regulated in the national legislation of Finland. The determination of citizenship status procedure is a central procedure, which benefits from the special expertise on nationality and statelessness of the Nationality Unit of Migri. The procedure provides a basis for a consistent decision-making concerning citizenship status, including statelessness in various procedures, i.e. registration, asylum and other immigration procedures as well as in the naturalization procedure. As there is one central body with the authority to determine citizenship, in principle status determination is not required repeatedly and the decision can be relied on throughout the different procedures. However, the purpose of the determination of citizenship status procedure is first and foremost linked to the acquisition or loss of Finnish nationality and the correctness of information in public registers. It is possible to identify stateless persons through the procedure but it is not one of the explicitly stated purposes of the procedure in the legislation. This is reflected in the nature of the procedure, which is largely a written procedure and where the burden of proof with regard to statelessness lies mainly on the applicant. Whereas the benefit of the doubt principle is reflected in the legislation concerning the asylum procedure and is a recognized and widely respected principle of refugee law in the Finnish jurisprudence, this principle is not recognized as being applicable in the determination of citizenship status procedure. This procedure is in principle accessible to persons residing illegally in Finland and who are not in any immigration procedure. Still, the law and the practice define the procedure rather as a procedure for determining the existence of Finnish nationality or other citizenship status as a part of another immigration procedure or registration than as a possibly separate procedure for identification of stateless persons. However, the Supreme Administrative Court in its jurisprudence has clearly interpreted that one of the purposes of the determination of citizenship status procedure is the determination and prevention of statelessness. This provides a solid basis for further development of the procedure in order for it to be better suitable for identification of stateless persons. The Nationality Unit of Migri is the decision-making authority in the determination of citizenship status procedure but does not have exclusive authority in determining statelessness. As illustrated in the statistical overview and in the review of the asylum decisions from 2009 to 2011, the determination of citizenship status is regularly requested internally by the Asylum Unit. Previously, including during the period from 2009 to 2011, there were no guidelines on what type of cases the internal request should be made and based on the review of the asylum decisions, the requests have not always been made in a consistent manner. In very similar types of cases the request was sometimes made and sometimes not, i.e. in some cases statelessness was determined by the Asylum Unit and sometimes by the Nationality Unit. There have however been some positive developments as Migri has recently issued more extensive instructions concerning the procedure, and also an official responsible for the effective functioning of the procedure within the Nationality Unit has been appointed in 2013.155 Because of the high standard of proof and heavy burden of proof regarding statelessness, a person’s nationality is sometimes determined as unknown or not known rather than stateless even though there are very strong indications of statelessness. Furthermore, in some of the cases the conclusions made in the asylum assessment refer to statelessness and the person’s situation as a stateless person and yet it was not concluded that the person indeed is stateless. Furthermore, while unknown nationality is determined in the Nationality Act, there is another widely used category which is not mentioned in the legislation: nationality not known. This is used especially in the asylum procedure. Nationality is most often defined as not known by the Asylum Unit, but the Nationality Unit also uses the definition as a possible result of the determination of citizenship status procedure. The difference between these two categories does not seem to be entirely clear within Migri nor based on the review of the asylum decisions from 2009 to 2011. In conclusion, there are some elements in place for determining statelessness in terms of the legislation and practical aspects in Finland through the determination of citizenship status procedure. The existing 155 The Finnish Ministry of Interior’s Comments on the draft study, 7 March 2014. UNHCR STOCKHOLM, NOVEMBER 2014 43