JUSTICE FOR ALL APPLICATION OF THE FRAMEWORK DECISIONS IN MEMBER STATES 05. 5.1 GENERAL CHALLENGES 5.2 LACK OF DATA The general tendency observed in both the national research and the workshop transcripts is that EU framework decisions were difficult to understand, difficult to apply and mostly time-consuming. Austria indicated that it was a long (and often costly) process for the legal representatives of persons concerned in the context of cross-border proceedings due, inter alia, to language barriers and the difficulties met in communicating with their client and the relevant authority.447 Bulgaria also evoked the issues of language barriers, notably in the context of the use of the PAS FD, reporting the unavailability of interpreters and translators for many languages, even European ones. This issue particularly applies in the context of smaller cities. In bigger towns, it was stated that there is no specialisation for interpreters anymore, neither for those who participate in proceedings where minors are involved nor in criminal matters where disabled persons are involved, which means they are not aware of the specific terminology.448 Slovenia mentioned the overly bureaucratic nature of the proceedings and the superficial nature of the checklists involved. They highlighted that information was aplenty but not always relevant, notably on the contextual part of the proceedings.449 The lack of data is the only issue which has been identified by all six partner countries as well as participants of the workshops concerning all four framework decisions. As was discussed during the regional consultation workshop, the fact that the defendant concerned is a person with intellectual and/ or psychosocial disabilities adds another layer of obstacle in the cross-border proceedings. It was said that such individuals will usually be perceived as dangerous, which will be used as an informal ground for refusal to rely on any FD involving the transfer to their jurisdiction or their supervision within their State for instance. Concerning the EAW FD, Bulgaria reported the absence of statistics at the national level on EAW in general.450 Austria, a federal state, wrote on the difference between the Ministry of Justice being the issuing authority and collecting data, and the regional courts as executing authorities which, on their side, do not systematically collect data.451 It was also reported how the data itself was not thorough. An Italian participant pointed out during the consultation workshop that either there is a lack of data altogether or databases exist but are unknown to the relevant actors. Regarding the TP FD, data is either not systematically gathered, like in Bulgaria452 or Lithuania,453 or collected in a very limited manner, like in Austria.454 There, while the Ministry of Justice collects data as issuing authority, the courts do not systematically collect data. Where data is available by the Ministry of Justice, it is also limited. For the ESO FD, partner countries including Bulgaria455 and Lithuania456 have reported a lack of data collection regarding its use. The latter added that data could exist but was not made public and accessible. Finally, concerning the PAS FD, just like the EAW, TP and ESO FDs, its application at the national level is also poorly documented because of an absence of data collection on these cases. Lithuania stated that, if there were any statistics on the use of the PAS, it was not accessible to the general public.457 105