Discrimination against (at risk of) stateless Roma 36. Antigypsyism may also increase the risk of statelessness, when some personnel from civil registries refuse to register or issue documents to Roma individuals with the pretext that they do not pay their taxes. This practice is, of course, forbidden by a specific Ministry of Interior instruction.29 37. In 2013 the People’s Advocate (Ombudsperson) proposed amending the Law on Civil Status, raising awareness about the fact that many Roma and Egyptians live in informal settlements and cannot enjoy political, social or economic rights as citizens, for the reason that they are not officially registered as residents in local and municipal administrations.30 38. Members of Albanian civil society and Roma individuals interviewed for the Roma Belong report suggested that the main obstacles to civil registration for Roma people is a lack of awareness about the required documentation, a culture of mobility, social and economic vulnerability, and widespread discrimination in daily life including in their treatment by the authorities. In addition, considering the high level of corruption in Albania, vulnerable Roma people might have faced more difficulties in getting through the birth registration procedure. 39. Furthermore, antigypsyism in Albania is often an incentive for migration, which can in turn further complicate access to citizenship rights based on residence criteria, thus constituting a vicious circle. 40. Sometimes the law itself does not appear discriminatory, but its implementation and effects, in reality, have a discriminatory impact. Because the Albanian Government does not take into account the specific circumstances of the Roma, they are disproportionately affected by statelessness compared to the general population. In cases where citizenship is acquired through an application procedure or naturalization, access issues, the criteria set, and discretion in decision-making permitted to the authorities, all leave room for discrimination. 29 Milena Isakovic Suni, Comparing Approaches to Combating Statelessness in Albania and Serbia, June 2015, p4, available at: https://www. statelessness.eu/sites/www.statelessness.eu/files/2015-0514%20Comparing%20Approaches%20Albania%20and%20Serbia.pdf 30 Milena Isakovic Suni, Comparing Approaches to Combating Statelessness in Albania and Serbia, June 2015, pp8-9, available at: https://www. statelessness.eu/sites/www.statelessness.eu/files/2015-0514%20Comparing%20Approaches%20Albania%20and%20Serbia.pdf 9