from 2009 to 2011, there were no clear guidelines or established practice as to when the Asylum Unit should request for the determination to be conducted by the Nationality Unit. 3.3.2 Procedural aspects 3.3.2.1 INITIATING THE PROCEDURE AND THE COURSE OF THE PROCEDURE In accordance with Section 36 of the Nationality Act, the determination of citizenship status procedure can be initiated either by a public authority or by the person her or himself. Section 2 of the Nationality Act places a responsibility on the Local Register Offices to always request for the citizenship status determination of a child whose birth they have been informed about when the child’s parents are not married to each other and are not Finnish nationals, or one of them is not a Finnish national, or when the child’s parents who are married to each other are neither Finnish nationals nor nationals of the same country. This is the most common type of citizenship status determination request which Migri deals with. Table 7: Initiation of citizenship determination-procedure (2010-2012)116117118 2010116 2011 2012117 - 3 10 Local Register Offices (S.2 Nationality Decree ) - 882 901 Internal, linked to asylum or other residence permit application - 89 78 Request made by Person concerned or guardian 118 Embassy notification acquisition of another nationality before 1 June 2003 - 8 2 Other - 157 163 Total 1817 1139 1154 Source: Migri, September 2012 Table 7 illustrates that the highest number of citizenship status determination requests is made by the Local Register Offices. The number of requests made by persons concerned or a guardian is surprisingly low. The number of requests made in 2010 was high compared to 2011 but seems to be on the rise again, as the 2012 figure only includes requests made by 20 September 2012. Subsection 2 of Section 36 of the Nationality Act further states that when the nationality of a person who has a home municipality in Finland is unknown, efforts should be made to determine the citizenship of the person. As mentioned above, the responsibility for initiating the process in this type of cases has not been defined in the law or in the Government Bill. According to the biggest Local Register Office of Finland, the one in Helsinki, the Register Office does not initiate this process when registering a person with unknown nationality and with a municipality of residence in Finland.119 There are no further provisions regarding the procedure for determining citizenship status in the Nationality Act or in the Nationality Decree. The Government Bill on the Nationality Act does not provide for further explanations or guidance either. The details of the procedure and the practice have to a large extent been left to be defined by Migri, but they also follow the legal provisions relating to administrative procedures generally. 32 116 The specifics of 2010 are not available; only the total number of requests is known. 117 1 January – 20 September 2012. 118 Section 2 of the old Nationality Decree 799/2004 which was replaced by the new Nationality Decree 293/2013 in May 2013. In the new decree, the Local Register Offices’ obligation to request for determination of citizenship status is stated in Section 1. 119 Email from the Local Register Office of Helsinki on 5 September 2012. MAPPING STATELESSNESS IN FINL AND