Ukrainian national strategies related to Roma access to personal documents Strategy for the Protection and Integration of the Roma National Minority into Ukrainian Society by 2020 and the National Plan of Action for its implementation It is worth noting that not all Roma in Ukraine experience problems in accessing personal documents. As a rule, this problem is mostly linked to impoverished Roma who are socially excluded, often unemployed, and with little or no formal education. With the adoption of the Strategy for the Protection and Integration of the Roma National Minority into Ukrainian Society by 2020 and the subsequent Plan of Action on Implementation of the Strategy for Protection and Integration into Ukrainian Society of the Roma National Minority for the Period until 2020 (NAP), the Ukrainian authorities recognized the challenges Roma face in accessing personal documents. Under Section 4 of the Strategy, the Government envisaged that one of the main tasks of the Strategy is to provide assistance with obtaining identity documents, citizenship and certificates of state registration of civil status acts for Roma who legally stay in Ukraine.46 Notwithstanding the fact that the adoption of these documents is a clear step forward for Roma inclusion in Ukraine, there have been also a number of concerns about the lack of a human rights perspective when it comes to the implementation of these documents.47 One of the main concerns is the lack of participation of Roma representatives in the process of the adoption of the Strategy, the lack of an earmarked budget for its implementation, and the absence of efficient mechanisms for the implementation and co-ordination of the Strategy and the NAP.48 Some of these challenges have already been noted by the UN treaty bodies and ODIHR, and there has been no progress in this regard. For example, in 2013 the Human Rights Committee recommended the Ukrainian authorities “allocate sufficient resources for the effective implementation of the Strategy on protection and integration of Roma”,49 while on the other hand ODIHR Assessment Report clearly suggested that amendments to these documents are necessary for a more effective Government approach to Roma inclusion.50 Moreover, ODIHR’s summary report of the 2015 expert seminar on access to identification and civil registration documents by Roma in Ukraine noted that “no concrete steps have been undertaken 46 The Strategy, op. cit., note 13. According to the Assessment Report, the Strategy and the NAP fail to reflect OSCE commitments with regard to Roma and Sinti, as well as other relevant international human rights standards. In particular, the Strategy and the NAP lack a clear anti-discrimination perspective and do not integrate gender equality as a cross-cutting issue. As such, the Strategy fails to recognize the existing situation of discrimination against Roma in Ukraine, including the multiple forms of discrimination experienced by them in all areas of life, and does not include anti-discrimination as an integral part of State measures for Roma inclusion in Ukraine. Assessment Report, op. cit., note 3, p. 14. 48 Assessment Report, op. cit., note 3, pp. 14–15. These problems were acknowledged in the Recommendations of the Ukrainian Parliament Committee on human rights issues, national minorities and inter-ethnic relation adopted after the Committee’s hearings “State of play in the implementation of National Strategy of the Protection and Integration of Roma national minority into the Ukrainian Society by 2020” (5 October 2016), <http://kompravlud.rada.gov.ua/uploads/documents/32594.pdf>. 49 Concluding observations on the seventh periodic report of Ukraine, UN Human Rights Committee, 22 August 2013, para. 12, UN Doc. No. CCPR/C/UKR/CO/7. 50 Assessment Report, op. cit., note 3, pp. 14, 25. 47 24