Recommendations 54. Based on the content of this submission, we urge States to consider making the following recommendations to the UK Government: i) Fully incorporate and comply with the 1954 Convention, including recognising ‘statelessness status’ as a protection status, ensuring that its definition of ‘stateless person’ is fully consistent with the 1954 Convention, and eliminating provisions that exclude stateless persons from being recognised as stateless. ii) Introduce adequate procedural safeguards during the statelessness determination procedure, including ensuring an adequate burden and standard of proof, access to legal aid, and a comprehensive right of appeal to an independent tribunal. iii) Provide regular training to decision-makers in the statelessness determination procedure to ensure quality and timely decision making. iv) Take concrete steps to protect stateless persons from arbitrary detention, including introducing a mechanism to identify (risks of) statelessness during the decision to detain, and implementing a thorough assessment of vulnerability and appropriateness of alternative measures in each individual case. v) Protect the right to acquire British citizenship of all children born in the UK who would otherwise be stateless, ensuring they acquire British citizenship as soon as possible after birth, regardless of the immigration status or identity of their parents. vi) Introduce an expedited procedure for stateless children to acquire British citizenship, and fee exemptions or appropriately reduced fees for children and stateless applicants. vii) Ensure that stateless persons have access to adequate legal advice and (free) legal aid in British nationality applications in all UK jurisdictions. viii) Take concrete steps to improve the recording of statelessness, namely by harmonising quantitative data on stateless persons, ensuring that statistical categories cover the entire stateless population, and publishing annual disaggregated, transparent and comparable statistics on stateless people and on deprivation decisions. ix) Protect everyone’s right to a nationality, and ensure that law, policy and practice is in line with the UK’s international obligations, including the prohibition of arbitrary and discriminatory deprivation of nationality, the duty to avoid statelessness, respect for the right to a fair trial and adherence to adequate procedural safeguards. x) End the practice of depriving people of nationality when they are abroad, instigating deportation proceedings against those who have been deprived of their nationality, and not notifying individuals of deprivation decisions. The UK Government should ensure everyone’s access to justice, the right to a fair trial and equality before the law, and prevent further regression in UK law, including by ensuring that Clause 9 of the NBB, as currently written, is not passed into law. 15

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