asylum applications with the asylum service.146 This is true regardless of whether they are in detention or not.147 Article 8 APD, transposed into Article 66 IPA, requires Member States to provide people with information on the asylum procedure from the moment there are “indications” that a person wishes to apply for international protection.148 However, the right to information extends beyond a person’s initial arrival and registration. Article 19 APD, transposed into Article 71 (2) IPA, requires MS to ensure that during the first instance procedures “applicants are provided with legal and procedural information free of charge, including, at least, information on the procedure in the light of the applicant’s particular circumstances”.149 This requires authorities to, at a minimum, provide an explanation of the “procedural steps, devices, rights and obligations that are likely to be relevant to the individual case”150 In the case of a negative asylum decision, Greek and EU law go even further by requiring authorities to provide a decision in writing that details the reason for the rejection and provides information on how to challenge a negative decision in a language that the applicant can reasonably be expected to understand.151 b. Access to Legal Services Although the APD does not guarantee every person a lawyer during the first stage of their asylum procedure, Article 71 IPA gives applicants the right to consult a lawyer or other adviser on their case.152 In the event that an applicant does appoint a lawyer or legal counsellor, both Greek and EU law make clear that legal counsel must have access to the applicant, particularly if they are in detention or at a border-crossing point. For example, Article 8 (2) APD obliges Member States to “ensure that organisations and persons providing advice and counselling to applicants have effective access to applicants present at border crossing points”153 while the RCD similarly stresses that “legal advisers or counsellors . . . have the possibility to communicate with and visit applicants in conditions that respect privacy”154 During the second stage of the procedure – i.e. after a person has received a first rejection – the law provides additional guarantees. Specifically, the IPA Article 71 (2) states that applicants, upon request, shall be provided with legal assistance in their proceedings before the Appeals Authority.155 c. The Right to Information in Detention and Individualised Detention Orders Greek, EU, and human rights law guarantee detained persons the right to access information about their detention and legal proceedings, regardless of whether they are asylum seekers or rejected asylum seekers. In this regard, Article 10 RCD – which concerns detention conditions – requires MS to “ensure that applicants in detention are systematically provided with information which explains the rules applied in the facility and set out their rights and obligations in a language which they understand or are reasonably supposed to understand”156. Similarly, for rejected asylum seekers, the RD and Law 3907/2011 both require the authorities to “systematically” provide detained persons with information regarding the rules, as well as their rights and obligations within, the detention centre.”157 146 Art 39(3)(d) L. 4636/2019, as amended by Art. 2(1) 4686/2020. 147 See Art. 6 (1) Directive 2013/32/EU. 148 Art. 8 (1) Directive 2013/32/EU. 149 Article 19 (1) Directive 2013/32/EU. 150 Vedsted-Hansen Commentary p. 1328. 151 Art. 10 (2) Directive 2013/32/EU. 152 Art. 71 (1) L. 4636/2019. 153 Art. 8 (2) Directive 2013/32/EU. 154 Art. 10 (5) Directive 2013/33/EU. 155 Art. 71 (3) L. 4636/2019. 156 Art. 10 (5) Directive 2013/33/EU. See also Art. 47 (6) L. 4636/2019. 157 Art. 31 (5) L. 3907/2011, Art. 16 (5) Directive 2008/115/EC. 22 DETENTION OF MIGRANTS ON THE ISLAND OF KOS