(see Identification and Special Procedural Guarantees). In any case, in 2022 only seven cases were exempted from the border procedures on grounds of vulnerability and need for special procedural guarantees.410 In Lesvos, legal aid actors observed that, since June 2022, RAO has automatically applied non-border procedures for applicants where the first instance decision has not been notified to them within 28 days from registration, without however issuing any decision for a referral to the normal procedure (as it is not foreseen in the law, according to RAO). 411 In these cases, the deadline for the appeal is automatically extended as follows: for admissibility, the 10 days turn automatically to 20 days and for eligibility they turn from 10 to 30 days. This practice is based on article 95 paragraph 2 of law 4939/2022, however the JMD regulating this procedure has not been issued for 2022. In Kos this practice was first noticed at the beginning of 2023, however, during 2022, all asylum applications were examined under the border procedure regardless of whether a first instance decision had been issued and served to the asylum seekers within 28 days of the registration of the asylum application. Furthermore, the total number of unaccompanied minors examined under border procedures in 2022 is not available. In particular, as far as unaccompanied minors are concerned, Article 80 (7) Asylum Code provides that applications filed by minors under the age of 15, as well as minors who are victims of human trafficking, torture, rape or other serious forms of psychological, physical or sexual violence shall be examined under the regular procedure. However, Article 95 (4) Asylum Code provides that unaccompanied minors are examined under the fast-track border procedure in the case that: ❖ the minor comes for a country designated as a safe country of origin in accordance with the national list (according to article 92 (5) Asylum Code); ❖ he/she submits a subsequent application; ❖ he/she is considered a threat to the public order/national security; ❖ there are reasonable grounds that a country can be considered as a safe third country for the minor, and given that it is in line with the best interest of the minor; ❖ the unaccompanied minor has misled the authorities by submitting false documents or he/she has destroyed or he/she has lost in bad faith their identification documents or travel document, under the conditions that they or their guardian will be given the opportunity to provide sufficient grounds on this. 5.2. Personal interview Indicators: Fast-track border procedure: Personal interview Same as regular procedure 1. Is a personal interview of the asylum seeker in most cases conducted in practice in the accelerated procedure? Yes No ❖ If so, are questions limited to nationality, identity, travel route? Yes No ❖ If so, are interpreters available in practice, for interviews? Yes No 2. Are interviews conducted through video conferencing? Frequently Rarely Never According to Article 69 (1) of the Asylum Code, asylum applicants are already required at the stage of registration of their asylum application before RAOs, to give exhaustive reasons for fleeing their country of origin. If they fail to mention all reasons during the registration, they have no right to develop claims which are only for the first time mentioned during their asylum interview. However, in practice the registration of the asylum application in the islands is by no means exhaustive and it mostly includes some very basic information. 410 411 Reply of the Ministry to the Greek Parliament. Information acquired during the Lesvos LAsWG meeting, 25 October 2022. 95