A geographical restriction is also systematically imposed on every newly-arrived person on the Greek islands by the Head of the Asylum Service, imposing the obligation to remain on the islands. This is separate to the decision of the Head of the CCAC imposing a de facto detention period of up to 25 days, within the premises of the respective CACC (so-called “restriction of movement”). For more details on the geographical limitation on the Greek Eastern Aegean Islands, see Reception conditions - Freedom of movement. Unaccompanied children, are prohibited from exiting the “SAFE Zone”, which is a fenced container section of the CCACs guarded by security personnel and where they are subject to “restriction of liberty” until their placement and transfer to shelters for minors. During 2024, the waiting period for the placement of UAMs in a ‘restriction of liberty status’ in CCAC to shelters for minors was short. However, by the end of 2024n the waiting time had alarmingly increased. As a result, the number of minors in the “SAFE Zones” of CCACs of Samos, Leros and Kos by far exceeded the actual capacity of the sites, further restricting the already limited access to essential services for children, such as medical care, legal aid and representation, education and often lack of essential clothing, blankets and bedding. 274 Minister Nikos Panagiotopoulos noted during a visit in Samos on February 2025 that the designated “SAFE zone”, designed for 200 minors, currently held 500, many exceeding the 25-day legal stay limit, some even having stayed for over 120 days.275 Similarly, the Leros “SAFE Zone” had reached over two times the sections’ nominal capacity by the end of November 2024, with the people living under deplorable conditions and constant police interventions in the “SAFE Zone” section.276 On 5 February 2025, the European Court of Human Rights (ECtHR) acknowledged the grave risks that children in CCACs face and granted interim measures in the case O.A. and Others v. Greece concerning four unaccompanied children in the CCAC of Samos. The ECtHR ordered the Greek authorities, among other actions, “to ensure their protection from ill-treatment, if necessary, by facilitating their lodging of criminal complaints,” as children report being subjected to police violence within the so-called “safe areas”, recognising that due to the extreme congestion and the absence of child-appropriate services, these children’s daily lives are marked by tension, insecurity, and fear.277 This judgment is part of a growing body of recent interim measures by the ECtHR highlighting the ongoing serious risks and harmful, inappropriate conditions faced by children in the “safe zones” of island CCACs. On 2 July 2025, the ECtHR granted interim measures upon an urgent request submitted in late June on behalf of ten unaccompanied children held in the so-called “safe zone” of the CCAC of Kos. Some of the children had already been detained for five months under conditions described as overcrowded, unhygienic, and unsafe, with the presence of insects, insufficient food in both quality and quantity, and no access to medical or psychological care. The Court ordered the Greek authorities to provide adequate reception conditions, sufficient food and clean water, new clothing, bedding and hygiene products, to ensure access to appropriate medical and psychological care, and facilitate their swift transfer to shelters or other suitable accommodation in accordance with Greek law. 278 Similarly, on 23 June 2025, the ECtHR granted interim measures for thirteen unaccompanied children detained in the “safe zone” of the CCAC of Leros, ordering the authorities to urgently provide clothing, hygiene items, medical care, and to relocate the children to safe and appropriate accommodation. 279 Earlier, on 12 May 2025 and 19 May 2025, the Court had issued similar interim measures concerning a total of forty-six unaccompanied children residing in the “safe zone” of the Samos CCAC. 280 Since detention (or “protective custody as it was called) was officially abolished in Greece in 2020, 281 the prolonged restriction of minors in the “SAFE Zones” of CCACs has been characterised as de facto 274 275 276 277 278 279 280 281 GCR, Joint Press Release “Hundreds of unaccompanied children in Unsafe Zones: Need for an Immediate Activation of Relocation”, 05 December 2024, available at: https://tinyurl.com/vuyau9zh. Kathimerini, “Samos’ ‘safe zone’ leaves migrant kids in limbo, 28 February 2025, available at: https://tinyurl.com/27vyukbf. Δημοκρατική Ρόδου, ”Tense atmosphere in the accommodation of unaccompanied minors in the Facility of Leros”, 21 November 2024, available in greek at: https://tinyurl.com/y9ns2v88. ECtHR, O.A. and Others v. Greece, [Application no.2570/25]: available at: https://tinyurl.com/4juu77jz. ECtHR, Interim Measure Decision, Application no. [details confidential], Kos CCAC – 10 unaccompanied minors, 2 July 2025. (Legal representation by NGO, Equal Rights Beyond Borders, Press Release available at: https://tinyurl.com/bdz9cf9e). ECtHR, Interim Measure Decision, Application no. [details confidential], Leros CCAC – 13 unaccompanied minors, 23 June 2025 (Legal representation by ΝGO Equal Rights Beyond Borders, Press Release available at: https://tinyurl.com/4hdjdffu). ECtHR, Interim Measure Decisions, Samos CCAC – 21 and 25 unaccompanied minors, 12 and 19 May 2025 respectively (Legal representation by ΝGO Human Rights Legal Project, Press Release available at: https://tinyurl.com/348m85bv). Article 43 of law 4760/2020. 65

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