The 2010 Greek Action Plan on Asylum already provided that third-country nationals should be subjected to first reception procedures upon entry. The competent authority to provide such services was the First Reception Service (FRS), established by L 3907/2011. First reception procedures included: (a) Identity and nationality verification; (b) Registration; (c) Medical examination and any necessary care and psychosocial support; (d) Provision of proper information about newcomers’ obligations and rights, in particular about the conditions under which they can access the asylum procedure; and (e) Identification of those who belong to vulnerable groups so that they be given the proper procedure.136 This approach was first implemented by the First Reception Centre (FRC) set up in Evros in 2013, 137 which has remained operational to date and has not been affected by the hotspot approach. Joint Ministerial Decision 2969/2015 issued in December 2015 provided for the establishment of five FRCs in the Eastern Aegean islands of Lesvos, Kos, Chios, Samos and Leros, 138 regulated by existing legislation regarding the First Reception Service. 139 However, this legislative act failed to respond to and regulate all the challenges arising within the scope of the hotspots’ functions. As a result, issues not addressed by the existing legal framework, for example the involvement of EU Agencies in different procedures, long remained in a legislative vacuum. On 3 April 2016, in the light of the EU-Türkiye statement of 18 March 2016, the Greek Parliament adopted a law ‘on the organisation and operation of the Asylum Service, the Appeals Authority, the Reception and Identification Service, the establishment of the General Secretariat for Reception, the transposition into Greek legislation of the provisions of Directive 2013/32/EU, provisions on the employment of beneficiaries of international protection and other provisions’. This reform was passed through L 4375/2016. 140 L 4375/2016 partially attempted to regulate the establishment and function of hotspots and the procedures taking place there. However, national legislation has failed to effectively regulate the involvement of the EU Agencies, for example Frontex agents. Following the enactment of L 4375/2016, the FRS was succeeded by the Reception and Identification Service (RIS). The RIS is currently subsumed under the General Secretariat for Reception of Asylum Seekers of the Ministry of Migration and Asylum.141 The IPA, in force since 1 January 2020, regulated the functioning of the RICs and the conduct of the reception and identification procedure in a similar way. Under the Asylum Code 142, the relevant regulations were codified to include Closed Controlled Access Centre of Islands (CCACI.)’. Article 38 of the Asylum Code, provides that: ‘All third-country nationals and stateless persons who enter without complying with the legal formalities in the country, shall be submitted to reception and identification procedures.’143 Reception and identification procedures include five stages: 144 1. Information on rights and obligations, transfer to other facilities, the possibility to seek protection or voluntary return, in a language the person understands or in a language that a person may reasonably be supposed to understand and in an accessible manner, by the Information Unit of the Reception and Identification Centre (RIC) or the Closed Controlled Access Centre (CCAC) or in case of mass arrivals, by the Police, Coast Guard or Armed Forces i;145 136 137 138 139 140 141 142 143 144 145 Article 7 L 3907/2011. Joint Ministerial Decision 11.1/1076/2012, Gov. Gazette 3543/Β'/31.12.2012; Reception and Identification Service, RIC at Fylakio, Evros. Joint Ministerial Decision No 2969/2015, Gov. Gazette 2602/Β/2-12-2015. Law 3907/2011 ‘On the Establishment of an Asylum Service and a First Reception Service, transposition into Greek Legislation of the provisions of the Directive 2008/115/EC ‘on common standards and procedures in Member States for returning illegally staying third-country nationals’ and other provisions’. L 4375/2016, Gov. Gazette 51/A/3-4-2016, available at: http://bit.ly/2kKm2cu. Article1 PD, 18/2020 (ΦΕΚ 34/Α/19-2-2020), available in Greek at: https://bit.ly/3wfJUHz. Asylum Code, see https://bit.ly/3Ek1hfp. Article 38(1) Asylum Code. Article 38(2) Asylum Code. Article 39 Asylum Code. 44