Dual Citizenship in the European Union: trends and analysis (2010-2020)
exceptions in this regard.30 One of these exceptions is a procedure for reacquisition of
citizenship by registration for Austrian citizens who were forced to leave Austria before 9 May
1945 due to (a fear of) persecution by the German Nationalist Socialist Working Party or the
regime of the Third Reich.31 This group is exempted from the requirement to renounce an
original citizenship upon acquisition of Austrian citizenship.32 On 20 September 2020, an
amendment came into force that extended the above-mentioned date limit to 15 May 1955 and
broadened the scope of the provision, now also including persons who were exiled from Austria
due to their support for a democratic Austria as well citizens of other states of the former
Austrian-Hungarian Empire who were residing in Austria before their exile.33 Most
importantly, the provision was extended to direct descendants of those who were eligible for
reacquisition of Austrian citizenship on the basis of this provision, also without requiring the
renunciation of the original citizenship.34
Bulgaria
Bulgaria’s approach towards dual citizenship can be regarded as asymmetrical. A Bulgarian
citizen who acquires a foreign citizenship does not lose Bulgarian citizenship, whereas foreign
citizens who acquire Bulgarian citizenship through ordinary naturalisation are required to
renounce their original citizenship (Art. 12 para. 1 sub 6 Bulgarian Citizenship Act). In 2013,
several exception grounds were introduced to this renunciation requirement. This entailed that
spouses of Bulgarian citizens, citizens of an EU- or EEA Member State or Switzerland as well
as citizens of countries that Bulgaria has concluded bilateral agreements with were no longer
required to renounce their original citizenship (Art. 12 para. 2 Bulgarian Citizenship Act).35 In
addition to that, persons who acquired a Bulgarian residence permit by investment and
subsequently applied for naturalisation were exempted from the renunciation requirement and
could therefore retain their original citizenship upon naturalisation.36
Czech Republic
Czech Republic traditionally held a negative attitude towards dual citizenship. Since the
introduction of the Czech Citizenship Act in 1993, applicants for naturalisation were in
principle required to renounce their original citizenship, while Czech citizens automatically lost
their citizenship upon voluntary acquisition of a foreign citizenship.37 Although the prohibition
of dual citizenship was initially nearly absolute, several mitigating provisions for particular
groups were introduced thereafter, which made the country’s negative stance on dual
citizenship increasingly untenable.38 In 2013, the Czech Republic came to accept dual
citizenship, as the existing citizenship law was replaced by Act 186/2013 and the above30
See for an historical overview of Austrian citizenship law: Stern, J., Valchars, G., Country Report: Austria,
San Domenico di Fiesole: Globalcit Observatory, 2013, p. 4 ff.
31
Art. 10 par. 4 sub 2 Austrian Citizenship Act 1985.
32
Ibid.
33
Citizenship Amendment Act, Federal Law Gazette [Bundesgesetzblatt], 22 October 2019.
34
Ibid.
35
Law to amend and supplement the Law on Bulgarian citizenship, state Gazette [Държавен Вестник], No. 108,
17 December 2013.
36
Law to amend and supplement the Law on Bulgarian citizenship, state Gazette [Държавен Вестник], No. 16,
19 February 2013.
37
Art. 7 par. 1(b) and Art. 17 Act No. 40/1992 on the Acquisition and Loss of Citizenship of the Czech
Republic, via <https://www.refworld.org>.
38
Baršová, A., Country Report: Czech Republic, San Domenico di Fiesole: EUDO Citizenship Observatory
2014, p. 23.
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