depending on the capacity of the Asylum Service and the number of detainees willing to apply for asylum. Delays in the full registration of asylum applications lodged by detainees results in the deprivation of basic procedural guarantees and in delays as regards the asylum procedure in detention, including the excess of the three months’ maximum detention time limit provided by law for asylum seekers.13 • Detention is imposed against persons who belong to vulnerable groups, including those who suffer physical or mental health issues, and families with minors and unaccompanied children (UAMs).14 The immigration detention of children is not prohibited by national law. There is a critical lack of reception capacity for UAMs, which results in unaccompanied children being held in “protective custody” in substandard conditions as they await transfer to an ageappropriate facility. Detention on the basis of the provisions concerning “protective custody” is not subject to a maximum time limit.15 No assessment of the best interests of the child takes place before or during detention. Moreover, no age assessment procedure is provided by the national framework to be applied by the Hellenic Police for minors held in detention. Thus, children may find themselves detained with adults due to their wrongful identification and registration as adults and shortcomings in age assessment procedures.16 As of 30 September 2019, 238 children remained under “protective custody” in police facilities while an additional number of UAMs remained in conditions tantamount to de facto detention in Evros Reception and Identification Centre (RIC).17 In 2019, the European Court of Human Rights has twice granted interim measures under Rule 39 with regards to UAMs who remained detained in Tavros Preremoval Detention Facility, Kolonos Police Station (Athens), and Amigdaleza Pre-removal Detention Facility, while awaiting to be transferred to a shelter.18 In May 2019, the European Committee of Social Rights of the Council of Europe urged the Greek authorities to take “immediate measures” with a view to avoiding serious, irreparable injury to the integrity of migrant minors at immediate risk of life, physical and moral integrity and inter alia “to ensure the UN High Commissioner for Refugees (UNHCR), “Recommendations by the Office of the United Nations High Commissioner for Refugees Concerning the Execution of Judgments by the European Court of Human Rights in the Cases of M.S.S. v. Belgium and Greece and of Rahimi v. Greece,” https://search.coe.int/cm/Pages/result_details.aspx?ObjectId=090000168094938c; Greek Council for Refugees (GCR), “Administrative Detention in Greece: Findings from the Field, 2018.” 13 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).” 14 Article 118 PD 141/1991. Greek Council for Refugees (GCR), “AIDA Report on Greece, Update 2018,”; see also: “Submission by the UNHCR in the case of International Commission of Jurists (ICJ) and European Council for Refugees and Exiles (ECRE) v. Greece (Complaint No. 173/2018) before the European Committee of Social Rights,” August 2019, https://rm.coe.int/cc173casedoc5-en-observations-by-theunhcr/168096c416 15 16 17 National Center of Social Solidarity (NCSS), “Situation Update: Unaccompanied Children (UAC) in Greece,” 30 September 2019, https://data2.unhcr.org/en/documents/download/71629 Greek Council for Refugees (GCR), “The European Court of Human Rights Grants Interim Measures in Favour of Two Detained Unaccompanied Girls,” 28 March 2019, https://bit.ly/36dGMyi; Arsis, “The ECHR Grants Interim Measures Putting an End to the Detention of Unaccompanied Minors in Police Stations,” 10 October 2019, http://www.arsis.gr/en/press-release-the-echr-grants-interim-measuresputting-an-end-to-the-detention-of-unaccompanied-minors-in-police-stations/; Efsyn.gr, “The ECtHR Issues a Second Decision on Interim Measures for Unaccompanied Minors”, 18 October 2019, https://www.efsyn.gr/ellada/koinonia/215393_deyteri-apofasi-asfalistikon-metron-apo-edda-giaasynodeytoys-anilikoys 18 GDP & GCR 2019 7