people without a residence permit. NGOs, a network of university law clinics, and faithbased organisations also provide legal assistance. 21. The official language for administrative procedures is German and no free interpretation services are available to applicants, although interpreters are provided in courts.27 In practice, friends or family usually support the applicant. Interviews are not mandatory but are permitted and in practice are often carried out. Positively, all administrative decisions are given in writing with reasoning. 22. There does not appear to be formal training for public officials on statelessness in particular, though some training is offered on an ad hoc basis by interested individual experts or NGOs. The lack of training creates inconsistencies in the implementation of the law, for example in birth registration (see Issue 2 below). There does not appear to be cooperation between relevant agencies for identifying and determining statelessness. Access to protection and the rights of stateless people 23. The rights attached to the statuses granted do not guarantee the rights provided for in the 1954 Convention and in UNHCR Guidance.28 Residence rights are not granted to people in Germany on the basis of statelessness, but stateless people may be eligible for temporary residence if they cannot be removed within a stipulated timeframe. In practice, a temporary permit is often not granted within this timeframe, thus people tend to remain with 'tolerated stay' and are often recorded as ‘nationality unclear'. Positively, a temporary permit can be granted even if a person does not have a passport or a travel document, as other forms of evidence of identity are accepted. 24. ‘Tolerated stay’ is usually granted for three months or six months in cases of particular hardship. Tolerated stay may be extended on a three-monthly basis if the person cooperates with the authorities, and the right to work may be granted under certain conditions. A person with tolerated stay may receive subsistence under the Asylum Seekers’ Benefit Act if they cannot meet their own subsistence, but they initially receive less than asylum seekers. After 15 months of uninterrupted stay they can access similar support, including healthcare, maternity services, and limited cash for basic personal needs. A temporary rule in force until 31 December 2023 allows people on tolerated stay permit to enter the labour market after 12 months (formerly after 15 months). 25. Since November 2019, a new form of ‘tolerated stay’ for those with ‘unclear identity’ was introduced, which limits the extension of the three-month stay toleration permit to one month maximum, for those who cannot provide identity documents or do not cooperate with the authorities.29 This toleration permit does not provide the right to work nor freedom of movement.30 The Coalition Agreement pledged to revoke the socalled ‘toleration light’ status.31 27 Article 185 of the Courts Constitution Act. UNHCR, Handbook on Protection of Stateless Persons under the 1954 Convention relating to the Status of Stateless Persons, 30 June 2014, available at: https://www.refworld.org/docid/53b676aa4.html. 29 This limit is also applicable in all cases where there is a lack of cooperation with the authorities, whether under § 60a or 60b of the Residence Act. 30 Residence Act (Aufenthaltsgesetz (AufenthG)), 25 February 2008 (BGBl 2008 I, 162), zuletzt durch Artikel 10 des Gesetzes vom 9. Dezember 2020 (BGBl 2020 I, 2855) [Residence Act], § 60b Abs. 5 S. 2: https://www.gesetze-iminternet.de/aufenthg_2004/BJNR195010004.html. 31 Coalition Agreement between the SPD, Greens, and FDP, 2021-2025, 7 December 2021, available at: https://www.spd.de/fileadmin/Dokumente/Koalitionsvertrag/Koalitionsvertrag_2021-2025.pdf. 28 6