In 2014 the Committee on Economic, Social and Cultural Rights reiterated the importance of access to personal documents as the “right to have rights” and linked this right to implementation of the adopted Strategy and the subsequent NAP. In their concluding observations, the Committee recommended the Ukrainian authorities “simplify procedures and remove existing obstacles to ensure that all Roma are provided with personal documents, including birth certificates, which are necessary for the enjoyment of their rights under the Covenant”.29 Finally, in 2016, the Committee on the Elimination of Racial Discrimination expressed its concern over the persistence of discrimination, stereotypes and prejudices against Roma, and at reports that Roma are unable to flee the crisis zones and to benefit from assistance, in some cases due to their lack of personal documents. Furthermore, the Committee recommended the state to strengthen its efforts “to firmly combat racial discrimination and prejudices against Roma and address the challenges that Roma continue to face in many areas, […]” and “to provide all Roma with identity documents free of charge”.30 Ukrainian legal framework applicable in the area of access to personal documents Laws and regulations governing civil registration In Ukraine there is an abundance of regulations prescribing the rules and procedures for obtaining personal documents. Civil registration, or the “registration of civil status acts”, involves the mandatory registration of all aspects of civil status for individuals, from birth, marriage, dissolution of marriage and death to the change of a person’s name. Article 49 of the Civil Code of Ukraine31 prescribes the legal foundations for the registration of civil status acts. Under the Civil Code of Ukraine, these acts are considered “events and acts inseparably connected with the individual that start, modify, amend or suspend capacity to be an actor with civil rights and obligations”.32 The issuance of civil registration documents is regulated by the Law of Ukraine on State Registration of Civil Status Acts33 which prescribes the general legal framework for civil registration. According to Article 13 (3) of this Law, civil registration of birth is to be performed no later than one month after birth. The basis for civil registration of a birth is a document certifying the fact of the birth of a child issued by the healthcare institution where the birth happened (hereinafter: Medical certificate of birth, form 103/o).34 If a child was not born in a 29 Concluding observations on the sixth periodic report of Ukraine, UN Committee on Economic, Social and Cultural Rights, 13 June 2014, para. 8, UN Doc. No. E/C.12/UKR/CO/6. 30 Op. cit., note 14, paras. 19–22. 31 Verkhovna Rada of Ukraine, Civil Code of Ukraine, Law No. 435-IV, 16 January 2003, <http://zakon2.rada.gov.ua/laws/show/435-15/print1475564456082547>. 32 Ibid. 33 Verkhovna Rada of Ukraine, Law of Ukraine on State Registration of Civil Status Acts, Law No. 2398-VI, 1 July 2010, <http://zakon2.rada.gov.ua/laws/show/2398-17/print1475564456082547>. 34 Form 103/o (“Medical certificate of birth”) is the document issued at the maternity ward immediately after the birth in accordance with the Instruction on completing and issuing a medical certificate of birth (form 103/o) approved by the Ministry of Health of Ukraine, Decree No. 545, 8 August 2006, <http://zakon3.rada.gov.ua/laws/show/ru/z1150-06>. 20