interpretation services throughout Greece’s camps, on account of the expiration and delays in the timely renewal of the contracts it had signed with the MoMA, while once more noting that it had yet to receive due payments for the services provided by its interpreters in the previous months.381 Following these developments, on 17 May 2024, the MoMA issued its own announcement, noting interpretation gaps had been addressed with the support of EUAA personnel and referring to delays, from the side of METAdrasi NGO, in presenting the necessary documents provided by law in order to sign a new contract, as the designated provider of interpretation services. 382 However, despite assurances, throughout 2024 there was nearly no interpretation available within the Asylum Service and extremely limited numbers of interpreters in refugee camps both on the mainland and the Greek islands. 383 As regards remote interpretation, its use continued to be observed frequently and was not limited to remote RAOs and AAUs, that may not have a sufficient number of interpreters. 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. Lastly, inaccuracies and mistakes in interpretation, including in the context of asylum interviews, with the potential to negatively influence the perceived credibility of applicants and thus their asylum case, were reported in March 2024.384 1.3.3. Recording and transcript The Asylum Code provides for the audio recording of the personal interview. A detailed report is drafted for every personal interview, which includes the applicants’ main arguments and all the essential elements of their claim. The audio recording of the interview accompanies the report. For interviews conducted by videoconference, audio recording is compulsory. When 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. 385 The applicant may at any time request a copy of the transcript, a copy of the audio file or both. 386 1.3.4. Notification of First Instance Decisions The IPA introduced the possibility for first instance decisions to not 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 have been maintained in the Asylum Code, significantly limiting applicants’ ability 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 them. As the Greek Ombudsperson has noted with regard to the provisions of fictitious service, said provisions effectively limit the access of asylum applicants to legal remedies. 387 More precisely, according to 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, through which applicants have unique access through an account they maintain, or; 381 382 383 384 385 386 387 METAdrasi, End of the provision of interpretation services in the asylum procedures and the Reception and Identification Centres throughout Greece, 14 May 2024, no longer available online. Also see Kathimerini, Refugees without the possibility to communicate, 17 May 2024, available in Greek here. MoMA, Anouncement, 17 May 2024, available in Greek here. Fenix, Open Letter: Put an end to the disruption of interpretation services still undermining asylum seekers’ rights in Greece, 01 November 2024, available here. Solomon, Lost for Words: Lack of interpreters puts asylum seekers’ lives on hold in Greece, 27 March 2023, available here. Article 82(13) Asylum Code. Article 82(15) Asylum Code. Ombudsperson, 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, available in Greek here. 79

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