Statelessness & Citizenship Review 2020 2(1) online platform to apply for Nigerian nationality, called eCitiBiz. The eCitiBiz platform is a highly customisable and industry standard organisational operations system designed to electronically capture and pivot all aspects of the operations and work flow of the Directorate of Citizenship and Business. 108 Similar to the UK’s FLR(S) online form to apply for leave to remain as a stateless person in the UK through a UK Government website, 109 this eCitiBiz could become a tool for individuals to apply for determination as a stateless person, for nationality verification, or for a residence permit. When a determination procedure will be finally adopted, the adjustment that needs to be made to the existing eCitiBiz is to create a provision for application for leave or a permit to remain in Nigeria as a stateless person, and removal of the requirement of application fee for stateless persons. Additionally, the proposed SDP framework should allow for Nigerian officials to initiate ex officio SDP for stateless persons, as it is done for instance in Moldova, 110 this would allow for people who would otherwise not be aware of such a procedure, or indigent and uneducated applicants, to be assisted by the State. As argued above, access to the SDP should not be subject to time limits. Also, like in the current refugee status determination procedure, 111 information on the procedure and counselling services should be available to applicants. 112 Also, considering the history of gender discrimination with regards to access to nationality in Nigeria, 113 it is important for an SDP for Nigeria to clearly spell out that women shall have access to the procedure and be able to transmit their status where necessary on an equal footing with men. D Proposed Procedural Guarantees To understand the procedural guarantees for a possible SDP in Nigeria, in the current absence of an SDP it is important to examine the RSD procedure, ie, the asylum procedure. Examining the current asylum procedure is relevant because, by virtue of Action 5 of the NPA, 114 the NCFRMI, the Government’s refugee agency, is inadvertently tipped to be the lead agency for SDP in Nigeria. The agency is also in the process of drafting Standard Operation Procedures (‘SOPs’) for SDP in Nigeria. It is very likely that the NCFRMI will rely on the existing 108 See 109 110 111 112 113 114 ‘Citizenship and Business’, Ministry of Interior (Web Page) <https://interior.gov.ng/citizenship-and-business/>. ‘Application to Extend Stay in UK as Stateless Person: Form FLR(S)’, GOV.UK (Web Page) <https://www.gov.uk/government/publications/application-to-extend-stay-in-uk-asstateless-person-form-flrs>. See Law No 200 of 16.07.2010 on the Regime of Foreigners in the Republic of Moldova (Republic of Moldova) art 871(1). (‘Moldova Foreigners Regime’). See above Part III. NCFRMI Act (n 92) pt V. See Good Practices Paper — Action 6 (n 38) 5; NCFRMI Act (n 92); and the suggestion in Part III(D) above. Nigerian women are unable to transmit their nationality to their foreign husbands as Nigerian men would to their foreign wives. Men married to Nigerian women must wait for 15 years before they qualify to apply for naturalisation as opposed to women married to Nigerian men who are almost immediately able to register as Nigerian citizens. See the Constitution of The Federal Republic of Nigeria 1999 (Nigeria) ss 26(2)(a), 27 (‘Nigerian Constitution’). The NCFRMI was made the focal agency to ‘review the existing national framework in order to mandate a State agency responsible for the determination of stateless persons and the protection of stateless persons’: NPA (n 93) 16. 105