10. In 2018, the Human Rights Committee welcomed “the amendments to the Law on Foreigners of 2016 and 2017, establishing a statelessness determination procedure, prohibiting the short-term detention of unaccompanied children and introducing new alternatives to detention for irregular migrants”.4 However, access to the statelessness determination procedure has been impeded in practice by the risk of immediate detention of irregularly residing stateless persons who present to the authorities in order to submit their statelessness application. National Law 11. Bulgaria’s nationality law is mainly found in the Law on Bulgarian Citizenship (Закон за българското гражданство), which stipulates the conditions for acquisition of Bulgarian nationality by birth and by naturalisation, as well as the conditions for loss of Bulgarian nationality. In December 2016, Bulgaria introduced a statelessness determination procedure (SDP), elaborated in the Law on Foreign Nationals in the Republic of Bulgaria (Закон за чужденците в Република България) and its Implementing Rules. In April 2019, Bulgaria further amended its statelessness law to provide for the right to a continuous residence permit (for a renewable period of up-toone year) for holders of stateless status. The latter amendments will enter into force on 24 October 2019. Statelessness Determination & Protection 12. The wording of the definition of a stateless person in the Law on Foreign Nationals, and de-facto exclusion provisions requiring lawful residence, mean that the interpretation of who is stateless under Bulgarian law is significantly narrower than under the 1954 Statelessness Convention. Positively, there is no time limit for access to the SDP, no fee, there is a right to an interview and an appeal, free legal aid is provided by NGOs, and there is cooperation between asylum and SDP decision-makers. However, an application can only be made in writing in Bulgarian, the burden of proof lies with the applicant and the standard of proof is higher than in asylum procedures. Decisions are given in writing with reasons within six months, although in practice there have been cases of 'silent rejections' whereby no acknowledgement or extension is communicated within the timeframe. There is no protection during the SDP so applicants have no access to basic services and may be detained during the procedure. Recognition as a stateless person may now lead to the granting of a year-long renewable residence permit, which should improve the situation for recognised stateless people in the country once new provisions come into force in October 2019. 13. Despite these welcome positive developments, there are a series of remaining issues in the protection of stateless persons in Bulgaria that still need to be addressed. 4 Human Rights Committee, Concluding observations on the fourth periodic report of Bulgaria, CCPR/C/BGR/CO/4 (2018), para 3 (d). 3