MAPPING OF THE POPULATION AT RISK OF STATELESSNESS IN ALBANIA 6.2.2. The discriminatory factor Anti-Roma feelings may also increase the risk of statelessness, when some personnel from civil registries refuse to register or issue documents to Roma individuals with the pretext that they do not pay their taxes. This practice is, of course, forbidden by a specific Ministry of Interior instruction.72 In 2013 the People’s Advocate proposed amending the Law on Civil Status, raising awareness about the fact that many Roma and Egyptians live in informal settlements and cannot enjoy political, social or economic rights as citizens, for the reason that they are not officially registered as residents in local and municipal administrations.73 Members of the Albanian civil society and interviewees suggested that one of the main obstacles of civil registration for Roma people is the lack of awareness on adequate documentation, culture of constant migration, social and economic vulnerability, and widespread discrimination in daily life including discouraging treatment in civil offices. In addition, considering the high level of corruption in Albania, vulnerable Roma people might have faced more difficulties in getting through the birth registration procedure. Furthermore, anti-Roma discrimination in Albania incites them to migrate, which makes it even more complicated for them to acquire citizenship. Discrimination impacts decisions on migration, which then jeopardize obtaining citizenship or naturalization, which is often based on residence criteria. All this constitutes an unfortunate vicious circle. Sometimes the law itself does not appear discriminatory, but its implementation and effects, in reality, have a discriminatory impact. Because the Albanian government does not take into account the specific circumstances of the Roma, the latter are disproportionately affected by statelessness and situations of undetermined nationality, as compared to the general population. In cases where citizenship is acquired following an application procedure or even through naturalization, the criteria set, as well as the primary access to the procedure itself, and at the end the margin of discretion that the authorities may have in determining the case can all leave room for discrimination.74 72 Milena Isakovic Suni, Comparing Approaches to Combating Statelessness in Albania and Serbia, June 2015, p4, available at: https://www. statelessness.eu/sites/www.statelessness.eu/files/2015-05-14%20Comparing%20Approaches%20Albania%20and%20Serbia.pdf 73 Milena Isakovic Suni, Comparing Approaches to Combating Statelessness in Albania and Serbia, June 2015, pp8-9, available at: https://www. statelessness.eu/sites/www.statelessness.eu/files/2015-05-14%20Comparing%20Approaches%20Albania%20and%20Serbia.pdf 74 De Verneuil M, Statelessness of Romani People in the Western Balkans: Negligence or Discrimination?, 2016, pp192-193 62 UNHCR - TLAS / May 2018