still undetermined. According to the information collected during the interviews and discussions with different stakeholders, estimates of the number of Roma without personal documents vary from 2 per cent to 30 per cent. The lack of data on the number of Roma without personal documents also affects the state’s plans and the implementation of existing public policies in this area. Clearly, without dependable data, the Government is not able to assess accurately the extent of this phenomenon and therefore not able to mobilize properly the kind of resources necessary, at national, regional and local levels, to address and solve the problem. Local Roma residents, Roma community leaders and Roma mediators claimed there has been no assessment of the scope of this problem and that the state authorities count on local NGOs and international organizations’ assistance with it. The 2015 Report on the Implementation of State Policy on Roma, prepared by the Ukrainian Ombudsperson’s Office, the International Renaissance Foundation and the European Roma Rights Centre (ERRC) found that 83 per cent of Roma had a passport or other identity document and the rest did not.57 The state authorities interviewed during the field visits were not able to provide official, reliable data on the number of Roma experiencing problems in accessing personal documents; the number of Roma that applied late for birth registration, internal passports, or registration of residence; the number of Roma at risk of statelessness; or the number of Roma rejected for such documents.58 It could be reasonably claimed that the practice of oral rejections and the lack of statistics in these cases are some of the reasons why the state authorities were not able to provide such data. The lack of data on this issue serves as a clear reminder that the Ukrainian authorities need to invest more effort into understanding the scope of the problem and to tackle it in a more coherent, systemic way. It is also very difficult for the Ukrainian authorities to assess whether the adopted Strategy has yielded positive results and decreased the number of Roma without personal documents. It is evident that a system for the collection of disaggregated data and a set of clear benchmarks and goals is needed in that regard. However, at least in the Transcarpathia and Odesa regions, such disaggregated data on the number of Roma provided with birth registration (without comparative data, e.g. on the total number of Roma applying for birth registration) or provided with personal documents does exist, which shows there has been some progress compared to previous years.59 Inconsistencies in administrative practice in cases related to access to personal documents Administrative practice with respect to personal documents is not coherent and this lack of legal certainty deters Roma from applying for personal documents. Together with the poor 57 Joint Submission to the Human Rights Council at the 28th Session of the Universal Periodic Review (Third Cycle, 6–17 November 2017), Desyate Kvitnya, R2P, Institute on Statelessness and Inclusion, European Network on Statelessness, European Roma Rights Centre, Ukraine, 30 March 2017, p. 10, <https://www.statelessness.eu/resources/joint-submission-human-rights-council-28th-session-universal-periodicreview-ukraine>. 58 Interviews conducted on 20 March 2017, 21 March 2017, 28 March 2017 and 30 March 2017. 59 Information received from the District State Registration in Odesa demonstrated a huge increase in numbers of Roma provided with birth registration. For example, in 2015 there were 78 Roma provided with birth registration, in 2016 there were 221, and in the first three months of 2017 there were already 96 Roma registered in the birth registry books. 26