law provides that detention should be a last resort, but in practice irregular migrants are almost automatically subject to removal and detention orders upon identification. Some procedural safeguards are in place, but these are often not implemented in practice. For example, the law provides that detainees must be informed in writing of the reasons for detention, but in practice this is given in Bulgarian only and interpreters are rarely present, so there is a lack of awareness about legal aid and available remedies. People released from detention are not routinely issued with documentation and have no access to other rights. Protecting the Right to a Nationality - Prevention and Reduction of Statelessness 21. Bulgaria has relatively strong safeguards in its nationality law to prevent childhood statelessness. Children born on the territory automatically acquire Bulgarian nationality if they would otherwise be stateless. Children born to Bulgarian parents abroad (and foundlings) also acquire citizenship at birth automatically. However, in the case of adoption of a foreign child by Bulgarian nationals, there is a potential risk of statelessness. The child does not automatically acquire Bulgarian nationality on adoption but must apply for nationality before the age of 18 (with the adoptive parents’ consent if under 14). Birth registration takes place within seven days of birth and late registration is possible in law and practice, although a court procedure is required if more than a year has passed. Cases of health services reporting undocumented migrants to the immigration authorities may constitute a barrier to civil registration in practice for some high-risk groups. Withdrawal of nationality is provided for in law and is not permitted if it results in statelessness. 22. The Bulgarian Constitution provides that the granting and withdrawal of Bulgarian nationality is a sovereign power of the President of the Republic. The acts of the President of the Republic are not subject to appeal. Bulgaria has made reservations to Articles 11 and 12 of the European Convention on Nationality in this regard. There are no remedies against refusal, withdrawal or deprivation of Bulgarian nationality. Although the Law on Bulgarian Citizenship provides that one shall not be deprived of Bulgarian nationality in case the person would remain stateless, there are no remedies if the provision is not observed, such as, for example, if statelessness is not identified. Recommendations 23. Based on the above information, the co-submitting organisations urge reviewing States to make the following recommendations to the Bulgarian Government: I. Take concrete steps to facilitate access to the statelessness determination procedure (SDP) for all persons on the territory who wish to submit an application under the SDP, regardless of their legal status in the country. II. Introduce a temporary residence permit for applicants for stateless status, granting rights in line with people seeking asylum, and thus ensuring access to minimum social rights and subsistence, and facilitating access to the procedure. 6