3.2.4 Registration of immigration permission The ISD is responsible for registering immigration permissions in Dublin city and county since taking over that function from the Garda National Immigration Bureau (GNIB) in 2016. Registration of immigration permissions for those outside Dublin is carried out by immigration officers under the control of the local Registration Officer in An Garda Síochána. When an immigration permission is granted, stateless persons may experience practical difficulties registering with the relevant authorities due to a lack of documentation evidencing their identity. Section 9 of the Immigration Act 2004 creates an obligation in respect of all non-Irish nationals over the age of 16 residing in the State to register with the relevant registration office. A person who contravenes section 9(2)(a) of the Immigration Act 2004 by failing to register may be found guilty of an offence and liable on summary conviction of a fine not exceeding €3,000 or to imprisonment for a term not exceeding 12 months or both.93 Pursuant to Section 9 there is also a requirement on individuals to produce their passport or other equivalent document, issued by or on behalf of an authority recognised by the Irish government, which establishes his or her identity and nationality. Permission to remain letters may include the following standard wording with regard to registration:  ‘you are required under Section 9(2)(a) of the Immigration Act 2004 to produce a passport issued by an authority recognised by the Irish government which establishes your identity and nationality, unless you can give a satisfactory explanation of the circumstances which prevent you from doing so.’94 This obligation extends to stateless persons granted immigration permission and stateless international protection beneficiaries alike. Furthermore, letters granting permission to remain frequently state that the permission is conditional upon registration with the relevant authorities. Letters may include standardised wording as follows: “[p]lease note that a failure to register promptly will be considered to constitute a failure to comply with the laws of the State and may constitute in itself a ground for revoking your permission to be in the State.” Without a certificate of registration having been issued, stateless persons may accordingly not be able to produce evidence of their right to be in the State or to work legally. The extent to which this is an issue at registration with ISD is unclear. However, legal representatives have noted that, while the number of persons impacted is low, such persons face similar obstacles at various stages of any administrative procedures they encounter during their time in Ireland. The challenge also remains that stateless persons at this stage of the process, without any formal recognition of their statelessness status, may not be visible. Under the Immigration Act 2004 (Registration Certificate Fee) Regulations 2012 persons must pay €300 when they register with ISD or immigration officers in An Garda Síochána.95 This fee is waived in the Immigration Act 2004 (Registration Certificate Fee) Regulations 2017 in the case of beneficiaries of international protection, programme refugees96 and a number of other categories of persons but not in the case of stateless persons.97 26 93 Section 13 Immigration Act 2004. 94 Immigration Act 2004 [Ireland], 13 February 2004, available at: https://www.refworld.org/docid/45e6f47a2.html; Section 9(2)(a) states the following “a non-national shall comply with the following requirements as to registration: (a) he or she shall, as soon as may be, furnish to the registration officer for the registration district in which he or she is resident, the particulars set out in the Second Schedule, and, unless he or she gives a satisfactory explanation of the circumstances which prevent his or her doing so, produce to the registration officer a valid passport or other equivalent document, issued by or on behalf of an authority recognised by the Government, which establishes his or her identity and nationality.” 95 Immigration Act 2004 (Registration Certificate Fee) Regulations 2012, S.I. 444/2012, available at: https://bit.ly/3uInQoP as amended by Immigration Act 2004 (Registration Certificate Fee) (Amendment) Regulations 2017, S.I. No. 277/2017, available at: https://bit.ly/3HrQNwG 96 A programme refugee is a refugee who has been resettled to Ireland under the Irish Refugee Protection Programme (IRPP). Section 59 of the International Protection Act 2015 provides the legal basis for programme refugees in Ireland. 97 Ireland: S.I. No. 277/2017 - Immigration Act 2004 (Registration Certificate Fee) (Amendment) Regulations 2017 [Ireland], 11 February 2021, available at: https://www.refworld.org/docid/6025081a4.html Mapping Statelessness in Ireland