(a) The registration of asylum applications, the notification of decisions and other procedural documents, as well as the receipt of appeals, may be conducted by staff of the Hellenic Police or the Armed Forces, if police staff are not sufficient. (b) The asylum seeker interview may also be conducted by Greek language personnel deployed by EUAA. However, Article 95(3) also introduced the possibility, “in particularly urgent circumstances”, that the interview can be conducted by trained personnel of the Hellenic Police or the Armed Forces –as long as they have received specific training, as opposed to the strict limitation to registration activities under previous L. 4375/2016. (c) The asylum procedure shall be concluded in a short time period. This may result – and it often has resulted- in compromising the procedural guarantees provided by the international, European and national legal framework, including the right to be assisted by a lawyer. As these extremely brief time limits undoubtedly affect the procedural guarantees available to asylum seekers subject to an accelerated procedure, as such, there should be an assessment of their conformity with Article 43 of the recast Asylum Procedures Directive, which does not permit restrictions on the procedural rights available in a border procedure for reasons related to large numbers of arrivals. More precisely, according to Article 95(3)(c) Asylum Code: ❖ the Asylum Service shall issue a first instance decision within seven days; ❖ the deadline for submitting an appeal against a negative decision is ten days; ❖ the deadline for, and submission of, the appeal does not always have an automatic suspensive result, as provided by Article 110 (3) Asylum Code and a separate application for suspension of removal needs to be submitted before the Appeals’ Authority, within the deadline for the submission of the appeal; ❖ the examination of an appeal shall be carried out within four days. The appellant is notified within one day to appear for a hearing before the Appeals’ Committees or to submit supplementary evidence; and ❖ the second instance decision shall be issued within seven days. It should be noted that these very short time limits seem to be exclusively at the expense of applicants for international protection in practice. In fact, whereas timelines are, by general principle, not compulsory for the authorities and case processing at the borders takes several months on average, applicants still have to comply with the very short time limits provided by Article 95(3) Asylum Code. 403 In 2022, the average time between the full registration of the asylum application and the issuance of a first instance decision under the same procedure was not available. The Greek Asylum Service is under constant pressure to accelerate the procedures on the islands, which was also one of the reasons invoked for the amendment of national legislation in late 2019. The FRA concerns related to the very limited processing time imposed in the scope of the previous legal framework and the impact that this could have on the quality of the procedure still remain. More specifically, FRA emphatically underlined that “even with the important assistance the European Asylum Support Office provides, it is difficult to imagine how the processing time of implementing the temporary border procedure under Article 60(4) L.4375/2016 or the regular asylum procedure on the islands can be further accelerated, without undermining the quality of decisions. Putting further pressure on the Greek Asylum Service may undermine the quality of first instance asylum decisions, which in turn would prolong the overall length of procedure, as more work would be shifted to the appeals stage.” 404 403 404 FRA, Update of the 2016 FRA Opinion on fundamental rights in the hotspots set up in Greece and Italy, 4 March 2019, available at: https://bit.ly/2HeRg79, 26. FRA, Update of the 2016 FRA Opinion on fundamental rights in the hotspots set up in Greece and Italy, 4 March 2019, 26 ‘in Kos, the average time from the lodging of the application until the first interview with EASO was 41 days while from the date of the interview until the issuance of the recommendation by EASO was 45 days’. 93