5.2 Recommendations 148. In conclusion, in order to facilitate the Netherlands’ full compliance with its obligations under the 1954 and 1961 statelessness conventions and to ensure that stateless persons are able to enjoy the rights to which they are entitled, UNHCR makes the following suggestions and recommendations. Some are of a definitional or procedural nature; others are intended to allow for the more humane treatment of a group of persons whose visibility and limited entitlements to assistance are not yet adequately understood or addressed. All fall within one or more of the four categories of identification, prevention, and reduction of statelessness, and/or of protection of stateless persons. Determination of statelessness 1 2 3 It is recommended that an accessible and efficient statelessness determination procedure be established. A dedicated procedure can better identify stateless persons, thereby allowing for more tailored protection measures, improving (statistical) awareness of the actual scope of the problem, and enhancing the Netherlands’ ability to fulfil its international obligations under the 1954 Convention. It is recommended that one centralized, designated and independent authority to determine statelessness be appointed. Such an authority should have expertise in statelessness and nationality matters and relevant expertise, financial and staff resources. Designating a specific authority would be important to ensure transparency and develop specialization and expertise within the authority concerned. Statelessness raises many issues that are distinct from those considered in refugee status determination. Based on experience in other countries where stateless determination procedures exist and on UNHCR’s expert roundtable discussions and conclusions in 2010– 11, UNHCR makes the following recommendations as to the operation of such a procedure: a) Bearing in mind that many stateless people are children, the procedure should be subject to a decision within a reasonable time limit. b) An unduly high standard of proof should not be imposed in the procedure. This would frustrate the object and purpose of the 1954 Convention, as it could prevent stateless persons from being recognized. The procedure should adopt an approach to evidence which takes into account the challenges inherent in establishing whether someone is stateless. c) The burden of proof should be shared between applicant and the determining authority. The 1954 Convention requires a negative to be proven – that an individual is not considered as a national by any State under the operation of its law. While individuals are obliged to cooperate in establishing relevant facts, they will often face challenges accessing the relevant evidence and documentation needed to prove their absence of in the Netherlands 59