freedom within the premises of the RIC for a period of maximum 25 days, or under a deportation decision
together with a detention order. This differs from the “geographical restriction” on the island, mentioned
below.
In practice, newcomers arriving on the Eastern Aegean islands and falling under the EU-Türkiye
Statement were subjected to a “restriction of freedom of movement” decision issued by the Head of the
RIC, preventing them from exiting the RIC until their registration and identification by the RIS. At the same
time, upon arrival, a removal decision “based on the readmission procedure” and a pre-removal detention
order was issued by the competent Police Directorate upon arrival, parallel to the decision of the Head of
the RIC. The removal decision and detention order are suspended by a “postponement of deportation”
decision of the General Regional Police Director. The latter decision imposed a geographical restriction,
ordering the individual not to leave the island and to reside – in most cases – in the RIC or another
accommodation facility on the island until the end of the asylum procedure.
Once the asylum application was lodged, a geographical restriction was applied by the Asylum Service
as well as by the RIS, by including relevant marking on the International Protection Applicant Card. For
more details on the geographical limitation on the Greek Eastern Aegean Islands, see Reception
Conditions, Freedom of movement. It is due to this practice of indiscriminate and en masse imposition of
the geographical limitation measures to newly arrived persons on the islands that a significant
deterioration of the living conditions on the islands has occurred.
Situation upon arrival in CCACs
Although the Rule of Procedure of CCAC on the islands does not provide for a blanket prohibition of exit,
the regime of de facto detention has been reintroduced in practice since the implementation of the CCAC
in 2021. According to the Asylum Code, this ‘restriction of liberty’ which amounts to de facto detention
shall not exceed 25 days from the day of arrival in the RIC or CCAC, Also, the ‘restriction of liberty’ is
provided in the Law by way of exception. 271 However, upon arrival especially when the arrivals are
increased and registration procedures are conducted with delay, newcomers might be placed under
arbitrary restriction of liberty until their registration by the RIS is concluded. Until then, people are denied
exit from the CCACs and certain cases they are restricted in the so-called ‘waiting areas’. Moreover, in
few cases, newcomers remained under arbitrary restriction of their liberty for more than 25 days. 272
Decisions imposing the ‘restriction of liberty’ shall be issued by the Head of the RIS within five days from
the arrival. However, it has been observed that these are not always notified as provided by the Law to
the de facto detained persons.
During 2024, registrations and identification procedures were concluded in a much faster pace, compared
to 2023 and therefore ‘waiting periods’ were eliminated or reduced to few days, unless mass arrivals
occurred and/or limited interpretation services- especially in certain languages- resulted in delays. In the
majority of the cases newcomers waiting to be registered are placed directly in sections of the CCACs
used as accommodation areas. In Kos and Samos, sections used in past as ‘Safe Areas’, in which dire
conditions prevail, might host the newcomers until registration. In Chios, the so called ‘Agnodikis’ section,
which was previously used as COVID-19 quarantine site, has been used in exceptional cases as a ‘waiting
area’. Moreover, in Lesvos exit from the accommodation structures (‘οικίσκους’) where newcomers are
placed, is permitted only in case of emergency until registration. During their waiting period, confined
newcomers have extremely hindered access to any services, including medical support, unless urgent
medical needs occur. The potential repercussions for limited access are significant, as newcomers are
frequently exposed to violence en route and/or in their country of origin and present specific health
vulnerabilities. This includes, for example, survivors of shipwrecks, GBV survivors, pregnant women,
individuals with non-communicable chronic diseases, such as diabetes or cardiovascular conditions who
may need immediate (health) support.
Based on observation from the field, in practice, newcomers are allowed to exit the CCACs following
registration, despite the imposition of the ‘restriction of liberty’, with the exception of Samos that followed
different practices during the reporting period.273
271
272
273
Article 40 (a) L.4939/2022
GNCHR, On-site visit to Samos: Non-compliance with basic standards reception conditions at the CCAC of
Samos, 2 April 2024, available in Greek here.
GNCHR, On-site visit to Samos: Non-compliance with basic standards reception conditions at the CCAC of
Samos, 2 April 2024, available in Greek here.
64
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