Ireland. UNHCR recommends that States grant recognised stateless people a renewable residence permit valid for at least two years, although longer permits, such as five years, are preferable in the interests of stability. 28. While stateless persons are not prohibited from making applications for residence permission under existing administrative or statutory schemes, there is no published guidance or policy on how such applications are handled. Evidence of identity, including a passport, must be provided in support of an application for a residence permit submitted to the Minister of Justice. While this requirement may be waived in practice, there is no published guidance on the evidentiary requirements to be provided by applicants, nor information on how to address issues related to statelessness. 29. When the Minister for Justice is considering the imposition of a deportation order there is no requirement to consider statelessness as a relevant factor, but regard must be had to humanitarian considerations and any representations made. 30. If residence permission is granted (either following an application to the Minister or following the Minister’s determination that a deportation order should not be made) this is set out in a decision letter. The decision letter that grants residence permission does not typically explain the basis of the decision, it will not state that the individual is a stateless person and may record a nationality that the individual asserts they do not hold. While a residence permit granted by the Minister for Justice can be renewed, it is at the Minister’s discretion whether it should be renewed and on what terms. 31. The decision letter granting residence permission typically directs the individual to attend the local immigration office with evidence of identity in order to obtain a certificate of registration (Irish Residence Permit card). Although the requirement to produce evidence of identity can be waived in practice, the decision letter does not always set this out. Even where certain requirements are waived by one State authority it may not be accepted by other State authorities as definitive evidence that a person is stateless and does not have a nationality. Aside from applications for international protection, all residence permission and nationality applications are written applications, relying on representations and documentary evidence and sometimes a specific application form. This means that a stateless person may be required to repeatedly make the same representations to different State authorities or even to different units of the Department of Justice. Consequently, even though it may have implicitly been accepted that the applicant cannot produce evidence of identity and is stateless, this is not confirmed in writing and gives rise to ongoing difficulties for the individual following the grant of residence permission in trying to deal with other State bodies that may require evidence of identity (for example, to issue public service cards, social security, or driving licences). 32. Stateless refugees are granted rights akin to nationals, including a right to employment, education, social security, healthcare, renewable residence of at least three years, a travel document, and family reunification. Stateless people granted residence outside of international protection proceedings are usually provided with terms and conditions by the Minister for Justice on an administrative basis and rights are not set out in law. These usually include a residence permit for a minimum of 12 months (renewable on certain conditions) and access to the labour market. They can also usually access social security and healthcare but may face barriers in practice due to the lack of identity documents. Travel documents may be granted on a discretionary basis to stateless 7

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