BARRIERS TO BIRTH REGISTRATION THROUGH EXPENSIVE DNA REQUIREMENTS 10. The CCL receives hundreds of requests for assistance from unmarried fathers who ae barred from registering the births of their children. Officials at the local offices instruct them to return with DNA proof of paternity at a cost of between R1500 and up to R4500 depending on how many children he has. This is an unaffordable expense to many South Africans. Children go undocumented as a result. 11. Having considered the matter carefully, the CCL has come up with a list of alternative ways of proving paternity which are free, and which already exist within South African law. We recommend that these alternatives to DNA proof of paternity be adopted by the Department and circulated via Departmental Circular to all its offices. 12. The children of married persons are not required to provide DNA proof of paternity. The marriage certificate is accepted as proof of the birth mother’s spouse’s paternity. This is regulated under regulation 3(3)(h). The children of unmarried parents who register the birth of their child within 30 days are not required by the Circular to provide DNA test results. 13. When a birth is registered after the 30-day period has lapsed, the registration becomes a late registration of birth (LRB) (see section 9(3A) and regulations 3, 4, and 5. Additional requirements must be complied with in an LRB application. Although the regulations do not prescribe DNA as a requirement of LRB, a Departmental Circular (5 of 2014) requires all LRB applications of children of unmarried parents, where one of the parents is a foreigner, to provide DNA proof of paternity. This DNA proof of paternity acts as an absolute barrier to the right to birth registration and is unconstitutional as a result. 14. The CCL suggest that a Departmental Circular be issued and circulated to all offices which confirms the alternative documents to prove paternity. We suggest the following documents in line with existing South African law: Page | 7