assessment such as their family relationships, country of origin, and reasons for fleeing. The sessions take less than 15 minutes and involve no explanation of the procedure or its outcome.’471 In the same report, it is mentioned that ‘Errors in the registration of personal details e.g. name, parents’ names, date of birth, are frequently reported in the different RICs. […]. Particularly as regards the date of birth, the RIS frequently sets artificial dates such as 1 January. This is especially relevant in the case of alleged minors. In several cases, documents held by individuals are disregarded on the ground that the authorities cannot assess the documents' authenticity, and the authorities assign a new date of birth to the applicant. This practice is verified, for instance, vis-à-vis applicants from Afghanistan. [….] Complaints also relate to wrong registration of children as adults. Frontex officers are reported to systematically register declared minors as adults, without recording their declared age and without referring them to age assessment procedures’.472 According to GCR’s findings, in practice, the age assessment of unaccompanied children is an extremely challenging process and the procedure prescribed is not followed in a significant number of cases, inter alia, due to the lack of qualified staff. According to GCR’s findings, on Kos, minors were treated as adults unless their lawyer submitted a request for age assessment. It is also observed that, in case of doubt, the medical and psychosocial assessment in the scope of the RIS was skipped and the individuals were directly referred to the public hospital for X-rays. During 2022 there was no pediatrician at the Public Hospital of Kos. Also, the authenticity of children’s documents proving their age was controlled by FRONTEX which always concluded that the documents were forged. On Chios, during the first semester of 2022, in case of minors lacking documents, both RIS and FRONTEX registered them as adults. Concerning age assessment in the asylum procedure, the Asylum Code (Article 80(3)) includes procedural safeguards and refers explicitly to ‘applicable regulatory procedures’, i.e. to JMD 9889/2020. Also, ‘when such a referral for age determination examinations is considered necessary and throughout this procedure, attention shall be given to the respect of gender-related special characteristics and of cultural particularities.’ The provision also sets out guarantees during the procedure: ❖ A guardian for the child is appointed who shall undertake all necessary action in order to protect the rights and the best interests of the child, throughout the age determination procedure; ❖ Unaccompanied children are informed prior to the examination of their application and in a language which they understand, of the possibility and the procedures to determine their age, of the methods used, therefore, the possible consequences of the results of the above-mentioned age determination procedures for the examination of the application for international protection, as well as the consequences of their refusal to undergo this examination; ❖ Unaccompanied children or their guardians consent to carry out the procedure for the determination of the age of the children concerned; ❖ The decision to reject an application of an unaccompanied child who refused to undergo this age determination procedure shall not be based solely on that refusal; and ❖ Until the completion of the age determination procedure, the person who claims to be a minor shall be treated as such. The law also states that ‘the year of birth can be modified after the age determination procedure under Article 80, unless during the interview it appears that the applicant who is registered as an adult is 471 472 RSA, HIAS, GCR, Legal Center Lesvos, DRC, Fenix, ActionAid, Mobile Info Team, The Workings of the Screening Regulation. Juxtaposing proposed EU rules with the Greek reception and identification procedure, January 2021, available at: https://bit.ly/3fL8xFF, 21. Ibid, 10-11. 114