for the possibility of legal assistance through video conferencing in every Regional Asylum Office. 327 The fixed fee of the Registry’s lawyers is €160 per appeal and €90 per overdue appeal. 328 In practice and given the fact that as described above, first instance decisions may be notified to the applicants with a registered letter or other ways of notification and the fact that access of applicant to RAOs/AAU continues to be restricted due to COVID-19 preventive measures, requests for legal aid at second instance can be mainly submitted online, by filling a relevant electronic form on the electronic application of the Ministry of Migration and Asylum.329 This may pose additional obstacles to applicants who are unfamiliar with the use of electronic applications or who do not have access to the required equipment/internet. As reported by the National Commission for Human Rights in September 2020, ‘a basic problem, remaining over the time and which it has not been resolved in practice, despite the corrective actions of the Administration, is the limited capacity of covering all requests of appellants for free legal aid at second instance in line with national and EU law’. The National Commission for Human Rights notes as ‘worrying’, the information received by the registry of lawyers of the Asylum Service regarding ‘an unusual dramatic reduction in the requests submitted for legal aid, after the entry into force of the IPA, as amended by L. 4686/2020. Amendments of the procedure for the notifications of first instance decision (fictitious service to the Head of the RAO/AAU and notification from RICs) and the digitalization of the procedure throughput the platform of the Asylum Service result in the inability of the asylum applicants to request on time free legal aid. Moreover, delays occur in the assignments of cases by the RAOs to Registry’s lawyers, resulting in certain cases […] the assignment of the case to take place after the lodge of the appeal, with an imminent risk the appeal to be rejected as inadmissible’.330 At the beginning of 2021, NGOs present in the field raised concerns regarding the insufficient provision of information to applicants for international protection following the decision of the Regional Asylum Office of Lesvos to restart the delivery of rejection decisions without prior notice. This service, along with the deadline for the submission of appeals on first instance rejection decisions, was informally suspended in the aftermath of the fire that destroyed the Moria camp at the beginning of September 2020, and was subsequently resumed at the beginning of January 2021 “without any explanation or information being provided to the applicants”.331 Following concerns expressed by legal actors, the notification of first instance rejections was postponed until April 2021 due to a lack of legal assistance.332 Post-April 2021, access to legal assistance was restored and first instance decision notifications resumed. As indicated above, a total of 16,830 appeals were lodged against Asylum Service decisions in 2022. According to Ministry of Migration and Asylum data, appellants only received free legal assistance in 7,925 cases through the Registry of Lawyers managed by the Asylum Service under the terms and conditions set in the Ministerial Decision 3449/2021.333 Since it is unlikely that the remaining 47.08% of appellants either had sufficient funds and/ or access to free legal provided by NGOs, this discrepancy highlights the difficulties faced by applicants in accessing and securing state funded free legal aid in appeals procedure, as provided by law. 327 328 329 330 331 332 333 Article 1(7) MD 3449/2021. Article 3 MD 3449/2021. See: https://bit.ly/3BPGrCV. National Commission for Human Rights, GNCHR Reference Report on the Refugee and Migrant Issue (Part B), September 2020, available at: https://bit.ly/3wzcNhm (in Greek), 61-62. Legal Aid Organisations are seriously objecting regarding the lack of free legal aid to asylum seekers in Lesvos, available at: https://bit.ly/3daoV0C. Ενημέρωση εξελίξεων σχετικά με το Δελτίο Τύπου 11.01.21 από την ομάδα εργασίας Legal Αid Working Group Lesvos, available in Greek : https://bit.ly/3oVmVxx. MoMA, Reply of the Ministry to the Greek Parliament, 16 March 2023, https://bit.ly/3JIy0y6. 71