Consequences of inflexible administrative practice Take, for example, the case of a Roma woman whom we will call “R.”. She was born in Ukraine in 1987 and her mother died in 2005, but the fact of her mother’s death was not registered with the authorities. R.’s father is a Ukrainian citizen with an internal passport of long standing. When R. applied for her own internal passport, the local authorities asked her to provide them with her mother’s internal passport. Because she was not able to provide the authorities with such a document, her application was rejected orally. R. is the mother of five children, two of whom are registered under her aunt-in-law’s name because she delivered them when she herself was a minor and was afraid of the consequences of delivering them without having her own internal passport or any other personal document. As a result, she cannot prove she is the mother of two of her children and cannot exercise many of her social and economic rights, such as receiving social assistance. Regional discrepancies were also identified in cases when an applicant fails to apply for a passport in due time. While in Kharkiv it would be sufficient to provide the authorities with a written explanation of the delay, one that an illiterate Roma person would then “mark” as their own explanation with the SMS officer as a witness, in such cases in the Transcarpathia region the relevant authorities only accept explanations written by a licensed lawyer on behalf of Roma who are unable to author or sign their own explanations. Although there is no provision in the legislation for requesting a licensed lawyer in these situations, such practices in Transcarpathia prevent illiterate Roma from applying for internal passports, as it overburdens them with the need to involve a licensed lawyer. A similar practice is observed in cases of illiterate witnesses regarding access to personal documents before the SMS in the Transcarpathia region. It seems that the practice of the SMS in the Kharkiv region provides more opportunities for illiterate Roma when applying for passports and this practice should be replicated in other regions. There are more examples confirming that administrative practice is not unified nationwide. For instance, in the Transcarpathia region birth registration can be initiated by a third party, while in the Dnepropetrovsk region such applications are rejected.64 Complicated administrative procedures In addition to a lack of coherent application of administrative procedures, there is also the problem of often very complicated administrative procedures for obtaining internal passports, registering the birth of a child, obtaining the duplicate of the birth certificate after one year, or in some cases, even registering residence. Simplification of the procedures for obtaining personal documents has been singled out by this study as the main tool for improving Roma access to personal documents.65 From the interviews conducted with the NGOs providing legal aid for Roma and interviews with Roma activists, it is 64 This information was received from Volodymyr Navrotskyy, an attorney-at-law providing pro bono legal aid to Roma without personal documents and monitor of the European Roma Rights Centre. 65 Seven out of eight representatives of NGOs interviewed saw this as a priority. 28