In Denmark, the naturalization criteria are not contained in the Nationality Act. Instead, they are agreed upon by a majority among the political parties in Parliament and included in a Circular on Naturalization. It is fair to say that the general naturalization criteria are strict, and almost all criteria apply for refugees and stateless persons as well. According to the Circular, the only facilitation of these persons’ access to nationality (required by the 1951 Convention, the 1954 Convention and the ECN) is a slight reduction of the general residence requirement: the general requirement of residence of nine years is reduced to residence of eight years.304 As explained above, stateless children born in Denmark may be naturalized without fulfilling the regular requirements for naturalization according to Section 17 of the Circular, stating that in accordance with the CRC, children who are born stateless in Denmark may be listed in a Naturalization Bill if they are residents in Denmark. Moreover, a provision implementing Article 1 of the 1961 Convention is now included in Section 26 of the Circular. Otherwise, in order to obtain Danish nationality, a stateless person must satisfy the general conditions laid down by (a majority among) the political parties in the Parliament and administered by the Ministry of Immigration and Integration. Applicants for naturalization, who satisfy the conditions codified in the Naturalization Circular, will be listed in a Naturalization Bill to be adopted by the Parliament.305 The Naturalization Bills are introduced in the Parliament, normally twice a year, in spring and in autumn. When a Naturalization Bill has been passed by Parliament, the persons listed in the Bill, and as a rule their children, will acquire Danish nationality.306 Ordinary naturalization is the most important mode for acquisition of Danish nationality after birth. As provided for in Section 6 of the Nationality Act and the Naturalization Circular, foreigners may be naturalized if they have a permanent residence permit and have resided in Denmark for nine years – or eight years in the case of stateless persons and refugees – and fulfil other rather strict requirements. Among those requirements are proof of good conduct and of the absence of a public debt, a certification of knowledge of the Danish language, passing of a citizenship test and proof of having been self-supporting during the past two years and during four years and 8 months in total within the last five years. Hence, the only “facilitation” of naturalization available today in Danish legislation and practice of stateless persons and refugees, pursuant to Article 32 of the 1954 Convention and Article 34 of the 1951 Refugee Convention, is the reduction of one year of the general residence requirement, from nine to eight years. 307 For many refugees and stateless persons this facilitation may be irrelevant insofar as they may not be able to meet the other rather strict requirements for naturalization. It is questionable whether the limited reduction of the residence requirement is sufficient to meet the obligation to ‘facilitate’ naturalization, considering among other things that many refugees and stateless persons with limited school attendance (see, by way of example, the case of Bhutanese refugees as explained above) are excluded from acquiring Danish nationality, as they cannot meet the language and naturalization test requirements. In this context, UNHCR would like to note that “[b]est practices in European countries to facilitate naturalization of immigrants, refugees and stateless persons include waiving language proficiency requirements and reducing the number of years of lawful residence required.”308 The Council of Europe Committee of Ministers has long recommended that each state should facilitate the naturalization of stateless persons, in particular reduce the required period of residence for stateless persons; not make language requirements stringent; ensure accessibility 304 Section 7 of the Naturalization Circular. 305 See the Naturalization Circular section 7. 306 The Immigration Service, ‘Statistical Overview: Migration and Asylum 2011’ (English version), p. 46. 307 See the Naturalization Circular. 308 UNHCR intervention at the Committee on Legal Affairs and Human Rights, Parliamentary Assembly of the Council of Europe, Paris, 12 November 2012, para 22, available at: http://www.refworld.org/pdfid/50f53c5d2.pdf. UNHCR Representation for the Nordic and Baltic Countries 73