Moreover, it should be underlined that in all of the islands the full registration of asylum applications is processed by the Reception Service (RIS). More specifically the RISs in Kos and Samos first introduced this practice at the end of 2021, and later, in 2022, the rest followed. It has been observed that ever since the registration of asylum applications was removed from the Asylum Service and was undertaken by the RIS, the registration form very often only includes very limited information. Nevertheless, in practice, asylum seekers have the opportunity during their interviews to present their claims, even if no mention of said claims has been included in their registration form. In any case, persons newly arrived on the islands had the full registration of their asylum application immediately after the end of the quarantine/first reception (waiting) area, where they could not have access to legal consultation (see the Reception and Identification Procedure). Subsequently, in most cases, their interviews were scheduled within 1-3 days after the registration, preventing them from having enough time to access legal aid and prepare for their asylum interview. In Lesvos, the issue of unavailability of interpreters in Somali remained, as the majority of organisations either did not have Somali interpretation or had very limited capacity. The lack of Somali interpretation combined with the fact that very often all newly arrived were scheduled for their interview on the same day, leaving them almost no time for preparation before the interview, hindered their access to legal aid even further. Moreover, the Lesvos UNHCR Field Office observed that interviews for asylum applicants with rare mother languages (i.e. Amharic or Tigrinya) were postponed depending on the availability of the interpreters.412 When there were no available interpreters in the Krio language, applicants from Sierra Leone had the full registration of their asylum applications made in English; in most cases, people had only basic English knowledge. 413 In Kos, the same practice was observed and the newly arrived asylum applicants who spoke rare languages were receiving invitations for the conduct of their asylum interview within one day of their asylum application registration or within three days in case they had been assessed as vulnerable, however, their interviews were postponed due to the lack of proper interpretation. 414 According to Article 82(4) of Asylum Code, asylum applicants that have been considered vulnerable, may have reasonable time to prepare for their interviews and consult a lawyer, if the interview is scheduled within 15 days from the submission of the asylum application. The preparation time may not exceed three days. If the interview is scheduled within more than 15 days from the submission of the asylum application, no reasonable time is granted for their interview preparation. If the interview is postponed, no time is granted again for their interview preparation. Decisions at first instance shall be issued within seven (7) days, according to Article 95(3)(c) of the Asylum Code. However, in practice in most cases the interviews of the newcomers are being scheduled and conducted before examination by the competent Medical and Psychosocial Units, thus they undergo the interview procedure without prior evaluation of their potential vulnerabilities. Most of the time, the authorities proceed with a typical medical screening and record only manifest vulnerabilities. In any case, there is no information exchange mechanism between the RIS’ Vulnerability Focal Point (VFP) and RAO, and no relevant joint process to ensure that interviews are scheduled after the vulnerability assessment is completed. Even when RAO caseworkers refer the case to RIC’s Medical and Psychosocial Unit for a further vulnerability assessment, they do so after the interview has been completed. No postponements have been granted for interviews despite the applicants’ and their legal representatives’ relative requests that vulnerability assessments have not been completed. Accordingly, no reasonable time for their preparation can be granted on the basis of their vulnerabilities, since they have not been identified as such. According to Article 74(3) Asylum Code, it is expressly foreseen that communication with asylum applicants (including interviews) may be conducted in the official language of their country of origin, or in 412 413 414 Information acquired during the Lesvos LAsWG meeting, 17 May 2022. Ibid. Information provided by the GCR lawyer based in Kos. 96