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