When a residence permit is granted, a residence permit card can be granted in accordance with Section 33a of the Aliens Act. A residence permit card is however not regarded as an identity document. A normal identity card can be granted in accordance with the Identity Card Act147 to a foreigner who is considered to reside in Finland permanently in accordance with the Act on Home Municipality,148 who has been registered in PIS and whose identity has been established. A working group led by the Ministry of Interior is currently conducting an investigation into possibilities of issuing asylum-seekers and immigrants who reside in Finland with a residence permit, but whose identity has not been established and who can therefore not obtain an identity card, with a document that would give them sufficient proof of identity needed for accessing certain commercial services, such as opening of bank accounts.149 Inquiries made in 2011 revealed that the vast majority of asylum-seekers and immigrants who had a residence permit in Finland but whose identity had not been established experienced difficulties opening bank accounts in Finland (which in turn made it difficult to sustain a job in some cases). Furthermore, many foreigners who had residence permits in Finland experienced problems in paying e.g. telephone bills, and receiving social security benefits. Sometimes they were even refused to be registered by the Local Registration Offices because of their lack of an identity document. It was pointed out by the municipalities hosting immigrants with residence permits based on international protection (whose identity has often not been established and who therefore could not obtain identity cards) that having to come up with alternative solutions for being able to use banking and other services puts these immigrants in an unequal situation as compared to other residents of the municipalities. The report of the working group further stated that in 2011, about half of the travel documents issued to immigrants in Finland in 2011 had been marked with “identity not established”, indicating that the number of immigrants who cannot currently obtain an identity document is significant. In 2012, 167 travel documents (Refugee travel documents, Aliens passports and temporary Aliens passports) were issued to stateless persons. In 33 of them it was indicated that the identity of the person had not been established. 26 travel documents were issued to persons of unknown nationality and 257 to persons whose nationality was not known.150 In seven documents issued to persons belonging to the last two categories, it was indicated that the identity of the person had not been established.151 Although the percentage of travel documents marked with “identity not established” issued to stateless persons and persons with unknown/ not known nationality was lower than the percentage of such travel documents issued to foreigners generally, the problem also clearly concerns stateless person and persons whose nationality is unknown/not known. The working group concluded that further investigation into solving the situation for asylum-seekers was needed; Migri is currently conducting a project for possible creation of an electronic payment card system for asylum-seekers. As for the immigrants residing in Finland with residence permits, the working group suggested that issuing an identity card for those immigrants whose identity has not been established and who are not in possession of a reliable, national identity document, should be considered, on the basis of the personal information registered in the RA. The working group report has been circulated for review by the various stakeholders. It is expected that the next step will be a project aiming at necessary legislative 147 Henkilökorttilaki, 829/1999, Section 1. 148 Kotikuntalaki, 201/1994. 149 Ministry of Interior Decision on Investigation on possibilities for issuing a type of a identity card to asylum-seekers enabling them to access certain services, Sisäasiainministeriön asettamispäätös, SM056:00/2011, email from the Ministry of Interior on 29 September 2012, and a report “Turvapaikanhakijoiden ja Suomessa jo asuvien ulkomaalaisten henkilöllisyyden osoittaminen pankki- ja muussa asioinnissa” (Proving of identity of asylum-seekers and other foreigners living in Finland with regard to accessing banking and other services), ISBN 978-952-491-807-7 (PDF), 30 November 2012, available at http://www.intermin.fi/julkaisu/462012?docID=38566 150 The Finnish term used in these statistics is “selvittämättä”. 151 E-mail from the Finnish Police (Poliisihallitus), 26 November 2013. In 2011 the figures were the following: 122 travel documents out of which 22 were marked with “identity not established” were issued to stateless person, 32 travel documents out of which 11 were marked with “identity not established” were issued to persons with unknown nationality and 188 travel documents out of which 12 were marked with “identity not established” were issued to persons whose nationality was not known. UNHCR STOCKHOLM, NOVEMBER 2014 41