Remaining gaps and shortcomings in the national legislation and practice The Government’s pledge reiterates the need for review of the national legislation and practice on statelessness and bring them into compliance with the 1954 and 1961 Conventions. A draft Law on Statelessness was developed in 2013, but in 2016 the Government returned the draft to the Police, which is currently in charge of statelessness issues, with a recommendation to incorporate it into a general Law on Foreigners and Stateless Persons. A new draft Law on Foreigners and Stateless Persons was circulated in 2017, and since then it has been pending adoption. UNHCR recommends prioritizing the adoption of the draft Law on Foreigners and Stateless Persons to bring it in accordance with the 1954 Convention. The statelessness determination procedure is not properly defined and regulated in the national legislation and conducted by the Police on an ad-hoc basis, mainly in case of an otherwise stateless child born in Armenia. The absence of clearly defined procedural standards and safeguards12 may result in shortcomings in the implementation of the statelessness determination procedure and may lead to a situation when stateless persons are not systematically and individually identified, a decision-making process is not fair and efficient, and access to rights and services and protection of stateless persons are not guaranteed. Consequently, these people remain legally invisible and are not granted the rights they are entitled to. UNHCR recommends and is ready to support the Government with the establishment of a fair and efficient Statelessness Determination Procedure in accordance with international standards and authoritative guidance provided in the Handbook on Protection of Stateless Persons.13 There is limited information available about the number, geographic locations and profile of stateless persons, persons at risk of statelessness and undocumented persons in the Republic of Armenia. The 2011 Population Census did not fully cover statelessness issues and did not provide comprehensive data on undocumented and stateless persons. As a result, it did not shed light on the number and profile of the stateless population and their geographical location. At present, UNHCR is in contact with relevant state agencies (the Statistical Committee, the Police, the Migration Service, etc.) to promote and advocate for an effective use of the upcoming census exercise and inclusion of statelessness-related questions to be able to collect data on statelessness. In addition, information on the registered stateless persons has not been regularly verified and does not provide up-to-date data on this population. In the absence of a comprehensive mapping assessment of this population, there is limited information on the nature and scope of the problem, and reasons of statelessness. In this regard, there is the need for development of effective mechanisms for identification and/or verification of the stateless population and establishment of a more formal, systematic methodology for information gathering, updating and sharing. UNHCR recommends strengthening of systematic and disaggregated data collection/verification on the number, geographic locations and profile of undocumented, at risk of statelessness and stateless persons, promote inclusion and coverage of the stateless population during the upcoming population census, and stands ready to support the Government with a comprehensive mapping assessment on stateless persons. In 2019, the Government has circulated the draft amendments to the Law on Citizenship, introducing additional procedural safeguards in case of renunciation of Armenian citizenship. UNHCR expects that as per the standard on renunciation specified in Guidelines on Statelessness No 5, after the adoption of the bill, the risk of becoming stateless, if the 12 13 Ibid 3. Ibid 3. 3