‘Legal Identity for All’ and Statelessness recognition of civil status documents, or the information that should be recorded in a birth register in the absence of existing documents. The UN Statistics Division published a new draft set of guidelines on a legislative framework for CRVS in January 2019, updating the 1998 version and expanding the scope, in order to take SDG Target 16.9 into account and provide a ‘holistic and integrated approach to civil registration, vital statistics, and national identity management’. 113 The guidelines mark an important departure, proposing a ‘rights-based approach to CRVS legal frameworks’, and urging states to ensure that their citizenship laws are ‘consistent with … obligations under international law, including the child’s right to a nationality’. 114 They emphasise the important role of the courts in ‘amending or correcting civil registration and identity records and appealing decisions of civil registration and identity management officials’. 115 There is also a focus on the reduction of statelessness and the minimum legal protections required, and on the registration of births to nationals occurring abroad (with a brief reference to the Apostille Convention). 116 But there is no guidance on the legal and procedural framework for recognition of foreign civil status documents, or their substitution by the state of residence, nor on the resolution of uncertain nationality of the parents or the child on registration of birth (whether that takes place at the time of birth or later). The recommended information to be registered at birth puts the citizenship of the parents as a low priority item. 117 Even if these interpretations of state obligations are adopted across the development sector, the impact of the SDG Target on those of undetermined nationality remains uncertain. Central to this uncertainty is the fact that the only action specified by the SDG Target is birth registration, and the only indicator adopted is the coverage of birth registration among those under five years old, with no specification as to the minimum information of the elements of identity to be recorded in the register. The barriers to birth registration explored above suggest that universal coverage of birth registration will not be possible to achieve unless it is delinked not only from the parents’ legal status in the country — creating a wall between civil registration and immigration enforcement — but also from the common requirements to provide documents to prove the nationality of the parent(s) and their legal marriage. But such a decision would have costs, not least in relation to a reduction in statelessness. If these requirements are removed, so that details noted in the birth registry entry could be based on simple declaration by the parents, the nationality of the child remains uncertain — unless the birth is in one of the minority of states (mostly in the Americas) that provide nationality on a jus soli basis without further conditions. 113 Guidelines on the Legislative Framework for Civil Registration, Vital Statistics and Identity 114 115 116 117 Management; Second Draft (Guidelines, United Nations Statistics Division January 2019) [3] (‘Draft Guidelines on the Legislative Framework for Civil Registration, Vital Statistics and Identity Management’) <https://unstats.un.org/unsd/demographic-social/Standards-andMethods/files/Handbooks/crvs/CRVS_GOLF_Final_Draft-E.pdf>. ibid 40, 117–64. ibid 199–204. ibid 162, 304–5. Draft Guidelines on the Legislative Framework for Civil Registration, Vital Statistics and Identity Management (n 113) annex A, 173; the recommendations are taken from Principles and Recommendations for a Vital Statistics System (n 36) 18–19 [66]. The revised framework also drops any hesitancy in the former version relating to the assignment of a single identity number to an individual: see at 61 [275]). 269