may be a bar to naturalisation, unless it is deemed that the trial was unfair or the punishment disproportionate. 73 There is a fee of 28.64 EUR for the naturalisation procedure. Exemptions are available for some groups including children in care, orphans, and severely disabled persons, and a reduced fee of 4.27 EUR is available for those in need, registered unemployed, large families, older people, some students and disabled persons. There are no exemptions for stateless people.74 Issue 4: Immigration detention of stateless persons 41. Stateless people face a heightened risk of arbitrary detention particularly where procedural safeguards to identify and determine statelessness and related barriers to removal are lacking.75 42. There are some safeguards against the arbitrary detention of stateless migrants in Latvia, but significant gaps remain.76 A proposed country of removal does not need to be identified prior to detaining someone for removal, and there is no clear legal provision guaranteeing that detention is only ever used as a last resort.77 Statelessness is only considered juridically relevant in that someone may be referred to the SDP for determination of their statelessness, but if they have no legal right to stay or there is a risk of absconding, a stateless person may still be detained until their statelessness is determined under a procedure.78 Vulnerability assessments are provided for in law, but statelessness is not considered a vulnerability factor.79 43. Alternatives to detention are established in law and the wording implies that reporting to the authorities should be considered prior to ordering detention. 80 However, evidence from practice and available data suggests that alternatives may only be applied in a small proportion of return decisions. 81 There are some procedural safeguards, but periodic reviews are undertaken by the authorities, rather than the courts, although decisions may be appealed to a judge. 82 Legal aid is limited to challenging the return decision and not detention. People released from detention are not guaranteed access to basic rights or assistance and cumulative time spent in detention does not count towards the maximum time limit.83 73 Citizenship Law, 2013, Section 11: https://likumi.lv/ta/en/en/id/57512 Cabinet of Ministers Regulations Nr. 849 Regulation on State Fee for the Submission of Naturalisation Application, 2013, Section 2-4 https://likumi.lv/ta/id/259981 75 ENS (2017) Protecting Stateless Persons from Arbitrary Detention: An Agenda for Change, https://www.statelessness.eu/sites/www.statelessness.eu/files/attachments/resources/ENS_LockeInLimbo_Detention_Agend a_online.pdf 76 ENS Statelessness Index Latvia: https://index.statelessness.eu/country/latvia 77 Imigrācijas likums (Immigration Law), 2017: https://likumi.lv/ta/id/68522-imigracijas-likums 78 ibid 79 Imigrācijas likums (Immigration Law), 2017, Art. 57 & 59: https://likumi.lv/ta/id/68522-imigracijas-likums 80 Asylum Law, 2017, Section 13 & 14: https://likumi.lv/ta/en/en/id/278986-asylum-law; Imigrācijas likums (Immigration Law), 2017, Art. 51: https://likumi.lv/ta/id/68522-imigracijas-likums 81 Latvian Centre for Human Rights (2015) The return of Third Country Nationals: Standards and their Implementation in Latvia: http://cilvektiesibas.org.lv/media/attachments/01/12/2015/Latvian_report_ korekturai_COR_NEWNEW.pdf 82 Imigrācijas likums (Immigration Law), 2017, Art. 52(2), 54, 56 & 59: https://likumi.lv/ta/id/68522-imigracijas-likums 83 ENS Statelessness Index Country Survey 2019: Latvia, pp. 40-41, available at: https://index.statelessness.eu/sites/default/files/ENS_Statelessness_Index_Survey-Latvia-2019.pdf 74 11