Dual Citizenship in the European Union: trends and analysis (2010-2020)
as stipulated in an EC Regulation can be considered ambiguous.22 Therefore, it cannot be
excluded that the figures as depicted in Table 2 do not capture all persons who acquired
citizenship in a particular EU Member State on the basis of modes A05-A27 in 2018.
In total, the approach results in 756 possible citizenship constellations. Of these 756
constellations, 461 constellations (61%) do not restrict dual citizenship in any case. The 756
constellations covered the acquisition of citizenship of 153,317 persons for the reference year
of 2018, or more than one fifth of the 672,300 citizenship acquisitions of EU citizens and nonEU citizens combined. Of these 153,317 persons, 141,669 (92.4%) were covered by a nonrestrictive citizenship constellation, meaning that dual citizenship was not restricted in any case.
This shows that the majority of EU Member States mutually tolerates the occurrence of dual
citizenship and that the abundant majority of EU citizens who acquired the citizenship of
another member state was able to retain his or her original citizenship.
In virtually all permissive states, the share of persons who acquired citizenship while
being able to retain an original citizenship exceeds 90%. The single exception is the Czech
Republic, where only 35.7% of persons who acquired Czech citizenship was able to do so. This
is mostly caused by the relatively large number of Slovak citizens who acquired Czech
citizenship in 2018 (346 out of 543 persons in total). While the Czech Republic does not restrict
dual citizenship, Slovak citizenship is automatically lost upon the acquisition of a foreign
citizenship (see Section 3).
It is likely that a share of the persons covered by a potentially restrictive constellation
in the EU-28 (11,648 persons out of 153,317 persons, or 11.6%) was still able to retain the
original citizenship. As stated earlier, many important exceptions to the restrictive provisions
could not be taken into account in this analysis. For example, in the Netherlands, national
statistics show that the majority of EU citizens who acquired Dutch citizenship in 2018 did so
on the basis of an option right.23 For seven out of eight option rights, the renunciation of the
original citizenship is not required.24
It is also clear that Brexit had a substantial impact on intra-EU citizenship acquisitions,
as 47,584 EU citizens acquired British citizenship in 2018, while 16,193 British citizens
acquired another EU citizenship in the same year, which covers more than one third of all EU
citizens who acquired another EU citizenship. Out of the 47,584 EU citizens who acquired
British citizenship, 46,228 (97.2%) were covered by a permissive citizenship constellation. Out
of 16,193 British citizens who acquired another EU citizenship, 14,835 persons (91.6%) were
covered by such a permissive constellation. This shows that a large majority of EU citizens
have been able to mitigate the personal consequences of Brexit by obtaining or retaining an EU
citizenship, next to British citizenship.
All in all, applying the concept of citizenship constellations on intra-EU acquisition of
citizenship clearly shows the pervasiveness of dual citizenship tolerance within the European
Union. It also shows that an abundant majority of EU citizens who acquired the citizenship of
another EU Member State most likely became dual citizens. However, the overrepresentation
of persons covered by a permissive citizenship constellation could also indicate that restrictions
22
EU Member States are required to provide statistical data on “persons having their usual residence in the
territory of the Member State and having acquired during the reference year the citizenship of the Member State
and having formerly held the citizenship of another Member State or a foreign or having formerly been stateless,
disaggregated by age and sex, and by the former citizenship of the persons concerned and by whether the person
was formerly stateless” (Art. 3 par. 1 sub d Regulation (EC) No. 862/2007).
23
CBS, Nationaliteitswijzigingen; geslacht, nationaliteit en regeling (2018) [data file], 2020, via
<https://www.cbs.nl>, last accessed on 20 June 2020.
24
Art. 6A Kingdom Act on Dutch Nationality 1985.
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RSCAS/GLOBALCIT-Comp. 2020/4 - © 2020 Author