Adopted children over the age of 12 years may acquire Danish nationality by naturalization after two years of residence before their 18th birthday.332 Other conditions apply, among others the requirement of the lack of a criminal record.333 4.3 Conclusions and recommendations Denmark has taken commendable steps by (re)introducing some of the provisions of the 1961 Convention and the CRC relating to every child’s right to a nationality and prevention of childhood statelessness in its nationality legislation. In principle, Denmark has relatively strong standards in place with regard to preventing stateless, but certain gaps in Danish nationality legislation allow situations where a child might be left stateless for an extended period of time. Therefore, in order to ensure full compliance with the requirements set out in the 1961 Convention, and with related provisions in the CRC and ICCPR, it is recommended that Denmark considers introducing automatic acquisition of nationality at birth for those children who are born stateless in the country. If Denmark opts to continue to grant its nationality through an application procedure, it is recommended that stateless children who are born in Denmark and who reside in the country habitually without having a lawful residence, are allowed to submit their application as soon as possible after birth in order not to be left stateless for an extended period of time. In any event, it is recommended that Danish born stateless children and young persons who are entitled to Danish nationality are informed about the entitlement individually. Due to the specific Danish naturalization process where nationality is granted by the legislature, there is a lack of procedural guarantees for applications for nationality to be processed within a reasonable time, to be subject to appeal or judicial review, and to be reasoned. It is therefore recommended that Denmark assesses to what extent the existing procedure might be discretionary and whether the right to acquire nationality for those children born in Denmark who would otherwise be stateless should be incorporated in the Nationality Act in order to ascertain full compliance with Article 1 of 1961 Convention and relevant international standards. Moreover, fees should not be charged in case of stateless persons who are entitled to Danish nationality; thus, the exemption for paying fees ought to also comprise stateless persons born on the territory who have turned 18. A real, substantial facilitation of naturalization should also be provided for stateless persons not born stateless in Denmark. Specifically, an exemption from the language and nationality tests could be provided for elderly stateless persons, who may otherwise be prevented from acquiring Danish nationality like their family members. In addition, it is recommended that the Nationality Act be amended in such a way that children of parents with unknown nationality are treated like foundlings and thus considered Danish nationals as long as they have not been established as nationals of a foreign state. Finally, it is recommended that the Nationality Act is amended in such a way to include safeguards against statelessness in case of loss and deprivation of nationality in any form, including when a nationality is considered never to have been acquired because conditions for the acquisition of nationality are deemed not to have been met in the first place (‘quasi loss’). 332 According to Section 14 of the Naturalization Circular. 333 See conditions applying to children who may apply for nationality independently on the website of the Ministry of Immigration and Integration, available at: https://bit.ly/2P3gnM8. UNHCR Representation for the Nordic and Baltic Countries 77