children of parents who already lack the documentation needed to fulfill the legal requirements for civil registration in general, including registration of births, deaths, marriages, legal residency transfers, divorces, and child custody. 22. While the challenges identified above are not exclusive to Roma, they disproportionately affect Roma. Lack of resources, economic migration, life in informal housing, and marginalisation more generally, are all factors impacting significantly on their ability to register the births of their children. This problem is further exacerbated by the law and policy framework, which makes it extremely difficult for undocumented parents with no permanent residence to acquire nationality for their children. Hence, there is an intergenerational aspect to the risk of statelessness. 23. Without birth registration, Roma face barriers in obtaining other documents from the civil registry office and identity documents when they become adults. Furthermore, as Roma are less likely to have property ownership records or housing lease agreements, they face many barriers at the civil registry office when changing or registering their residence. 24. Albanian authorities are generally conscious of the challenges faced by Roma related to accessing civil registration. There have been initiatives to address the problem, such as encouraging early registration through the provision of financial support. 21 However, despite this, access to civil registration in Albania is still unsatisfactory and there are still many cases of late registration of births among Roma in Albania. 25. According to the Ministry of Interior, in cooperation with civil society organisations, 148 Romani children had their births registered as late registrations and 500 Roma individuals were provided with civil registration assistance in 2014.22 26. TLAS’ own statistics for 2015 showed 515 unregistered children, of which 60% were Roma. In the first six months of 2016, 274 unregistered children were identified by TLAS, of which, again 60% were Roma. In the second half of 2016, the organisation helped 408 unregistered children of which 270 were Roma.23 27. Other barriers to birth registration that were identified include: I. Communities living in rural areas far from health care centres leading to women giving birth at home; 21 Article 41 of Law no. 10129, date 11.5.2009, “On Civil Status” amended that provides that parents who register births inside Albania within 60 days, and births outside Albania within 90 days, receive monetary rewards. For more insight on initiatives undertaken to resolve the issue, see also Decade for Roma Inclusion, Civil Society Monitoring Report on the Implementation of the National Roma Integration Strategy and Decade Action Plan in 2012 in ALBANIA, pp. 27-28, 2013. Available at: http://www.al.undp.org/content/dam/albania/docs/misc/ Roma%20decade%20_civilsociety-monitoring-report_en.pdf. 22 National Action Plan for Roma and Egyptians in Albania, available at: http://www.al.undp.org/content/albania/en/home/library/poverty/national-action-plan-for-integration-of-roma-and-egyptians-in-th.html. 23 These statistics are from TLAS’ internal casework management database. The data is collected based on selfdeclaration and any available legal documentation, as well as information from civil status offices or other organisations in some cases. 6