for the operation of civil society organisations in the Facilities and their certification. • B eyond the legal issues raised by the informal operation of these facilities and the failure to issue the regulatory acts required for their establishment and operation,254 this pending issue is the main reason for the creation of organisational dysfunctions, due to the lack of effective coordination of the involved agencies and the inability to monitor and attribute liability in cases where serious omissions are discovered. The Ombudsman further recommends: a) The official establishment of all accommodation facilities and the issue of the stipulated General Rules of Operation and the Internal Rules; b) the completion of the preparation of a Registry of accredited agencies by the Directorate for Reception of the General Secretariat for Reception and its appropriate use. 2.2. The deviation between provision and implementation of the rules This deviation is not of course a characteristic only of the migration legislation, but it entails in this case onerous restrictions of the rights of the irregular migrants and asylum applicants. The most characteristic example over time is that the first reception procedures are not implemented with all new arrivals to the islands, contrary to the mandates of Law 3907/2011.255 The practical result of this was that vulnerable individuals (minors, etc.) ended up in Pre-removal Centers, whereas their detention, at least up to now, is prohibited. As mentioned above, the medical examination card of each new arrival is still a goal at the hotspots, despite the provisions of Law 3907/2011. A second typical example is the way in which the legislative provision on lodging asylum applications in person was implemented in practice. The lodging via Skype mentioned above, caused more of an obstacle rather than the rationalisation of the access. The obligation for the lodging in person, also led to the violation of the rule of not detaining asylum applicants for more than 3 months 254 It is noted that the Ministry of National Defence has undertaken to take actions and enter into contracts for the establishment, construction and maintenance of the facilities, as well as specific issues of their operation (transportation, provision of food, accommodation, health care), according to Law 4368/2016, Article 96, but the decisions for the establishment of all types of facilities, the appointment of directors and their general operation belong to the competence of the Ministry of Migration Policy. 255 See Annual Report 2014, pg. 152 et seq. (Law 4375/2016), since the detention time counts from the registration of the application by the Asylum Service, for which there is a varying waiting time, and not from the applicant’s statement to the police authorities that he/she wishes to lodge a relevant application. Moreover, cases of failure to register in time the intention to lodge an asylum application were also reported. In at least two cases investigated by the Ombudsman, this omission appears to have resulted in the inclusion of the applicants in readmission procedures before their asylum application was examined (in more detail, see Chapter A5.2.). As regards the elementary rights of administrative detainees, a typical example of a case where the rules are not implemented is the lack of access to open-air exercise at the police station cells, with the exception of the Preremoval Centers. However, the most important provision also in EU legislation, which is not implemented in practice, as mentioned in the relevant chapter (A5), is the due diligence for the fast-track processing of the return to the country of origin of the third-country national, which would reduce the detention time. As regards the return procedure itself, the timely information, at least 24 hours in advance, is a dead letter of the European Return Handbook in all return/readmission procedures. It is also characteristic that the seamless educational integration of the refugee populations living in the country is still hindered by the lack of a cohesive framework. The Greek State tried, especially since early 2016, to introduce an adequate framework for the seamless educational integration of the refugee populations living in the country, taking into consideration the added needs that had emerged. The lack of prior experience, the gradual formulation of the curriculum under pressure, the difficulties that emerged and continue to emerge during its implementation, the fluidity of the population and the diverse needs, as well as the problems of coordination between the co-competent ministries or services, resulted to a great extent in the issue of a large number of legislation acts that frequently regulate the same issue, with amendments, corrections or additions. To this abundance of regulations is added a series of circulars that clarify separate issues, enhancing however the insecurity of the involved persons, with regard to the current framework. On the contrary, but for the same reasons as a rule, the regulatory framework remains incomplete in certain separate issues that are still not regulated, despite the fact that the 2016-2017 school year - when the plan for the 87