What's the rule for using "who" or "whom"?
Which is correct?
A certificate is a statement that states who is entitled.
A certificate is a statement that states whom is entitled.
Is who a subject?
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What counts is that 'who' is if you like the 'local' subject of clause ("who is entitled") in which it sits. To help you see where the clauses are, you could try turning the sentence round, e.g. turning the sentence round as follows more clearly indicates that the clause [Who is entitled] itself forms a constituent that is the subject of the main sentence:
[ Who is entitled ] is what is stated.
So, according to the most common form of the traditional, arbitrary, prescriptive rule regarding "who" vs "whom", "who" would be used in this case.
But it is just a traditional, arbitrary prescriptive rule. There's no compulsion to follow it. So if you really can't decide, then I would suggest a really simply rule that you'll never get wrong:
Proposed rule regarding 'whom' that you will never get wrong: Never use whom; always use who instead.
It's a nice, simple rule that reliably produces sentences that sound natural to native speakers of English.