amended so as to ‘ensure their full conformity with the Convention, including through the removal of requirements that may have punitive or discriminatory impacts on certain groups of children’.10 The requirement to provide parents’ identity documents is an important aspect of ensuring the integrity of birth registration mechanisms. However, it is submitted that the Draft Regulations must to reflect the reality faced by both foreigners and South Africans. South African citizens might face issues with their identity documentation such as ‘blocked IDs’ in which cases the registration of their child’s birth would not be possible.11 The requirement of a valid passport and visa or permit in South Africa is onerous and also does not reflect realities on the ground or best international practices. The closures of Refugee Reception Offices across South Africa – the office at which asylum applications are lodged and asylum seeker permits are granted and extended - has made access to the asylum system extremely difficult for many asylum seekers. Asylum seekers have been forced to take regular, lengthy journeys to extend their asylum seeker permits. This leads to a situation in which many asylum seekers' permits expire, leaving them undocumented and in a vulnerable position.12 For individuals who have visas issued under the Immigration Act (No 13 of 2002), obstacles also prevent many from maintaining valid documentation including delays in the issuance of permits, administrative errors, requirements to lodge applications from their country of origin, and high fees charged by VFS. There are a number of reasons why people fall into undocumented status in South Africa. This does not only affect foreign nationals only as even South African citizens often lack identity documentation.13 This framework therefore inhibits the rights of a child to a nationality. Without a birth certificate, access to their basic rights – such as education and health – is jeopardised. Put simply, the framework envisioned is likely to create a sizeable population of stateless people in South Africa, presenting challenges to both South Africa in the near future as well as for neighbouring states. 10 UN Committee on the Rights of the Child (CRC), Concluding observations on the second periodic report of South Africa, 27 October 2016, CRC/C/ZAF/CO/2, at paragraph 32(a). Available at: http://www.refworld.org/docid/587ce86b4.html. 11 See for example, Liesl Muller, ‘ID Blocking – A Growing Threat to Nationality,’(September 2013) http://www.lhr.org.za/blog/2013/9/id-blocking-growing-threat-nationality. See also: ‘No end in sight for man’s seven-year wait for ID,’ Berea Mail (4 September 2017). Available at: https://bereamail.co.za/116360/no-endin-sight-for-mans-seven-year-wait-for-id/. 12 Ra'eesa Pather, ‘Cape Town refugees in Limbo: "You can't stay here without your paper" ’, The Daily Vox (2 July 2015). Available at: https://www.thedailyvox.co.za/cape-town-refugees-in-limbo-you-cant-stay-herewithout-your-paper/. 13 Siri Linn Brandsoy, ‘They were never born on paper’, Mail & Guardian (December 2010). Available at: https://mg.co.za/article/2010-12-13-they-were-never-born-on-paper. 6