The public has an until the end of Friday to make submissions on proposed changes to legislation by the Department of Home Affairs, which could lead to children born to foreign parents not being issued with birth certificates. At least four groups, including three affiliated to the legal fraternity, have criticised the proposed changes.The Centre for Child Law, Lawyers for Human Rights, Scalabrini Centre of Cape Town and University of Cape Town Refugee Law Clinic said in a joint statement on Wednesday that the proposed changes to the Births and Deaths Registration Act would mean that foreign children would be issued with a "confirmation of birth" instead of a birth certificate.They added that the proposal violated Section 28 of the Constitution which afforded children the right to a name and nationality.Violation of the ConstitutionNot only did every child have a right to a birth certificate but, according to international law, it was the responsibility of the country of birth to issue a birth certificate, regardless of whether citizenship was granted or not. They also claimed it amounted to unfair discrimination based on ethnic origin and birth, which was also a violation of the Constitution. One of the troubling points expressed by the group was that the draft regulation required children to present their "confirmation of birth" to their embassy to obtain a birth certificate from their country of nationality. "This is particularly harmful to refugee and asylum seeker children, because they cannot approach their embassies, which would jeopardise their protection in South Africa."They said orphaned and abandoned children would also become vulnerable because they could not prove their nationalities if their parents were absent. "This proposed amendment comes in the wake of criticism from the UN Committee on the Rights of the Child (UNCRC).UNCRC recommendations The UNCRC recommended that South Africa "review and amend all legislation and regulations relevant to birth registration and nationality"."Instead of implementing this recommendation, the department is lowering the standard by removing birth registration for foreign children entirely. Without a birth certificate, children face immense barriers to basic services and human rights, such as education, health and social services. We urge the Department of Home Affairs not to pursue this amendment."Lawyers for Human Rights' Liesl Muller told News24 that if Home Affairs was trying to control migration through the proposal, it was the wrong way to go about it."A birth certificate is a legal document to recognise a person and their parents. It does not amount to citizenship. Now, if foreign children are left undocumented, they essentially cannot even leave the country," Muller told News 24 on Friday.She said the confirmation of birth document would limit children born to foreign parents to basic rights."Confirmation of birth is not a legal document. It is not recognised in hospitals, schools etc. Therefore it limits your right because the child on record does not even exist with such a certificate," Muller explained.Submissions close FridayThe Department of Home Affairs told News24 that it was not in a position to comment until it had received submissions on the proposed act."The comments on the draft regulations referred to have not been received and considered and therefore it is unfair to expect the department to comment when we have not even considered the submissions on the matter," media liaison officer, Thabo Mokgola, told News 24 on Thursday.The closing date for submissions on the proposed changes is November 16. An internal process of engagement is expected to follow.