Lesvos CCAP, Kara Tepes, Mavrovouni

27% of the total number of arrivals in 2022 entered Lesvos. The structure is located in the Mavrovouni location, about 5 km away from the centre of Mytilene. It began its operation as a Temporary Accommodation Structure for Asylum Seekers after the destruction of the Reception and Identification Centre in Moria from a fire in September 2020, and has since functioned as the Reception and Identification Centre of Mytilini (RIC Lesvos). In November 2022, the structure was transformed from a Reception and Identification Centre (RIC) to a Closed Controlled Access Centre (CCAC). It is located in a former shooting range and is very close to the sea, exposed to the weather conditions, especially to the north wind and dust, which makes living there really difficult.

We note that the structure has reached the upper limit of its actual capacity

(Lesvos Inter-agency coordination meeting, 27 March 2023)​


According to the Special Secretariat for the Protection of Unaccompanied Minors of the Ministry of Migration and Asylum[1], there were 95 unaccompanied minors on March 9 in Lesvos CCAC, 55 of whom lived in the “safe area” with a nominal capacity of 100 children.

There are worrying reports that unaccompanied minors, including unaccompanied girls, remain after arrival in the CCAC, often for an unspecified period of time, at periods when accommodation facilities for unaccompanied minors are full. RSA also points out that survivors of shipwrecks, belonging to a vulnerable group due to the state of danger they have experienced and because they often have lost family members, are driven to the CCAC immediately after their rescue, without receiving special reception conditions.

Regarding alternative forms of housing on the island, according to the UNHCR[2], the local NGO Iliaktida provides a structure for unaccompanied minors and IOM operates the “safe area” for unaccompanied minors. In addition, Diotima operates a programme for emergency housing for gender violence survivors, while the local NGO Solidarity Lesvos operates a housing programme for single women or/and with very young children. Finally, there are more than 220 people who have found housing on their own.

Within the CCAC, METAdrasi NGO provides non-formal education courses for minors and adults, while a few students attend evening schools. There is, however, an improvement over 2022 with regard to the participation of refugee children residing in CCAC in formal education, while at the same time, there are constant transfers of the children, since a significant number of the residents are transferred to structures in the mainland. In mid-March, out of 250 children at the age of compulsory education (4-14), 210 were enrolled in public schools, 150 were actually studying and 60 were on hold. Out of the 50 children in the 15-17 age group, 15 were enrolled and only 5 attended courses.

Difficult living conditions

The newcomers to Lesvos, before their official registration, resided quarantined in rubhalls[3] in the CCAC at least until the end of March 2023, with the exception of those who are transferred to the Controlled Facility for Temporary Accommodation of West Lesvos. According to testimonies from cases legally handled by RSA, there were cases in the previous period when newcomers had to sleep on mattress-free palettes and at particularly low temperatures.

There are shortages in hot water, children’s milk and bed linen, poor quality of mattresses, as well as complaints about the quality of food. Residents and people working in the structure speak of very frequent power cuts in addition to general problems. They also refer to economic hardship due to inability to find a job. Sabira*, an Afghan woman who has been living with her husband and three children for 5 months in a container, tells to RSA[4]: “We have no help. We used to be given shampoos and dish detergent, but now we receive nothing. There’s no organisation to help us here. (…) We have received the financial allowance only for 2 months. We used it to buy shampoo and internet access. Money is not enough. (…) My children need to take something to school for food, and we have nothing to give them. Not enough water is given to us, they only give us one bottle a day for each person.” Significant deficiencies are observed in adult empowerment and reception activities within the structure, aggravating the mental state of the residents. “One day spends like a year,” the woman adds.

On Lesvos, as in all CCAC, there are conditions of constant control, surveillance and repression, while actors in the field of protection report an increase in cases of violence and domestic violence. The mental state of many residents is especially burdened: “There are people who once they arrive on the island they are being chased by hooded people [in the context of informal forced return operations[5]]. They’re very traumatised. They constantly live in fear and insecurity” an employee emphasises to RSA.

Significant shortages of health and interpreting staff

Despite the relative improvement of housing conditions in relation to the notorious structure in Moria, the situation within the CCAC of Lesvos is particularly worrying, mainly due to the lack of medical staff, psychologists and interpreters. At the end of March there were only two National Public Health Organisation doctors inside the CCAC and the procedure for identifying vulnerability was very problematic. There is also reference to huge gaps in interpretation and shortages of personnel at the Reception and Identification Service.

There are people who have been granted refugee status and they have the document in their hand, and they don’t know what it writes and that they have been granted asylum,” a person working in an organisation tells us. We should also note that the National Public Health Organisation stated that from January 11, 2023 and until further notice, its Psychosocial Unit would not accept requests for psychological support due to lack of interpreters. By the end of March the provision of interpretation to the Unit had not been fully restored, resulting in significant gaps. The problems are exacerbated by the significant burden, due to the lack of staff, of the already understaffed general hospital of the island, causing reactions by the residents. In addition to this structure, Médecins Sans Frontières provides medical services and so does INTERSOS organisation with mental health and psychosocial support programmes. Regarding the effects of the security and surveillance regime within the CCAC on the physical and mental health of residents, Apostolos Veizis, doctor and general director of INTERSOS HELLAS, says to RSA: “Uncertainty, lack of health services, general lack of support services for these people, have serious consequences. We have seen in people who have had traumas, those traumas growing, and we have seen people who were healthy, then ailing, physically and mentally, under those circumstances. After the sessions in our centre these people have to go back to the CCAC, to the same place where the pain is ‘produced’.”

Problems with access to lawyers

Since the summer of 2022 and until the end of the year, there were significant problems in the access of lawyers within the structure. As RSA has pointed out in a joint submission along with the organisation HIAS to the European Ombudsman, lawyers wishing to enter the structure, had to submit a “request of entry” for each one beneficiary they wished to visit, at least one day in advance, in order to receive the “necessary approval” from the Administration of the CCAC. Beneficiaries also had to have given to the lawyers a signed authorisation in order for them to get an admission of entry – even for their first contact with them. These problems seem to have been solved for the time being after the reaction of the organisations in the field and the invocation of the opinion of the Athens Bar Association towards the Ministry of Migration and Asylum. At the present stage, for lawyers to enter, they must only show their lawyers’ identity.

According to the UNHCR[6], free legal services within the CCAC were provided in mid-March in the UNHCR Protection Centre on a daily basis, starting 10 a.m. by 5 pm, and alternately by the Greek Council for Refugees (GCR) with a Greek lawyer, METAdrasi with two Greek lawyers and the European Lawyers in Lesvos (ELIL) with two Greek lawyers. Furthermore, as the UNHCR points out, apart from the ordinary presence of the aforementioned institutions, all legal assistance organisations in Lesvos have agreed to share their contact details in a “leaflet of legal assistance organisations”, which is available in eight languages and distributed by the UNHCR to all newcomers on the island, before registration by the Greek authorities, and at any other time that the residents in the CCAC request information for legal assistance by the UNHCR. Refugee Support Aegean (RSA) is among the organisations that offer free legal assistance to CCAC residents on a permanent basis.

The Black Hole of the Controlled Facility for Temporary Accommodation of West Lesvos

The Controlled Facility for Temporary Accommodation of West Lesvos (Megala Therma or Kastelia) is complementary to the CCAC of Lesvos (Mavrovouni)[7]. The newcomers arriving within the Municipality of West Lesvos are transferred there. Although it is now officially under the jurisdiction and responsibility of the Reception and Identification Service of the Ministry of Migration and Asylum[8], this structure does not abide by the prescribed registration and identification procedure and the identification of vulnerable cases, nor does it provide for appropriate reception conditions, with residents remaining in isolation from the outside world. The structure is located in a rented space in a remote area and receives people who have just arrived on the island. A deputy commander has recently been appointed there, but there is no administrative staff of the Reception and Identification Service on a 24-hour basis[9]. At the end of 2022, two posts of specialised security personnel were provided for 24/7, as well as one post for general cleaning and disinfection duties, for 14 hours a day[10]. The duration of these services was set on January 1, 2023 and ended on March 31, 2023. For the remaining hours and at a distance from the site, there is Greek Police staff, who cannot, however, de facto, respond to any urgent medical needs.

In this structure there is no medical or nursing staff, despite the fact that it is located more than 50 km from the Lesvos General Hospital “Vostanio” and about 30 km from the Kalloni Health Centre. The National Public Health Organisation Unit visits the structure in order to perform tests for Covid-19 and the Médecins Sans Frontières mobile unit visits the residents twice a week.

This structure was originally intended for a short stay of people. Even today, the necessary material living conditions are not provided, since it is located in a fenced open-air area, within walking distance from the sea and exposed to weather conditions. The individual parts within the structure are separated by barbed wire and people cannot move even within the structure, as the residents do not have the option of exiting the fenced area designated for them. Within each distinct fenced section, there have been placed plastic huts (RHUs/Refugee Housing Units) without beds, where residents reside in overcrowded conditions and without meeting the minimum standards of safe accommodation. There are makeshift faucets/showers/toilets inside the area, while there is insufficient access to basic sanitation. Access to hot water is also extremely limited given the often large number of people living there. Electricity is provided by a generator for a few hours a day, with no provision for heating or cooling.

Newcomers are in fact kept in the structure arbitrarily without any information provided to them, without any relevant decision and without respecting the strict guarantees of legislation on imposing administrative detention or at least the restriction of liberty within the structure applicable during the reception and identification procedure, without initiating reception and identification procedures and without being notified of documents for them to know their legal status. Since November 2022, this informal detention usually takes five days and at least until a Covid-19 test is carried out. The actual time spent there, however, is unspecified and extended when no places are available in the CCAC, a phenomenon which was observed at the end of March in cases supported by RSA. The result is that people are arbitrarily detained without a formal reason, without a legal procedure, for a period which is not counted, albeit should, in the maximum number of 25 days of their ‘restriction of liberty’, as provided for in the Asylum Code.

Temporary break for the EU-funded superstructure in Vastria by the Council of State

H υπό κατασκευή νέα ΚΕΔ στη Βάστρια

The Greek government aimed to inaugurate the new CCAC in the Vastria region and close the structure in Mavrovouni before Easter 2023. The new structure, despite the strong reactions of the local society, was located on an area of about 240 acres in a remote district in Northern Lesvos next to the landfill, and has a budget of EUR 76 million plus VAT. It is adjacent to a protected NATURA area and is 100% funded directly by the European Union through the Emergency Support Mechanism. The workings for its construction were conducted at an intensive pace in the previous autumn, despite the fact that a request for suspension had been submitted by the Northern Aegean Region and the neighbouring communities of Komi and N. Kydonia in the Council of State, while the issuance of the necessary Environmental Impact Assessment and the approval of the fire protection study were also pending. The Mytilene City Council in early February issued a unanimous negative opinion on the delayed Environmental Impact Assessment for Vastria and recommended the Region to reject it on grounds of public interest. The reactions from local factors are also strong, accusing the Minister of Migration and Asylum of lying.

The Council of State, in its interim decision (199/19.12.2022), upheld the application on the part examined related to the route of access to the Vastria structure, prohibiting its construction until the final judgement of the court on the application for annulment. The court upheld that the construction of the road would lead to irreversible destruction of the forest wealth and rare avifauna of the protected area. At the beginning of February, the Minister of Migration and Asylum Notis Mitarakis stated that the project had reached 50% of its technical completion and is in the phase of full completion within 2023. At the end of March, and despite legal impediments, the construction continued on even non-working days.

Capturing the change of the natural landscape due to the construction of the new Lesvos CCAC in Vastria through satellite imagery.

The structure is designed to have a nominal force of 3,000 people, with the prospect of infrastructure being increased to nominal capacity of 5,000 or more people, while, within the same area, a Pre-Removal Detention Centre (PROKEKA) is also planned, that will have an initial nominal capacity of 2,000 people, which can also reach 5,000. As a result, the total nominal capacity of the two structures can easily reach or even exceed 10,000 people. There are serious concerns that, due to the remote location, there will be no information and control on what will happen there, and of course there will be no potential for social pre-inclusion of refugees. There are also serious concerns regarding safety and forest fires. “We are opposed to this construction in the heart of the biggest pine forest of the Aegean, since the risk of fire in these structures is very high, as we all know, and if, in the summer, a fire starts from there, it will burn thousands of acres of virgin forest and risk people’s lives, as escape routes for so many thousands of people are problematic” Michalis Bakas, environmentalist and coordinator of the Ecologist Greens in Lesvos, points out in RSA.


*Names have been changed for privacy and security reasons.


  1. Written response to RSA on March 16, 2023, with the clarification that in Lesvos, along with the safe area within the structure, there is a place of unaccompanied minors accommodation. This 40-person capacity space operates under the Ministry of Migration and Asylum with the cooperation of the IOM. 40 unaccompanied minors are currently housed there. The discrepancy between all unaccompanied minors and those living in a safe area refers to minors separated by a temporary custody act.

  2. Information from the UNHCR written response to RSA on March 16, 2023.

  3. Particularly large, shifting structure like a tent, often used in emergency situations.

  4. Interview by telephone, March 7, 2023.

  5. According to reports, apart from cases of informal forced returns during sea operations, in Lesvos there have been recorded informal forced returns even of people who had already arrived in Lesvos and stayed in the quarantine area in West Lesvos. See here and here (p. 21-22).

  6. Ibid. 2.

  7. Founded by Article 34 para. 1 case c’ PD 106/2020.

  8. Article 12 PD. 77/17.11.2022 (FEK A ‘212/2022), that amended Article 34 PD. 106/2020.

  9. Decision under protocol number 747752/12.12.2022 of the Secretary-General for the reception of asylum seekers is relevant, available here.

  10. See the decision under protocol number 750660 of the Secretary-General for Migration Policy.

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What is happening today in the refugee structures on the Aegean islands

Read in detail about the conditions prevailing at:
Chios, Samos, Kos, Leros

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On the island of Kos arrivals were increased since the end of the year compared to 2021[1]. The Closed Controlled Access Centre (CCAC) of Kos is located in an area of about 90 acres, at the site of the former camp “Makrygianni”, on a hill in the village of Pyli, 15 kilometres from the city of Kos. The CCAC was inaugurated in November 2021 despite opposition from local residents and stakeholders against the expansion of the existing structure. It is designed to run an office infrastructure for around 270 jobs.

According to the General Secretariat for Asylum Seekers of the Ministry of Migration and Asylum[2], on March 9 in the CCAC of Kos there were 53 unaccompanied minors, 34 of whom lived within the “safe area”, which has a nominal capacity of 170 children.

According to a recent publication by Equal Rights Beyond Borders and Terre des Hommes, conditions in the “safe area” for unaccompanied minors are miserable and extremely inadequate, as unaccompanied minors have limited access to schools, recreational or child-friendly activities and are guarded by the security staff at all times. Even very young children and babies separated from their mothers have been brought into the safe area. According to the publication, unaccompanied minors are not allowed to leave the safe area and remain restricted there for the whole duration of their legal procedure, which may take several months. Although there is a basketball court and a net, children sometimes cannot even use it, as the organisations report. “I was inside the safe area for two months along with other unaccompanied minors. We weren’t allowed out of there. There were no activities and the food was of bad quality; we felt like we were in a prison” says Khaled*, 17 years old, who is living in an space for adults along with his adult cousin who is in charge of his guardianship[3].

According to the UNHCR[4], there is no alternative accommodation other than self-housing in an urban environment on the island.

Volunteers provide Greek courses in places outside the structure. Volunteers also provide clothing and other essentials and try to help with medicines when needed.

As regards the non-formal education of children, based on the ARSIS data[5], in mid-March 70 children, of ages 4-17, attended the Centre for Homework and Creative Activities – KEDU, in Kos, which is part of the programme “All Children in Education”. Courses in Greek, English, natural sciences, art, as well as social skills development workshops are provided. According to the UNHCR[6], based on the most recent data available at the end of March (there may be deviations), approximately 40 children participated in the DYEP classes (Reception Facilities for Refugee Education – in kindergarten, primary and secondary school). Enrollment procedures have been normalised, while the number of children attending DYEP classes has increased.

Small amounts of food and problems of living

Refugees report poor food quality and very small amounts of food and also drinking water[7]. “We were given food once a day, and sometimes we received only one orange in the morning. We had reached the point where we were starving,” says Karim*, a 21-year-old Palestinian who is granted asylum status[8]. According to information provided by organisations working on the island, the catering company provides the three meals of the day (lunch, dinner and next morning’s breakfast) in one delivery every day at noon. There are also major shortages in the provision of essential food for children. “Previously, they were giving us a litre of milk a day for each child, now they give us only a glass of milk for each child; we have not received our monthly allowance and we have no money to buy food” emphasises Mahmoud* from Palestine, father of a small child[9].

Communal dining room, which while ready, has not been commissioned

Also, according to residents and organisations’ testimonies with whom RSA spoke, the washing machines and communal kitchens, while their construction is completed, are not put into service. There are also reports of shortages in clothes and shoes. “I arrived in September, and I’m still wearing the same clothes that I arrived with. When we arrived they only gave us soap and a sleeping bag” Ahmed*, a young Palestinian man, told us.

Finally, as is clear from refugees and solidarity groups’ testimonies, an extremely urgent housing problem arises for those who are granted international protection status and are forced to immediately leave the structure. They are mostly single men who are actually homeless, trying to either find an emergency solution by living together with several people in the hard-to-find apartments of Kos and looking for a job, or move to another Greek city with the same purpose. “Most people manage to find a job in the hotels when the [tourist] season starts in late April/early May, in poor working conditions (same as for local workers), mainly because of the exhausting working hours. Until then, they find themselves in a very bad state and even in conditions of homelessness, if they do not manage to find a solution through friends and acquaintances” a volunteer on the island points out to us.

Reported strict controls resembling imprisonment

Increased surveillance measures are prevalent also in Kos. In particular, the turnstiles with card readers placed in the separate sections of the structure result in certain categories of residents (such as those not registered or those whose asylum request is rejected) having their liberty restricted even within the CCAC, as we were told. There are also bad and dismissive behaviours towards residents and a severe shortage in interpreters, which significantly impedes communication between employees and residents and leads to tensions. Because of the exhaustive controls, many residents avoid leaving the structure at all. Residents told RSA that they had undergone intra-body controls upon their return in the evening to the structure, in search of drugs. In fact, we were told that this control has been implemented to female residents as well, with female police presence. “We do not have the money to buy food, would we buy drugs?” says Karim*[10]. We met him in the centre of Kos while he was waiting for his family from Gaza to send him money, in order to buy a ferry ticket and move to the mainland. The presence of the police is particularly intense around the CCAC and also in the city of Kos.

Further, there is tension in the area where the structure is located, with part of the residents and official representatives developing aggressive reflexes. In late March, the president of the Municipality of Pyli, declared in a publication that the anger of the residents for the whole situation is so great that they tell him that, unless something changes soon, they will take the guns and the law into their own hands.

Next to the CCAC is the Pre-Removal Detention Centre (PROKEKA). This is the only PROKEKA that operates on the islands of the Eastern Aegean, while transfers are made there from Kos and Leros CCAC. According to the testimonies we collected, the authorities ask newcomers to destroy the cameras on their mobile phones upon their arrival at the CCAC in order to prevent filming inside the PROKEKA.

Deficiencies in medical care and legal support

At the end of March there was neither a doctor nor a psychologist within the structure. Palestinian refugees told RSA that there are women even in late pregnancy who have not received the necessary medical help. “My wife is pregnant. (…) We went to the hospital and she had a blood test; when she asked for an ultrasound she was told to go to a private doctor. All we want is for a gynaecologist to see her (…) I don’t want her to give birth here (…) Since she hasn’t conducted an ultrasound, we don’t know exactly what month she is in, we count on ourselves” a resident in the structure told us[11].

Staff shortages in the hospital of the island are significant, with all that this entails for the local population and refugees in need of medical care. The fact that Kos’ hospital does not have an interpreter makes communication with patients significantly more difficult. Interpretation is extremely inadequate as it is conducted either by a compatriot accompanying the patient, or by another emergency solution. Due to the lack of a psychiatrist in the hospital of Kos, psychiatric cases involving those administratively detained are transferred, with the escort of police and even handcuffed, to the Leros Mental Hospital. In addition, there have been cases where severe psychiatric cases in the reception procedures in the CCAC, instead of being referred, have their “geographical restriction” lifted and are obliged to seek medical care elsewhere on their own.

According to the UNHCR[12], the organisations METAdrasi, Greek Council for Refugees (GCR) and PRAKSIS provide legal assistance within the CCAC: METAdrasi with two lawyers (one position is currently vacant), GCR with one lawyer and PRAKSIS (providing legal assistance to unaccompanied minors in the “safe area”) with another. In addition, Equal Rights Beyond Borders operates in the CCAC with four members.

*Names have been changed for privacy and security reasons.


  1. During 2022, 30% of total arrivals arrived in the Dodecanese. This is the largest percentage compared to the other islands.

  2. Written response to RSA on March 16, 2023. The discrepancy between all unaccompanied minors and those living in a safe area refers to minors separated by a temporary custody act.

  3. Interview in Kos on March 21, 2023.

  4. Information from the UNHCR written response to RSA on March 16, 2023.

  5.  Written answer of ARSIS to RSA on March 15, 2023. The programme  All Children in Education – ACE is an initiative of UNICEF, co-funded by the European Union, and  and is implemented by a series of partners, among which is ARSIS – Association for the Social Support of Youth.

  6. Written answer to RSA on March 23, 2023.

  7. The information about the small amount of food and water is confirmed by reports that the UNHCR has received from residents of Kos CCAC.

  8. Interview in Kos on March 22, 2023.

  9. Interview in Kos on March 22, 2023.

  10. Interview in Kos on March 22, 2023.

  11. Interview in Kos on March 22, 2023.

  12. Ibid., footnote 4.

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What is happening today in the refugee structures on the Aegean islands

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Immigration detention in 2022

Sharp rise in detention orders, no access to remedies and legal aid in Greece

Key figures

Deportations & returns

    • The Hellenic Police issued 30,631 detention orders, of which 16,977 in return procedures (Return Directive), 7,081 in deportation procedures (derogation from the Return Directive), and 6,573 in the asylum procedure (Reception Conditions Directive).
    • Detention was applied in 99.7% of a total of 7,103 deportation decisions, as opposed to 64.5% of 26,338 return decisions.

Review of deportation & return decisions

    • Only 450 removal decisions (1.3% of the total) were challenged by an administrative appeal before the Hellenic Police.
    • The Hellenic Police granted only 12 out of 450 appeals (2.7%).
    • No free legal assistance was provided in 2022 for detention or return proceedings.

Judicial review of detention

    • 5,011 objections against detention were lodged with the administrative courts. Most of those were filed at the Administrative Court of Athens (2,827).
    • The administrative courts granted 40% of objections. However, in the context of ex officio review under the same standards, the same courts quashed only 0.3% of detention orders.

Detention conditions

    • 2,813 people were held in detention at the end of the year. Of those, 316 were detained in police stations.
    • The total number of staff deployed in pre-removal detention centres throughout Greece was 37, including administrative staff and interpreters.

This Refugee Support Aegean (RSA) policy note analyses immigration detention statistics for 2022, as made available in response to parliamentary questions in March 2023.

Persisting systematic use of detention

The Hellenic Police issued a total of 30,631 detention orders in 2022, a 46% increase from 21,044 detention orders in 2021.

Specifically, detention orders rose by 8% in return procedures, and by 55% in deportation procedures conducted by way of derogation from the Return Directive. A striking 697% increase was recorded in asylum detention orders.

The Hellenic Police took a total of 33,441 removal decisions, of which 26,338 return decisions under the Return Directive and 7,103 deportation decisions on the Eastern Aegean islands by way of derogation from the Directive.

The Police clarifies that all new arrivals are channelled into screening (“reception and identification”) procedures, following which persons who do not fall under the asylum procedure “are referred to the competent police Authority for channelling into deportation, return or readmission procedures”. Yet, this position is called into question by the data pointing to 7,103 deportation decisions taken in 2022 even though the same authority concedes that “almost all entrants in our country make an asylum application during the reception and identification procedure”.[1]

Furthermore, official statistics confirm that Greece applies pre-removal detention systematically and not as a last resort measure in removal procedures. Deprivation of liberty is almost an automatic adjunct of deportation decisions taken in derogation from the Return Directive, since 99.7% of deportation orders were accompanied by detention. Conversely, the rate of return decisions carrying detention was 64.5%:

Lack of access to remedies

Administrative appeal against deportation or return

Greek law foresees an administrative appeal against deportation or return decisions before the Hellenic Police within a tight deadline of five days.

Data on such administrative appeals demonstrate systemic gaps in access to remedies. The past year saw as many as 33,441 deportation or return decisions but no more than 450 administrative appeals. Therefore, only 1.3% of removal decisions in Greece was challenged through an appeal.

Useful contrast may be drawn from the asylum procedure, where the rejection of an asylum claim by the Asylum Service involves the issuance of a return or deportation decision.[2] In 2022, the Asylum Service took 11,643 in-merit rejections and 8,962 inadmissibility decisions on asylum claims, while 16,830 appeals were lodged against Asylum Service decisions before the Appeals Authority.[3]

Severe obstacles to access to the remedy stem from the complete absence of state-provided free legal assistance, contrary to Greece’s obligations.[4] No progress has been marked on legal aid over one year after the Council of the EU urged Greece for measures to ensure “effective access to free legal assistance”, as “the issue is under review by the competent Services of [the Ministry of Citizen Protection] and the Directorate of the Hellenic Police”.[5]

In addition, serious doubts persist as to the effectiveness of the administrative appeal to the Hellenic Police as a means of review of the legality of removal or detention orders. In cases supported by RSA, Hellenic Police decisions on such appeals appear to be identical, to lack specific reasoning on submissions and merely to state that “the foreigner lacks residence documents and the return decision was issued without a departure deadline, according to the provisions of articles 21, 22, 23 of L. 3907/11”. This is the case even for asylum seekers who enjoy a right to remain on Greek territory.[6]

These concerns are corroborated by official data. In 2022, the Police rejected 438 administrative appeals and only approved 12, i.e. no more than 2.7%.

Judicial review of detention

5,011 objections against detention were lodged in 2022. This means that less than one out of five detention orders were challenged before the courts. Here too, effective access to the remedy is marred by the aforementioned obstacles and by Greece’s failure to observe its duty to provide free legal assistance.

The overwhelming majority of objections against detention were filed with the Administrative Court of Athens (2,827), followed by Corinth (940), Piraeus (298), Thessaloniki (240) and Kavala (157).

40% of objections against detention examined on their merits were granted by the administrative courts in 2022:

Striking disparities persisted in 2022 between the objections procedure and ex officio review of prolongation of detention orders, even though both categories of detention review are based on the same standards.

The above figures show evident discrepancies in the different mechanisms established for judicial review of detention. Whereas the administrative courts quashed 40% of detention orders challenged through objections, they only found 0.3% of ex officio reviewed orders to be unlawful.

Available data highlight yet again the pressing need for adequate free legal assistance with a view to a fair and effective scrutiny of immigration detention.

Detention conditions

A total of 2,813 persons were in immigration detention at the end of 2022, i.e. a 20% rise from 2,335 persons at the end of 2021. Of those, 2,497 were held in pre-removal detention centres and 316 in police stations throughout the Greek territory:

Critical gaps in health care and support to people detained in pre-removal detention centres persist. According to Ministry of Citizen Protection figures, the total number of staff deployed in pre-removal centres was 37, including administrative staff and interpreters:

The Ministry has not provided a disaggregation by category of medical or administrative staff profile in response to parliamentary questions.


  1. Directorate of the Hellenic Police, Reply to parliamentary question, 7017/4/25899-γ΄, 16 March 2022, available at: https://bit.ly/3LilM02.

  2. Article 87(8) Asylum Code.

  3. RSA, The Greek asylum procedure in figures in 2022: Analysis of main trends in refugee protection, March 2023, available at: https://bit.ly/3LWW41N.

  4. Article 13(4) Return Directive; Article 28(4) L 3907/2011.

  5. Ministry of Citizen Protection, Reply to parliamentary question, 7017/4/26334-γ΄, 13 March 2023, 3.

  6. Article 73(1) Asylum Code.

Persisting systematic detention of asylum seekers in Greece

Persisting systematic detention of asylum seekers in Greece

Greece continues to systematically impose deprivation of liberty against asylum seekers and to expose people seeking protection to serious violations of fundamental rights and to unsuitable conditions in pre-removal centres and police stations. The practice persists despite sharp criticism and mounting condemnations of the country by international bodies.

This note analyses current detention practice based on the latest available statistics on immigration detention and judicial review thereof, as well as on testimonies from refugees detained in Greece.




On May 19, 2022, the Single-Member Criminal Court of Appeal of Kalamata acquitted two Syrian nationals of the criminal charges imposed whilst entering the Greek territory, one of them defended by RSA lawyers. More specifically the refugees have been charged of a) being the captain of a vessel transferring into Greece third-country nationals from abroad who do not have the right to enter the Greek territory (1st accused) and of b) being an accomplice in transferring into Greece third-country nationals from abroad who do not have the right to enter the Greek territory (2nd accused). The Court also acquitted them for the accusations of illegal entry in Greece. Furthermore, the Court had declared guilty three Syrian nationals who were absent in the hearing for complicity in transferring into Greece third-country nationals from abroad who do not have the right to enter the Greek territory and convicted them to 364 years of imprisonment and a big fine.

Serious gaps and irregularities in the pre-trial and investigative procedure

This decision is particularly important as the hearing brought to light major irregularities, serious gaps, omissions and faults of the pre-trial and investigative procedure, which resulted in the prosecution and pre-trial detention of the two accused for one year and, of course, the conviction of the three accused who were absent from the hearing. In particular, the non compliance with procedural guarantees during pre-trial and interrogation proceedings, the lack of adequate interpretation, the irregularities in the collection and evaluation of evidence e.t.c. characterized the fast-track/summary pre-trial proceedings, quite common in similar cases, which lead to the above prosecution.

The judgment of acquittal though, should serve as a precedent for putting an end to a series of systematic violations of the rule of law and the application of summary proceedings against the weakest and in this case against refugees. At the risk of their lives, refugees are forced to seek the obvious, that is, a safe haven, asylum in a Europe which, by invoking its border security, denies protection and safe access to its territories, exposing thousands of people to danger. In this context, refugees are perceived and treated as ‘perpetrators’ for “illegal entry” or even “common criminals’ for carriers’ liability, facing serious accusations involving hundreds of years convictions without being taking into account their state of emergency and/or the particular circumstances provided by international, EU and national law and exempting them from penalties.   

The case of N.S, single-father pretrial detained for one year and deprived from his two minor children 

RSA lawyers defended Mr N.S who was the 2nd accused in the trial and acquitted by the Court for being an accomplice in transferring into Greece third-country nationals from abroad who do not have the right to enter the Greek territory. Mr N.S is a refugee from Syria, who arrived as a single-father with his two minor children (of 8 and 9 years old) and who has been singled-out and accused by the Greek authorities according to the problematic and summary pre-trial proceedings, while even his parenthood has been questioned.

 Mr N.S was forced to leave Syria and flee to Turkey with his minor children after the tragic death of his first wife and mother of his children by a bomb blast near the city of Idlib. Obviously, their lives and freedom were in danger due to the raging civil war also because of the political beliefs attributed to him, due to his refusal to serve as a soldier in Syrian army and on the other hand to join the opposition groups and turn either in one case or another against his compatriots. Due to the lack of effective protection in Turkey and with the assistance of the United Nations High Commissioner for Refugees, his family was selected for a resettlement program for Canada without though a successful completion. Therefore, he decided to leave Turkey and seek protection in an EU country.

 On 3/5/2021 they arrived at Kalamata rescued from an impending shipwreck. On 6/5/2021  Mr N.S was arrested for reasons he never understood, as being accused of complicity in the transfer of persons to Greece and then he was detained until his release, following the acquittal decision.

Mr N.S I applied for asylum in Greece, for him and his children. The children were recognized as refugees in Greece following his initial application, as the file was separated for procedural reasons, since he was a detainee and he is still an asylum seeker waiting for his decision.

It should be noted that the Prosecutor of the Court of First Instance of Kalamata acted as Temporary Guardian and took care of the minor children, due to Mr N.S’ arrest and detention and their mandatory separation, in combination with the absence of another relative in Greece to take care of them. The children were placed in a foster family and they were put by the Prosecutor under the protection of the Organization “METADRASI – ACTION FOR IMMIGRATION AND DEVELOPMENT in Greece.

Regarding his minor children, it is emphasized that it was the first time that they separated from their father after the tragic loss of their mother in 2015. All three of them have faced many difficult situations all these years as Syrian nationals in Turkey but they were never experienced a separation. However, despite the above difficulties due to Mr N.S’ detention, it was possible for them to communicate for the entire period, at Mr N.S’ request to the Prosecutor. Ensuring the best interests of his minor children and preserving their normal mental state and care was and is Mr N.S’ major concern.

Pursuant to the acquittal of the Single-Member Criminal Court of Kalamata, according to which he was acquitted of all charges against him, Mr N.S was released from prison and then went to Athens, where he is temporarily staying in order to prepare the conditions for his reunification with his children. To date, he has not been granted an asylum seeker card, nor has any reception conditions been activated (shelter, allowance), although his status as an asylum seeker has been established by the competent services for his release.

Mr N.S was prosecuted and was put in a pre-trial detention  for a year while deprived from his children, in spite of the fact that he had produced since the beginning all the necessary documents proving his whereabouts (documents of temporary protection in Turkey, relevant correspondence with UNHCR, certificate  of his wife’s death etc) while he has been subjected to DNA test for establishing his parenthood.

Mr N.S is a typical victim of the implementation of EU deterrence policies: the systematic and unlawful criminalization of refugees-and often of their rescuers- for irregular entering in EU territory, has become, nowadays a tool affecting and destroying the lives and freedoms of many people who are systematically deprived of their basic rights and guarantees, as provided by the rule of law, depriving them also of their protection.


UPDATED - Immigration detention in the first half of 2021: Systematic deprivation of liberty and inaccessibility of remedies

UPDATED - Immigration detention in the first half of 2021: Systematic deprivation of liberty and inaccessibility of remedies

Official data for the first half of 2021 released by the Hellenic Police in response to parliamentary questions demonstrate that the Greek authorities continue to systematically detain asylum seekers and irregular migrants. The figures reveal a severe violation of the duty of the state to use deprivation of liberty only as a last resort, when necessity and proportionality so require.

Figures at a glance

  • Serious disparities persist in the detention statistics held by different Greek authorities, namely the Ministry of Citizen Protection, the Ministry of Migration and Asylum and the Ministry of Justice. As a result, inconsistent data have been provided in response to the same parliamentary question.
  • 9,575 detention orders were issued
  • 4% of deportation decisions were followed by a detention order
  • About 1 out of 10 detention orders were challenged before the courts
  • Automatic judicial review quashed only 2 out of 3,918 detention orders
  • Out of 2,392 people in pre-removal centres, 1,109 were held for over six months
  • There were only 10 doctors for 2,392 detainees across 7 pre-removal centres
  • Xanthi and Fylakio pre-removal centres had no interpreters, and Paranesti and Kos only had one each
  • There were only 9 psychologists for the total number of detainees in pre-removal centres and only one psychiatrist in Tavros
  • Health visitors were only deployed in Amygdaleza and Corinth

Systematic recourse to detention

During the first six months of 2021, the Hellenic Police issued a total of 9,575 detention orders under migration and asylum legislation. Of those, 7,247 were issued in the context of return proceedings under L 3907/2011, 1,980 under deportation proceedings pursuant to L 3386/2005 and 348 in the context of the asylum procedure.

Statistics reveal widespread resort by the Greek authorities to deprivation of liberty for the purpose of effecting removal. The use of detention is palpable in so-called deportation procedures conducted under L 3386/2005 in derogation of the Return Directive safeguards. Deportation decisions were followed by detention in 99.4% of the cases.

Inaccessible remedies against detention

Greek law foresees the possibility to challenge detention through “objections” before the competent Administrative Court. Prolongation of asylum and pre-removal detention is also subject to ex officio judicial review by the same court.

About one out of ten persons sought legal redress against their detention during the first half of the year. Out of 9,575 detention orders, only 1,268 (13%) were challenged before the administrative courts through the objections procedure.[1] RSA has documented a series of barriers to access to the objections procedure, in particular the fact that people are not informed of the reasons for their detention in a language they understand and of access to legal assistance. The detention order issued by the police authorities is written in Greek and interpretation together with information on the right to challenge such decision are often not provided. For its part, the obligation to provide legal aid is not ensured by the state in practice.

Most objections against detention were filed before the Administrative Courts of Athens (457), Corinth (220), Piraeus (133) and Kavala (97).

The success rate of objections against detention before the administrative courts during the first half of the year stood at 39%[2]

The breakdown of decisions on objections across the main Administrative Courts concerned is as follows:

In sharp contrast, ex officio judicial review of the prolongation of asylum and pre-removal detention by the same courts continued to overwhelmingly result in approval of detention orders, with only 27 in 3,918 decisions opposing the continuation of detention:[3]

The majority of ex officio reviews of asylum detention were carried out by the Administrative Courts of Corinth (1,767), Kavala (758) and Athens (614). As for pre-removal detention, most ex officio reviews were conducted by the Administrative Court of Komotini (358) and Rhodes (100).

The above statistics demonstrate palpable disparities in the functioning of available judicial review mechanisms. Whereas over half of the detention orders brought to the courts through objections were found to be unlawful, no more than 0.3% of automatically reviewed detention orders were quashed. The figures highlight yet again the pressing need for adequate legal aid to ensure fair and effective detention review.

Conditions of detention

At the end of June 2021, 2,392 persons remained in pre-removal centres. Of those, 46% have been in detention for more than six months:

Note, however, that there were 96 people detained for over six months in Kos, according to the Kos Prosecutor.

Severe gaps persist in the provision of health care and support to people detained in pre-removal centres. The already limited number of medical staff deployed across the pre-removal centres dropped from 37 at the end of 2020 to 34 at the end of the first half of 2021:

The number of interpreters remains worryingly low as well. At the end of June 2021, there were no interpreters in Xanthi and Fylakio, only one interpreter in Paranesti and Kos and only two interpreters in Amygdaleza, Tavros and Corinth.

Finally, the Greek authorities continue to impose immigration detention in police stations, in dereliction of sharp and consistent criticism from international bodies. 601 people were held in police stations at the end of June 2021.

For more information:


[1]        The Ministry of Citizen Protection refers to 828 objections.

[2]        The Ministry of Citizen Protection refers to 437 decisions quashing detention and 391 decisions upholding detention.

[3]        According to Ministry of Citizen Protection statistics, the administrative courts quashed 10 asylum detention orders and 17 pre-removal detention orders, and upheld 1,360 asylum detention orders and 731 pre-removal detention orders.


A human rights “black hole”

Greece is intensifying its detention policy under the hypocritical and tolerating gaze of the EU. More specifically, on Kos and – during the operation of the pre-removal centre – in Evros the authorities apply a policy of generalised and systematic detention of newly arrived asylum seekers subject to a few exceptions, whereas even vulnerable people are detained for prolonged periods. On the mainland, persons without documentation continue to be detained for the purpose of removal, including persons that overwhelmingly wish to seek international protection without having had a prior possibility to make an application. The number of administrative detainees is expected to further increasing in light of the recent Joint Ministerial Decision (JMD) designating Turkey as a safe third country for the overwhelming majority of asylum seekers.


A human rights “black hole”

Greece is intensifying its detention policy under the hypocritical and tolerating gaze of the EU. More specifically, on Kos and – during the operation of the pre-removal centre – in Evros the authorities apply a policy of generalised and systematic detention of newly arrived asylum seekers subject to a few exceptions, whereas even vulnerable people are detained for prolonged periods. On the mainland, persons without documentation continue to be detained for the purpose of removal, including persons that overwhelmingly wish to seek international protection without having had a prior possibility to make an application. The number of administrative detainees is expected to further increasing in light of the recent Joint Ministerial Decision (JMD) designating Turkey as a safe third country for the overwhelming majority of asylum seekers.

Irregular migrants and asylum seekers remain in detention for several months under wholly inappropriate conditions during a pandemic, despite repeated recommendations from national and international bodies to guarantee dignified detention conditions and access to medical and other support[1].

In a press release on 14 June 2021, the Ombudsman points out the inadequacy of administrative detention facilities, citing, among others, overcrowding, especially in police detention facilities, absence or shortages of medical and nursing staff, psychologists, social workers, lack of interpretation services, lack of sanitary items and linen / clothing, complete absence of or limited yarding.

Detainees* in pre-removal detention centres (PRDCs) spoke to Refugee Support Aegean (RSA) of unacceptable conditions.

The death[2] of two people in the space of a few days three months ago provoked a series of reactions, without however triggering any changes or improvements to conditions or to the policy of prolonged detention[3]. Already in mid-January, RSA had warned of severe shortages in health care for detainees and in the prevention of health risks inside pre-removal centres, as well as of worrying gaps in communication of people with health care staff due to the absence of necessary interpretation services.

On 24 March, 44-year-old Maki Diabate from Guinea, detained in the pre-removal centre of Kos since January, died. According to reports, the forensic report concluded on intestinal obstruction as the cause of death. Diabate was shouting in pain for three days and had repeatedly asked to be taken to the hospital. “We saw that person begging the authorities to take them to the doctor every day and being told that there was no car, there was no doctor, until he died”, stated Amin, an asylum seeker detained for 18 months in the same centre.

On Kos, since the end of 2019, all new arrivals are systematically detained in the pre-removal centre, despite the fact that detention is permissible only as a measure of last resort, following an individualised assessment.[4] The only groups exempted from the automatic detention policy on Kos are unaccompanied minors and people with evident vulnerability. Nevertheless, given that not all arrivals are subject to reception and identification procedures, namely those arriving there from nearby islands e.g. Symi, Kastellorizo, unaccompanied minors have also been subjected to prolonged detention until their identification and recognition as children.

A few days following the death of the Guinean refugee on Kos, on 27 March, 24-year-old Ibrahim Ergun was found dead in the bathroom of the Corinth pre-removal detention centre. According to reports, the young Kurd from Turkey had been detained for 16 months. Shortly before ending his life, he had been informed of further prolongation of his detention.

Detention reaching 36 months

Following a November 2019 reform, detention can be extended to a total period of 36 months, since the 18-month time limit under L 4636/2019 is separate from pre-removal detention under L 3907/2011, which may also last for 18 months. Bearing in mind the lack of prospects of removal to Turkey due to the indefinite suspension of readmissions under the EU-Turkey deal since March 2020, the legality of continuous prolongations of detention – during a pandemic – is called into question.

During their detention, people face crucial gaps vis-à-vis access to medical and psychosocial services, lack of legal assistance and interpretation, as well as arbitrariness and police violence. Following the suicide of the Kurdish refugee in Corinth, the authorities further restricted yarding instead of taking necessary measures to mitigate the psychological pressure attached to detention. Hussein, detained in Corinth, states that people were allowed outdoor access twice a day prior to the tragic incident. However, yarding is now allowed once a day.

Amin, detained in the pre-removal centre of Kos, states: “There is a yard totalling 100 metres. Wandering here for 18 months is torture. It is a prison with high walls, barbed wire and a lot of police.” Detainees also denounce problems such as poor quality and limited quantity of food, the lack of heating and hot water, poor hygienic conditions and other gaps exacerbating their confinement.[5]

No interpretation and guaranteed access to legal aid and representation

Regarding the detainees’ effective access to remedies against detention and deportation decisions, UNHCR notes the lack of adequate provision of information to the detainees in a language they understand regarding their detention, the lack of interpretation in detention facilities as well as the fact that no legal aid scheme has yet been established by the Greek authorities for the provision of free legal assistance and representation to detainees as foreseen by Article 9(6) of the Reception Conditions Directive.[6]

If you want [legal] help you have to find a private lawyer. Most people paid a lot of money to private lawyers, but they never helped them. It happened to me too “, says Sohaib, an asylum seeker, who has been detained for more than four months at PRO.KE.KA in Paranesti, Drama, after an attempt to leave Greece for another European country.

Every now and then we are forced to sign documents [extension of detention] that are written in the Greek language and if we do not sign them, they hit us,” says Amin from the pre-removal centre of Kos.

Protests and police violence

In statements to RSA, detainees state that they do not have sufficient information about the length of and reasons for their detention, and denounce police violence in cases of protest.[7] 

No one knows how long they have to stay here. We have to wait and wait. Some people go crazy because they do not know when they will be free and have nothing to do here. Others are protesting. They go on hunger strike or injure themselves. Yesterday a man set himself on fire and fell from a building. As soon as he fell, the police went and beat him badly. When you complain, you are beaten or taken to the hospital where you are given an injection and then you sleep for a week. Many detainees take sedatives here… The police usually ignore us. The police mainly become aggressive when we protest… If I ask why I am here, how long I will stay, then they always answer, 18 months“, says Sohaib, from the pre-removal centre of Paranesti.

Similar situations are described by other detainees. “So far [for the 18 months I have been herewe have had three suicide attempts, where we detainees stopped them at the last minute. The police did not worry at all… We do not have a camera on our mobile phones. As soon as we arrive, they break them so that we do not talk to organisations“, underlines Amin from the pre-removal centre of Kos.

Insufficient provision of health services amid a pandemic

In their statements to RSA, detainees highlight difficulties in accessing medical services and serious gaps in measures to protect them against COVID-19.[8] 

There is a doctor but in order to go you have to make a lot of noise, to injure yourself, in order to visit a doctor or a social worker. We do not have masks, we do not wear them, nor do we do tests“, says Hussein, who has been detained for six months in the pre-removal centre of Corinth.

There is no doctor in the detention centre, but the hospital is very close. If someone gets sick we must inform the police that we need medical help. We do not have masks for everyday life, only if we have to go to the hospital. Most police officers do not usually wear masks. Only when [senior] officials visit the detention centre. There is nothing we can do to protect ourselves from the coronavirus. The police are the only ones coming in and out. They could carry the virus to us. We can’t get it anywhere else. But no one cares. We are forgotten here“, states Sohaib from in the pre-removal centre of Paranesti.

Amin from the pre-removal centre of Kos states: “We have a doctor who, whatever happens, gives you pills for the headache… We have diseases due to lack of hygiene, such as scabies. There is a psychiatrist and you can make an appointment every 8 days and when you go there he tells you all I can give you is a sleeping pill … They give us absolutely nothing to protect ourselves from the coronavirus and they do not pay attention to how we gather [to prevent overcrowding]”.

Parallel to the creation of so-called Closed Controlled Facilities on the Aegean islands, the government is proceeding with the upgrade of the pre-removal centre of Fylakio, Evros which has been out of operation since last September, while the new Reception and Identification Centre (RIC) and pre-removal centre in Samos are expected to be up and running soon. The Joint Ministerial Decision (JMD), which was released last week and designates Turkey as a “safe third country” for asylum seekers originating from Syria, Afghanistan, Pakistan, Bangladesh and Somalia, is expected to increase prolonged and indiscriminate detention and to exacerbate conditions, as thousands of refugees and migrants will find themselves in a legal limbo.[9]

Prolonged detention following the rejection of asylum applications, combined with proposed changes to deportation and return procedures currently under public consultation and expected to be adopted soon, is aimed at serving as a deterrent for asylum seekers in Greece  

Refugee Support Aegean (RSA) calls on the Greek authorities:

  • To immediately end the generalised and systematic implementation of administrative detention against refugees and migrants.
  • To comply with their obligation to conduct an individual assessment of the necessity of imposing in each case, taking particularly into account the conditions of detention in light of the pandemic.
  • To take immediate action to improve detention conditions in accordance with the recommendations of national and international bodies.
  • To immediately address deficiencies in the treatment of detainees and the prevention of health risks.
  • To ensure the communication of detainees with appropriate and adequate medical staff, as well as their access to legal assistance.


* The names and nationalities of the respondents are not listed to protect their privacy. The interviews were conducted by telephone between 7-26 May 2021.


  1. According to the AIDA (Asylum Information Database) report, six pre-removal centres are in operation with the following capacity: Corinth 960 persons, Amygdaleza 922 persons, Paranesti Drama 500 persons, Kos 474 persons, Tavros (Petrou Ralli) 270 persons, Xanthi 200 persons. During 2020, detention was applied to a total of 14,993 persons, of whom 10,130 asylum seekers. 
  2. In response to a parliamentary question in May, the Ministry of Citizen Protection states among others that a Sworn Administrative Inquiry has been ordered for the death in the pre-removal centre of Corinth. A Preliminary Administrative Inquiry was launched for the death in the pre-removal centre of Kos. 
  3. According to a report, citing the Hellenic Police, eight deaths have been reported in detention centres from 2012 to 2020. 
  4. According to UNHCR, vulnerable asylum seekers, including persons with medical conditions, are likely to remain in prolonged detention on Kos during the examination of their asylum application. Until April, newly arrived families were also detained in the pre-removal centre. The practice ended, however, following UNHCR intervention (Written response, 27 May 2021). In March, RSA published the stories of two vulnerable women held in the pre-removal centre of Kos, including one minor: https://rsaegean.org/en/stories-of-refugees-eu-turkey-deal-five-years-of-shame/ 
  5. According to UNHCR, conditions of detention differ among the PRDCs. While the provision of medical and psychosocial services in PRDCs by Health Units S.A. during the past years has gradually improved, there are still significant gaps in some PRDCs. Although refurbishment works have been conducted in some PRDCs (the most recent being Fylakio and Tavros), material detention conditions continue to be challenging in a number of PRDCs. This is due to a lack of maintenance of the infrastructure, inadequate provision of hygiene and non-food items, including clothes and shoes, clean mattresses and blankets and cleaning services, limited supply of relief items and limited access to recreational activities. Detention conditions are seriously substandard (e.g. no access to open air, natural light, poor hygiene conditions) in most police/port-police stations and border guard stations, where detention exceeds the 24 hours limit set by the European Committee for the prevention of torture (CPT) as upper time limit for detention in this type of facilities. (Written answer, 27 May 2021). 
  6. Written answer, 27 May 2021. 
  7. In late January, a group of detainees went on hunger strike, denouncing assault and mass torture by police. An international media report states that asylum seekers in Thessaloniki are hiding to avoid police control because, despite having documents, they end up in months of administrative detention or are illegally returned to Turkey, while there is a report of systematic use of force by police in the Paranesti pre-removal centre. 
  8. In response to a parliamentary question in December 2020, the Directorate of Migration Management of the Ministry of Citizen Protection spoke of a demarcation of quarantine areas for suspected cases of COVID-19 and newly arrived detainees, of provision of medical supplies to detainees, and of strict observance of hygiene standards. 
  9. According to a media report, scheduled appointments for asylum interviews in Attica structures have already been postponed, pending instructions for the implementation of the JMD. 

Legal aid organizations express concerns regarding the unprecedented administrative practice of the Regional Asylum Office of Lesvos, which goes against Greek, European and International law

Lesvos 22.11.2019

The undersigned legal aid organizations operating on the island of Lesvos have been surprised to learn that, from 15 to 20 November, the Regional Asylum Office (‘RAO’) of Lesvos has, without any prior notice, served negative asylum decisions on 28 asylum seekers from Sub-Saharan African countries without conducting the legally mandatory asylum interview.

The Administration justified its decision on the basis of its ‘inability’ to secure interpretation for languages spoken by the asylum seekers. The reasoning of the Administration, which was repeated in an identical manner in all the decisions, was that “the asylum seeker did not attend a personal interview since repeated attempts to find interpretation services for the mother tongue and the language of communication of the asylum seeker proved unsuccessful”. What is more, in one case, the application for international protection was rejected without conducting an interview because, according to the decision of the Asylum Office, finding interpretation for . . . Portuguese, proved impossible.

However, the omission of the personal asylum interview due to the inability to provide interpretation constitutes a violation of EU law. In addition, the fact that the majority of the applicants were rejected only a few days after they lodged their asylum applications is in direct contradiction to the statement of RAO Lesvos about “repeated and unsuccessful attempts to find suitable interpretation”.

Further questions arise from the fact that all the decisions were issued urgently and were signed by the same person, namely by the Head of the RAO of Lesvos, while in many cases the applicants were served fictitious invitations to interviews scheduled for the same day that the negative decisions were issued. It must be noted that the relevant negative decisions were served in languages it is uncertain if the asylum seekers understand. Moreover, the hearings of the appeals were scheduled in just a few days and the asylum seekers were never informed about their right to free legal aid, rendering the right to an effective remedy a dead letter.

Moreover, the Administration has rejected asylum applications, despite having assessed as credible the evidence in the administrative file of applicants for refugee status. For example, the Administration rejected an applicant even though it had accepted that he had been subjected to torture by his country’s authorities. In another case it rejected the asylum claim, although it was acknowledged that jihadi militiamen had attacked the applicant and killed two of his brothers because they were Christians.

This unprecedented for national, European and international legal standards, action of the Administration to decide on international protection claims without conducting a personal interview serves the purposes of another arbitrary practice which has been ‘tested’ on the island of Lesvos since mid-2016. Specifically, 27 of the 28 rejected applicants mentioned above have been arbitrarily detained at the Lesvos Pre-removal Detention Center (P.R.D.C.) since the first day of their arrival in Greece, as part of the program of detention of applicants considered as coming from ‘low refugee profile’ countries. The purpose of this program is to complete the entire asylum procedure before the release of the applicants from detention after the expiry of the maximum time limit for detention of asylum seekers. In this way, in the event of their rejection, they can be immediately returned to Turkey. However, this practice goes directly against the principle of individualized examination of any application for international protection and the prohibition of discrimination.

Conducting an asylum interview is a cornerstone of the process of examining an application for international protection, as it provides applicants with the opportunity to fully explain the reasons why they were forced to leave their country and are unable to return. Any omission of a personal interview constitutes a violation of Directive 2013/32/EU of the European Parliament and of the Council of 26 June 2013 on common procedures for granting and withdrawing international protection. In addition, the importance of the personal interview is also illustrated by the severe legal consequences for asylum seekers who do not appear in person for the interview.

This unlawful practice by the Administration does not occur in a vacuum, but is part of significant regression in relation to the procedural guarantees and rights of asylum-seekers which has become apparent for some time now from the announcements of the new government, which has been sanctioned with the adoption of the new law on international protection, 4636/2019. Additionally, it coincides with the Government spokesperson’s announcement of 20 November 2019 for a new ‘operational plan for the management of the migration/refugee issue’ that will include expanding the use of detention with the replacement of current structures with closed Reception and Identification Centers (RICs) and the creation of new Pre-removal Detention Centers (P.R.D.C.).

The Lesvos RAO follows practices that do not adhere to our legal acquis and breach national and EU law, which we believe is important to highlight. Moreover, these practices expose our country to future condemnations by European and international courts and institutions.

We call on the competent Greek authorities to respect the law and take the necessary steps in order to revoke all the above decisions, to restitute the harm caused to the asylum seekers, and to refrain from similar practices in the future.

Signing organizations: HIAS Greece, Refugee Support Aegean [RSA] Greek Council for Refugees, Equal Rights Beyond Borders, Legal Center Lesvos, Danish Refugee Council [DRC] and FENIX Humanitarian Legal Aid.


On 4 November 2019, the European Court of Human Rights issued a decision under Rule 39 indicating to the Greek Government to transfer two unaccompanied brothers to an accommodation with reception conditions which are compatible with Article 3 of the Convention and the minors’ particular status.

The two unaccompanied minors have been detained for almost 15 days in police station cells in implementation of the authorities’ policy of ‘protective custody’. Their detention takes place until today in degrading conditions detrimental to their mental health ; in cells that are completely inappropriate for detention longer than few hours, in premises where adults, including detainees under criminal law procedures/provisions are held, with no yarding, no natural light and fresh air, no access to doctor and proper hygiene conditions, no outdoor or indoor activities, no access to the outside world, no way to communicate with their family members and no information about the duration of their detention.

Since their arrival in Greece, the authorities have failed to provide the minors with the protection prescribed by national, European and international legislation. The minors had previously been detained for about 12 days upon arrival and have not received any guarantees during the time they underwent reception and identification procedures. A few weeks after their release from their initial detention, and after appearing before the competent asylum authorities to complete their asylum registration and family reunification procedure, they found themselves detained again in a police station behind bars.

RSA notes that it is the second time in less than a month, and at least the third time during this year, that the Court indicates to the Greek authorities to transfer unaccompanied minors from detention to safe accommodation.

The Court’s decision to grant interim measures in this case highlights once more the authorities’ unlawful practice to hold unaccompanied minors in degrading conditions, in implementation of their so-called ‘protective custody’ policy, as well as the absence of an effective protection policy for unaccompanied children in Greece.

RSA reiterates its condemnation about the widespread use of the so called ‘protective custody’ in general and in particular in police cells that are not designed even for detention for adults for more than a few hours. RSA notes that detention is not the only violation of their rights, refugee children face in Greece. Inefficient identification of minor children, gaps in the age assessment procedures, inadequate or absent reception conditions, insufficient appropriate shelters, the lack of an effective guardianship system for unaccompanied children, lack of consistent guarantees in the asylum procedure and not ensured access to education further endanger their rights and deprive them of effective protection.

RSA stresses that the lack of a coherent protection policy for refugee children does not relieve the state from its obligations to ensure their rights and protection.

RSA further emphasizes that apart from the minors represented by our organization, many more unaccompanied children remain detained in police stations, and Pre-Removal Centers in similar conditions. In particular, according to statistics of the National Centre for Social Solidarity, as of 30 September, there were 238 unaccompanied children in protective custody. Not to mention that, in the same police station concerning the application before the Court, more children remain in detention at the time of the publication of this statement.