)".
The EUAA considers that, in its current format, the above quoted section
of your request potentially relates to a very large number of documents,
and that assessing all concerned documents with a view to determining
whether they fall within the scope of your request would place an
excessive administrative burden on the Agency. By way of indication, an
estimated 500 documents would have to be examined to ascertain whether
they are covered by your request.
We note that your request comes at a time when the Greece sector is facing
a considerable surge in requests for public access to documents under
Regulation (EC) No 1049/2001. Only a few days ago, on 29 January 2025, the
Agency replied to a request that you yourself submitted on 2 December
2024. A considerable 183 documents fell within the scope of that request,
of which 164 were disclosed. As you can imagine, dealing with such a high
number of documents required dedicating considerable resources (from the
limited ones available) to your request. In the meantime, besides
maintaining normal operations, the Agency and the Greece sector also had
to deal with requests for public access to documents from other
applicants, that had their own deadlines and complications.
While we remain committed to complying with Regulation (EC) No 1049/2001
in full, pursuant to Article 6(3) of Regulation (EC) No 1049/2001
regarding public access to documents, we kindly ask for your cooperation
in finding a fair solution. With this in mind, we kindly request that you
add a degree of precision to your original request, and that you consider
narrowing down the temporal and/or material scope of the said request.
This will enable the Agency to properly identify all relevant documents,
carry out an individual assessment of each document and comply with the
applicable deadlines.
If you need assistance in clarifying or specifying your application, you
can contact us by email via: [1][EUAA request email].
The Agency awaits your reply, following which your request will be
registered.
Thank you in advance for your cooperation.
Sincerely,
European Union Agency for Asylum
Email: [2][EUAA request email]
Website: [3]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
************************************************************************************************************************
Dear Public Access To Documents Mailbox,
Thank you for your response and for the time and effort dedicated to processing my recent request. I appreciate the Agency’s commitment to transparency and the resources involved in handling public access to documents.
While I appreaciate the documents shared in the 29 January 2025 response, I am aware they had already been processed under a previous request.
Given that my current request covers only a two-month period, I believe this does not constitute an unreasonably broad scope. However, in the interest of facilitating a solution, I am willing to refine the scope of Item 2 as follows:
For the camps of Samos and Leros, I maintain my request for all documents related to reception conditions for unaccompanied and separated minors.
For the remaining camps, I would limit my request to documents specifically under the category of "Reception Support."
I hope this refinement addresses the Agency’s concerns while still allowing access to information relevant to my research. Please let me know if this adjustment is acceptable or if further modifications would be required to proceed.
I appreciate your time and cooperation.
Yours sincerely,
Lydia Emmanouilidou
Dear Public Access To Documents Mailbox,
I am following up on my public access to documents request, submitted on 05 February 2025, as I have not received a response to my proposal. As you are aware, under Regulation (EC) No 1049/2001, the EUAA must process applications promptly and within the prescribed time limits.
Given that my request is both specific and time-sensitive, I would appreciate an update on its status at your earliest convenience. If there are any outstanding concerns or clarifications needed, please do not hesitate to inform me so that we can move the process forward without further delay.
Yours sincerely,
Lydia Emmanouilidou
Dear Ms Emmanouilidou,
Thank you for agreeing to narrow down the scope of your request in order
to find a fair solution.
Reference is made to your below correspondence started on 5 February 2025.
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, as further agreed upon on 7 February
2025 and was registered under reference number 005269 on 13 February 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 6 March 2025. In case this
time limit needs to be extended, you will be informed in due course.
Yours sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents under
Regulation (EC) No 1049/2001, which was registered under reference number
005269 on 13 February 2025.
Please note that your application is currently being handled by the EUAA
in accordance with Regulation (EC) No 1049/2001 and the Agency’s
Management Board Decision No 6. However, the EUAA will not be in a
position to complete the handling of your application within the initial
time-limit of 15 working days, which is due to expire on 6 March 2025.
An extended time-limit is needed given that additional administrative
efforts are required in terms of, inter alia, carrying out consultations,
identifying all relevant documents, thoroughly examining their contents
and making comprehensive assessments against Article 4 of Regulation (EC)
No 1049/2001 - in order to be able to duly process your request in the
most diligent manner in accordance with the principle of good
administration.
In light of the above, the Agency has decided to extend the time-limit by
an additional 15 working days in accordance with Article 7(3) of
Regulation (EC) No 1049/2001. The new time limit is due to expire on 27
March 2025. Nonetheless, the Agency strives to get back to you as swiftly
as possible.
Yours sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
From: Public Access To Documents Mailbox <[EUAA request email]>
Sent: 13 February 2025 12:08
To: Lydia Emmanouilidou <[FOI #15524 email]>
Subject: RE: access to documents request - UAM reports December 2024 - Feb
2025
Dear Ms Emmanouilidou,
Thank you for agreeing to narrow down the scope of your request in order
to find a fair solution.
Reference is made to your below correspondence started on 5 February 2025.
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, as further agreed upon on 7 February
2025 and was registered under reference number 005269 on 13 February 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 6 March 2025. In case this
time limit needs to be extended, you will be informed in due course.
Yours sincerely,
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
Dear Ms Emmanouilidou,
Kindly find enclosed a letter from Ms Nina Gregori, Executive Director of
the EUAA, in response to your application for access to documents under
Regulation (EC) No 1049/2001 together with the disclosed documents.
Since the size of the documents does not permit that they be sent to you
in one email, the documents will be shared with you in batches, via
separate emails. You may find the first batch attached with this email.
Yours sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
From: Public Access To Documents Mailbox <[EUAA request email]>
Sent: 04 March 2025 17:03
To: Lydia Emmanouilidou <[FOI #15524 email]>
Cc: Public Access To Documents Mailbox <[EUAA request email]>
Subject: RE: access to documents request - UAM reports December 2024 - Feb
2025
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents under
Regulation (EC) No 1049/2001, which was registered under reference number
005269 on 13 February 2025.
Please note that your application is currently being handled by the EUAA
in accordance with Regulation (EC) No 1049/2001 and the Agency’s
Management Board Decision No 6. However, the EUAA will not be in a
position to complete the handling of your application within the initial
time-limit of 15 working days, which is due to expire on 6 March 2025.
An extended time-limit is needed given that additional administrative
efforts are required in terms of, inter alia, carrying out consultations,
identifying all relevant documents, thoroughly examining their contents
and making comprehensive assessments against Article 4 of Regulation (EC)
No 1049/2001 - in order to be able to duly process your request in the
most diligent manner in accordance with the principle of good
administration.
In light of the above, the Agency has decided to extend the time-limit by
an additional 15 working days in accordance with Article 7(3) of
Regulation (EC) No 1049/2001. The new time limit is due to expire on 27
March 2025. Nonetheless, the Agency strives to get back to you as swiftly
as possible.
Yours sincerely,
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
From: Public Access To Documents Mailbox <[5][EUAA request email]>
Sent: 13 February 2025 12:08
To: Lydia Emmanouilidou <[6][FOI #15524 email]>
Subject: RE: access to documents request - UAM reports December 2024 - Feb
2025
Dear Ms Emmanouilidou,
Thank you for agreeing to narrow down the scope of your request in order
to find a fair solution.
Reference is made to your below correspondence started on 5 February 2025.
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, as further agreed upon on 7 February
2025 and was registered under reference number 005269 on 13 February 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 6 March 2025. In case this
time limit needs to be extended, you will be informed in due course.
Yours sincerely,
European Union Agency for Asylum
Email: [7][EUAA request email]
Website: [8]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
Dear Ms Emmanouilidou,
Please, find enclosed documents from 19 to 37.
Yours sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
From: Public Access To Documents Mailbox
Sent: 27 March 2025 11:22
To: Lydia Emmanouilidou <[FOI #15524 email]>
Cc: Public Access To Documents Mailbox <[EUAA request email]>
Subject: RE: access to documents request - UAM reports December 2024 - Feb
2025
Dear Ms Emmanouilidou,
Kindly find enclosed a letter from Ms Nina Gregori, Executive Director of
the EUAA, in response to your application for access to documents under
Regulation (EC) No 1049/2001 together with the disclosed documents.
Since the size of the documents does not permit that they be sent to you
in one email, the documents will be shared with you in batches, via
separate emails. You may find the first batch attached with this email.
Yours sincerely,
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
From: Public Access To Documents Mailbox <[5][EUAA request email]>
Sent: 04 March 2025 17:03
To: Lydia Emmanouilidou <[6][FOI #15524 email]>
Cc: Public Access To Documents Mailbox <[7][EUAA request email]>
Subject: RE: access to documents request - UAM reports December 2024 - Feb
2025
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents under
Regulation (EC) No 1049/2001, which was registered under reference number
005269 on 13 February 2025.
Please note that your application is currently being handled by the EUAA
in accordance with Regulation (EC) No 1049/2001 and the Agency’s
Management Board Decision No 6. However, the EUAA will not be in a
position to complete the handling of your application within the initial
time-limit of 15 working days, which is due to expire on 6 March 2025.
An extended time-limit is needed given that additional administrative
efforts are required in terms of, inter alia, carrying out consultations,
identifying all relevant documents, thoroughly examining their contents
and making comprehensive assessments against Article 4 of Regulation (EC)
No 1049/2001 - in order to be able to duly process your request in the
most diligent manner in accordance with the principle of good
administration.
In light of the above, the Agency has decided to extend the time-limit by
an additional 15 working days in accordance with Article 7(3) of
Regulation (EC) No 1049/2001. The new time limit is due to expire on 27
March 2025. Nonetheless, the Agency strives to get back to you as swiftly
as possible.
Yours sincerely,
European Union Agency for Asylum
Email: [8][EUAA request email]
Website: [9]https://euaa.europa.eu
From: Public Access To Documents Mailbox <[10][EUAA request email]>
Sent: 13 February 2025 12:08
To: Lydia Emmanouilidou <[11][FOI #15524 email]>
Subject: RE: access to documents request - UAM reports December 2024 - Feb
2025
Dear Ms Emmanouilidou,
Thank you for agreeing to narrow down the scope of your request in order
to find a fair solution.
Reference is made to your below correspondence started on 5 February 2025.
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, as further agreed upon on 7 February
2025 and was registered under reference number 005269 on 13 February 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 6 March 2025. In case this
time limit needs to be extended, you will be informed in due course.
Yours sincerely,
European Union Agency for Asylum
Email: [12][EUAA request email]
Website: [13]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
Dear Ms Emmanouilidou,
Please, find enclosed documents from 38 to 53.
Yours sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
From: Public Access To Documents Mailbox
Sent: 27 March 2025 11:25
To: 'Lydia Emmanouilidou' <[FOI #15524 email]>
Cc: Public Access To Documents Mailbox <[EUAA request email]>
Subject: RE: access to documents request - UAM reports December 2024 - Feb
2025
Dear Ms Emmanouilidou,
Please, find enclosed documents from 19 to 37.
Yours sincerely,
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
From: Public Access To Documents Mailbox
Sent: 27 March 2025 11:22
To: Lydia Emmanouilidou <[5][FOI #15524 email]>
Cc: Public Access To Documents Mailbox <[6][EUAA request email]>
Subject: RE: access to documents request - UAM reports December 2024 - Feb
2025
Dear Ms Emmanouilidou,
Kindly find enclosed a letter from Ms Nina Gregori, Executive Director of
the EUAA, in response to your application for access to documents under
Regulation (EC) No 1049/2001 together with the disclosed documents.
Since the size of the documents does not permit that they be sent to you
in one email, the documents will be shared with you in batches, via
separate emails. You may find the first batch attached with this email.
Yours sincerely,
European Union Agency for Asylum
Email: [7][EUAA request email]
Website: [8]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
From: Public Access To Documents Mailbox <[9][EUAA request email]>
Sent: 04 March 2025 17:03
To: Lydia Emmanouilidou <[10][FOI #15524 email]>
Cc: Public Access To Documents Mailbox <[11][EUAA request email]>
Subject: RE: access to documents request - UAM reports December 2024 - Feb
2025
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents under
Regulation (EC) No 1049/2001, which was registered under reference number
005269 on 13 February 2025.
Please note that your application is currently being handled by the EUAA
in accordance with Regulation (EC) No 1049/2001 and the Agency’s
Management Board Decision No 6. However, the EUAA will not be in a
position to complete the handling of your application within the initial
time-limit of 15 working days, which is due to expire on 6 March 2025.
An extended time-limit is needed given that additional administrative
efforts are required in terms of, inter alia, carrying out consultations,
identifying all relevant documents, thoroughly examining their contents
and making comprehensive assessments against Article 4 of Regulation (EC)
No 1049/2001 - in order to be able to duly process your request in the
most diligent manner in accordance with the principle of good
administration.
In light of the above, the Agency has decided to extend the time-limit by
an additional 15 working days in accordance with Article 7(3) of
Regulation (EC) No 1049/2001. The new time limit is due to expire on 27
March 2025. Nonetheless, the Agency strives to get back to you as swiftly
as possible.
Yours sincerely,
European Union Agency for Asylum
Email: [12][EUAA request email]
Website: [13]https://euaa.europa.eu
From: Public Access To Documents Mailbox <[14][EUAA request email]>
Sent: 13 February 2025 12:08
To: Lydia Emmanouilidou <[15][FOI #15524 email]>
Subject: RE: access to documents request - UAM reports December 2024 - Feb
2025
Dear Ms Emmanouilidou,
Thank you for agreeing to narrow down the scope of your request in order
to find a fair solution.
Reference is made to your below correspondence started on 5 February 2025.
We hereby acknowledge receipt of your application for access to documents
under Regulation (EC) No 1049/2001, as further agreed upon on 7 February
2025 and was registered under reference number 005269 on 13 February 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 6 March 2025. In case this
time limit needs to be extended, you will be informed in due course.
Yours sincerely,
European Union Agency for Asylum
Email: [16][EUAA request email]
Website: [17]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
Confirmatory Application – PAD Request No 005269
Dear Sir/Madam,
Thank you for your reply of 27 March 2025, in which you provided a response to my access to documents request 005269. I would like to thank the European Union Agency for Asylum (EUAA) for (partially) disclosing some of the documents I had requested.
I hereby submit a confirmatory application under Article 7(2) of Regulation (EC) No 1049/2001, requesting that the EUAA reconsider its response of 27 March 2025 to my request for access to documents. This application concerns the excessive and unjustified redactions applied to 53 documents disclosed in response to my original request regarding reception conditions for asylum seekers, including unaccompanied minors, on the Greek islands.
In accordance with settled case law (T-188/98, Kuijer v Council, para. 46), I expect the Agency to examine and respond individually to each argument presented herein. I also ask that this application be treated confidentially, particularly in any communication with third parties.
1. Protection of Public Security – Article 4(1)(a)
In its response letter, the EUAA asserts that “the disclosure of certain documents would undermine the protection of the public interest as regards public security,” suggesting that transparency would jeopardize operational cooperation and erode trust between the EUAA and national authorities.
This justification is both overbroad and insufficiently specific. As the Court of First Instance held in Hautala v Council (T-14/98, para. 67), and reaffirmed in Sison v Council (C-266/05 P, para. 63), any limitation on access must be based on a concrete, individual analysis of each document, demonstrating how disclosure would seriously and foreseeably undermine a protected interest. The EUAA has failed to do so.
The documents in question contain logistical updates, numerical data on population and capacity, reports of registration delays, and field-level observations--none of which can be reasonably said to endanger public security. For example, the redaction of occupancy numbers or details about guardian shortages for unaccompanied minors on Kos (Document 32) cannot plausibly be said to threaten public order or national security.
2. Protection of the Decision-Making Process – Article 4(3)
The Agency also invokes Article 4(3), arguing that “disclosure would undermine the Agency’s internal decision-making process by hindering the possibility to express views and opinions freely, and would be likely to lead to self-censorship.”
This sweeping claim contradicts the narrow scope of the exemption. The CJEU has consistently held that Article 4(3) protects only those documents which reflect internal deliberations, and even then, only while a decision is under active consideration (Council v Hautala, C-353/99 P, para. 28). Many of the documents cited in the annex refer to past or ongoing operations whose policy contours are already settled. The content of these reports is primarily factual, not deliberative.
Field staff reporting that registration is delayed, that there are not enough interpreters, or that minors are sleeping outside established safe zones does not amount to the kind of sensitive policy development the exemption was intended to protect. The redaction of such content not only stretches the scope of Article 4(3) but also obstructs public oversight of EU-funded activities.
3. Failure to Conduct a Meaningful Public Interest Test
The EUAA claims in its letter that a public interest test was conducted but determined not to outweigh the risks posed by disclosure. Yet the Agency provides no reasoning, no weighing of harms versus benefits, and no document-by-document explanation of how that test was applied.
According to established case law (see Technische Universität München v Commission, C-139/07 P, paras. 38–40), when an exception applies, the institution must still assess whether an overriding public interest in disclosure justifies access. This is particularly relevant where, as here, the documents concern vulnerable populations, the use of EU public funds, and operational procedures subject to legal and public scrutiny.
This obligation is further heightened by the fact that the documents concern the treatment of unaccompanied minors (UAMs) -- a population that has been the focus of sustained public attention, media coverage, and institutional scrutiny at both national and EU levels. Several EU and Greek authorities have highlighted systemic issues relating to reception conditions, delays in guardianship, and family reunification procedures for UAMs. In this context, the public interest in accessing information about how these children are treated in EU-funded facilities is especially compelling. The Agency’s failure to conduct and document a proper public interest balancing exercise, particularly for content directly concerning the welfare and legal status of unaccompanied minors, constitutes a breach of Article 4 of Regulation 1049/2001.
4. Withholding of Statistical and Operational Data – Article 4(1)(b)
The redaction of general numerical and statistical data is unjustified. I explicitly requested data related to the number of asylum seekers, UAMs, reception capacity, and procedural delays — none of which constitutes personal data within the meaning of Article 4(1)(b).
In Document 03 (Samos, Dec 2024) and Document 04 (Kos, Jan 2025), for example, the number of unaccompanied minors present is redacted. In Document 34 (Lesvos, Jan 2025), even age-verification statistics for minors are withheld: “We had REDACTED cases of minors who turned 18 on January 1, 2025…”. These are precisely the types of figures that are routinely published by other EU institutions and national authorities. Their redaction runs counter to the proportionality principle and the obligation to interpret exceptions narrowly (Council v Hautala, C-353/99 P, para. 28).
5. Improper Redaction of UAM and Family Reunification Information
Several documents include redactions that obstruct public oversight of how unaccompanied minors are treated -- a key aspect of this request.
In Document 32 (Kos, Jan 2025), the following excerpt is redacted in part:
“There is only one guardian from the NGO Metadrasi. Τhe minors are almost REDACTED accommodated in the safe area. As a result, the procedures are delayed, and REDACTED minors have been waiting for a decision on their guardianship for a long period.”
Likewise, the redaction of information about referrals to Equal Rights Beyond Borders for legal aid and custody cases directly undermines transparency in a critical area of public interest.
Document 12 (Leros, Dec 2024) contains several references to family separation and reunification, yet relevant portions are redacted without justification. These omissions come despite the fact that the Agency routinely collaborates with third parties and national authorities on such cases, and that such coordination is part of EU-funded fieldwork that should be subject to democratic accountability.
6. Redaction of Key Operational Categories
Many of the documents redact entire standard sections — not because they contain sensitive information, but seemingly as a matter of blanket policy.
In the documents below, general blanket redaction of the “Challenges, Issues, & Action Points,” section, particularly the “Description of Action Needed,” “Who Needs to Act,” and “Status (solved, pending)” columns, as well as redaction of the “Recommendations” section.
01.ELAS1.1_Field-Asylum_2024.12_Kos_Redacted.pdf
02.ELAS1.1_Field-Asylum_2024.12_Leros_Redacted.pdf
03.ELAS1.1_Field-Asylum_2024.12_Samos_Redacted (Recommendations section redacted)
04.ELAS1.1_Field-Asylum_2025.01_Kos_Redacted.pdf
10.ELAS1.2_Field-Asylum_2025.01_Samos_Redacted.pdf (“Challenges, Issues, & Action Points” section heavily redacted)
27.ELREC2.1_Field-Reception_2024.12_Kos_Redacted.pdf
28.ELREC2.1_Field-Reception_2024.12_Leros_Redacted.pdf
29.ELREC2.1_Field-Reception_2024.12_Lesvos_Redacted.pdf
30.ELREC2.1_Field-Reception_2024.12_Samos_Redacted.pdf
31.ELREC2.1_Field-Reception_2025.01_Chios_Redacted.pdf (Recommendations section completely redacted)
32.ELREC2.1_Field-Reception_2025.01_Kos_Redacted.pdf
33.ELREC2.1_Field-Reception_2025.01_Leros_Redacted.pdf
34.ELREC2.1_Field-Reception_2025.01_Lesvos_Redacted.pdf
42.ELREC2.3_Field-Reception_2025.01_Samos_Redacted.pdf
In the documents below, general blanket redaction of the “Recommendations & Good practices” section:
05.ELAS1.1_Reg-Admin-Info_2024.12_KOS_Redacted.pdf
16.ELREC2.1_2024.12_LESVOS_Redacted.pdf
22.ELREC2.1_2025.01_Lesvos_Redacted.pdf (almost entirely redacted)
24.ELREC2.1_2025.01_LESVOS_Redacted.pdf
This approach violates the obligation to apply exceptions narrowly and proportionately and fails to respect Article 4(6), which requires that partial access be granted wherever possible. The Court held in Kuijer v Council (T-188/98, para. 38) that institutions must consider whether redacted or partial access is feasible -- a requirement the Agency has failed to meet.
7. Arbitrary and Disproportionate Redactions by Location
A particularly concerning pattern has emerged in how redactions are applied disproportionately across different field offices. Documents from Samos (e.g., 03, 10, 25, 30, 42) are far more heavily redacted than those from comparable facilities, despite covering similar operational ground. This raises serious concerns about the arbitrary or inconsistent application of Regulation 1049/2001 across EUAA operational sites.
Conclusion and Request
For all the reasons outlined above, I request that the EUAA conduct a new, case-by-case assessment of the documents identified in PAD 005269. This reassessment must comply with the legal obligations established in Regulation 1049/2001 and relevant case law. Specifically, the Agency must: Conduct a genuine overriding public interest test for all redacted material; Reassess the redaction of non-personal numerical and operational data; Disclose, in full or in part, the “Challenges, Issues, & Action Points,” “Recommendations,” and “Recommendations & Good practices” sections; Provide specific, individualized reasoning for any remaining redactions, rather than general appeals to public security or internal deliberation; Comply with Article 4(6) by granting partial access wherever possible.
Should further clarification be required, I remain available. I request that the Agency respond to each argument individually, as required by Case T-188/98.
Yours sincerely,
Lydia Emmanouilidou
[email address]
Dear Public Access To Documents Mailbox,
I am writing to follow up on a confirmatory application I submitted on 11 April 2024. I would like to kindly remind the EUAA of its obligation to register the application without delay, in accordance with Regulation 1049/2001.
Thank you for your attention to this matter. I appreciate your cooperation.
Sincerely,
Lydia Emmanouilidou
Dear Ms Emmanouilidou,
Reference is made to your below correspondence dated 11 April 2025.
We hereby acknowledge receipt of your confirmatory application for access
to documents under Regulation (EC) No 1049/2001, which was registered
under reference number 005586 on 16 April 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 14 May 2025. In case this
time limit needs to be extended, you will be informed in due course.
Sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents
(confirmatory) under Regulation (EC) No 1049/2001, which was registered
under reference number 005586 on 16 April 2025.
Please note that your application is currently being handled by the EUAA
in accordance with Regulation (EC) No 1049/2001 and the Agency’s
Management Board Decision No 6. However, the EUAA will not be in a
position to complete the handling of your application within the initial
time-limit of 15 working days, which is due to expire on 14 May 2025.
An extended time-limit is needed given that additional administrative
efforts are required in terms of, inter alia, carrying out consultations
and making comprehensive assessments against Article 4 of Regulation (EC)
No 1049/2001 - in order to be able to duly process your request in the
most diligent manner in accordance with the principle of good
administration.
In light of the above, the Agency has decided to extend the time-limit by
an additional 15 working days in accordance with Article 7(3) of
Regulation (EC) No 1049/2001. The new time limit is due to expire on 6
June 2025. Nonetheless, the Agency strives to get back to you as swiftly
as possible.
Sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
From: Public Access To Documents Mailbox
Sent: 16 April 2025 10:12
To: Lydia Emmanouilidou <[FOI #15524 email]>
Subject: RE: Internal review of access to documents request - UAM reports
December 2024 - Feb 2025
Dear Ms Emmanouilidou,
Reference is made to your below correspondence dated 11 April 2025.
We hereby acknowledge receipt of your confirmatory application for access
to documents under Regulation (EC) No 1049/2001, which was registered
under reference number 005586 on 16 April 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 14 May 2025. In case this
time limit needs to be extended, you will be informed in due course.
Sincerely,
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
Dear Ms Emmanouilidou,
Kindly find enclosed a letter from Mr Mikael Ribbenvik Cassar, Deputy
Executive Director of the EUAA, in response to your confirmatory
application for access to documents under Regulation (EC) No 1049/2001.
Sincerely,
European Union Agency for Asylum
Email: [1][EUAA request email]
Website: [2]https://euaa.europa.eu
Disclaimer: Please be informed that the easo.europa.eu domain is being
phased out. Please update your contact records with the EUAA domain name.
From: Public Access To Documents Mailbox <[EUAA request email]>
Sent: 13 May 2025 10:57
To: Lydia Emmanouilidou <[FOI #15524 email]>
Cc: Public Access To Documents Mailbox <[EUAA request email]>
Subject: RE: Internal review of access to documents request - UAM reports
December 2024 - Feb 2025
Dear Ms Emmanouilidou,
Reference is made to your application for access to documents
(confirmatory) under Regulation (EC) No 1049/2001, which was registered
under reference number 005586 on 16 April 2025.
Please note that your application is currently being handled by the EUAA
in accordance with Regulation (EC) No 1049/2001 and the Agency’s
Management Board Decision No 6. However, the EUAA will not be in a
position to complete the handling of your application within the initial
time-limit of 15 working days, which is due to expire on 14 May 2025.
An extended time-limit is needed given that additional administrative
efforts are required in terms of, inter alia, carrying out consultations
and making comprehensive assessments against Article 4 of Regulation (EC)
No 1049/2001 - in order to be able to duly process your request in the
most diligent manner in accordance with the principle of good
administration.
In light of the above, the Agency has decided to extend the time-limit by
an additional 15 working days in accordance with Article 7(3) of
Regulation (EC) No 1049/2001. The new time limit is due to expire on 6
June 2025. Nonetheless, the Agency strives to get back to you as swiftly
as possible.
Sincerely,
European Union Agency for Asylum
Email: [3][EUAA request email]
Website: [4]https://euaa.europa.eu
From: Public Access To Documents Mailbox
Sent: 16 April 2025 10:12
To: Lydia Emmanouilidou <[5][FOI #15524 email]>
Subject: RE: Internal review of access to documents request - UAM reports
December 2024 - Feb 2025
Dear Ms Emmanouilidou,
Reference is made to your below correspondence dated 11 April 2025.
We hereby acknowledge receipt of your confirmatory application for access
to documents under Regulation (EC) No 1049/2001, which was registered
under reference number 005586 on 16 April 2025.
In accordance with Regulation (EC) No 1049/2001 regarding public access to
European Parliament, Council and Commission documents and Decision No 6 of
the Management Board of EASO laying down practical arrangements regarding
public access to documents of EASO (now EUAA), your application will be
handled within 15 working days from the day of registration.
The (initial) time limit is set to expire on 14 May 2025. In case this
time limit needs to be extended, you will be informed in due course.
Sincerely,
European Union Agency for Asylum
Email: [6][EUAA request email]
Website: [7]https://euaa.europa.eu