registered and issued a birth certificate,23 which means that some parents face barriers to registering births without any other safeguards in place to protect the child’s right to a nationality. There are credible reports from the Ombudsperson and NGOs of barriers to birth registration for undocumented parents and children remaining unregistered as a result. 24 Romani communities are disproportionately impacted and many face challenges due to parents' lack of documentation. Positively, an amendment to the law which came into force in January 2018 recognises Transnistrian civil status acts, making it easier for parents of Transnistrian origin to register the births of their children in Moldova and for children born to Transnistrian parents to acquire Moldovan nationality. ISSUE 3 – Facilitated naturalisation 22. According to its obligations under the 1954 Convention, Moldova should as far as possible facilitate the naturalisation of recognised stateless persons. In particular, it should make every effort to expedite naturalisation proceedings and to reduce as far as possible the charges and costs of such proceedings.25 23. There are accelerated naturalisation procedures for recognised stateless people and refugees in Moldova, who can apply for naturalisation after eight years instead of the standard 10 years. However, eight years is still a long residence requirement in comparison to other countries in Europe, and a long time for people recognised as stateless to wait to resolve their lack of any nationality.26 There is no fee exemption nor waiver of language, citizenship test or minimum income level requirements. Some persons recognised as stateless may be refused access to Moldovan nationality, including if it is considered that the person has been “involved in activities that endanger the […] health and morality of the population”, which may unreasonably prevent stateless persons from acquiring a nationality.27 ISSUE 2 – Liberty and security of the person and arbitrary detention 24. Undocumented stateless people face a heightened risk of arbitrary immigration detention (‘public custody’) particularly where procedural safeguards to identify and determine statelessness and related barriers to removal are lacking. 28 Moreover, 23 Law 100/2001 on acts of civil status of the Republic of Moldova, available at: http://www.law-moldova.com/laws/rom/actahgrazhdanskogo-sostoeaniea-ro.txt (Romanian); Public Services Agency order nr. 1 , 19 July 2017: http://asp.gov.md/sites/default/files/pdf/acte-institutionale/Anexa4_Lista_serviciilor_SSC_07_06_2018.pdf (Romanian). 24 Ombudsperson of Moldova, Raport Tematic: Analiza situației pe țară privind documentarea copiilor cu adeverințe de Naștere (Analysis of the situation regarding children’s rights to a name and nationality), 2013: http://ombudsman.md/wpcontent/uploads/2018/10/raport_tematic_-_copii_nedocumentati_red_0.pdf (Romanian); Ombudsperson of Moldova, Report Observing Child Rights in the Republic of Moldova in 2017, page 91, right to name and nationality. Available at: http://ombudsman.md/wp-content/uploads/2019/05/Raport_2018_INTEGRAL-1.pdf. 25 Article 32 of the 1954 Convention. 26 Law 1024/2000 on Citizenship of the Republic of Moldova, Art. 17, available at: http://www.refworld.org/docid/3ae6b60ba.html (English) and the original at: http://lex.justice.md/md/311522/ (Romanian). For a comparison with other European countries, see: https://index.statelessness.eu/ 27 Ibid. 28 European Network on Statelessness, Protecting Stateless Persons from Arbitrary Detention: An Agenda for Change, 2017 https://www.statelessness.eu/sites/www.statelessness.eu/files/attachments/resources/ENS_LockeInLimbo_Detention_Agend a_online.pdf. 6