Comparative Regional Report on Citizenship Law: Oceania Foreign allegiance Loss of citizenship on the ground of allegiance to a foreign state provided a way for states to avoid dual citizenship. Dual citizenship could be avoided by removing citizenship from those who gained a foreign citizenship or by requiring children born with multiple citizenship to choose one upon adulthood. Some states provided that any manifestation of active foreign citizenship, such as swearing allegiance to a foreign state, travelling on a foreign passport or voting in an election, were grounds for loss of citizenship.95 In Oceania, eleven of the twelve states sought to avoid dual citizenship in their original citizenship laws. In 2019, however, only three states continue to prohibit dual citizenship. In the Federated States of Micronesia, the Marshall Islands and Kiribati (for those of non-iKiribati descent) holding a foreign citizenship is grounds for loss of citizenship. A person of non-i-Kiribati descent and any person in the Federated States of Micronesia who voluntarily obtains another citizenship will automatically lose their Kiribati or Micronesian citizenship. In the Marshall Islands, the relevant Minister can apply to the High Court for the cancellation of a person’s citizenship on the ground that the person has voluntarily obtained citizenship of another country. Failure to renounce a foreign citizenship within a specified period can automatically result in loss of citizenship in the Federated States of Micronesia and Kiribati, and makes a person in the Marshall Islands liable to such loss. In the Federated States of Micronesia and Kiribati, serving in the armed forces of another state, taking an oath of allegiance to a foreign state or voting in an election in another state are also grounds for loss of citizenship.96 In Papua New Guinea and Vanuatu, dual citizenship is permitted only in certain circumstances and must be registered. Amendments to Papua New Guinea’s Constitution in 2014 provided that Papua New Guinean citizenship could be held alongside citizenship of prescribed countries, which include Australia, Fiji, Germany, New Zealand, Samoa, United Kingdom, United States of America and Vanuatu.97 There is no legislative guidance about which countries will be prescribed, but recognition of dual citizenship by the prescribed countries was regarded as an important control.98 There are less restrictions on dual citizenship in Vanuatu, but a formal application must be made to the Citizenship Commission before a person’s dual citizenship is recognised.99 A person who is not a dual citizen will automatically lose their Papua New Guinea or Vanuatu citizenship upon obtaining or failing to renounce a foreign citizenship, serving in a foreign armed service (without express approval) or exercising a right exclusive to citizens of a foreign country, such as voting in an election or travelling on a foreign passport.100 While Solomon Islands permits dual citizenship, a person who serves in the armed forces of another country without the prior consent of the Minister, or of a country at war with Solomon Islands, is liable to have their Solomon Islands citizenship removed.101 95 Peter Spiro, ‘Multiple Citizenship’ in Ayelet Shachar and others (eds), The Oxford Handbook of Citizenship (Oxford University Press 2017) 625–7. 96 Citizenship and Naturalisation Act c 7.2 (FSM) § 206(1); Citizenship Act 1979 (Kiribati) s 8(1); Citizenship Act 1984 (Marshall Is) s 406. 97 Constitution Amendment (No 37) (Citizenship) Law 2014 (PNG), Citizenship (Amendment) Act 2016 (PNG) s 6C. 98 See Parliament of Papua New Guinea, Hansard, 19 February 2014, 26/06. 99 Constitution (Sixth Amendment) Act No 27 of 2013 (Vanuatu); Citizenship (Amendment) Act No 39 of 2013 (Vanuatu) Part 3A. 100 Constitution of Papua New Guinea 1975 s 70(1)(a)-(d); Citizenship Act s 112 (Vanuatu) s 14(1)(b). 101 Citizenship Act 2018 (Solomon Is) s 25(2), (3). RSCAS/GLOBALCIT-Comp 2020/1 - © 2020 Author 19