and other Muslim communities in Rakhine state, are required to identify as “Bengali” when applying for the cards (reinforcing inaccurate propaganda that they are from Bangladesh, thereby undermining their claim to Myanmar citizenship). Card holders are labelled as “foreigners”. At times, authorities have forced Rohingya at gunpoint to accept these identity cards,74 and subjected them to torture and arbitrary restrictions of movement and access to work.75 The holders of NVCs are barred from applying for citizenship.76 Access to Civil Documentation 52. Those applying for an ID card face extremely cumbersome evidentiary requirements. Applicants are required to bring many documents, including a household list, ancestral information, original birth certificate, original pink cards of the applicant’s parents and recommendation letters. In practice, the requirements may change depending on where the applicant is applying and what characteristics they possess. The requirements are inconsistent and unpredictable and are largely dependent upon the perceived ethnicity and religion of the individual. Applicants report being unable to list their ethnic or religious group of choice, as officials unilaterally determine their identity.77 53. Applicants face many other issues when applying for civil documentation including language barriers, geographic barriers (often government offices are very far away and not easily accessible), challenges linked to data entry, unofficial fees and bribes and undue delays in the decision-making process.78 The COVID-19 Impact on the Rohingya 54. Myanmar’s COVID-19 response has raised concerns that pandemic is being used as an opportunity to exercise increased control over the Rohingya and other vulnerable populations. The state’s pandemic response coupled with the ongoing violent conflict and internet blackout has worsened the vulnerability of populations, who cannot access crucial information about the virus and the ongoing conflict which is crucial for survival and stability. In certain townships, internet and information is so severely restricted that humanitarian workers have reported that those living there are completely unaware of the pandemic.79 55. Implementation and enforcement of public health policy has a clear discriminatory intent. Widespread diagnostic testing is limited in Myanmar, with IDPs in Rakhine being excluded, despite the heightened risk they face due to their living conditions. Additionally, punishments for not following public health guidelines have not been equitable. For example, the government fined only four of a hundred people who attended a Buddhist Monk’s funeral., But all 14 mourners at a Muslim funeral were sued, with the twelve adults in attendance being imprisoned for three months. 80 56. Organisations attempting to give humanitarian aid in the region have struggled to effectively distribute assistance without the internet. Journalists and news organisations in Rakhine have 74 Myanmar Forces Rohingya to Accept Cards That Preclude Citizenship, Reuters, Sept. 3 2019. Id. 76 Id. 77 Smile Education and Development Foundation and Justice Base, ‘Access to Documentation & Risk of Statelessness’, (December 2017). 78 Research available on file with ISI. 79 J. Slotkin, ‘Parts of Myanmar Unaware of COVID-19’, National Public Radio (24 June 2020), available at https://www.npr.org/sections/coronavirus-live-updates/2020/06/24/882893419/parts-of-myanmar-unaware-of-covid-19-due-to-internetban-advocates-say. 80 Different Laws Appied to Myanmar COVID-19 Restrictions, The Irrawaddy, May 2020, https://www.irrawaddy.com/specials/myanmarcovid-19/different-laws-applied-myanmar-covid-19-restrictions-lead-inconsistent-punishments-violators.html 75 12