The UK should fully incorporate and comply with the 1954 Convention. I.A. The UK should recognise ‘statelessness status’ as a protection status similar to ‘refugee status’ and ‘humanitarian protection’. I.B. The UK should ensure that its definition of ‘stateless person’ is fully consistent with the definition provided in the 1954 Convention and that no stateless persons are excluded from this definition on extraneous criteria. I.C. The UK should amend its policy to guarantee that persons with pending statelessness applications will be considered ‘lawfully in’ the UK and not expelled in violation of the 1954 Convention, Article 31. 1.D. The UK should amend or eliminate provisions of its laws and policies which operate to exclude stateless persons from leave to remain in the UK which are inconsistent with the provisions or object and purpose of the 1954 Convention or other international law. II. Procedural safeguards The UK should ensure that stateless persons have adequate procedural safeguards during the statelessness determination procedure on a non-discriminatory basis. II.A. The UK should ensure that stateless persons have access to: a comprehensive right of appeal against refusal of leave to remain as a stateless person; appropriately trained lawyers paid for by legal aid (as for asylum applications); an open-minded interview procedure; and assistance in making enquiries of national authorities, which are independently monitored and recorded. II.B. The UK should train to an appropriate standard the decision makers in the determination procedure and ensure that there are sufficient of them to allow them to make legally correct decisions within UNHCR-recommended time frames. III. Indefinite and arbitrary detention of stateless persons In any decision regarding immigration detention, the UK should consider, before a decision to detain and on an ongoing basis, statelessness and risk of statelessness. Where evidence suggests that a person subject to immigration detention may be stateless or at risk of statelessness, the Government should: refer them to the statelessness application procedure in Part 14 of the Immigration Rules; expedite their statelessness application; and consider, in view of statelessness or possible statelessness, whether removal is imminent and detention is necessary and justified. III.A. The UK should establish a reasonable time limit for immigration detention (28 days or less), particularly with respect to individuals who are stateless or at risk of statelessness and unlikely to be imminently removable. III.B. The UK should amend the provisions of the Immigration Act 2016 relating to mandatory bail hearings to make such hearings available in deportation cases. 15