lack of registration.18 Overly complex and bureaucratic civil registration procedures constrain the realisation of individual rights in practice. While the entire population is affected, marginalised communities and minorities are disproportionately impacted.19 30. Persons who are undocumented and unregistered face additional barriers in securing the registration of births of their children. This is particularly so in cases where the mother of the child is deceased or has abandoned her child or has no personal documents; children are born outside hospitals; mothers use another person’s health cards to access maternity care; or late registrations as adults (over 18 years) are pursued. 31. Further, if the mother of the child is unregistered the child as well cannot be registered until the mother obtains a birth certificate and an ID card or residence permit, if she is a foreigner or a stateless person. 32. This is the core problem regarding birth registration. There are no legal provisions stipulated in the Law on Records of Births, Deaths, and Marriages20 that deal with such cases and the registry officers do not know how to record the children that are in such situations, and thus do not adopt an official decision. The Roma are disproportionately impacted, further entrenching their disadvantage and risk of intergenerational statelessness. 33. The lack of birth registration for children who are born at home is another concern. This is usually due to women not possessing personal identification documents and health insurance, thus being unable to access maternity and reproductive healthcare. In these cases, the authorities usually insist on DNA analysis to prove the relationship between mother and child. However, obtaining DNA analysis is intrusive and expensive and many of the families affected live in extreme poverty, without steady incomes and cannot afford the procedure. The Ministry of Labour and Social Policy covers the fees for 20 to 40 DNA analyses per year, but this is not a systematic or sustainable solution to the inability of many undocumented Romani women in Macedonia to access their rights to maternal and reproductive healthcare. 34. All of these problems make the procedure for additional inscription in the civil records very lengthy (in some cases several years), expensive (a lot of evidence is required, especially an expensive DNA analysis) and thus inaccessible for many. Evidence from the Roma Belong report demonstrates how Roma in Macedonia are disproportionately affected by these barriers to civil registration due to marginalisation and discrimination, with the impact being that the risk of statelessness is perpetuated from one generation to the next, and many unregistered children do not have access to basic rights - above all, the right to citizenship, and then to education, health care, social welfare, and other rights.21 35. In this way, the services for civil records, particularly the Directorate for Keeping Records of Births, Deaths and Marriages (the Directorate) violate the basic rights of unregistered persons – including Roma - in the Republic of Macedonia. 18https://index.statelessness.eu/country/macedonia 19Roma Belong: Statelessness, Discrimination and Marginalization of Roma in the Western Balkans and Ukraine available at: http://www.errc.org/uploads/upload_en/file/roma-belong.pdf, page 53 20Law on Records of Births, Deaths, and Marriages (Official Gazette of the Republic of Macedonia No.8/1995 from 15.02.1995) 21 Roma Belong: Statelessness, Discrimination and Marginalization of Roma in the Western Balkans and Ukraine available at: http://www.errc.org/uploads/upload_en/file/roma-belong.pdf. 8