regional courts. Legal practitioners and civil society organisations report several such errors in Bulgaria, Hungary, Spain, and the United Kingdom, for example. A common error in several countries relates to the treatment of stateless Palestinians. Palestinians who do not hold the nationality of another country should be considered stateless. However, as research has shown, 45 there are divergent approaches across Europe, often based on a lack of statelessness-related expertise and information about the situation in UNRWA’s areas of operation, the validity of travel and residence documents, and the incorrect assumption that the recognition of Palestine as a State has an influence on the status of Palestinians as stateless. This leads to inconsistent decision-making by competent authorities and courts.46 There is developing jurisprudence in regional and national courts on this issue. For example, in June 2024 the CJEU held that stateless Palestinians should be granted refugee status if UNRWA protection is believed to have ceased.47 In Hungary, the practice of the authorities of rejecting applications by stateless Palestinians on the grounds that Palestine is recognised as a State by the United Nations has been challenged in court. Applications for statelessness status by Palestinians in Bulgaria are reportedly automatically rejected on similar grounds. Swiss courts have restrictively interpreted the 1954 Convention as excluding Palestinians from protection in certain circumstances. 3.5. Procedural safeguards recommended Best practice • • • • • • • • (Free where available) legal aid is offered to all applicants on the same basis as asylum applicants. Applicants have the right to an individual interview. Applicants have the right to (free) interpreting and translation. Quality assurance audits of the procedure are undertaken. Access to UNHCR is guaranteed as a safeguard in the procedure. Decisions are given in writing with reasons. There is a time limit for decisions, and it is no more than six months (except in exceptional circumstances where it should be no more than 12 months). Referral mechanisms are in place including cross-referral between asylum procedures and the SDP. There are several minimum procedural safeguards that must be provided for in an SDP. Applicants should be offered free legal aid, interpreting, and translation services on the same basis as asylum applicants. They should have the right to an individual interview and necessary assistance to ensure they can present their situation and clarify any questions material to their application. 48 In particular, for child applicants, there should• be child-rights-based adaptations and procedural safeguards in place, including ex officio initiation of the •SDP,Referral prioritisation in the processing ofincluding claims andcross-referral provision of adequately trained legal representatives, mechanisms are in place between asylum procedures and the 49 interviewers, guardians and interpreters (where appropriate). The determination should be carried out SDP. expeditiously and decisions issued in writing within an established, reasonable time limit of no longer than six months (or twelve months in exceptional circumstances). 50 There should be a mechanism for cross-referral between the SDP and asylum procedures (giving primacy to the asylum claim), and procedures to recognise or grant nationality, should an entitlement to nationality become apparent during the procedure. The SDP should be subject to regular quality-assurance audits and UNHCR should be guaranteed access to the procedure as an additional safeguard.