2021 Statelessness & Citizenship Review 3(1) When the applicant does not have an ID, inquiries to relevant local institutions, including the national civil registry, are made as part of due diligence in the SDP investigation phase. Like Moldova, the applicant must wait until the SDP ends — which may take six to nine months according to the law 90 — before they are notified of the decision rejecting the application on the basis that they are not stateless but, instead, have the right to Georgian citizenship. Turkey: Implementing Regulation on Foreigners and International Protection (‘Regulation on Foreigners and International Protection’) 91 In Turkey, determination of statelessness occurs under art 49(3) of the Regulation on Foreigners and International Protection. Article 49(3) provides that: investigations shall be carried out to determine whether the foreigners are among the ‘unrecorded population’ by contacting the relevant provincial/district directorates of civil registration and citizenship where there is a question of whether the applicant may be among the ‘unrecorded population. 92 It can be elucidated that the SDP norm considers those who could be nationals as an ‘unrecorded population’ or unregistered. In the case of ‘doubt’ regarding whether the applicant is a national, the application rules grant the SDP discretion to conduct an investigation in consultation with national sources, such as local or national civil registry offices. The Regulation is silent on the timing of the investigation and what should be done if the applicant is identified as a national of the country. It is unclear whether the SDP would be suspended or filed, or if the applicant would have to wait until a final decision rejecting the application based on the applicant’s entitlement to citizenship. Ukraine: Law of Ukraine on Amending Certain Legislative Acts of Ukraine Regarding Recognition as a Stateless Person (‘Ukraine Statelessness Amendment Law’) 93 Article 61(2) of the Ukraine Statelessness Amendment Law governs the recognition of applicants as stateless persons. It states that: [i]f any circumstances demonstrating the applicant’s eligibility for the Ukrainian citizenship as per the Law of Ukraine on Citizenship of Ukraine arise during the procedure of recognition as a stateless person, review of the application on recognition as stateless person shall be suspended until completion of verification of belonging to the Ukrainian citizenship. Depending on the outcomes of such verification the review of the application on recognition as a stateless person shall be renewed or ceased. According to art 61(3): 90 91 92 93 Georgian Ordinance No 523 (n 68) art 8(2). Implementing Regulation on Foreigners and International Protection (2016) 29656 Official Journal (Turkey) (‘Turkish Implementing Regulation’). The SDP norm considers those who could be nationals as part of the ‘unrecorded population’. See ibid art 49(3). Law of Ukraine on Amending Certain Legislative Acts of Ukraine regarding Recognition as a Stateless Person (2020) (Ukraine) (‘Ukraine 2020 Statelessness Amendment’). This law amended the Law of Ukraine on the Legal Status of Foreigners and Stateless Persons (1994) (Ukraine). 82