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What Is Citizenship?

For many people the word ‘citizenship’ conjures images of a strong national identity determined by birth, ethnicity, history, culture and upbringing – so the idea of a second citizenship may be foreign and difficult to grasp. However, in a legal sense, ‘citizenship’ indicates the relationship between an individual and a nation state. Normally, the individual is conferred protection by the state, in return for the fulfilment of certain obligations owed by the individual to the state. It is therefore possible to gain a second citizenship from another country if the second citizen meets the criteria set by that country’s government.

What Is a Dual Citizen?

A dual citizen is an individual who holds two separate nationalities that were conferred by two independent sovereign states. It is up to each state, its laws, and policies whether an individual is considered a citizen or not – and some individuals may be automatically deemed citizens even though they did not actively seek out citizenship. In order to be a dual citizen, an individual must hold two citizenships concurrently.

How Do You Get Dual Citizenship?

Most individuals are awarded at least one citizenship at the time of their birth, but there are several ways in which a person can obtain a second citizenship, and thus have more than one nationality.

Citizenship by Birth: Jus Soli

An individual can be granted citizenship by ‘jus soli’ – or the ‘right of soil.’ This is the right to be a citizen of the place in which you were born, irrespective of your parentage. Canada, the United States, and many Latin American and Caribbean countries award citizenship by jus soli. These countries will generally award citizenship to those born within their territories even if the parents of the individual were only temporarily within their borders, or if they were there illegally. The most prominent exception to this rule applies to children of diplomats or foreign officials travelling within the country’s borders in their capacity as government employees.

Other nations apply modified versions of the jus soli principle – sometimes known as restricted jus soli. These countries require birth within their exclusive jurisdiction plus the fulfilment of at least one more condition. Children born in New Zealand, for example, will only be awarded citizenship if at least one of their parents is a citizen or permanent resident (or if the child would otherwise become stateless). Spain is less strict, allowing children whose parents are legally residing or domiciled in Spain at the time of their birth to become citizens. Children who are born in Egypt are only granted Egyptian citizenship if their father is also an Egyptian national.

Citizenship by Descent: Jus Sanguinis

The most common means of obtaining citizenship is through ‘jus sanguinis’ – or the ‘right of blood.’ This is the right of an individual to obtain citizenship by descent, whether from their parents or, at times, more distant relatives whose children’s continued relationship with a country was interrupted by relocation. Croatia, for example, allows those whose ancestors were Croatian to apply for citizenship even if their parents or grandparents never laid claim to the right of citizenship. More welcoming than other nations, Croatia also allows those who are ethnic Croatian and who can show a link to Croatian culture to apply for citizenship. Ireland applies a more limited form of jus sanguinis, allowing persons with at least one Irish grandparent to become Irish citizens by registering their citizenship in the Foreign Births Register.

Citizenship by Residence

A vast majority of countries allow individuals to obtain citizenship of their nation after several years of legal residence therein. Most countries offering citizenship by residence will apply minimum residence requirements, as well as language and culture tests to show a connection to the nation. For example, the United States allows a permanent resident, also known as a Green Card holder, to become a citizen after five continuous years of residence. The minimum residence requirement is reduced to three years if the Green Card was obtained through marriage. Applicants must also pass a basic language and civics test, and sign a loyalty oath, before obtaining citizenship. The United Kingdom offers a similar citizenship structure, although the language requirement is waived for those whose country of origin has English as its official language, such as St Kitts and Nevis.

Citizenship by Marriage: Jus Matrimonii

Some nations will award citizenship to spouses of current citizens even without the spouse fulfilling residence requirements. Jamaica, for example, will allow spouses to apply upon proof that an officially recognised marriage took place.

Citizenship by Investment

The fastest way of obtaining citizenship other than by birth is by ‘economic citizenship,’ also known as ‘citizenship by investment (CBI).’ CBI is the process of making an investment in a country in return for citizenship. Four Caribbean nations, namely St Kitts and Nevis, St Lucia, Grenada, and Dominica allow investors to become nationals without fulfilling any residence, language, business, skill, or interview requirement. Each of these nations offers investors at least two citizenship options: a one-time donation to a government fund, or the purchase of real estate, to be held for a fixed number of years (ranging between three and five depending on the jurisdiction).

How Many Citizenships Can a Person Have?

Countries that allow their citizens to hold dual nationality will generally also allow their citizens to hold any number of nationalities. In most countries, a person who has two citizenships can thus have three, four, ten, or more.

Certain nations however are stricter with the number and type of additional citizenships an individual can have. For example, Germany allows its nationals to become naturalised citizens of any European Union member state, but it will not allow them to obtain any other citizenship without prior approval. A German national could thus become a citizen of up to 27 other countries (the 27 remaining EU member states) without losing German citizenship.

Some countries will allow you to have any number of nationalities, so long as these were acquired by specific means. For example, the Netherlands will allow its citizens to hold multiple nationalities if these were acquired by birth or by marriage. Therefore, an individual who was born in the United States (where jus soli prevails) and who is the child of an Italian father and of a Tunisian mother (where citizenship is awarded on the principle of jus sanguinis) would be able to retain all three of these citizenships while also being a national of the Netherlands.

Other countries will allow multiple nationalities only when the additional nationalities cannot be renounced. For example, a Norwegian national would not be allowed to hold another citizenship unless that other citizenship could not be relinquished – such as is the case for Greek nationals who have been prosecuted for a felony.

Finally, some countries will only allow their citizens to hold dual nationality until they become of age. In Japan, for example, citizens below the age of 18 may hold two nationalities. However, upon turning 18, they must choose whether to keep their Japanese citizenship or that of the other country. A similar rule is applied in Venezuela, where the decision must be made when the individual turns 25.

What Countries Do Not Allow Dual Citizenship?

As we enter an era of international communication, travel, and interaction, more and more nations are allowing their citizens to become nationals of a second country while retaining their original citizenship.

A small number of countries, however, still restrict the right of its citizens to obtain a second nationality. Some nations, such as Russia, simply do not recognise second citizenship, meaning that nationals can acquire dual citizenship but can only interact with their nation of birth as citizens of that nation and through their original passport. Other nations, such as Indonesia, will deprive an individual of citizenship if they discover that the individual holds another nationality. Some countries require individuals to renounce their original citizenship when that individual naturalises.

Below is a list of nations that restrict the right to hold an alternative citizenship.

Disclaimer: This list has been compiled with the most recent information available in early 2016. However, we advise checking with the relevant Government authorities for an accurate understanding of each country’s dual citizenship laws.

  1. Algeria
  2. Andorra
  3. Austria, with some minor exceptions for individuals who automatically receive a second citizenship by descent or location of birth or who cannot renounce their additional citizenship
  4. Azerbaijan
  5. Bahrain, with the exception of certain Gulf state second nationalities
  6. Belarus
  7. Bhutan
  8. Bolivia
  9. Botswana
  10. Brunei
  11. Burundi
  12. Cameroon
  13. Chile
  14. China
  15. Congo
  16. Cuba
  17. Czech Republic
  18. Djibouti
  19. Ecuador
  20. Egypt, which only allows naturalisation if the Egyptian authorities are properly informed.
  21. El Salvador, with the exception of those who obtain El Salvadorian nationality by birth
  22. Equatorial Guinea
  23. Estonia, but only for naturalised Estonians who later seek to take another citizenship
  24. Fiji
  25. Gabon
  26. Germany, which only allows naturalisation in non-EU countries (other than Switzerland) following permission from the German Government. Second citizenship by birth or parental descent is allowed.
  27. Guinea
  28. Honduras
  29. India
  30. Indonesia
  31. Iran
  32. Iraq
  33. Japan, with the exception of children who have dual citizenship and who have not reached adulthood
  34. Kazakhstan
  35. Kenya
  36. Kiribati
  37. Kuwait
  38. Kyrgyzstan
  39. Laos
  40. Latvia
  41. Libya
  42. Lithuania, with the exception of citizens whose ancestors had to leave the country due to past persecution
  43. Malawi
  44. Malaysia
  45. Mauritius
  46. Mali
  47. Mexico
  48. Monaco
  49. Mongolia
  50. Montenegro
  51. Myanmar (Burma)
  52. Nepal
  53. The Netherlands, with exceptions for those who hold a different citizenship by birth or marriage
  54. Nicaragua
  55. Niger
  56. North Korea
  57. Norway, except for those whose other citizenship cannot be renounced
  58. Oman
  59. Pakistan, except for citizens of an enumerated list of countries
  60. Palau
  61. Papua New Guinea
  62. Peru
  63. Principe Island
  64. Poland
  65. Qatar
  66. Russia, which requires dual nationals to declare their alternative citizenship, and which only recognises Russian citizenship when an individual enters or leaves the country
  67. Rwanda
  68. Saudi Arabia
  69. Sierra Leone
  70. Singapore
  71. Slovakia, unless Slovakian citizenship is obtained through birth or marriage
  72. Solomon Islands
  73. South Korea
  74. Sri Lanka, where dual citizenship must be requested
  75. Sudan
  76. Swaziland
  77. Sweden
  78. Spain, except for citizens of an enumerated list of countries
  79. Tanzania, with the exception of women who obtain a second citizenship by marriage
  80. Thailand
  81. Tonga
  82. Turkey, where naturalisation must be declared to the Government
  83. Uganda
  84. The Ukraine
  85. United Arab Emirates, except for those who obtained another citizenship at birth and who also obtained UAE citizenship through descent from a UAE father
  86. Uzbekistan
  87. Venezuela, with the exception of children who have dual citizenship and have yet to reach the age of 25
  88. Vietnam
  89. Yemen
  90. Zimbabwe
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