behalf of ten unaccompanied children held in the so-called “safe zone” of the CCAC of Kos. Some of the children had already been detained for five months under conditions described as overcrowded, unhygienic, and unsafe, with the presence of insects, insufficient food in both quality and quantity, and no access to medical or psychological care. The Court ordered the Greek authorities to provide adequate reception conditions, sufficient food and clean water, new clothing, bedding and hygiene products, to ensure access to appropriate medical and psychological care, and facilitate their swift transfer to shelters or other suitable accommodation in accordance with Greek law. 282 Similarly, on 23 June 2025, the ECtHR granted interim measures for thirteen unaccompanied children detained in the “safe zone” of the CCAC of Leros, ordering the authorities to urgently provide clothing, hygiene items, medical care, and to relocate the children to safe and appropriate accommodation. 283 Earlier, on 12 May 2025 and 19 May 2025, the Court had issued similar interim measures concerning a total of forty-six unaccompanied children residing in the “safe zone” of the Samos CCAC. 284 Since detention (or “protective custody”, as it was called) was officially abolished in Greece in 2020, 285 the prolonged restriction of minors in the “SAFE Zones” of CCACs has been characterised as de facto detention of children also by recent national administrative court decisions. 286 The situation of overcrowding and de facto detention under inadequate living conditions remains the reality for unaccompanied minors in CCACs waiting placement in shelters. Since the implementation of the EU-Türkiye Statement, all newcomers are registered by the RIS. 287 In 2024 the pace of conclusion of Reception and Identification Services has been accelerated compared to 2023. According to GCR observations from the field, as a rule RIS’ registration is completed with few days. As already reported, during 2024, due to the understaffing of the Medical and Psychosocial Divisions of the RIS, coupled with the limited interpretation services, there were recorded significant shortcomings or lack of provision of medical and psychosocial assessment/services, as required by law. 288 Moreover, a long lasting issue regarding Identification Procedures concerns the lack of transparency in the way the authorities identify newcomers’ data, such as their country of origin. 289 In many cases, the Police and/or Frontex determine a nationality to individuals- different to what the latter had declared- in a way that this determination cannot be disputed and challenged. For example, stateless Bidoons born and raised and/or residing for years in Kuwait are erroneously identified as Iraqi nationals and Eritreans with lengthy residence in Ethiopia are incorrectly identified as Ethiopian nationals 290 (see also Identification). The registration of initial asylum claims on the islands was conducted by the RIS. 282 283 284 285 286 287 288 289 290 ECtHR, Interim Measure Decision, Application no. [details confidential], Kos CCAC – 10 unaccompanied minors, 2 July 2025. (Legal representation by NGO, Equal Rights Beyond Borders, Press Release available at: https://tinyurl.com/bdz9cf9e). ECtHR, Interim Measure Decision, Application no. [details confidential], Leros CCAC – 13 unaccompanied minors, 23 June 2025 (Legal representation by ΝGO Equal Rights Beyond Borders, Press Release available at: https://tinyurl.com/4hdjdffu). ECtHR, Interim Measure Decisions, Samos CCAC – 21 and 25 unaccompanied minors, 12 and 19 May 2025 respectively (Legal representation by ΝGO Human Rights Legal Project, Press Release available at: https://tinyurl.com/348m85bv). Article 43 of law 4760/2020. See e.g., 1st Instance Administrative Court of Syros, Decision ΑΡ 7/2025, 21 February 2025; 1st Instance Administrative Court of Rhodes, Decision ΑΡ 16/2025, 5 March 2025; see also, Human Rights Legal Project, ‘Court Acknowledges De Facto Detention, Declares it Unlawful in Groundbreaking Decision’ (21 February 2025), available at: https://tinyurl.com/bdjxcs4r; see also, Equal Rights Beyond Borders, ‘Greek Court Rules Minor‘s Stay in “Safe Zone” as Unlawful Detention’ (12 March 2025), available at: https://tinyurl.com/547kfjzn. Article 8(2) L 4375/2016 as amended by Article 116(3) L 4636/2019, Article 9 L 4375/2016 as amended by Article 39 IPA; see also, Ministerial Decree No 1/7433, Governmental Gazette Β 2219/10.6.2019, General Operation Regulation of the RICs and the Mobile Units of Reception and Identification. Equal Rights Beyond Borders, HIAS Greece & RSA, Tthe state of the border procedure on the greek islands, September 2022, available at: https://bit.ly/3AtPXLu, 13. Equal Rights Beyond Borders, HIAS Greece & RSA, Tthe state of the border procedure on the greek islands, September 2022, available at: https://bit.ly/3AtPXLu, 13. RSA, The Workings of the Screening Regulation, January 2021, available here. GCR’s observation on the file. 70

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