C) Factors to consider when designing a national system  What are the practical rules for submitting applications for refugee status, residence permits and naturalisation? Do they ensure proper access to these procedures? Can they be used as models for statelessness determination?  Is statelessness determination foreseen to be conducted in a centralised structure?  If yes, would allowing the submission of claims only where the procedure is conducted ensure effective access to statelessness determination (for example in case of a small country)?  If it would not, are there other branches within the same authority, or are there other relevant authorities that would be suitable for being in charge of receiving claims for stateless status (as they have a relevant scope of activities and good geographical coverage/network in the country)?  Does the country’s legal system allow authorities in certain cases to receive oral – rather than just written – applications (for example in asylum cases)? Does the country’s legal system allow authorities in certain cases to receive applications in a language which is not official in the country? Do proper procedural guarantees apply (for example written registration of the claim) in these cases?  If yes, a similar flexible framework should apply for the submission of claims for stateless status, and the existing example can be copied for this purpose. III.3 Ex officio initiation of statelessness determination A) Summary of international standards Given that individuals are sometimes unaware of statelessness determination procedures or hesitant to apply for statelessness status, procedures can usefully contain safeguards permitting state authorities to initiate a procedure ex officio.50 B) Existing good practices At the time of writing, Spain and Moldova allow for the ex officio initiation of a statelessness determination procedure.51 The Spanish regulation clarifies also that ²A statelessness determination procedure³ will be initiated ex officio when the Office of Asylum and Refuge has knowledge of facts, data or information that may indicate the possible concurrence of circumstances that determine statelessness. In this case, the Office of Asylum and Refuge will duly inform the applicant so that he may have the opportunity to submit his allegations.52 50 See UNHCR Statelessness Guidelines 2, Para 16 51 Royal Decree No. 865/2001 of 20 July approving the Regulation on the Recognition of the Stateless Status, 20 July 2001, Section 2 (1); Act on the Amendment and Completion of Certain Legislative Documents, adopted by the Parliament of the Republic of Moldova on 28 December 2011, 10 February 2012, Section 871 (1), respectively 52 Royal Decree No. 865/2001 of 20 July approving the Regulation on the Recognition of the Stateless Status, 20 July 2001, Section 2 (2) 16