representation through legal aid and the absence of a statutory appeal right. We have found through our casework that these concerns were justified. The result is that decision-making is of variable quality. The UK is ahead of many other countries in having a statelessness application procedure, but it does not treat statelessness as a protection status equivalent to refugee status or humanitarian protection. In practice, this means that there are deficiencies in the process and in the rights associated with the grant of leave. If the Home Office decided to treat statelessness as a protection status or equivalent, alongside refugee status and humanitarian protection, a person in the stateless application procedure would have similar entitlements to an asylum applicant. These include a right of appeal and legal aid. A person with statelessness leave would have the same rights and benefits as a refugee or person with leave to remain on humanitarian protection grounds. Notable examples of rights that those with statelessness leave do not have at present include access to home student fees and access to student finance in order to attend University, and entitlement to social housing and other benefits. The description in the introductory note to the Convention of the ‘profound vulnerability’ of many stateless people is correct. We have seen it in our casework and through it we have identified ways in which the procedure could be modified to reduce rather than reinforce this vulnerability. The key challenges, examined in detail in this report, are: a. Decision-making is inconsistent and at times poor. This is compounded by the lack of legal aid and the absence of a statutory appeal right. Particular problems have arisen with basic country information. It is unclear how the Home Office interprets “shared burden”, in particular when it takes steps to investigate a person’s statelessness through interviews or enquiries. Its guidance is reasonably clear but we do not always see this reflected in practice. There is a lack of Home Office guidance addressing related applications involving stateless persons. There are delays in processing claims – especially those of adults without dependent children. Cases can be outstanding for periods in excess of 20 months. b. A lack of legal aid means many applicants do not have legal representation. This makes it difficult for people to make informed decisions about whether or not statelessness (or another) claim is most appropriate. It also means that applications are neither prepared nor evidenced as well as they could be leading to more refusals and repeat applications. c. Lack of appeal right means that there is insufficient judicial scrutiny. Administrative review is not a sufficient remedy as it is limited in scope and conducted internally. Judicial Review does not commonly require the court to make factual findings, but the facts are often in dispute where there is a contested statelessness decision. It is also is expensive (for both sides), slow, sometimes opaque, and difficult to access. d. We have found links between trafficking and statelessness cases. The statelessness applications process and the NRM processes do not always work well together for the benefit of stateless victims of trafficking. e. There are deficiencies in the entitlements of individuals in the statelessness application procedure. It is not clear that they are entitled to Home Office accommodation and support, 7