interpretation services in all the establishments visited during the 2023 visit. Further, access to information in a language and form that detained foreign nationals understand also remains insufficient”.886 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-described categories of organisations active in Greece are 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 practice employees of NGOs and members whose 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 these new registration requirements, ECRE’s Expert Opinion upon request from the ELENA Coordinator in Greece, published in December 2021,887 emphasises that the registry has 886 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 20 November to 1 December 2023. The Government of Greece has requested the publication of this report and of its response. The Government’s response is set out in document CPT/Inf (2024) 22. Strasbourg, 12 July 2024, para 32, available here. 887 ECRE, Expert Opinion upon request from the ELENA Coordinator in Greece 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. 172