residence permit as a consequence of statelessness determination. 50 Not granting residence rights to persons determined to be stateless is contrary to UNHCR guidance and good practice standards set by other countries worldwide. In not granting residence rights to stateless persons, the Netherlands would be an exception among other countries with an SDP. To meet its international obligations, the Dutch Government should amend its legislative proposal to ensure applicants under the SDP and persons determined to be stateless acquire a residence permit. 30. Lastly, the current legislative proposal establishes that the burden of proof in determining statelessness would be shared between the applicant and the authorities. Whilst a shared burden of proof is in line with UNHCR guidance, the co-signatories are concerned that applying this without explicitly considering the inherent difficulties in proving statelessness, could prevent stateless people from accessing protection. This is especially the case if the SDP applicant is required to make every effort to demonstrate their nationality status by means of documents, as many stateless people lack identity documents or any other documentary evidence of their lack of nationality precisely due to the nature of statelessness. If the lack of documentation is used as evidence to undermine the credibility of a statelessness claim, stateless persons will find themselves stuck in a vicious circle. In line with UNHCR guidance, it is recommended that the burden of proof is shared but that authorities should take into account the difficulties in substantiating statelessness through documentary evidence. The standard of proof necessary to determine statelessness should establish "to a reasonable degree" that the person is not considered a national by any State under the operation of its law. 51 Additionally, when determining statelessness, it is important that all possible pieces of evidence are considered, including testimonies, and not just the submission of documents. To this end, UNHCR guidance, as well as official UNHCR letters and/or interventions that further clarify certain pieces of evidence, can be taken as a guideline. Issue III: Access to facilitated naturalisation 31. The Netherlands is obliged to facilitate the naturalisation of stateless persons, in line with Article 32 of the 1954 Convention. Under the current national legal framework, stateless persons whose statelessness has not been determined due to the lack of an SDP do not benefit from the expedited process. They are - like all other persons – required to establish at least five years of legal residence in the country and to present a valid passport as part of the procedure. 32. Those registered as stateless in the BRP have access to a facilitated naturalisation procedure. They can apply for naturalisation after three years, instead of five years. While they are exempt from the passport requirement, proof of their identity (i.e. a birth certificate) is a requirement stateless people often cannot meet. 52 Given that many stateless people lack of documents and many States are unwilling to issue birth certificates for non-nationals, this requirement may still pose an insurmountable and discriminatory barrier to some stateless people, undermining the objective of facilitated 50 UNHCR, Mapping Statelessness in the Netherlands, November 2011, https://www.refworld.org/docid/4eef65da2.html; ACVZ, No country of one’s own, 2013, https://www.adviescommissievoorvreemdelingenzaken.nl/publicaties/publicaties/2014/09/11/no-country-ofone%E2%80%99s-own 51 UNHCR, Handbook on Protection of Stateless Persons, para 90-91, https://www.unhcr.org/dach/wpcontent/uploads/sites/27/2017/04/CH-UNHCR_Handbook-on-Protection-of-Stateless-Persons.pdf. 52 ACVZ, No Country of One’s Own (The Hague: ACVZ, September 2014), p. 63. 10