4. PRE-REMOVAL DETENTION CENTERS 4.a. Policy and legislative developments in 2019 This year was marked by key institutional developments, including the transfer of 37 migration competences from the Ministry of Migration and Asylum to the Ministry of Citizen Protection and changes regarding the prerequisites for the administrative detention of third-country nationals (L.4636/2019 entry into force on 1.1.2020). Although, it is too early to assess this change of policy and namely its impact on the detainees' living conditions and human rights that would allow a well-documented overall assessment, the NPM is alert in order to ensure its compatibility with the guidelines and priorities set by international and European legislation regarding migration policies and conditions of freedom deprivation. In his intervention before the competent parliamentary committee, the Ombudsman made extensive remarks regarding the provisions of the introduced bill (voted as Law 4636/2019) and namely the vague notion of the closed reception and identification centers that "shall be organized according to the standards of pre-removal detention centers". Among other, the Ombudsman commented on the prolongation of detention time regarding minors, which also falls within the Mechanism's focus area. In particular, there are issues with the expansion and prolongation of the administrative detention of asylum seekers and namely with three policy choices: a) the provision introducing general administration detention instead of the continuation of detention only for asylum applicants b) the establishment of closed reception and identification centers and c) the dissociation of the administrative detention time from the administration time for returns. In that manner, the maximum time limits set in the Directive 2008/115/EC "on common standards and procedures for returning illegally staying third-country nationals" do not apply. It must be noted that the 18 month-time limitation set by the Directive 2008/115/EC (para.5-6 of article 15, ECJ Katzoev C-457/09 and Bashir Mohammed Ali Mahdi C-146/14) may under no circumstances be violated. The proposed provision allowed for an 18 plus 18 detention period, which was unacceptable for a rule-of-law state. The Mechanism has reiterated its solid objection regarding the administrative detention of minors 37 The Ministry of Immigration and Asylum was abolished after the 2019 parliamentary elections and its competencies were transferred to the Ministry of Citizen Protection (Presidential Decree 81/2019). The Ministry was subsequently re-established with Presidential Decree 4/2020 47