States parties to the ECN have substantive and procedural obligations beyond those established by the 1961 Convention. Notably, Article 7(3) of the ECN forbids provisions for the loss of nationality if persons concerned would thereby become stateless, even where there is no “genuine link between the State Party and a national habitually residing abroad”.68 Additionally, Chapter IV of the ECN sets forth a number of procedural safeguards and requirements that apply to all matters relating to nationality: applications must be processed in a timely manner (Article 10); decisions must be issued with accompanying reasons in writing (Article 11); there must be access to judicial or administrative review (Article 12); and fees must be reasonable and not an obstacle for applicants seeking review (Article 13). Sample laws and good practices From the point of view of avoiding statelessness, a general good practice for States is simply to avoid establishing or applying grounds for loss of nationality ex lege. A number of States do not provide for loss of citizenship at all, minimizing the risk of statelessness resulting from mere unawareness about the requirements applicable – to register with national authorities while residing abroad, for example. Other States retain provisions on ex lege loss of nationality but still provide a full safeguard against statelessness. The Nationality Act of Finland, for example, provides for loss of Finnish nationality by dual nationals who at age 22 lack a sufficient connection with the country. Persons are deemed to retain a sufficient connection if they give “notice in writing to a Finnish diplomatic mission, or a consulate headed by a career consul or the Register Office, of his or her wish to retain Finnish citizenship”.69 Importantly, the law compels national authorities to maintain a “population information system” with the addresses of all Finnish citizens reaching the age of 18 years “so that they can be reached” and “given instructions on how to retain citizenship when reaching the age of 22 years”. In addition, “[i]f a person has lost Finnish citizenship when reaching the age of 22 years because he or she has not had a sufficient connection with Finland, the Register Office will make an entry to that effect in the population information system and so notify the party of this if his or her address is available”.70 Such a regulation follows the object and purpose of the 1961 Convention and conforms to the Final Act on the Elimination or Reduction of Future Statelessness.71 68 69 70 71 26 ECN, Art. 7(1)(e). Nationality Act (359/2003), 359/2003, 1 June 2003, Section 34, available at: www.refworld.org/docid/3ae6b51614.html. Ibid., Section 37 – 38. Final Act of the United Nations Conference on the Elimination or Reduction of Future Statelessness, Resolution III, supra.