have applied for international protection and against whom a detention decision is issued,” which would be “organised like Pre-removal Detention Centres,” in effect mandating the creation of new detention centres.9 • Immigration detention is on rise. The number of administrative detainees in Greece is one of the highest among all EU member states. Following a significant reduction of the number of detainees in 2015, the use of administrative detention has been gradually resumed, in particular after the launch of the EU-Turkey Statement of 18 March 2016. A total number of 31,126 detention orders were issued in 2018, compared to 25,810 in 2017. The total number of asylum seekers detained in 2018 was 18,204, almost doubling 2017 figures (9,534). Out of the total 2,933 persons detained by the end of 2018, 1,815 were asylum seekers.10 • No individual assessment procedure prior to the imposition of detention is in place and detention continues to be applied indiscriminately, including against vulnerable applicants—families with children, persons suffering from mental health problems, victims of torture, among others—while non-custodial “alternatives” are not examined or applied in practice. This results in migrants and asylum seekers being systematically detained. Within the framework of the EU-Turkey Statement, in Lesvos and Kos island, authorities continue to automatically detain upon arrival and for the entire asylum procedure, asylum applicants from countries that have low asylum recognition rate (below 25% in Lesvos and below 33% in Kos).11 • In contrast to the EU Returns Directive, Greek legislation includes ground for detention on account of threat to public order or national security. Public order is used as a ground for detention in an excessive and frequently wholly unjustified manner. This is particularly the case where these grounds are based solely on a prior prosecution for a minor offence, even if no conviction has ensued, or in cases where the person has been released by the competent Criminal Court after the suspension of custodial sentences. In addition, detention on national security or public order grounds has been also ordered for reasons of irregular entry into the territory, contrary to Article 31 of the Refugee Convention and the prohibition on detaining asylum seekers on account of their irregular entry or presence under Article 46(1) of Law 4375/2016.12 • Access to the asylum procedure while in detention remains a matter of serious concern as the full registration of the asylum application of detainees is delayed See: Greek Council for Refugees (GCR), “GCR’s Comments on the Draft Bill ‘On International Protection,’” 21 October 2019, https://www.gcr.gr/media/k2/attachments/GCR_on_bill_about_International_Protection_en.pdf 9 Greek Council for Refugees (GCR), “AIDA Report on Greece, Update 2018,” https://www.asylumineurope.org/reports/country/greece; Greek Council for Refugees (GCR), “Administrative Detention in Greece: Findings from the Field (2018), Executive Summary,” https://www.gcr.gr/media/k2/attachments/GCR_Leaflet_ENGL_small_v1.pdf 10 Greek Council for Refugees (GCR), “AIDA Report on Greece, Update 2018”; Greek Council for Refugees (GCR), “Administrative Detention in Greece: Findings from the Field (2018),” https://www.gcr.gr/media/k2/attachments/GCR_Leaflet_ENGL_small_v1.pdf 11 Greek Council for Refugees (GCR), “AIDA Report on Greece, Update 2018”; Greek Ombudsman, “Return of Third Country Nationals, Special Report,” 2018, https://www.synigoros.gr/resources/docs/english-final.pdf 12 GDP & GCR 2019 6