representatives may sometimes submit an affidavit to the effect that that the applicant is stateless, but there is a lack of information available on the practice to demonstrate whether that is sufficient for a stateless person to avail of the 2-year waiver. All applicants for naturalisation must pay a €175 application fee to initiate a citizenship application. The standard certificate fee for citizenship applications is set at €950, but in the case of recognised refugees and stateless persons there is no certification fee.119 As indicated by the Minister of State at the Department of Justice in relation to a parliamentary question on the circumstances upon which fees for an application for naturalisation can be waived “The fees in relation to applications for a certificate of naturalisation are governed by the provisions of the Irish Nationality and Citizenship Regulations 2011….the standard certification fee is set at €950, while a reduced fee of €200 applies in the case of an application made on behalf of a minor or in certain cases where the application is made by a widow, widower or surviving civil partner of an Irish citizen. In the case of recognised refugees or stateless persons, there is no certification fee.”120 The Department of Justice reported that if an individual is accepted by the Minister for Justice as stateless then they will be able to avail of the certificate fee waiver. However, to UNHCR’s knowledge there has been no formal declarations of statelessness issued since 2014 so it is unclear how stateless individuals who are not officially recognised as such can successfully apply for fee waivers in practice. A legal representative in this area noted that in her experience the citizenship unit does not waive the naturalisation fees for stateless persons. In June 2021, UNHCR delivered training with the citizenship unit within the Department of Justice on the specific situation of refugees and stateless persons seeking naturalisation in Ireland. It is hoped that this training will assist the unit in their future engagement with stateless persons. Nevertheless, the application of waivers relating to the period of reckonable residency and certification fee for stateless naturalisation applications remains a challenge in the absence of a formal determination procedure. 32 119 Parliamentary question response to question no. 492 of 7 September 2018 by former Minister for Justice Deputy Charles Flanagan, available at: https://www.justice.ie/en/JELR/Pages/PQ-07-09-2018-492 120 Parliamentary question report to question 579 of 28 September 2021, by Minister of State at the Department of Justice James Browne, available at: https://www.oireachtas.ie/en/debates/question/2021-09-28/579/ Mapping Statelessness in Ireland