9. The Act also provides for citizenship by naturalisation which is also dependent on birth registration: 4(3). children born in South Africa to other migrants (non-citizen and non-permanent residents); or those on a visa that does not lead to permanent residence status, are entitled to citizenship by naturalisation at the age of 18. 68 10. There are no regulations in place to guide and monitor the implementation of sections 2(2) and 4(3) of the Citizenship Act, both of which have been designed to safeguard against childhood statelessness. 11. The Birth and Deaths Registration Act (BDRA) and its regulations 69 provide the legal framework for birth registration of all persons born in South Africa. Birth registration must ideally be initiated by both parents and occur within a prescribed time frame after birth. The late registration of births is possible but is subject to penalties. IV. About the co-submitting organisations The Scalabrini Centre of Cape Town is a not-for-profit organisation specialising in working with migrants, refugees and asylum seekers. The Centre’s vision is to foster the cultural, social and economic integration of migrants, refugees and South Africans into local society. The Centre’s Advocacy Programme provides one-on-one assistance to migrant, refugee and asylum seeker clients, as well as engaging in policy advocacy, high level advocacy and strategic impact litigation in order to strengthen the human rights of persons on the move in South Africa. Lawyers for Human Rights is an independent human rights organisation with a 35-year track record of human rights activism and public interest litigation in South Africa. LHR uses the law as a positive instrument for change and to deepen the democratisation of South African society and operates a Refugee and Migrants Rights Programme which has a specialist focus on issues of citizenship, nationality and statelessness. The Centre for Child Law is an impact litigation organisation that was established in 1998. The Centre is registered as a Law Clinic and is based in the Faculty of Law at the University of Pretoria. The Director of the Centre is Ms Karabo Ozah. The vision of the Centre is to establish child law and uphold the rights of children in South Africa, within and international and regional context, particularly insofar as these interests pertain to their legal position. The Centre’s mission is to work towards the development of child law and the realisation of children’s rights in South Africa, within a regional and international context. The UCT Refugee Rights Unit is a research unit situated in the Law Faculty of the University of Cape Town. The work of the Unit comprises a legal aid clinic, a research unit, teaching, and advocacy and training. The provision of legal aid for refugees was started as a project within the existing UCT Law Clinic, fulfilling a social responsibility function. The Refugee Rights Project became operationally independent from the Law Clinic in 2006 and has since evolved into a fully-fledged research Unit, incorporating a Refugee Rights Clinic which provides direct legal services to thousands of refugees and asylum seekers each year. The Unit conducts applied research in refugee law and related topics and teaches refugee law to undergraduate law and masters' students within the Department of Public 68 Ibid., Section 4(3) Birth and Deaths Registration Act 51 of 1992, and Regulations on the Registration of Births and Deaths, 2014, Available at: https://www.gov.za/documents/births-and-deaths-registration-act 69 17