2020 Statelessness & Citizenship Review 2(2) of civil registration documents, most importantly through the adoption of the 1961 Convention to Abolish the Requirements of Legalisation for Foreign Public Documents (‘Apostille Convention’). 54 More recently it has launched an initiative to facilitate the recognition of foreign judicial decisions relating to parentage, in particular in the new context of international surrogacy arrangements. 55 The Commission Internationale de l’État Civil (International Commission on Civil Status) (‘ICCS’), an intergovernmental organisation established in 1950, aims specifically ‘to facilitate international cooperation in civil status matters’ and has adopted 34 conventions to that effect, including Convention No 13 of 1973 aimed at reducing statelessness caused by gender discrimination in nationality law; Convention No 16 of 1976 on multilingual certificates; and Convention No 17 of 1977, with objectives similar to the Apostille Convention for the reduction of the burden of legalisation of foreign documents. 56 In 2010, the ICCS published a study on the comparative laws and policies of its 15 member states (at that time), highlighting the great variation in relation to proof of civil status for irregular migrants. 57 But the ICCS has gradually lost support and had only six member states as of 2020; its relevance diminished, it seems, by low levels of ratification of its treaties, the lack of political backing from some core states and the overlapping of different institutional efforts to resolve these questions. Most (current or former) ICCS states are members of the European Union, and since 1997 the Court of Justice of the European Union has held that the certificates and other documents issued by one EU member state must be recognised by other member states, ‘unless their accuracy is seriously undermined by concrete evidence relating to the individual case in question’. 58 More recently, the EU has attempted to take steps to resolve the ‘extremely complex international legal 54 55 56 57 58 Convention to Abolish the Requirement of Legalisation for Foreign Public Documents (The Hague Conference on Private International Law, opened for signature 5 October 1961, entered into force 24 January 1965). The Hague Conference of Private International Law, Parentage/Surrogacy Project, launched 2011, documents collected at: Experts’ Group on the Parentage/Surrogacy Project, ‘The Parentage/Surrogacy Project’, The Hague Conference of Private International Law (Web Page) <https://www.hcch.net/en/projects/legislative-projects/parentage-surrogacy>. See, eg, Advisory Opinion Concerning the Recognition in Domestic Law of a Legal Parent–Child Relationship between a Child Born through a Gestational Surrogacy Arrangement Abroad and the Intended Mother (Requested by the French Court of Cassation) (Advisory Opinion) (European Court of Human Rights, Request No P16-2018–001, 10 April 2019). Convention No 13 to Reduce the Number of Cases of Statelessness (International Commission on Civil Status, opened for signature 13 September 1973) (‘Convention No 13’). Convention No 13 had seven states parties; now superseded by CEDAW (n 33). Convention No 16 on the Issue of Multilingual Extracts from Civil Status Records (International Commission on Civil Status, opened for signature 8 September 1976) (‘Convention No 16’). Convention No 16 has 24 states parties, the most widely ratified and used. Convention No 17 on the Exemption from Legalisation of Certain Records and Documents (International Commission on Civil Status, opened for signature 15 September 1977) (‘Convention No 17’). Convention No 17 has 10 states parties. Conventions 26 to 34, the most recent, have less than five ratifications each, see generally ‘Conventions’, International Commission on Civil Status (Web Page) <http://www.ciec1.org/>. For an outline of the work of the Commission see Chantal Nast, ‘Aspects d’état civil: aperçu des activités de la Commission Internationale de l’État Civil’ (Colloque, Centre de Droit Priv�� Fondamental, Université de Strasbourg 7 December 2012) <http://cdpf.unistra.fr/fileadmin/upload/CDPF/Colloques/La_reforme_du_nom_de_l_enfant _et_de_l_autorite_parentale/CIEC-CNast_Colloque_7.12.2012.pdf>. Persons Deprived of Civil-Status and Identity Documents (“Undocumented Migrants”) (Memorandum, International Commission on Civil Status October 2010). Eftalia Dafeki v Landesversicherungsanstalt Württemberg (C-336/94) [1997] ECR I-06761, [21]. 258