implementation of the existing legislation, this could also be impeding access to personal documents among Roma. For example, even though the Law of Ukraine on State Support of Families with Children60 provides individuals without registered residency the opportunity to register their residence at the address of a local homeless centre, in the Transcarpathia region this practice is still not in place. In some cases in Transcarpathia, Roma women with children are reluctant to register their residence at homeless people’s centres, as the administration of one homeless centre allegedly informs them that children cannot stay with a homeless mother and must instead be sent to special education institutions. It has been reported that this deters Roma women with children from registering any place of residence and consequently prevents them from applying for passports for either themselves or their children. Furthermore, it is observed that Roma in the Transcarpathia region cannot register their residences because they live in informal settlements (tabors) or other forms of informal housing. Most Roma visited in this region reported that their biggest challenge is to register their residence.61 Another concerning practice reported by civil society in the Odesa region is that in some cases the SMS applies internal procedural rules, the content of which is not available to the general public.62 This practice is clearly not in accordance with well-established standards of interpreting the European Convention on Human Rights and Fundamental Freedoms with respect to the socalled standard of “lawfulness” of national law. This standard requires that all national laws “whether written or unwritten, be sufficiently precise to allow the citizen – if need be, with appropriate advice – to foresee, to a degree that is reasonable in the circumstances, the consequences which a given action may entail”.63 Moreover, in cases where local authorities find a way to ease administrative procedures and to be more flexible in cases when Roma without personal documents apply for internal passports, those practices are not yet being broadly replicated in other regions or districts. For example, in Beregovo in the Transcarpathia region, local Roma from the tabor are officially recognised as inhabitants of a “separate settlement”, which provides them with the opportunity to register their residence and to apply for social assistance and access other services. 60 Verkhovna Rada of Ukraine, Law of Ukraine on State Support of Families with Children, Law No. 2811-XII, 21 November 1992, <http://zakon3.rada.gov.ua/laws/show/2811-12/print1489007495067300>. 61 For example, in Telmana Street in Uzhgorod, a Roma tabor with approximately 800 inhabitants, local Roma mediators stated that at least 60 per cent of Roma from this settlement experience problems with the registration of their residence. Interview with local Roma mediator on 18 March 2017. 62 Information from the meeting with the NGO 10th of April, Odesa, 28 March 2017. 63 See Case of Baranowski v Poland, Application no 28358/95, Judgment of 28 March 2000, para. 52. See also Case of Steel and Others v the United Kingdom, Judgment of 23 September 1998, Reports 1998-VII, p. 2735, para. 54, Case of S.W. v the United Kingdom Judgment of 22 November 1995, Series A no. 335-B, pp. 41–42, paras. 35–36, and, mutatis mutandis, the Case of the Sunday Times v the United Kingdom (no. 1), Judgment of 26 April 1979, Series A no. 30, p. 31, para. 49, and the Case of Halford v the United Kingdom, Judgment of 25 June 1997, Reports 1997-III, p. 1017, para. 49. Ukraine is party to the Convention as of 11 September 1997. 27