international law standards and UNHCR Guidance. In particular, the law should ensure that the statelessness determination procedure is fair, effective and accessible to all persons in Ukraine regardless of their legal status, including those who are subject to removal and detention proceedings; reduce the burden of proof of the applicant; and provide applicants with temporary documentation and status until a final decision is made. V. Ensure that the definition of ‘stateless person’ under Ukrainian law is fully consistent with the definition provided in the 1954 Convention and that no stateless persons are excluded from this definition. VI. Ensure that stateless persons are not subject to arbitrary detention. The 2016 law reform, which requires a court order to detain before a person can be subject to detention, must be fully implemented. The practice of detaining persons pursuant to a court order to remove must end. VII. Ensure that detention is only implemented as a last resort, when necessary and proportionate, after all alternatives (starting with the least restrictive) have been exhausted. The list of alternative measures should be expanded and their application simplified. In order to determine if detention is necessary and proportionate, statelessness must be identified at the point of the decision to detain and reviewed on a continued basis. VIII. Ensure that the barriers to obtaining temporary residence permits for former detainees who cannot be removed – including the requirement of compulsory registration of the place of residence/stay, and the requirement that the applicant was detained for the maximum detention period – are abolished. Furthermore, grant temporary residence permits for periods longer than one year, and ensure that permit holders have stay rights including the right to study and to work. IX. Take all necessary steps to address historical and structural discrimination against the Roma community, which heightens their lack of documentation and risk of statelessness. Fully implement the recommendations of the UN Committee on the Elimination of Racial Discrimination, the Committee on the Rights of the Child and the Office of the Ukrainian Ombudsman, to break the cycle of discrimination and statelessness faced by Roma, and ensure their equal access to all human rights. X. Take adequate measures to quantify the scale of statelessness in Ukraine and assess the risk of statelessness among particularly vulnerable populations. 13