2020 Statelessness & Citizenship Review 2(2) happens on a non-discriminatory basis; and that the restrictions to it are ‘necessary and limited in scope’. 95 Equal Access to Citizenship and Naturalisation Equally important to the question of whether citizenship legislation could include ethnic elements is the manner in which these laws are applied. Vague standards, arbitrary application of procedures related to acquisition of nationality or discriminating procedural requirements, can prevent individuals from access to citizenship or naturalisation, despite fulfilling the criteria set out in the respective citizenship laws to become a citizen. In its Guidelines for the CERD-Specific Document to be Submitted by State Parties under Article 9, Paragraph 1, of the Convention (‘SRG’), the Committee is clear and requests information on ‘measures taken to ensure that particular groups of non-citizens are not discriminated against with regard to access to citizenship or naturalization’. 96 The Committee recommended Cambodia to take measures to ensure identification documents recognising their citizenship are provided to Khmer Krom — an ethnic minority often associated with neighbouring Vietnam and, further, to allow individuals belonging to this group to record their true name and place of birth in their identification documents. 97 On Tajikistan, the Committee recommended, in 2004, that it should apply its laws on citizenship without discrimination, ‘as requested in Article 5(d)(iii) of the Convention’. 98 In its next Concluding Observations, in 2012, the Committee reiterated this and simply recommended to ‘resolve the problem of the stateless persons’. 99 It has made similar remarks on the Croatian Citizenship Act, ‘which appears to establish different criteria in granting citizenship to ethnic Croats as compared to other “nationalities” in Croatia’. 100 In particular, it was concerned that former long term residents of Serb origin and other minorities with ‘pre-conflict attachment’ to 95 Committee on the Elimination of Racial Discrimination, Consideration of Reports Submitted by States Parties under Article 9 of the Convention: Concluding Observations of the Committee on the Elimination of Racial Discrimination: Israel, UN Doc CERD/C/ISR/CO/13 (14 June 2007) [17], [20]; Committee on the Elimination of Racial Discrimination, Concluding Observations on the Combined Seventeenth to Nineteenth Reports of Israel, UN Doc CERD/C/ISR/CO/17-19 (27 January 2020) [16], [24], [25]. 96 SRG, UN Doc CERD/C/2007/1 (n 25) [19]. 97 Committee on the Elimination of Racial Discrimination, Concluding Observations on the Combined Fourteenth to Seventeenth Reports of Cambodia, UN Doc CERD/C/KHM/CO/1417 (30 January 2020) [25]–[26]. 98 Committee on the Elimination of Racial Discrimination, Consideration of Reports Submitted by States Parties under Article 9 of the Convention: Concluding Observations of the Committee on the Elimination of Racial Discrimination: Tajikistan, UN Doc CERD/C/65/CO/8 (10 December 2004) [14]. 99 Committee on the Elimination of Racial Discrimination, Concluding Observations on the Sixth to Eight Periodic Report of Tajikistan, Adopted by the Committee on the Elimination of Racial Discrimination at Its Eighty-First Session, UN Doc CERD/C/TJK/CO/6-8 (24 October 2012) [14] (‘Concluding Observations: Tajikistan’). 100 Committee on the Elimination of Racial Discrimination, Consideration of Reports Submitted by States Parties under Article 9 of the Convention: Concluding Observations of the Committee on the Elimination of Racial Discrimination: Croatia, UN Doc CERD/C/60/CO/4 (22 February 2002) [14] (‘Concluding Observations: Croatia’), citing Croatian Citizenship Act (1991) Official Gazette NN 53/91, 70/91, 28/92, 113/93, 4/94, 130/11, 110/15 (Croatia). 236