The appointment process mandates a maximum 25-day detention period in order for the procedure to be completed, restricting the freedom of movement of those who have registered for asylum. Pursuant to Article 8 of the EU Reception Conditions Directive (RCD), Member States ‘shall not hold a person in detention for the sole reason that he or she is an applicant for international protection’.201 Despite this, the new platform utilises detention as the status quo for the registration of an asylum application, violating the RCD’s conditions of exceptional implementation. During this detention period, asylum seekers complete their asylum interview and wait for the first instance decision on their case. If the individual’s decision is negative, they are permitted to leave the camp, yet no specific instructions are provided regarding the competent Regional Asylum Office for submission of their appeal or their right for free legal aid in the second instance of their asylum procedure, further obstructing individuals’ effective access to asylum and due process. The new camps in Diavata and Malakasa are far from the urban centres where most asylum seekers live and are extremely difficult to reach as no financial or logistical provisions have been made for asylum seekers’ transport, resulting in an increased risk for individuals to miss their registration appointments and consequently their access to international protection. Furthermore, the camps began operating with understaffed and under resourced Mobile Units of the RIS, lacking the medical and psychosocial personnel required for first reception procedures. The failure to provide first reception services and adequate registration procedures for refugees and migrants has left hundreds of people unregistered and vulnerable to detention. In addition, there have been reports of an irregular distribution of appointments and extensive delays of appointment dates, with several appointments being assigned over twelve months after the initial preregistration application was submitted.202 In many cases, appointments were not available at all, further highlighting the lack of capacity of the facilities and resources available, forcing people to remain undocumented for extensive periods of time, without basic medical care, accommodation or essential services. Consequently, the issues that existed during the previous Skype pre-registration system persisted, where people were forced into a legal limbo without any official documentation or legal status and remain unsupported by appropriate structures to provide for their essential needs. 3.3 Access to the procedure from administrative detention Access to the asylum procedure for persons detained for the purpose of removal is highly problematic. The application of a detained person having expressed his or her wish to apply for asylum is registered only after a certain period of time. The person remains detained between the expression of the intention to seek asylum and the registration of the application, by virtue of a removal order. He is deprived of any procedural guarantees provided to asylum seekers,203 despite the fact that according to Greek law, any person who expresses his/her intention to lodge an application for international protection is an asylum seeker. Since the waiting period between expression of intention and registration is not counted in the Duration of Detention, asylum seekers may be detained for a total period exceeding the maximum detention time limit for asylum seekers.204 201 202 203 204 Article 8 (1) RCD Greece // Bimonthly Bulletin on Refugees and Migrants, October 2022, available https://www.gcr.gr/media/k2/attachments/GCR_OXFAM_STC_Advocacy_Update_October_2022.pdf Global Detention Project & Greek Council for Refugees, Joint Submission to the Working Group on Arbitrary Detention in Preparation for its Mission to Greece in December 2019, Submitted in October 2019, available at: https://bit.ly/2TRYmna. Communication from the UNHCR (15.5.2019) in the M.S.S. and Rahimi groups v. Greece (Applications No.30696/09, 8687/08). 54