against their detention or deportation decisions or to lodge an appeal against their deportation was conditional on them being able to access a lawyer’.624 Similar observations were made by the Council of the European Union after the 2021 evaluation and its recommendations to the Greek Government that followed. 625 and were reported once again in a legal note issued in June 2022 by NGO Refugee Support at the Aegean (RSA).626 2. Access to NGOs and UNHCR Indicators: Access to NGOs and UNHCR 1. Do asylum seekers located at the border have effective access to NGOs and UNHCR if they wish so in practice? Yes With difficulty No 2. Do asylum seekers in detention centres have effective access to NGOs and UNHCR if they wish so in practice? Yes With difficulty No 3. Do asylum seekers accommodated in remote locations on the territory (excluding borders) have effective access to NGOs and UNHCR if they wish so in practice? Yes With difficulty No Access of NGOs to Reception and Identification Centres, camps on the mainland and pre-removal detention facilities is subject to prior permission by the competent authorities. Article 78 of the Asylum Code (Greek Law 4939/2022 ratifying the Code on reception, international protection of third-country nationals and stateless persons, and temporary protection in cases of mass influx of displaced persons) provides for the obligation of all Greek and International Organisations of Civil Society active in the field of refugee support and protection as well as their members to register in the established Registry of Greek and Foreign Non-Governmental Organisations (NGOs) in the Special Secretariat for the Coordination of Involved Agencies of the Ministry of Immigration and Asylum. NGOs that meet the minimum necessary conditions for participation as provided in the Asylum Code are registered by the competent service. Non-profit organisations, voluntary organisations and any corresponding organisation, Greek or international, that is not registered in the registry, may not participate in the implementation of international protection, immigration and social integration actions within the Greek territory, and in particular in the provision of legal, psychosocial and medical services The Law also provides of an additional registry of Members of Non-Governmental Organisations (NGOs) active in matters of international protection, immigration and social integration, in which the members, employees and partners of the above organisations active in Greece are registered and registered. The registration of these persons in the Registry and their certification is a necessary condition both for their activity within the Greek territory and for their cooperation with public bodies. In practise employees of NGOs and members that their name is not provided for in the registry are banned from entering places of detention and reception facilities under the Ministry’s responsibility. GCR is aware of several instances when access was refused to interpreters and on occasion lawyers or were obliged to wait for several hours before they were granted permission to enter. Concerning the lawfulness of the registration in ECRE’s Expert Opinion upon request from the ELENA Coordinator in Greece published in December 2021627 mentions that the registry has been heavily 624 625 626 627 CPT, Report to the Greek Government on the visit to Greece carried out by the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) from 13 to 17 of March 2020, CPT/Inf (2020) 36, Strasbourg, 19 November 2020, available at: https://bit.ly/3quLJ4r, para.22 -23. Council of the European Union, Council Implementing Decision setting out a recommendation on addressing the deficiencies identified in the 2021 evaluation of Greece on the application of the Schengen acquis in the field of return, 9 November 2021, available at: https://bit.ly/3BVJWYB. RSA, Persisting systematic detention of asylum seekers in Greece, June 2022, available at: https://bit.ly/3qcFGkD. ECRE Concerning the lawfulness of Greek legislation regulating the registration of non-governmental organisations (NGOs) on the Registry of NGOs working with refugees and migrants in Greece, December 2021, available at: https://bit.ly/3yvt6xc. 141