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Passports: What are the post-Brexit rules for dual-nationals travelling in Europe?

People who have more than one citizenship often hold multiple passports, so what does this mean for crossing borders? Here's what you should know.

A person holds a German and British passport.
A person holds a German and British passport. Photo: picture alliance / Britta Pedersen/dpa-Zentralbild/dpa | Britta Pedersen

For many readers of The Local, gaining citizenship of the country where they live helps them to feel more settled – but there are also travel benefits, including avoiding the long ‘non EU’ queue when coming back into the Schengen zone.

But this week the problems associated with travelling while holding dual citizenship came to light, leaving many people wondering what they should know when they are entering different countries.

Put simply – which passport should you use? And do you have to carry both with you?

Financial Times journalist Chris Giles tweeted that the UK Border Force “detained” his dual-national daughter while she was travelling from France into the UK with her German passport – and not her British one. 

He went on to say that UK border guards released his daughter. According to Giles, the border staff said she should have had both passports with her “and asked why she was travelling on her German one”.

The rules on dual-nationality have not changed, but now that the UK is not in the EU, there are strict rules on non-Brits who enter the country (and vice-versa) which has made it trickier for travel.

For instance, UK nationals receive a stamp in their passport when entering Schengen member states because they are only allowed to stay up to 90 days within an 180 period (unless they have a visa or residency card).

READ ALSO: Brexit: EU asks border police not to stamp passports of British residents 

People coming from the EU to the UK can generally visit as a tourist for up to six months without a visa – but are not allowed to carry out any work while there.

So which passport should you show?

The first thing to be aware of is there are no specific rules on travelling with more than one passport. 

Travellers can choose to use whichever passport they prefer when going to a country. 

But one thing to note is that it’s worth using the passport that is best suited to your destination when travelling there. Each country has its own set of immigration and visa rules that you’ll need to research closely.

It could be that one passport is better suited for your trip – and you may be able to avoid visa requirements.  

READ ALSO: How powerful is the German passport?

In the case of the UK, many people are still getting to grips with the different rules that apply because it’s not in the EU anymore.

A question submitted to the Secretary of State for the Home Department in September 2021 provided some insight into this issue. 

The question from Labour’s Paul Blomfield asked what steps the UK government “is taking to enable dual UK and EU citizens to travel to the UK on an EU member state passport without having to further prove their UK citizenship?”

The Conservatives Kevin Foster said: “Border Force Officers examine all arriving passengers to establish whether they are British citizens, whether they require leave to enter or if they are exempt from immigration control.

“Where the passenger claims to be British, but does not hold any evidence of British citizenship, the officer will conduct all relevant checks to satisfy themselves the passenger is British.

Border control at Hamburg airport.

Border control at Hamburg airport. Photo: picture alliance/dpa | Christian Charisius

“When dual nationals who are eligible to use e-gates travel to the UK, they will enter via the e-gates without being examined by an immigration officer.

“We recommend all dual nationals, including EU citizens, travel on their British passport or with evidence or their British citizenship to minimise any potential delay at the border or when commencing their journey.”

The Local contacted the UK Home Office to ask if there was any official advice. 

A spokesman said: “An individual can present whichever passport they desire to enter the UK, however they will be subject to the entry requirements associated with the nationality of the passport they present.”

They said anyone who is looking for more information should check out guidance on entering the UK and on dual nationality.

In short, if you present a German passport on entry to the UK you will be treated the same as any other German citizen – which can include being quizzed about your reasons for visiting the UK – as border guards have no way of knowing that you are a dual-national. 

Do I have to carry both passports?

There’s no rule requiring you to have both passports, but you won’t get the benefits of a British passport (entry into the UK without questions) if you don’t show it.

Likewise if you are a French-British dual national and you enter France on your UK passport, you will need to use the non-EU queue and may have your passport stamped.

Should I think about anything else?

An important thing to remember is that if you apply for a visa and register your passport details, the same passport has to be used to enter the country. 

It could also make sense to travel with both passports, just in case. 

However, note that some countries – like the US – require that US nationals use a US passport to enter and leave the States even if they are dual nationals. 

In general, it’s best to use the same passport you entered a country with to depart.

The rules and systems are different depending on the country. But many countries require people to show their passport when leaving – and they will either stamp or scan the passport – this is how authorities know that a foreign visitor hasn’t overstayed their time in the country. 

So if your passport is checked as you leave the UK, you should show the one you arrived with, just to ensure there is a record of you arriving and leaving.

However as you enter France/Germany/other EU destination, you can show your EU passport in order to maximise the travel benefits of freedom of movement.

Member comments

  1. You mentioned above that “The first thing to be aware of is there are no specific rules on travelling with more than one passport. Travellers can choose to use whichever passport they prefer when going to a country.”

    However, many countries require you to enter with the passport of that country if you are a citizen of that country.

    E.g. from this official US government site: https://travel.state.gov/content/travel/en/legal/travel-legal-considerations/Advice-about-Possible-Loss-of-US-Nationality-Dual-Nationality/Dual-Nationality.html

    “U.S. nationals, including dual nationals, must use a U.S. passport to enter and leave the United States.”

    1. Hi Steven, yeah we mention the US rule further down in the article – but this is focusing on travel between the UK and EU for dual UK/EU nationals

  2. If you have a Swedish and UK passport, leave Sweden with your Swedish passport and enter Britain with your UK one. On return, leave Britain with your UK passport and enter Sweden with your Swedish. Simple. And if you travel to elsewhere in Europe, use your Swedish passport, unless you love queuing!

  3. As a dual EU/UK national I’d understood best practice is now to use the EU passport when entering and leaving the EU and the Uk passport when entering and leaving the Uk. A pain to carry both but allows a quicker passage, ensures the systems in each country register who’s coming and going and avoids issues with visas etc. Usually no problems doing this, but recently at Eurostar terminal where the UK and French controls are next to each other a member of staff tried to stop me doing this. Said I had to leave the Uk and enter EU with the same passport. Another then stepped in and said it was fine… so it seems clarification would indeed be helpful!

  4. It’s a no brainier really and the journalist from the FT should simmer down.

    It’s obvious that they must go by the passport presented. I think reasonable to ask why you didn’t use your UK passport.

    My partner is dual German/British.

    By ferry from Caen to Portsmouth.

    UK at checkin (booking on UK)
    German at French control.
    UK at Portsmouth

    Dual nationals are so lucky, take all your passports 🙂

  5. Those with an Irish passport just need to carry that one: the benefits of an EU citizen entering France and unrestricted UK access due to the Common Travel Area.

  6. I agree with Steven above – many countries require that you enter the country of your nationality on that passport. For example Canadians CANNOT enter Canada on anything other than a Canadian passport. But when travelling back to Ireland, I need to use my Irish passport meaning that, as far as Canada know, I am still there, drifting around without a job or home.

  7. I hold both Canadian and British passports. What’s to stop me entering the Schengen zone with my UK passport and staying the maximum 90 days? At that point, I leave Schengen for a day and re-enter with my Canadian passport. Can I then stay another 90 days?

  8. The Local continually gives good advice to dual nationals holding the UK passport. But what about the rest of us??? I would like you to address the dual citizen carrying the US and the Italian/EU passport. We count too.

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TRAVEL NEWS

Reader question: How do the EU’s new EES passport checks affect the 90-day rule?

As European travellers prepare for the introduction of enhanced passport checks known as the Entry & Exit System (EES), many readers have asked us what this means for the '90-day rule' for non-EU citizens.

Reader question: How do the EU's new EES passport checks affect the 90-day rule?

From the start date to the situation for dual nationals and non-EU residents living in the EU, it’s fair to say that readers of The Local have a lot of questions about the EU’s new biometric passport check system known as EES.

You can find our full Q&A on how the new system will work HERE, or leave us your questions HERE.

And one of the most commonly-asked questions was what the new system changes with regards to the 90-day rule – the rule that allows citizens of certain non-EU countries (including the UK, USA, Canada, Australia and New Zealand) to spend up to 90 days in every 180 in the EU without needing a visa.

And the short answer is – nothing. The key thing to remember about EES is that it doesn’t actually change any rules on immigration, visas etc.

Therefore the 90-day rule continues as it is – but what EES does change is the enforcement of the rule.

90 days 

The 90-day rule applies to citizens of a select group of non-EU countries;

Albania, Andorra, Antigua and Barbuda, Argentina, Australia, Bahamas, Barbados, Bosnia and Herzegovina, Brazil, Brunei, Canada, Chile, Colombia, Costa Rica, Dominica, El Salvador, Georgia, Grenada, Guatemala, Honduras, Hong Kong, Israel, Japan, Kiribati, Kosovo, Macau, Malaysia, Marshall Islands, Mauritius, Mexico, Micronesia, Moldova, Monaco, Montenegro, New Zealand, Nicaragua, North Macedonia, Palau, Panama, Paraguay, Peru, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Samoa, San Marino, Serbia, Seychelles, Singapore, Solomon Islands, South Korea, Taiwan, Timor-Leste, Tonga, Trinidad and Tobago, Tuvalu, Ukraine, United Arab Emirates, United Kingdom, United States, Uruguay, Vatican City and Venezuela.

Citizens of these countries can spend up to 90 days in every 180 within the EU or Schengen zone without needing a visa or residency permit.

People who are citizens of neither the EU/Schengen zone nor the above listed countries need a visa even for short trips into the EU – eg an Indian or Chinese tourist coming for a two-week holiday would require a visa. 

In total, beneficiaries of the 90-day rule can spend up to six months in the EU, but not all in one go. They must limit their visits so that in any 180-day (six month) period they have spent less than 90 days (three months) in the Bloc.

READ ALSO How does the 90-day rule work?

The 90 days are calculated according to a rolling calendar so that at any point in the year you must be able to count backwards to the last 180 days, and show that you have spent less than 90 of them in the EU/Schengen zone.

You can find full details on how to count your days HERE.

If you wish to spend more than 90 days at a time you will have to leave the EU and apply for a visa for a longer stay. Applications must be done from your home country, or via the consulate of your home country if you are living abroad.

Under EES 90-day rule beneficiaries will still be able to travel visa free (although ETIAS will introduce extra changes, more on that below).

EES does not change either the rule or how the days are calculated, but what it does change is the enforcement.

Enforcement

One of the stated aims of the new system is to tighten up enforcement of ‘over-stayers’ – that is people who have either overstayed the time allowed on their visa or over-stayed their visa-free 90 day period.

At present border officials keep track of your time within the Bloc via manually stamping passports with the date of each entry and exit to the Bloc. These stamps can then be examined and the days counted up to ensure that you have not over-stayed.

The system works up to a point – stamps are frequently not checked, sometimes border guards incorrectly stamp a passport or forget to stamp it as you leave the EU, and the stamps themselves are not always easy to read.

What EES does is computerise this, so that each time your passport is scanned as you enter or leave the EU/Schengen zone, the number of days you have spent in the Bloc is automatically tallied – and over-stayers will be flagged.

For people who stick to the limits the system should – if it works correctly – actually be better, as it will replace the sometimes haphazard manual stamping system.

But it will make it virtually impossible to over-stay your 90-day limit without being detected.

The penalties for overstaying remain as they are now – a fine, a warning or a ban on re-entering the EU for a specified period. The penalties are at the discretion of each EU member state and will vary depending on your personal circumstances (eg how long you over-stayed for and whether you were working or claiming benefits during that time).

ETIAS 

It’s worth mentioning ETIAS at this point, even though it is a completely separate system to EES, because it will have a bigger impact on travel for many people.

ETIAS is a different EU rule change, due to be introduced some time after EES has gone live (probably in 2025, but the timetable for ETIAS is still somewhat unclear).

It will have a big impact on beneficiaries of the 90-day rule, effectively ending the days of paperwork-free travel for them.

Under ETIAS, beneficiaries of the 90-rule will need to apply online for a visa waiver before they travel. Technically this is a visa waiver rather than a visa, but it still spells the end of an era when 90-day beneficiaries can travel without doing any kind of immigration paperwork.

If you have travelled to the US in recent years you will find the ETIAS system very similar to the ESTA visa waiver – you apply online in advance, fill in a form and answer some questions and are sent your visa waiver within a couple of days.

ETIAS will cost €7 (with an exemption for under 18s and over 70s) and will last for three years.

Find full details HERE

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