a person’s will to apply for asylum and therefore that that person has the status of an asylum applicant. The procedure applies to all third country nationals who have not been through reception and identification procedures. The platform is available in twelve languages (Greek, Kurmanji, Albanian, Georgian, Arabic, Bengali, Dari, English, Farsi, Pashto, Turkish and Urdu), and after applicants have provided their personal information, they are asked to choose one of two registration facilities: Diavata RIC (Thessaloniki) or Malakasa RIC (Attica). Once the electronic form is completed, a registration appointment would be assigned to the applicant and communicated via email. Upon appearance at the above RICs at the pre-arranged appointment, asylum seekers are subject to de facto detention period of maximum 25 days in order for the procedure to be completed, despite the Directive's provision “not to hold a person in detention for the sole reason that he or she is an applicant for international protection”.340 During this de facto detention period, asylum applicants complete their asylum interview and wait for the first instance decision on their case. As of 23 June 2023, the Asylum Service has not published data on the pre-registration of applications through the platform. As of 15 May 2024, there was a discontinuation of the provision of interpretation services which until then was exclusively provided by the organisation METAdrasi, due to the expiration of its contract with the Ministry of Immigration and Asylum and also due to months of delayed payments. Previously, as of 29 April 2024, for the same reasons, the provision of services to the Asylum Service had also been discontinued. The interpretation services are funded by European funds, from the Asylum, Migration and Integration Fund (AMIF) for the period 2021-2027. As a result, Asylum Service in almost the entire territory stopped carrying out all procedures related to the applications for international protection (indicatively: registration of both initial and subsequent asylum applications, conducting interviews, service of decisions, etc.). Part of these serious deficiencies in interpretation have been covered by the EUAA.341 According to official statistics of 30 June 2024, released as part of parliamentary scrutiny,342 in Malakassa RIC there were 1.411 residents, out of which 154 vulnerable and 7 interpreters. In Diavata RIC, there were 445 residents, out of which 50 vulnerable and 6 interpreters. Although the law requires that interpretation services be provided by the state in a language understood by applicants throughout the entire reception and identification and asylum process, in many cases, the gaps in interpretation have been attempted to be filled in questionable -and not provided by law- ways. Illustratively, asylum seekers are often requested to state their consent to the proceedings being carried out in Greek by signing solemn declarations confirming that they understand the language; asylum seekers are requested to sign declarations that they accept third parties who are not certified interpreters to assist them during the proceedings; on the recommendation of the Asylum Service, the asylum seeker is accompanied by a lawyer, who is required to sign the act of lodging an appeal and, thus, assume responsibility of informing on the document and interpreting for the asylum seeker.343 Due to these deficiencies, in 2024, access to the asylum procedure was extremely limited, exposing third country nationals wishing to file an application for international protection to the risk of arrest and administrative detention, in a legal limbo without any official documentation or legal status, unsupported by appropriate structures to provide for their essential needs. creating at the same time huge delays in the processing of already registered asylum applications.344 3.3. Access to the procedure from administrative detention Access to the asylum procedure for individuals detained for the purpose of removal remains problematic. The application of a detained person having expressed the wish to apply for asylum is registered with delay. The person remains detained between the expression of the intention to apply for asylum and the registration of the application, by virtue of a removal order. The person is deprived of any of the procedural 340 341 342 343 344 Article 8 (1) RCD EFSYN,", Mε translate και... τηλεπάθεια η διερμηνεία της υπηρεσίας Ασύλου, 30 October 2024 available in Greek here. Hellenic Parliament, see here. RSA, Major deficiencies in the provision of interpretation services in Greece, Even asylum interviews are no longer being conducted”, 5 November 2024, available here. For this situation, individualized interventions were made by organizations to the Ministry of Migration and Asylum, as well as questions raised within the framework of Parliamentary Control by Members of Parliament from opposition parties. See, Ελληνικό Κοινοβούλιο, Μέσα Κοινοβουλευτικού Ελέγχου, 20 january 2025, available here. 73