or unconfirmed by documents, 62 in practice this is not always the case. 63 Moreover, there is generally a lack of training for public officials on antigypsyism and specific issues faced by Roma and Egyptian communities, as well as a prevalence of stereotypical attitudes and distrust, which further hinder equal access to birth registration.64 39. In addition, the field verification carried out by UNHCR in November 2017, jointly with the Ministry of Interior and the Ministry of Labour and Social Work, mentioned under Issue 4 below, did not take into account the Roma population born in Montenegro who do not have regulated legal status and have been returned under a readmission agreement, and internally displaced persons from Serbia and Kosovo. Issue 4 – Statelessness population data 40. Collecting accurate, disaggregated data on statelessness and the risk thereof is crucial to be able to implement and review policies and developing practice, and to prevent discrimination. The State should collect reliable qualitative and quantitative disaggregated data on stateless people on its territory and procedures for determining statelessness, including by gathering, analysing, and making available statistical data and trends in relation to asylum, immigration, and statelessness, that is disaggregated by sex and age.65 41. Montenegro has undertaken some positive steps in the collection of data on the stateless population, but shortcomings also remain. In November 2017, jointly with the Ministry of Interior and the Ministry of Labour and Social Work, UNHCR carried out a field verification of all refugees from the Former Yugoslavia with unresolved status issues, including those at potential risk of statelessness. The exercise confirmed that documentation problems as a result of the dissolution of the former Yugoslavia remained widespread, particularly among Roma and Egyptian communities. Based on the results, some 605 persons were identified as being at risk of statelessness, of which at least 145 were without birth registration. After targeted follow-up following the verification, as of the end of July 2021, the number of people identified to be at risk of statelessness was 450. However, the data available through the verification exercise does not reflect all persons affected by statelessness in Montenegro. It is incomplete, does not cover the entire stateless (and at risk) population, and is not disaggregated by age, gender and other key factors. Although this verification exercise and follow up actions have improved registration levels, the verification did not take into account all groups who face issues with legal status and documentation in Montenegro. For example, the exercise overlooked the Roma population born in Montenegro who do not have regulated legal status and have been returned under a readmission agreement, and internally displaced persons from Serbia and Kosovo. A new field verification is planned for autumn 2022.66 42. Additionally, in the latest 2021 report on protection against discrimination, as in previous 62 Law on Vital Registers, Official Gazette of Montenegro, No. 047/08, 041/10, 040/11, 055/16 of 17 August 2016, Art. 18, para. 3. 63 Information gathered through casework by Civil Alliance. For more information see ENS, Statelessness Index - Montenegro at: https://index.statelessness.eu/country/montenegro. 64 Institute on Statelessness and Inclusion, European Network on statelessness and European Roma Rights Centre, Roma Belong - Statelessness, discrimination and marginalisation of Roma in the Western Balkans and Ukraine, October 2017, available at: https://www.statelessness.eu/sites/www.statelessness.eu/files/attachments/resources/roma-belong.pdf. 65 UNHCR, Global Action Plan to End Statelessness 2014-24 (2014); CEDAW, General recommendation No. 32 on the genderrelated dimensions of refugee status, asylum, nationality and statelessness of women (2014); Institute on Statelessness and Inclusion, The World’s Stateless (2014); Council of the European Union, Conclusions on Statelessness (2015). 66 For more information see ENS, Statelessness Index - Montenegro at: https://index.statelessness.eu/country/montenegro. 11