does not comply with the right to liberty as it is not applied for any of the reasons exhaustively listed under article 5 of the European Convention on Human Rights. Detention sanctioned under article 13(6)(b) is a solution to the constant problem of insufficient reception facilities, giving the authorities an unlimited amount of time and thus discretion before transferring the child (GCR 2012). According to Amnesty International and HRW, in practice unaccompanied minors are routinely detained because they can only be released once they are accorded a place in a reception centre. Since there are not enough places in reception facilities, they remain detained for prolonged periods. AI expressed concern that in the centres in Athens and Evros children are detained with adults or are registered as adults. They are not spared from harsh detention conditions. AI reported cases of children held in the Soufli Border Guard Station for three months without the possibility to go outdoors (AI 2013a; AI 2012; HRW 2012a). The WGAD and the CAT have expressed concern over the frequent failure to properly register unaccompanied minors and their systematic detention. In particular, the UN bodies reported that national legislation did not provide for a statutory prohibition of the detention of unaccompanied minors and that due to the limited capacity of existing reception facilities, unaccompanied minors often remain in detention for prolonged periods (WGAD 2013; CAT 2012). The CAT urged Greece to “strengthen its efforts to provide adequate protection and proper care in respect of unaccompanied or separated minors entering the country, including by promptly amending its legislation to prohibit their detention. The Committee concurs with the recommendation of the Special Rapporteur on the question of torture that the Ministry of Health and the Ministry of Interior should cooperate closely to ensure that they are placed in suitable and separate reception centres” (CAT 2012). The UN Committee on the Rights of the Child (CRC) called on Greece in 2012 to “[e]nsure that children, either separated or together with their families, who enter the country in an irregular manner, are not detained, or remain in detention only in very exceptional circumstances and for the shortest period of time necessary” (CRC 2012). Places of detention. Greek law provides an open-ended framework for where people can be detained for immigration-related reasons, stipulating that they can be held in police facilities and any site designated by a range of government ministries. According to Article 81 of Law 3386/2005: “1. Aliens who fulfill the requirements of paragraph 3 of article 76 hereof shall be detained at the relevant police authority. Until the completion of expulsion procedures, they shall be detained in special premises, established by decision of the Ministers of Interior, Public Administration and Decentralisation, of Economy and Finance, of Health and Social Solidarity and of Public Order. The same decision shall determine the standards and terms of operation of such premises. 2. The Hellenic Police shall be responsible for guarding such special premises.” Non-custodial measures. Non-custodial “alternatives to detention” were introduced following transposition of the Returns Directive. Non-nationals may be placed in preremoval detention if no other sufficient but less coercive measures can be applied 9