obstacles to birth registration and access to documents for the Roma population and remove those constraints; particular emphasis will be placed on registering new-born children. In 2019, Praxis also identified some practical issues. 23 Data collected by this NGO indicate that amendments to the Law on Non-Contentious Procedure have largely contributed to the reduction of the number of legally invisible persons, there remain obstacles in its implementation. The key issue here concerns lengthy procedures for establishing date and place of birth: even though the law requires this process to be completed within 90 days from application, the time limits are often exceeded. Additionally, applicants are frequently ordered to pay court fees, even though the law exempts them from having to pay procedural costs. As has already been discussed, amendments to the Law on Permanent and Temporary Residence have to a large extent resolved issues with residence registration of those living in informal Roma settlements. That being said, individuals already registered elsewhere are denied access to this option, even though they have been living away from their formal place of residence for years. This problem especially affects IDPs from Kosovo and Metohija who now reside at addresses where they cannot register permanent residence. An additional issue identified at two of the five local authorities interviewed involves CSWs. Here, the residence registration procedure requires the local police station to send the residence registration form to the appropriate CSW for verification, which in effect means the CSW approves registration. In some communities, however, the CSWs are reluctant to follow this rule and refuse to verify registration forms, primarily due to limited human resources at the CSWs and the resulting belief they will not be able to meet the needs of the new beneficiaries. Such behaviour is contrary to instructions from the Ministry of Labour, Employment, Veterans’ and Social Affairs, which requires CSWs to approve registrations of residence. It seems the situation has improved since the enactment of the Law on Permanent and Temporary Residence, but inconsistencies remain that indicate a need to continue raising awareness of social workers and improving CSW capacities. The local authorities that took part in the Survey claimed they were investing efforts to ensure persons at risk of statelessness understood the importance of having a complete set of personal documents. All local authorities agreed that there was often limited awareness of the requirement to register children at birth, have a personal identity card, or register permanent residence, and that this was driven by a variety of factors, including illiteracy, language barriers (especially in Bujanovac), fear, and mistrust of Government bodies amongst the Roma, Ashkalis, and Egyptians. (The local governments’ staff interviewed agreed that the Roma community was highly mistrustful of the authorities.) Most local authorities’ actions are pursued in the field, in direct contact with individuals who live in informal settlements. All five local authorities felt cooperation with national institutions to address issues of RAE individuals at risk of statelessness was good, 23 Praxis, Review of the remaining obstacles in exercise of the right to birth registration, acquisition of citizenship and permanent residence registration, 2019, available at: https://www.praxis.org.rs/images/ praxis_downloads/Review_of_the_remaining_obstacles.pdf 50 PERSONS AT RISK OF STATELESSNESS IN SERBIA OVERVIEW OF CURRENT SITUATION AND THE WAY FORWARD

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