Reception and identification procedure

Author

Greek Council for Refugees Visit Website

The “hotspot approach” was first introduced in 2015 by the European Commission in the European Agenda on Migration, as an initial response to increased refugee arrivals to the EU.^[1] Its adoption was part of the immediate action to assist Member States which were facing disproportionate migratory pressures at the EU’s external borders and was presented as a solidarity measure.

The initial objective of the “hotspot approach” was to assist Italy and Greece by providing comprehensive and targeted operational support, so that the latter could fulfil their obligations under EU law and swiftly identify, register and fingerprint incoming migrants, channel asylum seekers into asylum procedures, implement the relocation scheme and conduct return operations.^[2]

In order to achieve this goal, EU Agencies, namely the EUAA (previously EASO), Frontex, Europol and Eurojust, worked alongside the Greek authorities within the hotspots.^[3] The hotspot approach was also expected to contribute to the implementation of the temporary relocation scheme, proposed by the European Commission in September 2015.^[4] Therefore, hotspots were envisaged initially as reception and registration centres, where Greek authorities, with the support of EU Agencies would “swiftly identify, register and fingerprint incoming migrants”, following which “[t]hose claiming asylum [would] be immediately channelled into an asylum procedure”.^[5] Interestingly, at the time, nowhere was it specified or mandated that said “channelling” (or referral) was to be made within the premises of the initial arrival/reception facility (i.e., the RICs or “hotspots”). Instead, the initial Greek response to the “hotspot approach” seems to refer to ‘[a] headquarter Hotspot in Piraeus […] where asylum seekers [would have been] received from different arrival points’, which if implemented as such, could have perhaps led to the establishment of a more functional reception system.^[6]

Five hotspots, under the legal form of First Reception Centres – later known as Reception and Identification Centres (RIC) – were established in Greece on the islands of Lesvos, Chios, Samos, Leros and Kos. In 2021, on Samos, Leros and Kos, the RICs were converted into ‘Closed Controlled Access Centres of Islands (CCAC) and new EU facilities were established.^[7] The CCAC in Samos was inaugurated on 18 September 2021 and the ones in Leros and Kos on 27 November 2021.^[8]

Source: National Coordination Centre for Border Control, Immigration and Asylum, National Situational Picture regarding the islands at eastern Aegean sea as of 31 December 2025, available at: https://tinyurl.com/4t2ke5jw.

Local communities, as well as local authorities have expressed their opposition against the creation of the new CCAC because they do not consider them necessary and because they have strong concerns both related to the degradation of the islands and the rights of newcomers. In Lesvos and Chios, several protests took place and citizens attempted to disrupt the construction of the centres.^[10] In Leros and Kos, criticism against the construction of the new facilities was expressed not only by local communities but also by the local authorities. The Mayors of both islands refused to attend the inauguration of the new centres. In 2021, the local authorities of both Leros and Samos challenged^[11] – with no success^[12] – the construction of new centres. At the end of October 2024, the Head of the Region of North Aegean, repeated the vivid opposition of the Regional Authority against the construction of the new structures in Lesvos and Chios,^[13] an opposition that was restated during 2025.[14]

In 19 August 2022, a decision of the Greek Council of State paved the way for the continued construction of a new EU-funded CCAC in a 71,250 km2 forest in Vastria, on Lesvos island. However, an application for suspension by the North Aegean Region and by local communities (Komi and N. Kydonia), regarding the access road to the structure of Vastria was accepted by the Commission of Suspensions of the Greek Council of State in temporary decision 199/2022-19/12/2022. This prohibited any construction until the final judgment of the court on the application for its annulment, as it was considered that the construction of the road would lead to irreversible destruction of the forest and impact the rare birdlife of the protected area.^[15]

In August 2023, following an application submitted by the North Aegean Region, the Greek Council of State, in 1335/2023 decision,^[16] annulled the authorisation approving the CCAC’s construction project in Lesvos, due to lack of an environmental study. In the same judgement, the Council of State annulled the authorisation approving the intervention to the forest area for the construction of the road giving access to the CCAC.^[17] Subsequently, the then-Minister of MoMA declared that the Ministry has already taken all the necessary steps for the proper environmental classification and approval of the construction of the structure and its accompanying works and so, according to him, its construction was estimated to be finalised by spring 2024.^[18] However, The North Aegean Region appealed to the Council of State against the validity of the Environmental Impact Assessment (EIA) submitted by the State in September 2023. During the Council’s scheduled session on 16 October 2024, the State decided to withdraw the EIA with the reservation of replacing it with another.^[19] According to information published by the local authorities, the MoMA is in the process of signing a joint ministerial decision by the competent ministers, which repeals the annulled by the Council of State joint decision [No. 364995/25-07-2023 (D’ 701/2023)] and grants a new permit for the construction of the site in Vastria.^[20]

In Chios, no construction work took place in 2024 either, as the examination of the application submitted by the State to exercise a right to access the area of the construction, had been pending before the Chios Court of the First Instance.^[21] On 21 October 2024, the Court ruled that the rightful owner of the disputed land is the Municipality of Chios, not the Greek State, thereby reaffirming the local community’s long-running opposition against the construction of the closed structure at the Tholos site.^[22]

On Samos and Leros, the CCAC have been moved to different areas compared to where the previous RICs were located, namely in Zervou (Samos) and Lepida (Leros). Similarly, the new facilities under construction on Lesvos and Chios are located in different areas, namely in Plati – Vastria (Lesvos) and in Akra Pachi – Tholos (Chios). In Kos, the CCAC has been expanded in an area attached to the then-existing RIC located in Pyli.

The new structures have been placed in remote locations, isolated from urban areas with very poor connection to the main cities of each island. More specifically, the new centre in Samos is located 7km away from the city of Vathy, the new centre in Leros is 6km from the city of Agia Marina and the centre in Kos is 15km far away from the city of Kos. Similarly, the new centre in Lesvos is being constructed in an area which is 30km from the city of Mytilene and the planned facility in Chios, is located 11km from the city of Chios.^[23]

Conditions prevailing in the old RICs, converted into CCACs, namely the existing structures in Lesvos and Chios, have not improved and people continue to be hosted in degrading conditions. In the former Reception and Identification Centre (RIC) of Vial, renamed as “CCAC” in Chios, the conditions remain substandard, in need of maintenance and disinfection due to cockroaches and rodents. The food is of poor quality and there are no refrigerators to store it, even though meals are sometimes distributed all at once during the weekend. There is limited provision of interpretation services, which are in any case provided only during the weekdays and working hours (from morning until early afternoon). Moreover, the medical division of the RIS had no stable presence of doctor since March 2021. As a result, the vulnerability assessment procedure has been conducted principally by the nursing staff and Doctors of Medical Units of other CCACs or the Chios General Hospital. Due to limited provision of interpretation, psychosocial evaluations are nearly impossible due to the severe shortage of interpreters, who must focus on urgent needs.^[24]

Similarly, the former RIC in Lesvos, which has been converted into CCAC, remains completely inadequate. As reported, large number of individuals, including vulnerables, at the Lesvos facility reside in tents (RHU) or rubhalls. Moreover, inaccessible and poor sanitation facilities, shortages of hot water, constant power cuts, poor quality of food and shortages of basic supplies such as blankets and clothing are observed. During 2024, the medical and psychosocial division of the RIS in Lesvos remained understaffed, leaving individuals with obvious vulnerabilities unidentified. Moreover, references for understaffing concerned also interpretation provision services^[25] (for detailed information on reception conditions, see Conditions in reception facilities).

The new CCAC are also a cause for serious concern, despite the large amount of funding that was used for their construction. More specifically, the Commission granted the Greek Government €121 million in November 2020 for the construction of CCAC on Samos, Kos, and Leros. In April 2021, the grant agreement was amended to include additional funding (€155 million) for the CCACI on Chios and Lesvos. The grant agreement was further amended in September 2021, and in February 2022.^[26] According to the MoMA’s website, €43 million were granted for the construction CCAC of Samos, €39,36 million for the construction of CCAC of Kos, and €35.3 million for the CCAC of Leros.^[27]

Conditions prevailing in the new centres appeared to be better than the ones in the RICs in terms of infrastructure. Yet in practice, the majority of the facilities hailed as significant improvements to residents’ quality of life by the European Commission and the Greek authorities – such as restaurant and communal areas, shared kitchens, IT ‘labs’, distribution points for non-food items, as well as playgrounds and recreational areas – have never been used.^[28] This, coupled with the shortcomings in the provision of basic services and material conditions resulted in a severe deterioration of living conditions in the CCAC. More specifically, in all CCAC, shortcomings in access to sanitary facilities and items, provision of hot water, as well as in the maintenance of the containers used for accommodation have been observed. Issues with food quality and quantity persist. Moreover, the medical divisions of all CCAC face significant shortages in medicines and supplies and are deprived of on-site doctors, which results in shortcomings in the identification of vulnerabilities. Interpretation services are also limited and insufficient to cover the actual needs.^[29]

Moreover, in the CCAC of Leros, long lasting issues with provision of water (running, hot and potable), malfunctions in the sewage system, challenges related to cleanliness and access to sanitation facilities, poor quality of food and shortages of basic supplies such as hygiene items and clothing are observed. ^[30]

The living condition in the CCAC of Samos are alarming. The condition of the containers, where even the vulnerable applicants reside, are completely deplorable and in need of maintenance, disinfection and cleaning. Many beds have no mattress and residents have very limited access to basic hygiene items. The supply of running and drinking water also remains unstable.^[31]

In Kos, the residents of the CCAC have very limited access to basic supplies and good quality food, while the accommodation areas are in very poor condition, partially damaged and in need of maintenance. Living conditions in the CCAC further deteriorate in times of mass arrivals due to lack of adequate spaces to accommodate people, newly-arrived individuals are placed in common spaces (i.e., restaurants, classrooms), without beds, mattresses, blankets, etc. Part of the PRDC in Kos is also used as accommodation area. Issues related to restricted freedom of movement even between the different sections of the CCAC persist. As a result, the access of the residents to sections where the offices of the administration are based is hindered.^[32]

Regarding the conditions prevailing in the CCAC, the CPT has observed:

‘The living conditions at the CCACs visited were poor at the time of the visit, notably due to overcrowding, and the conditions of detention for large numbers of persons met at Kos CCAC could only be described as inhuman and degrading. For instance, in some accommodation areas, up to eight persons were accommodated in 10 m2 rooms and many persons had to sleep on the floor without even a mattress. The former RIC area had been temporarily re-opened even though it was unfit for human habitation and most containers had no functioning sanitary facilities and no electricity. Further, there was a lack of hygiene and cleaning products, as well as non-food items (including beds mattresses, and blankets, as well as winter clothing and shoes) offered to foreign nationals. The totally chaotic and undignified way in which food was distributed at Samos CCAC, with hundreds of persons jostling to get their portion of food, should also be reviewed. The Greek authorities should ensure that all persons who are detained in a CCAC or RIC are offered decent living conditions.’^[33]

Furthermore, repeated reports by civil society organisations since the inauguration of CCACs to date, indicate prison-like conditions in the CCACs.^[34] As the European Ombudsperson has pointed out, the new structures on the islands “are, rather, reminiscent of detention facilities“, raising doubts as to “how respect for human dignity and protection of the best interests of the child and of vulnerable individuals can be ensured” in these facilities“. Also, the European Ombudsperson suggested that the Commission should carry out a fundamental rights impact assessment of the centres, with a view to identifying measures to mitigate any potential risks.^[35] Moreover, the CPT has pointed out that ‘the new EU-funded “Closed Controlled Access Centres” (CCACs) on the Aegean Islands have the potential to offer better living conditions for migrants and asylum seekers for periods of up to a few months. However, they face significant shortcomings, and the basic reception and protection needs of applicants for international protection are often not met. In the CPT’s view, the excessive security and unnecessary barbed wire fencing make the CCACs unsuitable for accommodating children and persons in a vulnerable situation. Moreover, when the number of foreign nationals arriving on the islands increases, the systems break down quickly and many persons find themselves being subjected to treatment which could be described as inhuman and degrading. This was the situation found by the CPT delegation during the visit, notably at the Kos and Samos CCACs’.^[36] The Ministry of Asylum and Migration focuses on the 24/7 surveillance and security control mechanisms of the new centres, while the residents face practices of illegal de facto detention and arbitrary restrictions of personal liberty and freedom of movement and have limited access to healthcare.

In view of the above, the European Court of Human Rights has granted interim measures, pursuant to Rule 39 of the Rules of the Court, with regards to reception conditions in the Closed Controlled Access Centers (CCACs) in Samos and Kos. More specifically:

• In September 2023, the European Court of Human Rights (ECtHR) granted interim measuresin a case concerning a single mother residing at the Samos CCAC along with her six-month old baby with a serious heart condition, ordering the Greek Government to ensure that the baby will be provided with medical treatment and that both the baby and mother will be provided with suitable accommodation.^[37]
• On 12 December 2023, the European Court of Human Rights (ECtHR) has granted Interim Measures with regards to two Afghan women and their five minor children, residing at the Closed Controlled Access Centre (CCAC) of Kos in absolutely inadequate conditions, ordering the Greek authorities to ensure that the Applicants “have full access to reception conditions which respect human dignity and take into account their multiple vulnerabilities.^[38]

Οn 5 February 2024, the European Court of Human Rights granted Interim Measures with regards to a single woman asylum applicant and her infant child, who resided in inhuman conditions in the Samos Closed Controlled Access Centre (CCAC) ordering Greek authorities to provide her with safe and suitable accommodation.^[39]

No significant developments were noted during 2025. GCR Submission to the Committee of Ministers of τhe Council οf Europe concerning the execution of the M.S.S. v. Greece group of judgments in April 2025 According to the submission, poor or inhuman and degrading conditions and/or uninhabitable housing units, no functioning sanitary facilities and insufficient availability of electricity, hot water, heating or cooling, as well as concerns with regards to hygiene and the safety of vulnerable groups have been reported since the beginning of the operation of the CCACs and up to the writing of this report.^[40]

Hotspot transformation following the EU-Türkiye statement

In March 2016, the adoption of the highly controversial EU-Türkiye Statement, committing ‘to end the irregular migration from Türkiye to the EU’,^[41] brought a transformation of the so-called hotspots on the Aegean islands.^[42]

With the launch of the EU-Türkiye Statement, hotspot facilities turned into closed detention centres. People arriving after 20 March 2016 through the Aegean islands, and thus subject to the EU-Türkiye Statement, were automatically de facto detained within the premises of the hotspots in order to be readmitted to Türkiye in case they did not seek international protection or their applications were rejected, either as inadmissible under the Safe Third Country or First Country of Asylum concepts, or on the merits.^[43] Following criticism by national and international organisations and actors, and due to the limited capacity to maintain and run closed facilities on the islands with a high number of people, the practice of blanket detention was largely abandoned from the end of 2016 onwards. It has been replaced by a practice of systematic geographical restriction, i.e., an obligation not to leave the island and reside at the hotspot facility, which is imposed indiscriminately to every newly arrived person (see Freedom of Movement).

L.4825/2021^[44] replaced Article 8(4) L.4375/2016^[45] as follows:

‘The Regional Services of the Reception and Identification Services are:

1. the Reception and Identification Centres (RIC),
2. the Controlled Structures for Temporary Accommodation of asylum applicants and
3. the Closed Controlled Access Centres, which are structured and have the responsibilities of RIC ​​and within which, in separate spaces, facilities of temporary accommodation and the special detention facilities provided in Article 31 of L. 3907/2011 operate.
4. Within the premises of the above-mentioned facilities, special areas dedicated to people belonging to vulnerable groups as per Article 14(8) are provided’^[46]

Although the Rule of Procedure of Closed Controlled Access Centres 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. According to the Asylum Code, this ‘restriction of liberty’ which amounts to de facto detention, is provided by way of exception and shall not exceed 25 days.^[47] However, on arrival, newcomers might remain under arbitrary restriction of liberty until they are registered by the RIS. During this time, people are denied exit from the CCAC (see below, Reception and Identification procedures on the islands).

From April 2016 to 31 March 2020, 2,140 individuals were returned to Türkiye on the basis of the EU-Türkiye Statement (19% Syrian nationals). Of those, 43 were returned on the basis that their asylum claims were found inadmissible at second instance based on the “safe third country” concept and, of all those returned, 23% had not expressed the will to apply for asylum or had withdrawn their asylum application in Greece.^[48] No readmission operations have taken place since 30 March 2020.^[49]

According to official data, returns under the EU-Türkiye Joint Declaration have not resumed since March 2020.^[50] It should be noted that both Greek authorities and the European Commission^[51] have requested Türkiye to resume returns based on the EU-Türkiye Joint Declaration.^[52] However, despite the suspension of readmissions to Türkiye since March 2020, Greece included Türkiye in the national list of Safe Third Countries pursuant to JMD 42799/2021 (FEK B’ 2425/07.06.2021). This list remains in force pursuant to JMD538595/2023 (FEK B’ 7063/15.12.2023) amending the above mentioned initial JMD and thus the applications lodged by individuals falling under the scope of JMD are still examined in the context of the Safe third country concept and the Fast-Track Border Procedure.

On 2 February 2023, the Council of State issued its decision 177/2023,^[53] on an annulment application lodged by the Greek Council for Refugees (GCR) and Refugee Support Aegean (RSA) against the aforementioned JMD. In its decision, the Council of State formulated preliminary questions to the CJEU regarding the national list which includes Türkiye as a safe third country for asylum applicants originating from Syria, Afghanistan, Somalia, Pakistan and Bangladesh, whose applications are therefore being rejected as inadmissible. In particular, the Council of State submitted preliminary questions regarding the ‘influence on the legality of the national list of the fact that, for a long period (over 20 months), Türkiye has refused the readmission of applicants for international protection, while at the same time it is not clear whether the possibility of a change in Türkiye’s attitude in the near future has been taken into account’.^[54]

On 14 March 2024 the preliminary questions referred by the Plenary Session of the Council of State (CoE) in its judgment No. 177/2023 concerning the inclusion of Türkiye in the national list of Member States of the European Union national list of ‘safe third countries’ (JMD 42799/2021), was discussed at an oral hearing before the Court of Justice of the European Union (CJEU) in Luxembourg on 14 March 2024.^[55]

At the hearing, the legal representatives of GCR and RSA focused on how the inclusion of Türkiye in the national list of “safe third countries” practically “consolidates the policy of abdication of responsibility for the protection of refugees in Europe”.^[56]

On Friday 4 October 2024, the CJEU, in line with the Advocate’s General Opinion,^[57] ruled that Member States cannot issue a decision rejecting an asylum application as inadmissible on the basis of the concept of a “safe third country” in cases where they have established that the asylum seeker will not be allowed to enter the territory of a country designated as safe. The Court accepted, however, that a country may be listed as a safe third country even if, despite its legal obligation, that third country has, in general and without any prospect of a contrary development, suspended the admission or readmission of those applicants to its territory. Therefore, the decision on the existence or not of the possibility of readmission to the third country, in this case Türkiye, becomes a prerequisite at the stage of issuing the decision on the asylum application and not at the stage of its execution, as has been the practice by asylum examination authorities in Greece, up to the present.^[58] On 27 February 2025, the Plenary Session of the Greek Council of State ruled by majority that the Joint Ministerial Decision (538595/12.12.2023), which established Türkiye as a safe third country, must be annulled. The decision accepted the fact that the necessary legal criteria outlined in Article 91 of Law 4939/2022, which are in line with EU Directive 2013/32/EU, were not sufficiently assessed. Furthermore, the Court unanimously annulled the individual decisions made by the Appeals Committees that rejected the examined asylum applications from Türkiye nationals based on Türkiye’s designation as a safe third country. The Court finally noted that, since Turkey had suspended the readmission of asylum seekers in March 2020, the Greek authorities cannot reject asylum claims as inadmissible on the grounds of Türkiye being a safe third country, in line with the CJEU’s ruling in October 2024 (C-134/23).[59] However, concerns have been and continue to be raised regarding the compliance of the Ministry and responsible authorities with the Council of States’ decision.[60]

On 9 April 2025, even before the Council of State’s decision was published, the Greek government released a new, identical Joint Ministerial Decision re-designating Türkiye as a “safe third country” for asylum seekers originating from Syria, Afghanistan, Somalia, Pakistan and Bangladesh. The Ministers co-signed the new Joint Ministerial Decision, without waiting for the finalisation and publication of the Council of State judgment. In a joint press release GCR and RSA uderlines that the particular practice is in blatant violations of principles of legality and legal certainty and in dereliction of Article 95(5) of the Constitution, which provides that “[…] the administration has an obligation to comply with judicial decisions[…]“. In addition to applying for judicial review of the new Joint Ministerial Decision, GCR and RSA stated they will exhaust legal avenues – including the law on the administration’s obligation to comply with court decisions – to legally claim and impose sanctions.[61] The new JMD was again challenged before the Council of State by GCR and RSA in June 2025,[62] with the decision pending, following a hearing on 4 November 2025.

The domestic framework: Reception and Identification Centres

The 2010 Greek Action Plan on Asylum already provided that third-country nationals should be subjected to first reception procedures upon entry. The competent authority to provide such services was the First Reception Service (FRS), established by L 3907/2011, as described in the previous country report.^[63] On 3 April 2016, in the light of the EU-Türkiye statement of 18 March 2016, the Greek Parliament adopted a law ‘on the organisation and operation of the Asylum Service, the Appeals Authority, the Reception and Identification Service, the establishment of the General Secretariat for Reception, the transposition into Greek legislation of the provisions of Directive 2013/32/EU, provisions on the employment of beneficiaries of international protection and other provisions. This reform was passed through L 4375/2016.^[64]

L 4375/2016 partially attempted to regulate the establishment and function of the hotspots and the procedures taking place thereat. However, national legislation has failed to effectively regulate the involvement of the EU Agencies, for example Frontex agents. Following the enactment of L 4375/2016, the FRS was succeeded by the Reception and Identification Service (RIS). The RIS is currently subsumed under the General Secretariat for Reception of Asylum Seekers of the Ministry of Migration and Asylum.^[65] The IPA, in force since 1 January 2020, regulated the functioning of the RICs and the conduct of the reception and identification procedure in a similar way. Under the Asylum Code,^[66] the relevant regulations were codified to include Closed Controlled Access Centre of Islands (CCACI.).^[67] Article 38 of the Asylum Code, provides that: ‘All third-country nationals and stateless persons who enter without complying with the legal formalities in the country, shall be submitted to reception and identification procedures.’^[68] Reception and identification procedures are carried out in five stages:^[69]

1. Information on rights and obligations, transfer to other facilities, the possibility to seek protection or voluntary return, in a language the person understands or in a language that a person may reasonably be supposed to understand and in an accessible manner, by the Information Unit of the Reception and Identification Centre (RIC) or the Closed Controlled Access Centre (CCAC) or in case of mass arrivals, by the Police, Coast Guard or Armed Forces;^[70]
2. Channelling to reception and identification procedures: According to the law, newly arrived persons should be directly transferred to a RIC or CCAC, where they are subject to a 5-day “restriction of freedom within the premises of the centre” (περιορισμός της ελευθερίας εντός του κέντρου), which can be further extended by a maximum of 25 days if reception and identification procedures have not been completed.^[71]This restriction of freedom entails “the prohibition to leave the Centre and the obligation to remain in it”.^[72] Such a restriction is ordered on the basis of a written, duly motivated decision;^[73]
3. Registration and medical checks, including identification of vulnerable groups;^[74]
4. Referral to the asylum procedure: As soon as asylum applications are made, the Special Rapid Response Units (Ειδικά Κλιμάκια Ταχείας Συνδρομής) of the Asylum Service distribute the cases according to country of origin. Subsequently, they proceed to prioritisation of applications according to nationality (see Prioritised Examination);^[75]
5. Further referral and transfer to other reception or detention facilities depending on the circumstances of the case.^[76]

 Reception and identification procedures on the islands

Situation upon arrival in RICs

At the early stages of the implementation of the EU-Türkiye Statement, individuals arriving on the Eastern Aegean islands and thus subject to the Statement, were systematically and indiscriminately detained. Such measure was imposed either de facto, under the pretext of a decision restricting the individual’s 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 CCACs 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.^[77] 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.^[78]

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.[79]

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 unaccompanied minors (UAM) 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. [80] 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.[81] 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.[82] 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.[83]

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.[84]

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.[85] 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.[86]

Since detention (or “protective custody”, as it was called) was officially abolished in Greece in 2020,[87] the prolonged restriction of minors in the “SAFE Zones” of CCACs has been characterised as de facto detention of children also by recent national administrative court decisions.[88] The situation of overcrowding and de facto detention under inadequate living conditions remains the reality for unaccompanied minors in CCACs waiting placement in shelters.

Since the implementation of the EU-Türkiye Statement, all newcomers are registered by the RIS.^[89] In 2024 the pace of conclusion of Reception and Identification Services has been accelerated compared to 2023. According to GCR observations from the field, as a rule RIS’ registration is completed with few days. As already reported, during 2024, due to the understaffing of the Medical and Psychosocial Divisions of the RIS, coupled with the limited interpretation services, there were recorded significant shortcomings or lack of provision of medical and psychosocial assessment/services, as required by law.^[90] Moreover, a long lasting issue regarding Identification Procedures concerns the lack of transparency in the way the authorities identify newcomers’ data, such as their country of origin.^[91] In many cases, the Police and/or Frontex determine a nationality to individuals- different to what the latter had declared- in a way that this determination cannot be disputed and challenged. For example, stateless Bidoons born and raised and/or residing for years in Kuwait are erroneously identified as Iraqi nationals and Eritreans with lengthy residence in Ethiopia are incorrectly identified as Ethiopian nationals^[92] (see also Identification).

The registration of initial asylum claims on the islands was conducted by the RIS.

In Kos, a Pre-removal Detention Center (PRDC) of nominal capacity of 567 places is operational.^[93]

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,[94] 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.[95] 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.[96]

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.^[97] 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.^[98] 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 the Greek authorities lack relevant resources, such as interpreters. The conduct of these procedures by Frontex is defined by an internal regulation. It should be noted that, even though the Greek authorities may base their decision concerning the nationality of a newcomer exclusively on an assessment by Frontex, documents issued by the latter are considered to be ‘non-paper’ and thereby inaccessible to individuals. Assessments by Frontex are thus extremely difficult to challenge in practice.

UNHCR/IOM: provide information to newly arrived persons.

Asylum Service: According to IPA, the Asylum Service is present in the hotspots. Specifically:

‘(a) third-country national or stateless person wishing to seek international protection, shall be referred to the competent Regional Asylum Office, a Task Force of which may operate in the RIC;

(b) both the receipt of applications and the interviews of applicants may take place within the premises of the RIC, in a place where confidentiality is ensured’.^[99]

EUAA (previously EASO): EUAA also participates in the asylum procedure. EUAA experts have a rather active role within the scope of the Fast-Track Border Procedure, as its officers conduct first instance personal interviews, and they issue opinions regarding asylum applications. Following a legislative reform in 2018, Greek-speaking EASO (now EUAA) personnel can also conduct any administrative action for processing asylum applications, including in the Regular Procedure.^[100] Following a mission conducted in Greece in 2019, ECRE published a report in November 2019 which provides a detailed overview on the role of EASO in Greece.^[101]

RIS: The RIS previously outsourced medical and psychosocial care provision to NGOs until mid-2017. Since then, the provision of said services have been undertaken by the Ministry of Health, throughout different entities under its supervision. At the end of 2019, the National Organisation for Public Health (Εθνικός Οργανισμός Δημόσιας Υγείας, ΕΟΔΥ, also EODY), a private entity supervised and funded directly by the Ministry of Health and Social Solidarity,^[102] was the competent body for the provision of medical and psychosocial services in CCACs. EODY had serious shortcomings in staffing and medical supplies, resulting in poor provision of services, including vulnerability assessment procedures. As of 8 June 2024, EODY was replaced by ‘Ippocratis I’ project run by IOM.^[103] Since then, the project has initiated a recruiting process, however shortages in medical staff and supplies (i.e., no doctor in Samos, Leros, Chios and Kos) are observed in all Medical and Psychosocial divisions of CCACs, fact that has significant impact on the provision of vulnerability assessment/ provision of health services.^[104] ‘Ippocrates I’ staff is present in the CCAC only during the weekdays and working hours (from morning until early afternoon) .

Security personnel in CCACs: The surplus private security personnel guarding each accommodation and other sections of the CCAC is not assisted by interpreters. The lack of interpretation services leads to the endogenous inability of the CCAS’s residents to communicate their needs; especially considering that the latter cannot access services or exit their containers if they do not carry with them their asylum applicant’s ID cards.

In the aftermath of the fires which destroyed the Moria facility on the Greek island of Lesvos, the Task Force was set up within the European Commission’s Directorate General for Migration and Home Affairs (DG HOME). The mission of the Task Force is the coordination of the Union’s work on all strategic, operational, legal and financial issues linked to migration management. The Task Force works in a matrix approach, tapping into established resources in DG HOME’s relevant units (policy, operational, financial) and cooperates closely with all other Commission services and EU agencies involved. Its work covers a wide range of coordination and support activities for Member States both in the Eastern and Southern external borders. The Task Force has a coordinating and supporting function and does not change or replace the prime responsibility of the national authorities in migration management on their territory.^[105] However, issues arise as its actual role remains unclear. Moreover, its contribution to the fulfillment of the objectives for which it was created is doubted.^[106]

Reception and identification procedures in Evros

Individuals entering Greece through the Greek-Turkish land border in Evros are not subject to the EU-Türkiye statement. Therefore, they are not subjected to the fast-track border procedure and there is no geographical restriction imposed on them while their asylum application remains pending.

However, they are subjected to reception and identification procedures at the RIC in Fylakio, Orestiada, which was inaugurated in 2013 and is since operating as a closed facility. People transferred to the RIC in Fylakio are also subjected to a “restriction of freedom of movement” applied as a de facto detention measure, meaning that, according to the Law they remain restricted within the premises of the RIC for a period of 5 days that can be extended for up to an additional 20 days. However, according to GCR observation, in few cases, de facto detention in the RIC exceeded 25 days, mostly due to delays in transfers in second line reception facilities, which have reached their capacity.[107]

During the reported period, it has been observed that certain arrivals from entry points other than Evros, were channelled to Fylakio RIC, in order to be subjected to reception and identification procedures, as a result of the lack of capacity in the RICs in the mainland (namely in Malakasa and Diavata).

New arrivals, including families and minors, once detected and apprehended by the authorities, are first transferred to a border guard police station or the Pre-Removal Detention Centre (PRDC) in Fylakio, where they remain in detention (so called ‘pre-RIC detention’) pending their transfer to the RIC Fylakio. By the end of 2024, the period of pre-RIC detention was limited to a few days as far as GCR is aware.

By the end of September 2024, 5,746 individuals were registered by the RIS in Evros, out of which 4,331 were men and 1,415 were women.^[108] According to official statistics, the nominal capacity of the Fylakio RIC is 768 places, out of which 284 places belong to the Pre-removal Detention Center. It shall be noted that during 2024, a new section (extension) of the RIC, which has 142 accommodation places, started to be in use.[109] Moreover, the Safe Zone for UAMs was inaugurated in September 2024. During 2025, 7,673 individuals were registered by the RIS in Evros, out of which 5,751 were men and 1,922 were women.

Since 2022, the lodging of asylum applications is no longer conducted by GAS. In the scope of Reception and Identification procedures, RIS conducts the registration of the asylum applications, during which all personal details of the applicants and the reasons for seeking international protection are recorded. According to GCR observation, registration took place immediately upon arrival for all newcomers (single adults, families and UAMs). In a number of cases concerning UAMs, the registration of the asylum application took place in the presence of a Guardianship Officer, however before they were officially appointed to a child protection actor.

Following the conclusion of the Reception and Identification Procedures, newly arrived persons were released and the vast majority were referred by the RIS to open reception facilities in the mainland, with the exception of UAMs who remained in the RIC, pending their placement and transfer to a shelter for minors.

During 2024, depending on the capacity of the second line reception facilities,[110] and ensuing delays in official transfers of applicants from the Fylakio RIC to other facilities in the mainland, according to GCR observation, in certain cases registered applicants who had initially expressed their wish to be referred to such facilities as part of their right to reception conditions, have been given the option to be released and leave the RIC on their own. However, in order to do so, applicants are first required to sign a solemn declaration, stating an address, as well as their willingness to no longer be included in official transfers to other facilities on the mainland, and for their right to reception conditions to be waived. Accordingly, this practice, aimed at decongesting the Fylakio RIC, needs to be checked, at least, with respect to the extent to which applicants are effectively informed of the consequences of singing this form, particularly given the link between residence in the Greek reception system and access to a set of provisions, both under material reception conditions (receipt of financial aid), and in the context of limited support to integration (enrolment to Helios) for those that may end up being granted international protection in Greece.

By the end of December 2024, 343 UAMs (308 boys and 35 girls) were registered by the RIS in Evros.^[111] During 2025, 322 unaccompanied minors were registered ( 310 boys and 12 girls).[112]

During 2023, the waiting period for the placement of UAMs in a ‘restriction of liberty status’ (namely in protective custody or in the RIC) to shelters for minors remained short. According to official data available, the average waiting time for the placement was 8.8 days.^[113] Transfers from the RIC in Fylakio to shelters for minors were conducted with delays of up to 2-3 weeks. By exception, according to GCR observations, certain transfers were carried out after a period that exceeded one month.

[1] European Commission, European Agenda on Migration, COM(2015) 240, 13 May 2015, available at: https://bit.ly/3TrnbG3.

[2] Ibid.

[3] Ibid.

[4] European Commission, Council Decisions (EU) 2015/1523 of 14 September 2015, OJ 2015, L239/146 and 2015/1601 of 22 September 2015 establishing provisional measures in the area of international protection for the benefit of Italy and Greece, OJ 2015, L248/80, available at: https://bit.ly/43T44rt.

[5] European Commission, European Agenda on Migration, COM(2015) 240, op.cit. p. 6.

[6] European Commission: Migration and Home Affairs, The Hotspot approach to managing exceptional migratory flows, 11 September 2015, available at: https://tinyurl.com/2kxbbt9y; See also GCR, Limits of Indignation: the EU-Turkey Statement and its implementation in the Samos ‘hotspot’; 10 April 2019, available at: https://tinyurl.com/4h3szes5.

[7] Ministerial Decision 25.0 / 466733/15-12-2021, according to which the RIC of Samos, Leros and Kos are renamed as ‘Closed Controlled Access Centres of Islands (C.C.A.C.I.)’, See also Article 8 par. 4 L.4375/2016, see also EU Commission, DG Migration and Home, Annual Activity Report 2020, https://tinyurl.com/4ctyva7w.

[8] MoMA, The Minister for Migration and Asylum, Mr. Notis Mitarachi, inaugurated the new closed controlled access centres in Samos, 18 September 2021, available at: https://bit.ly/3DHQzOe; MoMA, N. Mitarachi: Today in Leros and Kos, as a few days ago in Samos and in a few months in Chios and Lesvos, we inaugurate the new Closed Controlled Access Centres, with a view to the future. Images we can all recall from the period 2015-2019 belong definitely to the past, 27 November 2021, available at: https://bit.ly/3j61isb.

[9] A new facility in Kara Tepe (Mavrovouni) was established in September 2020 after Moria RIC burnt down. In November 2022, the RIC in Mavrovouni has been converted in CCAC. (Article 12, Presidential Decree 77/2022- Gov. Gazette 212/A/17-11-2022).

[10] Tvxs, Χίος – Λέσβος: Μαχητικό «όχι» των κατοίκων στις προσφυγικές δομές – φυλακές, 6 January 2022, available in Greek, https://tinyurl.com/27xjwmuw .

[11] CNN Greece, Προσφυγικό: Στο ΣτΕ ο δήμος Λέρου κατά της κατασκευής ΚΥΤ στο Λακκί, 4 January 2021, available in Greek at: https://bit.ly/3DFVT4y and ECRE, Greece: Significant Decrease of Arrivals – Chaos Continues, 15 January 2021, available at: https://bit.ly/37tbYPr.

[12] Δημοκρατική , ΣτΕ, Απορρίφθηκε η αίτηση του Δήμου Λέρου για ακύρωση της απόφασης κατασκευής της νέας κλειστής δομής, , 9 June 2023, available at, https://tinyurl.com/4mxvfhv4.

[13] TaNeA, ΞΕΚΟΨΕ Ο ΜΟΥΤΖΟΥΡΗΣ ΚΑΘΕ ΒΛΕΨΗ ΓΙΑ ΤΗ ΒΑΣΤΡΙΑ: «Θα φτάσουμε στα όρια», 31 October 2024.

[14] Region of Northern Aegean, “Dinner with Ambassadors”, 4 April 2025, available in Greek at: https://tinyurl.com/2pdauyp3 and politikalesvos, “Warning statement from Regional Governor Kostas Moutzouris: ‘Southern Crete is experiencing today what we lived through in 2015-2020 – No to new facilities’”, 9 July 2025, available in Greek at: https://tinyurl.com/y7bkx523.

[15] Commission of suspensions, Council of State, 19-12-2022, decision 199/2022, available in Greek at: https://bit.ly/3Vdnva1.

[16] Summary of Greek Council of State’s the decision n.1335/2023 available in Greek at: https://tinyurl.com/5n88drdz.

[17] ΤaΝea, Council of State: Invalid licensing of a structure in Plati – Vastria, Lesvos, 9 August 2023, available in Greek at: https://tinyurl.com/mpvj7xcv.

[18] LesvosNews.Net, Τι θα γίνει τελικά με την Βάστρια; Ι απαντά ο Υπουργός, 19 October 2023, available in greek at: https://tinyurl.com/sn4snjn5.

[19] RSA, Refugee facilities on the Aegean islands, Lesvos, 10 December 2024, available at: https://tinyurl.com/3rjz3ku2.

[20] POLITIKA, ΠΕΡ. ΒΟΡΕΙΟΥ ΑΙΓΑΙΟΥ για Βάστρια: «Η Διοίκηση με νέα ΚΥΑ περιφρονεί τις αποφάσεις του ΣΤΕ, 23 October 2024, available here.

[21] Ert News, Chios: Discontinuation of the hearing for the New Structure in Τholos, 20 September 2023, available in Greek at: https://tinyurl.com/3x2w8sxy.

[22]  Ert News, Χίος: Δημοτική η έκταση στο Θόλο με απόφαση δικαστηρίου, 25 October 2024 available at: https://tinyurl.com/bdne3dc2.

[23] RSA, What is happening today in the refugee structures on the Aegean islands, available at https://tinyurl.com/bdpc6byj.

[24] RSA, Refugee facilities on the Aegean islands, Chios, 10 December 2024, available at: https://tinyurl.com/2c2skt5s.

[25] RSA, Refugee facilities on the Aegean islands”, Lesvos, 10 December 2024, available at: https://tinyurl.com/3rjz3ku2.

[26] European Commission DG Migration and Home Affairs, Annual Activity Report 2021 Annexes, 2 May 2022, https://tinyurl.com/3985fuc5.

[27] MoMA, R.I.C & C.C.A.C., available in Greek at: https://tinyurl.com/4a4kb3f3.

[28] GCR& Oxfam International, Submission Inquiry on Fundamental Rights in the EU-funded Migration Facilities on the Greek Islands Case OI/3/2022/MHZ, November 2022, available at: https://tinyurl.com/5ebxr3rh

[29] RSA, What is happening today in the refugee structures on the Aegean islands, available at https://tinyurl.com/bdpc6byj; RSA, Refugee facilities on the Aegean islands, Kos, 10 December 2024, available here; RSA, Refugee facilities on the Aegean islands, Leros, 10 December 2024, available here; RSA, Refugee facilities on the Aegean islands, Samos, 10 December 2024, available here; information also based on GCR’s observations from the field.

[30]   RSA, Refugee facilities on the Aegean islands, Leros, 10 December 2024, available here.

[31] RSA, Refugee facilities on the Aegean islands, Samos, 10 December 2024, available here, also based on GCR’s observations from the field.

[32] GCR, Absolutely inadequate conditions in the new Closed Controlled Access Center (CCAC) of Kos: The European Court of Human Rights has granted Interim Measures, 14 December 2023, available at: https://tinyurl.com/mr36kzwr and Civil Society Joint Statement, Not again in 2024: Call for upholding human rights in the Samos Closed Controlled Access Centre, 31 January 2024, available at: https://bit.ly/3vKHJje, RSA, “Refugee facilities on the Aegean islands”, Kos, 10 December 2024, available here, GCR’s observations from the field.

[33] CPT, Executive Summary of the CPT Report to the Greek Government on the visit to Greece carried out by the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) from 20 November to 1 December 2023, available here; and CPT, Council of Europe anti-torture Committee (CPT) again calls on Greece to reform its immigration detention system and stop pushbacks, 12 July 2024 available here.

[34] Civil Society Joint Statement, Unlawful detention and worsening conditions: Over 4,000 asylum seekers unlawfully detained on Samos and Lesvos,19 September 2023, available at: https://tinyurl.com/727ubb4r.

[35] European Ombudsperson, Decision in strategic inquiry OI/3/2022/MHZ on how the European Commission ensures respect for fundamental rights in EU-funded migration management facilities in Greece, 7 June 2023, https://tinyurl.com/3v82dswd, para. 48.

[36] CPT, Executive Summary, CPT/INF (2024)21-Part, available here and CPT, Council of Europe anti-torture Committee (CPT) again calls on Greece to reform its immigration detention system and stop pushbacks, available at: https://tinyurl.com/442wpk7t.

[37] HRLP, Interim measures granted by the ECtHR for a woman and her daughter on Samos, 20 September,2023, available at: https://tinyurl.com/2p3u7bcp.

[38] ECtHR, M.K. and Others v. Greece [Application no. 42416/23]. See also, GCR, Absolutely inadequate conditions in the new Closed Controlled Access Center (CCAC) of Kos: The European Court of Human Rights has granted Interim Measures,14 December 2023, available at: https://tinyurl.com/mrw65ahy.

[39] ECtHR, H.T. and M.T. v. Greece [Application no.2868/24]. See also ΙHaveRights, Degrading conditions in Samos CCAC: The European Court of Human Rights grants Interim Measures”, 7 February 2024, available at: https://tinyurl.com/3m959tz6.

[40] GCR Submission to the Committee of Ministers of The Council οf Europe concerning the execution of the M.S.S. v. Greece group of cases April 2025  available here

[41] European Council, EU-Türkiye statement, 18 March 2016, available at: http://bit.ly/1VjZvOD.

[42] The Greens / European Free Alliance in the European Parliament, The EU-Türkiye Statement and the Greek Hotspots, a failed European pilot project in refugee policy, June 2018, available at: https://bit.ly/3sYrduD.

[43] In this respect, it should be mentioned that on 28 February 2017, the European Union General Court issued an order, ruling that ‘the EU-Türkiye Statement, as published by means of Press Release No 144/16, cannot be regarded as a measure adopted by the European Council, or, moreover, by any other institution, body, office or agency of the European Union, or as revealing the existence of such a measure that corresponds to the contested measure.’ Therefore, ‘the Court does not have jurisdiction to rule on the lawfulness of an international agreement concluded by the Member States’. The order became final on 12 September 2018, as an appeal lodged before the Court of Justice of the European Union (CJEU) was rejected. See, General Court of the European Union, Cases T-192/16, T-193/16 and T-257/16 NF, NG and NM v. European Council, Order of 28 February 2017. See also, General Court of the European Union’s press release, 28 February 2017, available at: https://bit.ly/46KLkdk. See also, CJEU, Cases C-208/17 P, C-209/17 P and 210/17 P NF, NG and NM v European Council, Order of 12 September 2018.

[44] Article 28 L.4825/2021 on ‘Reform of deportation and return procedures of third country nationals, attraction of investors and digital nomads, issues of residence permit and procedures for granting international protection, provisions of competence of the Ministry of Immigration and Asylum’.

[45] According to Article 8(4) L. 4375/2016, ‘[t]he Regional Services of the Reception and identification Service shall be: a. The Reception and Identification Centres (RIC) b. Mobile Reception and Identification Units (MRIU) c. The Open Temporary Reception Structures for third-country nationals or stateless persons who have applied for international protection, d. The Open Temporary Accommodation Structures for third-country nationals or stateless persons: who are under a return procedure in accordance with Article 22 of law 3907/2011, or with paragraph 3 of this Article in conjunction with Article 30 of law 3907/2011 or whose removal has been postponed in accordance with Article 24 of law 3907/2011 or who fall under the provisions of Article 76 para. 5 or Article 78 or Article 78a of law 3386/2005’. Article 30(4) L. 4686/2020 amended Article 8(4) L.4375/2016 and foresaw the establishment of the so called ‘Closed Temporary Reception Facilities’ for asylum seekers against whom a detention decision has been issued and the ‘Islands’ Closed Controlled Facilities’, for asylum seekers, persons under a removal procedure and persons under geographical limitation. Article 8(4) L. 4375/2016 as amended by Article 30(4) L. 4686/2020 was applied until the entry into force of L. 4852/2021 on 4 September 2021.

[46] As amended by Article 62 L.4939/2022.

[47] Article 40 (a) L.4939/2022.

[48] UNHCR, Returns from Greece to Türkiye, in the framework of the EU – TUR Statement. Source: Greek Ministry of Citizen Protection, 31 March 2020, available at: https://bit.ly/3xtx5hp.

[49] HIAS, RSA, GCR, Asylum Case Law Bulletin, Vol.2/2023, December 2023, Decision No. ΙP/21911/2023, issued on 18 July of 2023 by the 20^th Appeals’ Committee, p.7, available in Greek at: https://tinyurl.com/255ucet2.

[50] ΜοΜΑ, Information Note, November 2024 Asylum Reception Integration Procedures, available in Greek here.

[51] European Commission, Key Findings of the 2023 Report on Türkiye, 8 November 2023, available at: https://tinyurl.com/wdv96598; And ΜοΜΑ, Information Note, November 2024 Asylum Reception Integration Procedures, available in Greek here.

[52] EUAA, The EU- Turkey Statement, Asylum report 2022, Return of former applicants, available at: https://tinyurl.com/r3nxu7r2.

[53] Greek Council of State, Decision 177/2023, 3 February 2023, available in Greek at: https://bit.ly/3GvzhGl.

[54] RSA, Greek Council of State: Preliminary questions regarding Turkey as a safe third country, 6 February 2023, available at: https://bit.ly/4156P7u; RSA, Key points on the Greek Council of State ruling on the “safe third country” concept, 17 February 2023, available at: https://bit.ly/3RriH0o.

[55] GCR RSA Joint Press Release, Hearing before the Court of Justice of the European Union on Thursday 14 March on the preliminary questions of the Greek Council of State regarding Turkey as a “safe third country”, 13 March 2024, https://tinyurl.com/yjpfa4w2

[56] ECRE, Greece: More Crossings and Pushbacks in the Aegean Sea ― One of “Moria6” Loses Appeal Against Arson Conviction ― NGO Report on Sexual and Gender-based Violence in Asylum Policy on Lesvos ― Concerns about Lack of Accommodation on Crete Following Large Number of Arrivals ― CJEU Hearing on Designation of Türkiye as a “Safe Third Country”, 15 March 2024, available at: https://bit.ly/3VOMdzq.

[57] See Opinion of the CJEU Advocate General in Case C-134/23, available here.

[58] See Judgment of the CJEU in Case C-134/23, available here. See also GCR, Joint Press Release, CJEU ruling on the concept of “safe third country”, 8 October 2024, available here.

[59] Announcement by the President of the Council of State on the outcome of the conference on cases discussed in plenary on 7 February 2025 concerning the designation of Türkiye as a safe third country, available at: https://tinyurl.com/yc6kwjb4.

[60] Documento, “Βαφτίζει «ασφαλή χώρα» την Τουρκία η Βολουδάκη – Νέα πρόταση στο ΣτΕ από το υπουργείο Μετανάστευσης, 27 March 2025, available in Greek at: https://tinyurl.com/4a4rtmpw.

[61] GCR/RSA New designation of Türkiye as a “safe third country” for refugees in defiant contempt of the Greek Council of State’s ruling 14 April 2025 https://tinyurl.com/mrdasbys. 

[62] GCR & RSA, ‘Ministry of Migration and Asylum’s persistence on Turkey’s characterisation as a “Safe Third Country” for refugees returns to the Council of State’, 11 June 2025, available at: https://tinyurl.com/4nw3ey4z.

[63] AIDA, Country Report Greece 2022 update, June 2023, p.42 available at: https://tinyurl.com/m5wkkj3.

[64] L 4375/2016, Gov. Gazette 51/A/3-4-2016, available at: http://bit.ly/2kKm2cu.

[65] Article1 PD, 18/2020 (ΦΕΚ 34/Α/19-2-2020), available in Greek at: https://bit.ly/3wfJUHz.

[66] Asylum Code, available in Greek: https://bit.ly/3Ek1hfp.

[67] See also Article 12 of PD 77/2023 on the Establishment of Closed Controlled Access Centers.

[68] Article 38(1) Asylum Code.

[69]  Article 38(2) Asylum Code.

[70] Article 39 Asylum Code.

[71] Article 40 Asylum Code.

[72] Ibid.

[73] Article 40(a) Asylum Code.

[74] Article 41 Asylum Code.

[75] To exit Article 42(c) Asylum Code.

[76] Article 43(a) Asylum Code.

[77] Article 40 (a) L.4939/2022

[78] 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.

[79] 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.

[80] 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.

[81] Kathimerini, “Samos’ ‘safe zone’ leaves migrant kids in limbo, 28 February 2025, available at: https://tinyurl.com/27vyukbf.

[82] 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.

[83] ECtHR, O.A. and Others v. Greece, [Application no.2570/25]: available at: https://tinyurl.com/4juu77jz.

[84]  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).

[85] 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).

[86]  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).

[87]  Article 43 of law 4760/2020.

[88] See e.g., 1st Instance Administrative Court of Syros, Decision ΑΡ 7/2025, 21 February 2025; 1st Instance Administrative Court of Rhodes, Decision ΑΡ 16/2025, 5 March 2025; see also, Human Rights Legal Project, ‘Court Acknowledges De Facto Detention, Declares it Unlawful in Groundbreaking Decision’ (21 February 2025), available at: https://tinyurl.com/bdjxcs4r; see also, Equal Rights Beyond Borders, ‘Greek Court Rules Minor‘s Stay in “Safe Zone” as Unlawful Detention’ (12 March 2025), available at: https://tinyurl.com/547kfjzn.

[89] Article 8(2) L 4375/2016 as amended by Article 116(3) L 4636/2019, Article 9 L 4375/2016 as amended by Article 39 IPA; see also, Ministerial Decree No 1/7433, Governmental Gazette Β 2219/10.6.2019, General Operation Regulation of the RICs and the Mobile Units of Reception and Identification.

[90] Equal Rights Beyond Borders, HIAS Greece & RSA, Tthe state of the border procedure on the greek islands, September 2022, available at: https://bit.ly/3AtPXLu, 13.

[91] Equal Rights Beyond Borders, HIAS Greece & RSA, Tthe state of the border procedure on the greek islands, September 2022, available at: https://bit.ly/3AtPXLu, 13. RSA, The Workings of the Screening Regulation, January 2021, available here.

[92] GCR’s observation on the file.

[93] MoMA, Reception and Identification Service, Reception and Accommodation, RIC and CCAC, Kos CCAC, available here.

[94] 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.

[95] Parliamentary Control No. 517/30.10.2024 Question to Hellenic Parliament, available in Greek at: https://tinyurl.com/ys6nwynh.

[96] Based on GCR observations on the field.

[97] Article 90(2) IPA.

[98] Article 90(3), b IPA.

[99]  Article 39(6) IPA

[100] Article 65(16) and 90(3) b IPA. See also ECRE, The Role of EASO Operations in National Asylum Systems, November 2019, available at: https://bit.ly/3cSt5rs.

[101] ECRE, The Role of EASO Operations in national asylum systems, November 2019, available at: https://bit.ly/3cSt5rs.

[102] Established by L 4633/2019.

[103] IOM, IPPOKRATIS I – Provision of medical and psychosocial services to residents of the accommodation facilities under the responsibility of the Reception and Identification Service, available here.

[104] RSA, What is happening today in the refugee structures on the Aegean islands, available at https://tinyurl.com/bdpc6byj, RSA, Refugee facilities on the Aegean islands, Kos, 10 December 2024, available at: https://rsaegean.org/el/kos-2024/, RSA, “Refugee facilities on the Aegean islands”, Leros, 10 December 2024, available at: https://rsaegean.org/el/leros-2024/, RSA, “Refugee facilities on the Aegean islands”, Samos, 10 December 2024, available at: https://rsaegean.org/el/samos-2024/, also based on GCR’s observations from the field.

[105] EU Commission, Task Force Migration Management, available at: https://tinyurl.com/4hyxbes9.

[106] RSA, What is happening today in the refugee structures on the Aegean islands, available at https://tinyurl.com/bdpc6byj.

[107] GCR, Reception of asylum seekers in Greece: the demand for humane conditions remains, 9 November 2023, https://tinyurl.com/5d789w58. Still valid observation in 2024.

[108] As per the latest available data (time of writing) published on the MoMA’s website, under Statistics. See also, Reception and Identification Service, 2024, nine months of 2024, registrations of TCNs/stateless persons per location of registration, available in Greek here.

[109] MoMA, Reception and Identification Service, Reception and Accomodation, RIC and CCAC, Fylakio RIC, available in Greek (2024)  https://migration.gov.gr/statistika/

[110] GCR, Reception of asylum seekers in Greece: the demand for humane conditions remains, 9 November 2023, https://tinyurl.com/5d789w58.

[111] As per the latest available data (time of writing) published at the MoMA’s website, under Statistics. See also Reception and Identification Service, 2024, nine months of 2024, registrations of TCNs/stateless persons per location of registration, available in Greek here.

[112] Ibid

[113] Data received from the General Secretariat for Vulnerable Persons & Institutional Protection of the MoMA, on 7 January 2025.