3. Access to protection in Europe A form of temporary protection for refugees from Ukraine is being implemented in most of the 17 countries reviewed, except for Moldova and the UK, where other routes to protection are available (although in the UK these are very restricted). In Hungary, the EU Temporary Protection Directive is being implemented in a very restrictive way and alternative routes to protection (including asylum) are not available to stateless people fleeing Ukraine. Routes to protection for stateless people from Ukraine are also very limited in Austria. In other EU countries, implementation of the Temporary Protection Directive varies. No country has extended eligibility to all stateless people and those at risk of statelessness to include those who cannot prove prior legal residence in Ukraine. In most EU countries, in addition to Ukrainian nationals, eligibility for temporary protection is limited to (stateless) people who held international protection (or equivalent) or permanent residence in Ukraine, and their family members. The widest scope of application is in Spain and Portugal where temporary protection is extended to those fleeing Ukraine who had permanent or temporary stay (Spain), or permanent or temporary stay or a long-stay visa (Portugal) in Ukraine and are unable to return to a country or region of origin. However, this still does not account for most stateless people and those with undetermined nationality from Ukraine who do not have links to any other country. Positively, the Czech Republic, Belgium, and Spain have specified that people recognised as stateless under Ukraine’s Statelessness Determination Procedure are eligible for temporary protection, but in other countries this is still unclear. As the Ukrainian authorities continue processing applications for statelessness status submitted prior to 24 February 2022, there is a growing number of people recently recognised as stateless in Ukraine but who are unable to obtain documentary proof of that status if they have fled Ukraine or been internally displaced. In most European countries, those ineligible for temporary forms of protection may apply for international protection under regular asylum or subsidiary protection procedures. Some countries have dedicated Statelessness Determination Procedures providing a route to protection for stateless people. Others offer at least a form of temporary admission or ‘tolerated stay’ if the person cannot be removed to their country of origin. However, these are often complex and lengthy procedures, sometimes with very limited rights, and often prevent onward travel and/or return to Ukraine. In some cases, applicants have no rights during the procedure at all and may face detention and expulsion. UNHCR has recommended that European States take an inclusive approach and grant temporary protection to stateless people, including those who did not have permanent residence status in Ukraine. However, stringent documentation requirements and the policies currently applied throughout Europe are excluding from protection significant parts of the Ukrainian population, which defeats the objective of temporary protection and may frustrate longer term return, reintegration, and re-building efforts. This urgently needs fixing if the European Commission and European States are to fulfil their stated intention of extending protection to everyone fleeing Ukraine. EU Member States and other European countries must extend temporary forms of protection to all stateless people and those with undetermined nationality who cannot meet current eligibility requirements, due to their statelessness or documentation status. Our analysis further evidences the need for the European Commission to revise the Operational Guidelines for implementation of the Temporary Protection Directive and call on EU Member States to extend protection to everyone fleeing Ukraine. 4. Discrimination and antigypsyism Reports are continuing to emerge of antigypsyism and discrimination in access to the territory, temporary protection, services, and support faced by Romani people fleeing Ukraine, including in Poland, Moldova, and the Czech Republic. A significant proportion of the Romani population (estimates range from 10-20%) from Ukraine lack identity documents and proof of nationality, adding to the barriers they face in accessing safety and protection outside Ukraine.