Luuk van der Baaren
2. Citizenship constellations
So far, this report has analysed national restrictions of dual citizenship taken separately.
However, dual citizenship can only occur if two states concurrently permit dual citizenship.
Therefore, provisions related to dual citizenship should be studied in cohesion, or as ‘citizenship
constellations’. The term ‘citizenship constellations’ was coined by Bauböck and aims to “[…]
[bring] into view how host and home countries create a web of legal and political ties with
migrant and ethnic kin groups that also affects intergovernmental relations and public policy
reform in each country”.20
The concept of citizenship constellations will be applied in this report in order to outline
the extent of dual citizenship acceptance in the European Union. Although the concept has a
broader connotation, it will be used here in a narrow sense, focusing on the interactions between
legal provisions in receiving countries and sending countries that potentially restrict dual
citizenship. More precisely, the interactions between provisions requiring the renunciation of
the original citizenship upon acquisition of citizenship (A05-A27) and provisions imposing the
(automatic or non-automatic) loss of original citizenship upon acquisition of another citizenship
(L05) will be studied for the 28 EU Member States. Thereby, it will be elucidated whether both
the receiving country and the sending country in a particular citizenship constellation allow for
the occurrence of dual citizenship. One could argue that studying the acquisition of dual
citizenship among EU Member States is a needless exercise, as the status of EU citizenship
already grants a ‘bundle of rights’ across all Member States (see Section 2). However, as will
be shown below, the number of EU citizens acquiring citizenship of another Member State is
far from negligible, and therefore deserves special attention.
In Table 2, each cell depicts whether a state (referred to in column) requires the
renunciation of origin citizenship upon acquisition of citizenship and whether a state (referred
to in row) imposes the loss of original citizenship upon acquisition of another citizenship on
the reference date of 31 December 2018. If the renunciation of the original citizenship is not
required in any case for that particular constellation and if the loss of citizenship upon
acquisition of another citizenship is also not imposed in any case for that particular
constellation, the cell is marked grey. In all other cases, the cell is unmarked. An important
caveat is that many important nuances of dual citizenship restrictions cannot be taken into
account in this manner. For example, certain states (e.g. the Netherlands and Spain) do not
restrict dual citizenship for all relevant modes of acquisition of citizenship (A05-A27), but only
for some of these modes. Other states (e.g. Austria) in principle restrict dual citizenship, yet
permission can be granted for the retention of citizenship in individual cases. Therefore, if a
cell has remained unmarked, this merely indicates that dual citizenship is potentially restricted
for a particular constellation.
In order to also depict the numerical significance of each citizenship constellation, the
number of persons who acquired citizenship in the reference year of 2018 is depicted for each
particular constellation on the basis of data provided by Eurostat on the acquisition of
citizenship.21 Another caveat is necessary here, as it has remained unclear which data
citizenship acquisitions is provided to Eurostat by EU Member States, as the data requirements
20
Bauböck, R., “Studying citizenship constellations”, Journal of ethnic and migration studies, Vol. 36, No. 5,
2010, p. 849.
21
European Commission, “Acquisition of citizenship (2018)” [data file], Eurostat, 2020, via
<eurostat.ec.europa.eu>.
RSCAS/GLOBALCIT-Comp. 2020/4 - © 2020 Authors
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