UNHCR, Statistical Reporting, and the Representation of Stateless People 79 that states may misuse data and personal information.39 As noted elsewhere, there is a long history of states’ culpability in the creation of stateless people.40 Third, while recognizing that “a formal definition of a person with undetermined nationality does not exist,” UNHCR has changed its terms of measurement from one year to another: “UNHCR previously also reported on de facto stateless populations but discontinued doing so in mid-2019 based on an assessment that de facto statelessness was often incorrectly used to refer to people who meet the statelessness definition in the 1954 Convention and who should, therefore, be reported as such.”41 This inconsistency makes longitudinal and comparative analysis especially problematic. Fourth, the presentation of figures raises additional queries about coverage. As the Center for Migration Studies (CMS) found in their 2020 study of statelessness in the United States, the net used by UNHCR misses a large number of people who are stateless or potentially at risk of statelessness. Rather, drawing upon different datasets, including the American Community Survey (ACS) data, they maintain that the population of stateless people is both more diverse and significantly larger than UNHCR assumes.42 There is also a lack of published statistics for countries that have experienced major refugee flows and that have historically hosted stateless groups. Most importantly, there are no data for large refugee-hosting states and countries that have significant internal migration, such as Pakistan, South Africa, and Uganda. There is no information on other countries that previously were reported to have stateless populations such as Nepal, where the US government reported that an estimated six million individuals lacked citizenship documentation.43 There are even gaps in reporting on states that have introduced statelessness determination procedures; there should be some reliable information, for example, for Switzerland. In other cases, these figures are bizarrely low.44 For example, Egypt, a country with a population of more than 100 million, which has been home to 39 See Economic Commission For Europe, Difficult To Measure Census Topics: Measuring Statelessness through Population Census, Conference of European Statisticians, U.N. Doc. ECE/CES/AC.6/2008/SP/5 (May 13, 2008), https://unstats.un.org/unsd/censuskb20/Attachm ents/2008UNHCR_ECE-GUIDe59366dbdf874942bae645a8b8319128.pdf, p. 4. 40 See B. K. Blitz and M. Lynch (eds.), Statelessness and Citizenship: A Comparative Study on the Benefits of Nationality (Cheltenham, UK: Edward Elgar Publishing, 2011). 41 Ibid. 42 The CMS authors argue that some 218,000 people are at risk of statelessness in the United States. See D. Kerwin, D. Alulema, M. Nicholson, and R. Warren, “Statelessness in the United States: A Study to Estimate and Profile the US Stateless Population” (2020) 8(2) Journal on Migration and Human Security 150–213. 43 U.S. Department of State, 2019 Country Reports on Human Rights Practices: Nepal, Bureau of Democracy, Human Rights, and Labor (2020), www.state.gov/reports/2019-country-reports-onhuman-rights-practices/nepal/. 44 The UNHCR tool, the “Refugee Data Finder,” www.unhcr.org/refugee-statistics/download/? url=U3cg, provides “information on displaced and stateless populations, including their demographics. The database also reflects the different types of solutions for displaced populations.” https://doi.org/10.1017/9781108914994 Published online by Cambridge University Press