Moreover, UACs are not provided with any written decision as to why they cannot leave the CCAC. As such this places the restriction of their liberty in variance with EU law which requires, in situations that people are detained, that there should be a written decision issued to the applicant, in a language they are reasonably expected to understand, highlighting the reasons, in fact and in law, for their detention.[110] The only time unaccompanied children can leave the so called "safe-zone" and enter the general population of the CCAC. 12am 4am 8am 12pm 4pm 8pm 12am I Have Rights has consistently raised their concern regarding the detention of UACs in the CCAC including inhuman living conditions, deficiencies in the age and vulnerability assessment procedures, lack of access to asylum including access to a lawyer and lack of access to basic services for UACs in the CCAC. [111] Children in the so-called "safe-zone" are unable to leave the CCAC and as such are de facto detained for extended periods, with UACs often staying in the CCAC for on average up to four months. Through conversations with actors that work in the Samos CCAC, I Have Rights has learnt that the detention of UACs has contributed to children’s reticence to challenge age assessments which incorrectly determine them to be adults as they fear that appealing means they will remain stuck in the procedure for UACs, which so far has resulted in their detention. This is hardly surprising when, in addition to being de facto detained for extended periods, UACs are left with limited access to essential services.[112] Their access to education is dependent on a NGO that provides informal education as, despite the law giving them the right to enrol at public schools, the RIS refuses to register them at Samos public schools. This can be compared with Commissioner Johansson’s promise that CCACs "[...]will allow children to get schooling – essential so that precious years are not wasted".[113] [110] Directive 2013/33/EU of the European Parliament and of the Council of 26 June 2013 laying down standards for the reception of applicants for international protection (recast). Article 9(4), ECHR, Article 5 (2). [111] I Have Rights and Still I Rise. 2022. The Committee of the Rights of the Child Sides with Still I Rise and I HAVE RIGHTS. Available here. [112] Ibid. [113] Ylva Johansson. 2023. Spring is the best time to prepare for Winter – why I am visiting Lesvos now. Available here. Page 30

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