43 order after the reception and identification has accounted for an individual’s specific procedures were completed. In other needs or vulnerabilities, such as the need words, by the time RIS issued the for medical care or access to legal services restriction order, the sole legal basis for it outside the CCAC. Finally, the conditions of no longer existed. Even once RIS began the CCAC may raise potential issues under Art. issuing the decision before completing the 3 ECHR, particularly given that at the time of reception and identification procedures, reporting there was no permanent doctor or the practice remained unlawful. To start, psychologist working inside the CCAC. Art. 40 states that “the decision to extend the restriction of liberty for the purposes of completing the reception and However, such an assessment requires further reporting on the conditions of the CCAC that is outside the scope of this report. identification procedures under the conditions of this case shall contain factual and legal justification and shall be in writing.”117 Moreover, as the restriction of liberty amounts to detention, both EU and Greek law oblige the authorities to assess if the detention is both necessary and proportional.118 However, like the police do D. The CCAC Greece inaugurated the first EU-Funded CCAC on Samos in September 2021.119 Just a few months later in November 2021, two new CCACs opened on Leros and Kos,120 although the Kos CCAC has only been in use since August 2022. The Greek government has hailed for administrative detention in the PRDC, the CCACs as part of a “new period for RIS Kos issues asylum seekers template 25- migration,”121 and promoted them as a day orders that say little more than the departure from the past conditions on the applicant’s freedom is restricted to the islands and as containing “all the modern CCAC until reception and identification technical and functional infrastructure that procedures are complete and for a period makes them safe […] with upgraded living not exceeding 25 days. Indeed, Equal conditions […] that aim to ensure decent living Rights has never seen a 25-day order that Art. 40(a) L. 4939/2022. See Art. 50 L. 4939/2022; Art. 8 Directive 2013/33/EU. 119 Hellenic Republic Ministry of Migration & Asylum, The Minister for Migration and Asylum, Mr. Notis Mitarachi, inaugurated the new closed controlled access center in Samos, Press Office (18 September 2021) available at: https://bit.ly/3vT0wFD. 120 Hellenic Republic Ministry of Migration & Asylum, N. Mitarachi: Today in Leros and Kos, as a few days ago in Samos and in a few months in Chios and Lesvos, we inaugurate the new Closed Controlled Access Centers, with a view to the future. Images we can all recall from the period 117 118 conditions for asylum seekers.”122 The Ministry of Migration advertises that the Kos CCAC has 2015-2019 belong definitely to the past, Press Office (27 November 2021), available at: https://bit.ly/3WYzFTS. 121 Hellenic Republic Ministry of Migration & Asylum, The Minister for Migration and Asylum, Mr. Notis Mitarachi, inaugurated the new closed controlled access center in Samos, Press Office (18 September 2021), available at: https://bit.ly/3vT0wFD. 122 Hellenic Republic Ministry of Migration & Asylum, The Minister for Migration and Asylum, Mr. Notis Mitarachi, inaugurated the new closed controlled access center in Samos, Press Office (18 September 2021), available at: https://bit.ly/3vT0wFD. ‘Still detained and forgotten’ – Update on Detention Policies, Practices, and Conditions on Kos 2022/23