Regional Overview Regional Overview Birth registration in the sub-region acts as an essential foundational document that is required to access other primary legal identity documents and its corresponding digital ID systems (should they exist). In the case of Nepal, alternative documents besides birth certificates can be provided to acquire citizenship certificates, showing alternative options for those who may not have access to birth registration.4 Legal identity in East Asia is characterized by the use of family or household registration records, which serve as prerequisite documents for applying for national ID cards in all seven countries of the sub-region.5 One common feature across China, Japan, Taiwan, and South Korea is the linkage between birth registration and the household registration system, which serve as the basis for establishing permanent residency status and gaining access to public services from education to healthcare.6 Legal identity in Southeast Asia is characterized by civil registration–based systems where birth registration serves as the foundation for obtaining national identity cards. These cards are the primary legal identity documents across all eleven countries in the sub-region. While birth registration establishes legal identity and enables entry into population registries, national ID cards are mandatory for citizens and widely used to access services. In some countries it also serves as proof of citizenship. However, most Southeast Asian countries maintain a legal distinction between identity and citizenship. In Central Asia, legal identity is characterized by a layered system in which birth registration serves as a universal and mandatory foundational document, but national ID cards or internal passports function as the primary proof of legal identity for adults. While birth registration establishes initial legal identity, individuals must subsequently obtain national ID documents to access services, reflecting a system where legal identity is built progressively and does not in itself constitute proof of citizenship. sub-regions, they play a critical role in structuring access to rights and services. Overview of Digital ID India, Australia, and New Zealand stand out as countries that do not have a single primary legal identity, and multiple forms of legal identity are accepted.7 For example, in India, there is no officially recognized single legal identity document, so individuals rely on a combination of documents such as birth registration records, Aadhaar numbers, voter ID cards, passports, and ration cards to establish identity in different contexts.8 Similarly, in Australia, legal identity is typically established through a range of documents rather than a single foundational ID, including passports, driver’s licenses, birth certificates, and citizenship certificates, depending on the service or transaction.9 In New Zealand, multiple documents are explicitly recognized as proof of legal identity, including passports (New Zealand or foreign), driver’s licenses, firearms licences, birth certificates, citizenship certificates, refugee travel documents, and certificates of identity, with no single document serving as the sole authoritative ID.10 Access to legal identity for non-citizens varies significantly across all five sub-regions, particularly between birth registration systems and national ID frameworks. Birth registration is generally more accessible. In many countries it is not formally restricted by citizenship status, meaning that children of non-citizens can often be registered at birth. However, birth registration does not necessarily translate into legal status, nationality, or access to rights beyond the recording of a birth event. Digital identity systems have been introduced at varying stages of development across the five subregions over the past decade. South Asia has the longest-running large-scale systems with India’s Aadhaar (operational since 2009),14 Bangladesh’s NID (rolled out in 2007/2008)15 and Bhutan’s National Digital Identity, launched on 13 October 2023, billed as the first national-scale SSI system in Asia and globally.16 Across South Asia, East Asia, and the Pacific, primary legal identity systems do not uniformly constitute or confer citizenship, although they are often closely tied to it in practice. In many countries, foundational identity documents, such as household registration systems in East Asia or national ID systems in South Asia, are used to access services and legal recognition, which can make them functionally equivalent to proof of citizenship even when they are not legally defined as such. In the Pacific, the relationship is more varied: while birth registration is widespread, only three countries (Fiji, Palau and Samoa) treat birth certificates as direct proof of citizenship, whereas in most cases, a birth certificate merely records a birth event and must be supplemented by additional documentation to establish nationality. Overall, while legal identity systems do not automatically confer citizenship across the five While some countries provide alternative forms of identification for non-citizens, these are typically distinct from citizen ID systems and confer more limited rights and recognition. Examples include residence cards in Japan, foreign resident registration systems in South Korea, ImmiCards in Australia, certificates of identity or refugee travel documents in New Zealand, and an Alien Residence Certificate in Taiwan.12 In India, where there is no single primary legal identity document, systems such as Aadhaar are accessible to residents regardless of citizenship status, but they function primarily as proof of identity and not proof of nationality.13 By contrast, access to national ID cards and their corresponding digital identity systems depends on citizenship. In East Asia, Southeast Asia, and parts of South Asia, national ID systems are closely tied to citizenship or legal residency status. This limits access for undocumented migrants and stateless populations.11 In the Pacific, countries that rely on national ID cards restrict them to citizens or permanent residents, except in Tonga, where ID cards are mandatory regardless of citizenship status. See Table 1 - Primary legal identity document across Asia Pacific ( page 24 ) The case of India illustrates why the distinction between legal identity and citizenship matters. Although the Aadhaar Act, 2016 expressly states that Aadhaar is not proof of citizenship, in practice Aadhaar has become deeply embedded in access to subsidized food, school enrollment and welfare.17 For those unable to enroll in Aadhaar, often due to lack of documentation, literacy, or education, it means exclusion from access to basic rights such as welfare or work. Aadhaar has reinforced existing structural inequalities, particularly for marginalized groups such as stateless persons, migrants, and those lacking legal identity documents. This demonstrates that even when a digital ID system is not legally tied to citizenship, its integration into welfare and governance systems can produce citizenship-like effects of inclusion and exclusion.18 Digital identity development across Pacific Island countries remains at an early stage,19 with only Australia, New Zealand, and Vanuatu having operational systems, each differing in design and function. Australia’s myID and New Zealand’s RealMe are voluntary, service-oriented systems that enable secure access to government services but do not serve as proof of citizenship, whereas Vanuatu’s system combines a mandatory national ID card with a voluntary E-ID that functions as a foundational legal identity. Most other countries are in planning or early implementation phases: Fiji has announced a comprehensive 14 15 STATELESSNESS ENCYCLOPEDIA ASIA PACIFIC THIRD EDITION - REGIONAL OVERVIEW REPORT 2026