In Kos, a Pre-removal Detention Center (PRDC) of nominal capacity of 567 places is operational. 291 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,292 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.293 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 following objections before the Administrative Court of First Instance of Rhodes are accepted in the CCAC, provided the decision accepting Objections is requesting the Administration to ensure their access to RIS’ services.294 Actors present in the RIC and CCACI In addition to civil society organisations, a number of official actors are present in the RIC facilities on the islands, including RIS, Frontex, the Asylum Service, the EUAA and the Hellenic Police. Police: The Police is responsible for guarding the external area of the hotspot facilities, as well as for the identification and verification of nationalities of newcomers. According to the IPA, the registration of the applications for international protection, the notification of the decisions and other procedural documents, as well as the registration of appeals may be carried out by police staff. 295 Moreover, in exceptional circumstances, the interviews of the applicants under the “fast track border procedure” may be carried out by police staff, provided that they have received the necessary basic training in the field of international human rights law, the EU asylum acquis and interview techniques.296 However, during 2023 and 2024 all the interviews, including those of the “fast track border procedure“, were exclusively conducted by EUAA or Asylum Service staff. Finally, the decisions on applications for international protection are always taken by the Asylum Service. Frontex: Frontex staff also participates in the identification and verification of nationalities. Although Frontex should have an assisting role, in practice, it conducts nationality screening almost exclusively, as 291 292 293 294 295 296 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. Based on GCR observations on the field. Article 90(2) IPA. Article 90(3), b IPA. 71