on statelessness without it. The Seeds for Solution funding that was used for statelessness programming discussed earlier was considered impactful. One UNHCR Country Representative shared a preference for earmarked funding, highlighting the inherent challenge of prioritizing statelessness without it (see Box 17). Box 17: Earmarking for Countries “For our country programs I would probably rather have earmarked funding because we will always struggle in giving [statelessness] priority. The refugee needs obviously always must be met as well…. It would probably be useful to earmark something [at the country-level] just to ensure that something is done on statelessness.” Opinions of the Global Action Plan to End Statelessness. Many UNHCR staff accepted the GAP as the road map or path forward to eradicating statelessness. There were also critics who were concerned that the GAP is overly legalistic or that it does not put enough emphasis on addressing discrimination, especially against minorities (see Box 18). Discrimination as a cause and consequence of statelessness is dealt with at greater length later in the report. Our data shows that outside of the UN, the GAP is not widely known or understood, especially among actors at the country-level. It was often confused with the #IBelong Campaign, or at least undistinguishable from it. Informants highlighted that little progress has been made on Action 1, as explained in Box 19, (for a list of the 10 GAP actions, see Table 1 on page 1). A Gap in Statelessness Statistics and Data. The evaluation research revealed that there is a lack of data on the extent of statelessness in many countries. While the Joint Data Centre is a promising initiative to improve statistics on statelessness, the World Bank remains under-invested in addressing statelessness, due in part to the perception of World Bank staff that statelessness is not a major concern for country development. Box 18: GAP’s Link to Discrimination “UNHCR is valuable as an actor, but how can we complement this with much more resources flowing into the ground level? I think this is the next battle to be waged. We now have a lot of standards. We have a lot of policies. We have a lot of ideas how to change laws. Now, it is about tackling the social underpinnings of statelessness at the country levels, particularly the discriminatory dynamics.” In part, this lack of investment is due to a perceived lack of data on statelessness, though PRM has funded a small study on the impact of statelessness on livelihoods.23 It is not clear to what extent UNHCR is engaging with UNFPA and other development actors on statelessness to include statelessness in the census at country levels. Box 19: Little Support for Action 1 "There’s a lot of interest at improving data on statelessness which relates to Action 10 of the GAP. Less so -- but actions that are important— on Action 1, which relates to situations like in Myanmar where you’ve got large protracted stateless populations where a fix is needed to bring those numbers down. There was less support shown for those actions." Without better data and statistics (and unless there are large numbers of people at risk), it is difficult to compel the World Bank, UNFPA and even UNICEF to prioritize the issue. Interviews with the World Bank exposed the view that evidence for statelessness as a cause of poverty is lacking, as is evidence that stateless people are poorer than other populations. As a result, the World Bank will not focus attention on statelessness without clearer evidence and, until then, would be disinclined to raise it as an issue with governments. UNHCR lacks the capacity to conduct large-scale, complex statistical studies and, although the Joint Data Center is a good initiative, the World Bank has yet to make a major commitment to studying the intersection between statelessness and poverty. There are big challenges in collecting data on stateless persons, especially in countries like Nepal, whose government does not accept that statelessness exists. Forum for Women, Law and Development (FWLD) data estimates that in 2021 there will be 6.7 million people in Nepal without citizenship certificates, with an undetermined number among that group at risk of statelessness. Much of what UNHCR knows about statelessness statistics comes from countries like Thailand and Cote d’Ivoire, which have compiled statistics on statelessness through national census bureaus, sometimes with UNHCR assistance. 23 Kingston University, “The Cost of Statelessness” (2011). 16