DPCE online, 2020/4 – Saggi ISSN: 2037-6677 Governing through uncertainty? Migration Law and governance in a comparative perspective c. Identification and protection. In the context of forced migration, given the low rate of adherence to the main international instruments on statelessness, protection of stateless individuals may happen the framework of the provisions in national law deriving from transposition of the 1951 Convention relating to the Status of Refugees (hereinafter 1951 Convention). Even the definition of a refugee in the 1951 Convention contains a reference to statelessness: ‘(…) who, not having a nationality and being outside the country of his former habitual residence as a result of such events, is unable or, owing to such fear, is unwilling to return to it’. Moreover, there are limitations of protection on the basis of the 1954 Convention, such as a lack of non-penalisation for unauthorised entry and lack of non-refoulement39. However, the modalities of transposition of the 1951 Convention vary from country to country, and cannot fully address the peculiarity of a legal vacuum created by statelessness. Asylum procedures should not replace statelessness determination procedures, not only because the status of a stateless person does not necessarily derive from forced displacement. The establishment of a statelessness status might be decisive in asylum procedure and in what might come after: from family reunification to potential return. Hungary and Italy both have statelessness determination procedures. In case of the former, it derives out of secondary law, but is narrower than in the 1954 Convention. In case of the latter, it is based on the direct effect of the 1954 Convention, which has, however, a vague implementation in practice. Protection during the procedure is highly limited in Hungary and inconsistently applied in Italy. Access to citizenship for recognised stateless individuals, despite the reduction of years prior to naturalisation, retains considerable practical obstacles. In Germany and Poland, where there is no statelessness determination procedure as such, protection is limited. Although the definition of a stateless person in German law is in line with the 1954 Convention (as opposed to Poland, where there is no definition of a stateless person in the law), in the both countries a ‘tolerated stay’ is the maximum level of protection, which enables access to a right to work, social assistance and healthcare in Poland, and basic assistance and restricted employment in Germany. d. Sustainable Development Goal 16.9: ‘provide legal identity for all, including birth registration’. The EU’s policies and actions supporting specific SDG 16 targets include both external and internal aspects. However contributions to the 16.9 target focus mainly on the former40. A description of the general legal framework and of the 39 cf. ISI, op.cit., Grand Challenges 5: Foster Informed Decisions and Actions. 40 The three main components include European neighbourhood instrument, Instrument for pre-accession assistance (IPA II) and Integration of non-EU nationals (cf. European 5268