Refraining from a thorough analysis of these amendments, the NPM would like to bring attention to the following issues:  The NPM is particularly concerned about the provisions regulating detention of asylum seekers, including minors, in closed-type centres during asylum proceedings. The NPM is of the opinion that children should not be detained in closed-type facilities. This position has been reiterated and justified in previous NPM reports. The NPM is further of the opinion that the amendments create a parallel detention regime similar to the one applied to foreigners who have been imposed coercive administrative actions and who are detained in the special centres for temporary accommodation of foreigners under the Foreigners in the Republic of Bulgaria Act. No maximum duration or suo motu judicial review of detention has been regulated. This may lead to violations of domestic and international law in the area of asylum and human rights. The NPM will monitor closely procedural guarantees, lawful detention and period of detention of asylumseekers during its inspections in 2016;  The statutory period within which the competent administrative body – SAR chairperson – must issue a decision thereby granting or refusing a refugee or humanitarian status has been extended from three to six months;  The NPM is satisfied that its repetitive recommendations regarding problems with the appointment of guardians/custodians to unaccompanied minors, asylum seekers or beneficiaries of international protection, as well as the legal regulation of healthcare practices in SAR centres have been addressed in the law;  The NPM considers positive the amendments made as regards access of asylum seekers to education and labour market, as well as expanding the scope of vulnerable persons. In 2016 the Ombudsman acting as NPM will pay particular attention to the rights of women and children, especially minors, and will focus on violence against women placed in centres operated by SAR and the Migration Directorate. MONITORING FORCED RETURN Pursuant to Article 39a, para 2 of the Foreigners in the Republic of Bulgaria Act and letter no. 0403-18 of 24 August 2015 of the MoI Migration Directorate requesting that a representative of the Ombudsman institution monitors forced return of foreigners, and upon anexpress order of the Ombudsman issued under Article 2 of the Rules of Procedure, Lyubomir Kirilov Krilchev, director of National Preventive Mechanism and Fundamental Rights and Freedoms Directorate monitored an operation of forced return of foreigners to Pakistan. The operation took place on 23 and 24 September 2015. It was organsed by the Republic of Bulgaria and coordinated by the European Agency for the Management of Operational Cooperation at the External Borders of the Member States of the European Union (Frontex). international protection, for a uniform status for refugees or for persons eligible for subsidiary protection, and for the content of the protection granted (recast). 22