agencies, and in many, the SDP cannot be initiated ex officio by the authorities. Furthermore, there is no evidence of routine referrals to SDPs from immigration detention. In Ukraine and the United Kingdom, a lack of coordination and cooperation between government agencies coming into contact with stateless people has been raised as a concern. Good practice: Flexible access to the SDP in KOSOVO In Kosovo, the examination of applications is conducted centrally by the Division of Citizenship under the Department for Citizenship, Asylum and Migration of the Ministry of Internal Affairs. Instructions on how to make an application are available online. Applications can be made orally or in writing through a simple form. The form and interpreting are available in three languages. Applicants must submit all available evidence, although authorities often request documents from other institutions on their own initiative to complete the application. There is an obligation on the authorities to consider applications, and they may initiate the procedure ex officio (although this option has never been used). There is no fee, lawful stay requirement, nor time limit to access the procedure. There is cooperation between the competent authority, UNHCR, and civil society to refer cases for statelessness determination. 3.4. Assessment of applications recommended Best practice • • • • • The burden of proof is shared between applicant and examiner, taking into consideration the difficulties inherent in proving statelessness. The standard of proof is the same as in asylum procedures (‘reasonable degree of likelihood’), in keeping with the humanitarian objective and inherent difficulties of proving statelessness in the likely absence of documentary evidence. Measures are in place to guarantee substantive equality for women, children, LGBTIQ+ people, and other groups at risk of discrimination in procedures. State follows the principle of pursuing the best interests of the child. Clear guidance is available to determining authorities, including accurate and reliable country of origin information relating to statelessness. There is no evidence of significant errors in decision-making. The assessment of SDP applications must be fair and non-discriminatory. This means ensuring fair evidentiary requirements, implementing measures to prevent discrimination against disadvantaged groups, and providing clear guidance, including accurate and reliable country of origin information relating to statelessness, to support high-quality decision-making. As statelessness determination requires a mixed assessment of fact and law, all available evidence should be considered, including about the applicant’s personal history, the nationality laws of relevant countries, and their implementation in practice.32 Evidence can be both oral or written and could include testimonies from the applicant or members of the community, responses from foreign authorities about the nationality status of the applicant, country of origin information, information provided by UNHCR, identity and travel documents (even if expired), documents relating to nationality applications, school and medical certificates, or identity documents from family members.33 Enquiries should be limited to States with which the applicant has a relevant link, especially through birth on the territory, descent, marriage, adoption, or habitual residence.34 States must take into account the primacy of any asylum claim and should never contact the

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