is a safeguard in the law permitting a decision to be made based on available documentation). In Bulgaria, the competent authority is reported to discontinue the SDP if applicants do not provide certain documents within a very short timeframe (usually three days). In France, applicants must submit a specific written form in French accompanied by two recent photographs and sometimes other documentation. Such requirements hinder access to SDPs and could prevent people accessing the protection they are entitled to due to the nature of their statelessness, which can mean they cannot access certain documents or forms of identity. Lack of information, language barriers and complex procedures Language barriers are an issue in most of the countries analysed. In Bulgaria, France, Italy, Latvia, Spain, Switzerland, Ukraine, and the United Kingdom, applications must be made in an official language. In Bulgaria and Switzerland, the application can also be made in another language accompanied by a certified translation, but may result in significant cost to the applicant. Another common challenge is a lack of information about how to access and apply for statelessness status. In Bulgaria and Switzerland, the authorities do not provide information about how to apply under the SDP, although UNHCR and civil society have published resources to assist stateless people or their lawyers in submitting an application. In France, information is only available online and detailed guidance is only in French. Similarly, in Latvia information is only provided in Latvian, although it can be accessed both online and by phone. In the United Kingdom, the SDP application form is long and complex and only available in English. Similarly, in Spain, the application form is only available in Spanish and contains complex legal questions with limited space provided for answers.44 Ex officio initiation and cooperation between agencies In most countries, it is left to affected individuals to initiate the SDP on their own behalf, which is particularly problematic considering the lack of information about procedures and how to apply. Many stateless people are unaware of the existence of an SDP or may fear approaching public authorities. Stateless women, children, people with disabilities, older people, marginalised and minoritized groups are particularly disadvantaged in such circumstances if State authorities do not put measures in place to guarantee substantive equality of access to procedures and protection. In Bulgaria, France, Hungary, Italy, Latvia, Switzerland, and Ukraine, the SDP cannot be initiated ex officio by the authorities, and in Spain and the United Kingdom ex officio initiation is possible but is rarely used in practice. Few countries have formal mechanisms for referral or cooperation between agencies.

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