Inside Police Custody 2 3. The right to information 3.1 Transposition of the Directive Member states were required by the terms of the Directive to bring into force the laws, regulations and administrative provisions necessary to comply with the Directive by 2 June 2014, and to transmit the text of those measures to the Commission (Art. 11(1) and (3)). The governments of all of the countries in the study did introduce measures, and reported having done so to the Commission. However, as with the Directive on interpretation and translation, the extent and level of detail of such measures varies significantly. Again, some States went to considerable lengths in order to ensure that their laws and regulations comply with the various requirements of the Directive, whereas others appear to have taken a minimalist approach, in some cases avoiding key obligations imposed on them by the Directive. Half of the countries in the study reported to the EC that they adopted only one or two measures in order to transpose the Directive, but Hungary reported that it had adopted 31 measures, and Lithuania, 19 measures. In some countries, such as Lithuania, the measures initially adopted by way of transposition were subsequently supplemented by further provisions. The Directive on the right to information adopts the same approach to scope as the Directive on interpretation and translation in that it applies from the time a person is made aware by the competent authorities of a Member State that they are suspected or accused of having committed a criminal offence until the conclusion of proceedings. Whilst the right to information about rights (Art. 3), the right to be informed about the criminal act of which a person is suspected or accused (Art. 6(1) and 6(3)), and the right of access to material evidence (Art. 6(2)), always apply to such persons (although at different stages of the process), the provisions regarding the letter of rights (Art. 4), information about the reasons for arrest or detention (Art. 6(2)), and documents that are essential to challenging the lawfulness of the arrest or detention (Art. 7(1)), only apply to suspected or accused persons who have been arrested or detained. The restrictive approach which was adopted by Bulgaria and, to a lesser extent, Romania regarding the application of the Directive on interpretation and translation, was also taken in respect of the Directive on the right to information; and the same concerns about this approach also apply (see section 2.1 above). However, it is important to note that, in the case of Bulgaria, this does not mean that those who are subjected to police detention have no procedural rights under domestic law, as is explained further below. Whilst aspects of the right to information in criminal proceedings formed part of domestic law in most, if not all, of the countries in the study before transposition of the Directive, broadly it is the case that transposition resulted in significant developments in the laws of many of the countries. For example, in Slovenia, a right to information applicable to persons deprived of their liberty had been protected by the constitution since 1991. However, on transposition, the right to information about procedural rights was extended, making it applicable to all detained persons (previously it only applied to persons detained for longer than six hours), by including a right to interpretation of the information provided, by requiring that the information be provided both orally and in writing, and by providing for a right of access to case materials. Similarly, a right to information was recognised by the Spanish constitution prior to the coming into force of the Directive, but transposition resulted in the criminal procedure code being amended so that persons who are arrested must be immediately informed of the reason for arrest and ‘the facts attributed 30