burden of proof, the standard of proof should be reduced and applicants should be offered an individual interview.28 Moreover, information and counselling about the procedure should be widely disseminated in order to facilitate access to the procedure.29 Additional procedural and evidentiary safeguards for child applicants should be put in place, including ‘priority processing of their claims, provision of appropriately trained legal representatives, interviewers and interpreters as well as the assumption of a greater share of the burden of proof by the State’.30 Government officials who may come in contact with stateless persons through their regular work (for example, social services or immigration control) should be trained to identify potential applicants and should refer them to the determination procedure.31 Finally, authorities involved in the identification of stateless persons should be provided with training on statelessness and the human rights of stateless persons. 46. Although the legislation of the Republic of Macedonia does not establish such a procedure for determining stateless status, in practice, the Ministry of Interior, when regulating the residence and issuing a temporary residence permit enters the signifier ‘xxx’ in the citizenship section of those it deems to be stateless. This serves as a confirmation that the person does not have citizenship. 47. Article 7A of the Law on Citizenship provides the possibility of facilitating the naturalisation of stateless persons, by reducing the required residence and other criteria for stateless applicants. For example, the standard requirement of eight years of legal and uninterrupted residence on the territory of Macedonia, is reduced to six years from the moment of determining stateless status. Under this procedure, persons with “xxx” on their residence permit are eligible for simplified naturalisation. However, in order to fulfil this condition, they must provide proof of accommodation and financial support in Macedonia. Financial support is understood as employment or support from a member of their household who is a Macedonian citizen and in employment or in receipt of social security payments. Accommodation must be proven through proof of ownership or a notarised lease agreement. These requirements are extremely difficult to meet for Roma who are marginalised, face very high unemployment rates and discrimination, often live in informal settlements, and have limited rights to employment based on temporary residence permits (usually valid for only one year). Recommendations 48. Based on the above information, the co-submitting organisations urge reviewing States to make the following recommendations to Macedonia: I. II. Ensure that all international and regional obligations related to the right to nationality, prevention of statelessness, protection of stateless persons, non-discrimination, and birth registration are fully incorporated into national law and implemented in practice. Consider nominating a dedicated lead with responsibility for protecting the rights of Roma whose mandate includes, as part of the eradication of discrimination, the reduction and 28 Ibid, paras. 71, 89-93. Ibid, para 68; UNHCR, Good Practices Paper – Action 6, p. 5. 30 UNHCR, Statelessness Handbook, para 119. 31 UNHCR, Good Practices Paper – Action 6, p. 4. 29 11