detention of children also by recent national administrative court decisions. 282 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. 283 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. 284 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. 285 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 286 (see also Identification). The registration of initial asylum claims on the islands was conducted by the RIS. In Kos, a Pre-removal Detention Center (PRDC) of nominal capacity of 567 places is operational. 287 Lastly, there are growing concerns regarding the provision of Reception and Identification services at entry points deprived of reception facilities and services, until the transfer of the newcomers in RICs and CCACs. Even in Rhodes, Gavdos and Crete, where there is a steady flow of arrivals,288 there is no provision for the satisfaction of not even the most basic needs of the people arriving with regard to respect for human dignity until their transfer. As a result, access for new arrivals to fundamental rights such as housing, food and health care, an obligation and responsibility of the central administration, is left to the discretion of local authorities and civil society. Up until spring 2024, newcomers from Grete/Gavdos were transferred directly to PRDCs, where they remained detained without being subjected to any Reception and Identification Procedures, in contravention with what the Law provides. Following reactions, arrivals from Crete/Gavdos are channeled to RICs in the mainland for registration. Every person arriving in the Aegean Islands without documentation must be brought by the Police or the Coast Guard to the nearest of the five island CCAC or the three mainland RIC for the purposes of identification.289 Concerns are raised regarding individuals who arrived in Rhodes and remained undetected by the authorities there. Some of them reach Kos on their own by boat and present themselves to the police authorities. The latter issue a decision for return and a police note (Υπηρεσιακό Σημείωμα) granting them 25 days to return, despite the fact that they have express their will to apply for asylum. Additionally, the RAO refuses to schedule and conduct their registration on the grounds that their registration falls under the competency of RICs of Malakasa/Diavata. Many cases result in detention upon expiration of the 25 days to return and individuals end up filing their asylum application from detention, as detainees. During detention, they have no access to RIS services, as they are not considered newcomers by the RIS. Therefore, they are not provided –amongst others- with Reception and Identification procedures and they are not assessed regarding potential vulnerabilities. This is the case even following their release, regardless the fact that they might be asylum seekers at the time. Only detainees released 282 283 284 285 286 287 288 289 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. MoMA, Reception and Identification Service, Reception and Accommodation, RIC and CCAC, Kos CCAC, available here. RSA, ‘Crete – Gavdos: Sixfold increase in refugee arrivals in 2024 – Lack of organised first reception and accommodation infrastructure’, 30 January 2025, available at: https://tinyurl.com/2k59jnm3. Parliamentary Control No. 517/30.10.2024 Question to Hellenic Parliament, available in Greek at: https://tinyurl.com/ys6nwynh. 66