but emphasised the need for continuing joint activities and raising awareness amongst the RAE population of the importance of personal documents. Some local authorities are also working closely with NGOs (such as Bujanovac, Obrenovac, and Kostolac) and the UNHCR. Urban municipalities (in Belgrade and Požarevac) are primarily relying on their respective city/town administrations to serve as intermediaries whilst they benefit from this collaboration. The key NGO in this field is Praxis, as has been noted above. Huge progress has been made in addressing the issue of legally invisible persons since 2011. At that time, there were thousands of persons at risk of statelessness, with numbers in some local authority areas ranging from dozens to hundreds (such as in Bujanovac). The situation has now greatly improved, and the local authorities claim that the figures range from fewer than ten (as in Kostolac, Obrenovac, and Leskovac) to several dozen (in Southern Serbia and some parts of Belgrade). The NGOs surveyed also noted problems with application of the General Administrative Procedure Law, which requires authorities to use official channels to obtain the documents they need to substantiate an individual’s identity. The law is applied properly in most cases, but at times civil servants will ask applicants to collect the documents themselves, alleging this will accelerate the process. (This issue was reported by both the A11 Initiative and some local authorities, such as Kostolac.) The Roma population is the most severely affected by such behaviour as their poor finances prevent them from obtaining a variety of documents (as this requires paying fees and, in some cases, travelling to one’s place of birth). Three of the five local authorities interviewed (Leskovac, Obrenovac, and Čukarica) have established free legal aid services. The local governments claimed no legally invisible persons had applied for assistance, and that most petitions involved Roma individuals seeking help with housing and education. Kostolac Municipality relies on the free legal aid service of its parent town, Požarevac, and the resulting expense of having to travel to town has constrained access for the most vulnerable and poverty-stricken groups, who are also most at need of free legal aid. A solution for this situation was found in co-operation with an NGO that has hired a lawyer to help the most vulnerable individuals once a week at the local Roma Office. The NGOs, by contrast, reported that the Free Legal Aid Law does not regulate this area appropriately and that staff of local free legal aid services, and especially law practitioners, lack experience in working with undocumented persons. As many legally invisible persons are also illiterate, in some cases the complex procedures and requirements for filing applications in writing using specific forms preclude access to legal aid for persons at risk of statelessness, or these individuals require legal advice before they can even access free legal aid. Internally displaced persons from Kosovo and Metohija are a particularly vulnerable sub-group of the Roma, Ashkali, and Egyptian community, both generally and in terms of their risk of statelessness. According to the MoI and CSOs, the position of IDPs is especially difficult as civil registers for some parts of Kosovo have been destroyed or are missing or unavailable to Serbian authorities, requiring the authorities to reconstitute these records and re-register individuals. Even though these civil registers have now been reconstituted to a large extent and the situation is much better than before 2010, some persons have failed to provide documents to substantiate re-registration. Internally displaced persons encounter multiple problems when registering permanent residence. The Government Order on assessing compliance with requirements for issuance of passports to individuals in the territory of the Autonomous Province of Kosovo and Metohija requires PERSONS AT RISK OF STATELESSNESS IN SERBIA OVERVIEW OF CURRENT SITUATION AND THE WAY FORWARD 51