108. The Commission remains concerned about the under-registration of births to Aboriginal and Torres Strait Islander mothers. 109. For example, Queensland Health reported in 2014 that 15–18% of births to Aboriginal and Torres Strait Islander mothers were not registered, compared with 1.8% of births to mothers who were non-Indigenous.72 110. Reasons for this included: • fees and penalties for the late registration of a birth and obtaining a birth certificate • the move to an online birth registration process (which has a negative impact on remote Aboriginal and Torres Strait Islander communities) • methods of interacting with Aboriginal and Torres Strait Islander communities which may not be culturally appropriate.73 Recommendation 17: Australian Governments adopt measures to ensure birth registration of Aboriginal and Torres Strait children, in consultation with their communities. Identity documents for children in out-of-home care (b) 111. Children in out-of-home care often experience difficulties in accessing identity documents, such as birth certificates, proof of Aboriginality, proof of Australian citizenship, and passports. 112. Since 2016, the NCC has co-chaired the Identity Documents Working Group. The group is committed to: (c) • identifying practical solutions to reduce the complexity of accessing identity documents for children receiving statutory child protection services • liaising across jurisdictions to discuss reforms and effective practices. Birth certificate changes for transgender and intersex children 113. There is considerable variability across Australia’s jurisdictions in terms of modifying birth certificates. 114. Transgender children have the right to seek legal recognition of their gender identity, but this is not always possible within Australia. 20