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DUAL CITIZENSHIP

COMPARE: Which European countries have the strictest rules on dual citizenship?

Being a citizen of your country of long-term residence brings a lot of advantages, especially when it comes to peace of mind, but some countries in Europe have far stricter rules than others.

COMPARE: Which European countries have the strictest rules on dual citizenship?
COMPARE: Which European countries have the strictest rules on dual citizenship? Photo by ConvertKit on Unsplash

However, gaining citizenship in another state is not a walk in the park. Beyond the bureaucratic headache, and varying residency rules and exceptions, some countries may require to give up the nationality of origin as a result of the process.

Few countries in Europe require foreign nationals to do this, but some do. Here is an overview of how the countries covered by The Local deal with dual citizenship, starting with the ones with the strictest rules.

‘Special circumstances’

Austria, Germany and Spain generally do not allow dual citizenship, except in some special circumstances. This means that foreign nationals who obtain the citizenship of one of these countries have to give up their nationality of origin.

Austria

“In principle, anyone who acquires Austrian citizenship by conferral loses their foreign citizenship,” says the Austrian government website. This also applies to Austrian citizens who acquire a foreign citizenship.

Austria only waives the requirement to renounce previous citizenship if this is in the special interest of the state on the basis of “extraordinary achievements” in the past or expected in the future.

Austrians at birth can maintain citizenship if they apply to do so before acquiring another nationality and if this is justified by “special circumstances”, for instance if losing it would have “a severe detrimental impact on their ability to work” or, in the case of minors, if this is in their best interest.

Children with at least one Austrian parent are Austrian and can have dual citizenship. “The child does not have to decide on their (sole) nationality upon reaching the age of majority. However, the other state involved may require them to make such a decision,” the website adds.

Thanks to a recent law, Austrians who left the country before 15 May 1955 because of persecutions by the Nazi regime, and their descendants, can have their citizenship restored and retain any other citizenship they have since acquired.

Germany

Only EU and Swiss nationals can retain their citizenship of origin when they naturalise as German, and so can German citizens with these countries. British citizens were allowed to retain dual citizenship if they applied for naturalisation until the end of the Brexit transition period, but now they also have to renounce it.

Children with a German parent acquire German citizenship at birth and can keep dual citizenship permanently.

It is possible to retain dual citizenship if the country of origin does not allowed to renounce it or this is not possible for other reasons (for instance in case of conflict). 

German citizens who wish to naturalise in another country and keep German nationality can apply for a retention permit. In this case they will have to provide evidence of “continuing ties with Germany” and of “substantial reasons” for acquiring the other nationality.

Individiuals who between 30 January 1933 and 8 May 1945 were deprived of their German citizenship on political, racial or religious grounds, and their descendants, may have their citizenship restored and retain any other citizenship they have since acquired.

The current government coalition has promised in its programme a “modern citizenship law” allowing for multiple nationalities, but this is yet to materialise.

While in Austria applying for citizenship requires at least 10 years of continuous residence in (six for EEA citizens), as well as knowledge of the language and a ‘positive attitude’ towards the country, in Germany the requirement is 8 years. But foreigners who complete an ‘integration course’ can apply after 7 years. People who apply for German citizenship also need to know the German language and take a naturalisation test to prove they are familiar with the legal system, society and living conditions. Spouses or registered same-sex partners of German citizens can apply for naturalization after 3 years of legal residence.

Spain

As a general rule, people naturalising as Spanish citizens have to renounce their previous nationality. This is not required of nationals of Latin American countries, Andorra, the Philippines, Equatorial Guinea, Portugal or Sephardic Jews of Spanish origin.

This refers to a law that allowed Sephardic Jews descendants of those expelled from Spain in the 15th century to acquire citizenship. However, the deadline to apply for citizenship via this route has expired in 2021 (a similar citizenship route is open in Portugal).

For citizens from these countries the residency requirement to apply for naturalisation is 2 years. It is otherwise one year for people married to a Spanish national, 5 years for refugees or 10 years in other situations. 

Spain has also recently signed an agreement that allows dual citizenship with France.

Spanish citizens by origin can naturalise in another country and retain their citizenship if they require so within 3 years of acquiring the other nationality.

Children born in Spain can acquire citizenship if the parents are from a country that does not recognise the nationality of children born abroad.

Dual citizenship permitted

In many other countries, such as France, Italy and Sweden, as well as Belgium, Ireland, Switzerland and the UK, dual citizenship is permitted.

In France the residency requirement for naturalisation is generally 5 years, showing integration into the French way of life and knowledge of the French language.

In Italy it is possible to apply for citizenship after 10 years of residence, or 4 for EU citizens and 2 for a resident married to an Italian citizen. A language test is also required.

Sweden is one of the few countries where a language test is not needed. The general rule is 5 consecutive years of residence, with absences of more than six weeks during a year subtracted from the total. People married, in a registered partnership or cohabiting partners with a Swedish citizen can apply after three years.

On the other hand, Denmark has one of the strictest citizenship laws. Naturalisation requires an extra waiting period of two years after obtaining a permanent residence permit, which usually takes eight years. There is also a citizenship test.

Denmark allows dual citizenship after the law changed in 2015. Former Danish who lost their citizenship by acquiring a foreign one before 1 September 2015 can reacquire it by making a declaration to the Ministry of Immigration and Integration by 30 June 2026.

After a recent change in regulations, dual citizenship is also allowed in Norway. Those who lost their Norwegian citizenship before 2020 can reacquire it by submitting a notification of citizenship.

There are stricter rules, however, in the Netherlands. Foreign nationals acquiring Dutch citizenship, or Dutch nationals acquiring a foreign one, need to give up their citizenship of origin, except in some specific circumstances – for example, for those acquiring their spouse’s or partner’s citizenship or those holding an asylum residence permit.

Restrictions also exist in many Eastern European countries.

This article was produced by the team at Europe Street news.

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