evident that these respondents perceive the procedures for birth registration (including obtaining the duplicate of a birth certificate) and the issuing of internal passports as very complicated for most Roma without personal documents. According to the information collected from the regional representatives of the SMS and the Department of State Registration, the application procedure is the same for everybody and need not be made more flexible for those who are in a vulnerable situation due to illiteracy, lack of legal aid or poverty. Representatives of the relevant state authorities said that in order to be provided with personal documents, all Roma “just” need to meet the prescribed criteria. This difference in perception demonstrates that there is a lack of understanding among state authorities of the problems Roma face in accessing their personal documents in Ukraine. Complex administrative procedures are mostly visible in cases where children are not registered in birth registry books. Under the existing law, identification of a child’s parents is a crucial aspect of the procedure for birth registration. The parents who want to register the fact of birth of their child need to possess internal passports. This reportedly prevents some Roma women from registering their children, as they cannot provide their own internal passports. According to information from local lawyers providing legal aid to Roma without personal documents, registration offices have refused to accept applications initiated by mothers without personal documents, alleging that in such cases the record would lack information about the mother’s citizenship66 and would consequently leave their children without the citizenship that should be acquired at birth.67 In some cases of late birth registration, registry offices refuse to register the fact of the birth even in a situation when an applicant is able to provide the office with a duplicate of the medical certificate issued by the hospital. In these cases applicants are told the courts must establish the fact of the birth. Court procedures are costly,68 particularly for the most impoverished Roma. Also, in practice, court proceedings take more time than the administrative procedure for late birth registration does. Another challenge observed is related to the procedure for issuing a duplicate birth certificate. If already-registered applicants older than 18 have no personal documents and no contact with their parents, they cannot obtain duplicate birth certificates, because without personal documents the registry office cannot identify applicants and provide them with the document necessary for further administrative procedures. This practice traps applicants in a vicious cycle and leaves them without remedy to acquire their personal documents: Without proof of birth registration, 66 Law on Citizenship of Ukraine, op. cit., note 37. According to Article 6 of this Law, the citizenship of Ukraine is acquired: (1) by birth; (2) by territorial origin; (3) as a result of [legal procedures] granting citizenship; (4) as result of renewal of citizenship; (5) as a result of adoption; (6) as result of guardianship or custody, in the case of a minor; (7) as a result of guardianship/custody appointed for a person recognised as incapable by a court of law; (8) due to a minor's one or both parents being citizens of Ukraine; (9) as a result of filiation; (10) due to other reasons envisaged by international treaties to which Ukraine is a party. 67 “Birth Registration”, European Network on Statelessness, <https://www.statelessness.eu/resources/birthregistration-and-statelessness>. 68 Please see subsection “Financial aspects of administrative and court procedures for obtaining personal documents” of this report. 29