reports, the Protector of Human Rights and Freedoms of Montenegro again emphasised “the need to establish and operationalize a standardized data collection system related to this area and provide access to the Protector for a comprehensive analysis of the situation in the field of discrimination”.67 43. Despite the Law on Foreigners requiring records on stateless people to be held electronically, these are still only held in handwritten files, making it difficult to access data.68 Recommendations 44. Based on the above information, the co-submitting organisations urge reviewing States to make the following recommendations to Montenegro: I. Take concrete steps to facilitate access to the statelessness determination procedure for all stateless persons in Montenegro, regardless of their residence status, and ensure its implementation is harmonised across the territory and in line with UNHCR guidance and good practice. II. Amend the Law on Foreigners to allow for persons recognised as stateless to be automatically granted a residence permit and all rights protected under the 1954 Convention relating to the Status of Stateless Persons. III. Ensure that policies and practices relating to birth registration take into account UNHCR guidelines and good practice and remove all practical barriers to birth registration, with a particular focus on minority groups including Roma and Egyptian communities, so that all children are registered immediately regardless of their parents’ documentation or residence status. IV. Ensure that children’s nationality status is determined as soon as possible after birth in order to ensure that otherwise stateless children born in Montenegro acquire a nationality. V. Provide training and capacity building to frontline civil registry officials to address discriminatory and stereotypical attitudes and take steps to build trust between the authorities and Roma and Egyptian communities to facilitate access to essential services including civil registration. VI. Improve the recording of statelessness, namely by harmonising quantitative data on stateless persons and those at risk of statelessness, ensuring that statistical data covers the entire population affected by statelessness, and publish annual reliable, transparent, disaggregated and comparable statistics on statelessness determination. 67 Report on Protection against Discrimination from the Point of View of the Institution of Protector of Human Rights and Freedoms of Montenegro for the period 1 January - 31 July 2021, November 2021, Podgorica, page 40, available at: https://www.ombudsman.co.me/docs/1639560831_final_08122021_polugodis--nji%20izvjes--taj%20o%20zas-titi%20od%20diskriminacije%2022112021-1.pdf. 68 Report on Protection against Discrimination from the Point of View of the Institution of Protector of Human Rights and Freedoms of Montenegro for the period 1 January - 31 July 2021, November 2021, Podgorica, page 40, available at: https://www.ombudsman.co.me/docs/1639560831_final_08122021_polugodis--nji%20izvjes--taj%20o%20zas-titi%20od%20diskriminacije%2022112021-1.pdf. 12