The Dual Citizenship Report Series

Building on the success and insight of the first two editions of the Dual Citizenship Report, Chetcuti Cauchi Advocates are now pleased to issue the third report on Dual Citizenship. While the previous editions delved into specific regions, this first Global edition is singular in the sense that it evaluates dual citizenship laws in over 100 jurisdictions worldwide.

As a relevant work of legal expertise, the Dual Citizenship Report has become a respected point of reference for many with queries on the topic of dual citizenship. The Dual Citizenship Report series looks at whether a country or territory allows, restricts, or prohibits its citizens from holding dual and multiple citizenship. To ensure the utmost accuracy, each country chapter is strictly based on the feedback from law firms that provided critical assessment on the laws governing citizenship in their respective countries.

The Global edition of the report acts as a significant addition to the series by expanding the research to cover dual citizenship legislation in more than 100 countries from all regions in the world. The report also incorporates the country chapters from the previous regional editions, all of which were reviewed and updated to reflect any recent revisions to the law. By incorporating countries from all over the world, the report conveniently allows the reader to extensively compare and contrast the status of dual citizenship. The primary research for this edition of the Dual Citizenship Report was carried between January and March 2019.

Dual Citizenship around the World

Although each country is uniquely influenced by its background, the Global edition of the Dual Citizenship Report allows for a few generalisations to be made. At present, dual citizenship is widely accepted, and most countries do not actively suppress dual citizenship rights. 60% of the jurisdictions under review in the report unrestrictedly allow dual citizenship, and only 20% completely prohibit dual citizenship with no special exceptions. Many have abandoned the practice under which naturalization in another country automatically resulted in loss or revocation of citizenship. As to those born with dual citizenship, few states now require a choice to be made between the two, upon reaching the age of majority or adulthood.

The great majority of European countries allow dual citizenship, as do most countries in North America, Latin America, the Caribbean, and the Pacific. Dual citizenship laws in Africa and the Commonwealth of Independent States (CIS) region are more varied, while Southeast Asia predominantly stands out as being the most restrictive region on the issue.  

Countries including Malta, the United Kingdom, Cyprus, New Zealand, the United States, Saint Kitts and Nevis, Saint Lucia, and Canada, amongst others, permit dual citizenship with absolutely no restriction. While some countries do not explicitly make any references to dual citizenship in their legislation, in doing so they also refrain from laying down any repercussions arising from the attainment of another nationality thereby leaving the matter subject to interpretation.

The report however finds that although some countries allow dual citizenship and do not force dual citizens to renounce either citizenship, they may still pose other restrictions namely when it comes to public office. Russia, for instance, does not allow dual citizens to be elected as members of the Federation Council or constitute/participate in the editorial office of a mass media or broadcasting entity, amongst other things. Certain countries also allow dual citizenship on the condition that an individual notifies the authorities, as is once again the case with Russia, and also with South Africa.

On the other end of the spectrum, there are countries that expressly forbid dual citizenship in the law and further elaborate that the acquisition of another citizenship is grounds for the loss or revocation of citizenship. These countries include the likes of China, Monaco, Nepal, Ethiopia, Kazakhstan, and India. In some cases, such as Japan, Indonesia, and Estonia, an exception is made for children or adult dual citizens under a certain age. Upon reaching the specific age of majority, however, the individuals are required to make a choice to keep one citizenship and renounce the other.

Other countries that do not normally allow dual citizenship, however, make allowances in limited circumstances or subject to certain conditions, including international treaties with specific countries or in the instances of birth or marriage. In the cases of European countries such as Bulgaria, Germany, and Latvia, dual citizenship is allowed in relation to EU member states, amongst other criteria. Spain, the Honduras, Nicaragua, and Pakistan, are among the countries that have a set of dual nationality agreements in place. Meanwhile countries including Austria, Lithuania, Norway and South Korea make allowances for dual citizenship for either dual citizens by birth, or dual citizens by marriage, or both.

To learn more about the report visit https://www.dualcitizenshipreport.org/

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.