Until 30 September 2022, interpretation was provided both by interpreters of the NGO METAdrasi and EUAA interpreters.248 Following the non-renewal of the agreement with the NGO METAdrasi, the capacity of the interpretation services has been challenging, as currently, EUAA is the sole provider of such services. The use of remote interpretation has been observed more frequently and is not limited to distant RAOs and AAUs. Technical deficiencies and constraints should be taken into consideration when assessing the quality of remote interpretation. When it comes to rare languages, if no interpreter is available to conduct a direct interpretation from that language to Greek (or English in cases examined by EUAA case workers), more interpreters might be involved in the procedure to translate through different languages. 1.3.3. Recording and transcript Both the IPA and the Asylum Code envisage audio recording of the personal interview. A detailed report is drafted for every personal interview, which includes the main arguments of the applicant for international protection and all its essential elements. Where the interview is audio recorded, the audio recording accompanies the report. For interviews conducted by video-conference, audio recording is compulsory. Where audio recording is not available, the report includes a full transcript of the interview and the applicant is invited to certify the accuracy of the content of the report by signing it, with the assistance of the interpreter who also signs it, where present. 249 The applicant may at any time request a copy of the transcript, a copy of the audio file or both. 250 1.3.4. Notification of First Instance Decisions The IPA further introduced the possibility for first instance decisions not to be communicated in person to the applicant (‘fictitious service’ πλασματική επίδοση) or the first instance decision to be communicated to the applicant by administrative authorities other than the Asylum Service. Both practices were maintained in the Asylum Code throughout 2022 and may significantly underestimate the possibility of the applicant to be informed about the issuance of the first instance decision and/or the content of said decision and/or the possibility to lodge an appeal. Consequently, deadlines for submitting an appeal against a negative first-instance decision may expire without the applicant being actually informed about the decision, for reasons not attributable to him/her. As the Greek Ombudsman has noted with regard to the provisions of fictitious service, said provisions effectively limit the access of asylum seekers to legal remedies. 251 More precisely, according to the IPA and the Asylum Code, a first instance decision can be communicated: ❖ in person or; ❖ with a registered letter sent by the Asylum Service to the applicant or; ❖ by e-mail to the applicant or; ❖ by uploading the Decision on an electronic application managed by the Asylum Service or ; ❖ by communicating the decision to authorised lawyers, consultants, and representatives. 252 In this regard, it should be mentioned that according to the IPA, once a lawyer is appointed by the applicant at any stage of the procedure, the lawyer is considered to be a representative of the applicant for all stages of the procedures, including the service of the decision regardless of the actual representation of the applicant at the time of the fictitious service unless the appointment of the lawyer is revoked by a written declaration of the applicant with an authenticated signature.253 248 249 250 251 252 253 METAdrasi, ‘METAdrasi was officially informed about the non-renewal of the agreement for the provision of interpretation services at the Asylum Service’, October 2022, available at: https://bit.ly/42Y1qPO. Article 77(13) IPA and 82(13) ASYLUM CODE. Article 77(15) IPA and 82(15) ASYLUM CODE Ombudsman, Παρατηρήσεις στο σχέδιο νόμου Προσαρμογή της Ελληνικής Νομοθεσίας προς τις διατάξεις της Οδηγίας 2013/33/ΕΕ (αναδιατύπωση 29.6.13) σχετικά με τις απαιτήσεις για την υποδοχή των αιτούντων διεθνή προστασία κ.ά. διατάξεις, April 2018. Article 82(3) IPA, as amended by L. 4686/2020 and 87(3) ASYLUM CODE Article 71 (7) IPA and 76(7) ASYLUM CODE 60