Authorities, undoubtedly amounts to such an expression of intention. Accordingly, the request for a registration appointment must absolutely be expressly acknowledged as “making” of an asylum application, regardless of the availability of appointments in mainland RIC or the date of potential appointments granted by the platform. 2. The uniform registration procedure at the RIC of Malakasa and Diavata and the operation of the online platform in no way remedy systematic non-compliance with the maximum time limits set by law for the lodging of asylum applications in Greece. At least “registration” should therefore take place within three working days from the “making” of the application through the request of an appointment via the online platform. A document bearing the applicant’s photograph and details must also be granted at that stage, in accordance with Article 69(2) of the Asylum Code. 3. As long as the issue persists, asylum seekers continue to be deprived of documents attesting their right to remain on the territory and to receive reception conditions until their claim is lodged at the RIC. The RIS must therefore offer full material reception conditions to those in need thereof already at the point when a registration appointment is requested through the platform. Furthermore, where people with an appointment in mainland RIC are apprehended before “registration”, police authorities must refrain from detention and immediately transfer them to the RIC for reception and identification procedures under Article 38 of the Asylum Code. Alternatively, they should themselves proceed to immediate “registration” of the persons’ “intention” to apply for international protection and refer them to the Asylum Service for the lodging of the application. 4. RSA reiterates that the “restriction of liberty” within the RIC amounts to arbitrary deprivation of liberty, given that it does not comply with the strict legislative safeguards on administrative detention. Greece should amend Article 40 of the Asylum Code and repeal the “restriction of liberty” in the RIC to bring its legislation in line with Articles 8, 9 and 11 of the Reception Conditions Directive.51 We recall that permissible restrictions on asylum seekers’ freedom of movement are already regulated in Articles 49 and 50 of the Asylum Code. 5. RSA repeats that the last sentence of Article of Article 41(d) of the Asylum Code must be repealed to bring Greek law in line with Article 24 of the Asylum Procedures Directive.52 At a minimum, Greece should amend the provision to bring it line with the last sentence of Article 77(3) of the Asylum Code, expressly referring to “the provision of special procedural guarantees to those persons”. 6. Greece should ensure that sufficient registration officers and interpreters are deployed to ensure rapid and uninterrupted registrations in the RIC, automatic issuance of AFM and uploading of registration elements e.g. lodging forms, 51 52 RSA et al., Deportations and Returns Bill – Comments from legal organisations, June 2021, 11. RSA, Ειδικές διαδικαστικές εγγυήσεις στη διαδικασία ασύλου: Παρατηρήσεις επί της νομολογίας, June 2022, 19. 14 RSA REPORT │ 2023