T H E G L O B A L S TAT E O F C I T I Z E N S H I P
In 33 countries, whether or not a child born in the country
becomes a citizen will depend on additional requirements.
A child born to foreign parents may become a citizen if their
parent is born in the territory or fulfils a certain residence
requirement. For example, a child born in Germany is automatically a German citizen if one of the parents has legal
residence there for five years before the child’s birth. For
countries that mainly rely on descent-based transmission
of citizenship, this additional form of territorial birthright
citizenship ensures that the children of immigrants are also
included in the nation. Interestingly, in Germany, the residence requirement for parents was lowered from eight to five
years before the child’s birth, as part of a broad ‘modernisation’ of German citizenship law in 2024. In section 3 of
this report, we discuss more extensively how countries have
adjusted their citizenship laws (or failed to do so) to the phenomenon of immigration.
1.4 DIFFERENT PATHWAYS TO CITIZENSHIP
Beyond birthright
All states specify the grounds for birthright citizenship in
their laws, but they do so in different ways, mixing the principles of descent and territory. Beyond birthright, in most
countries, there are other pathways to become a citizen. In
this section, we map these pathways, as well as the ways to
lose citizenship.
Descent (birth abroad)
191
Residence-based acquisition
177
Marriage
171
Reaquisition
160
Descent (birth in country)
158
Foundlings
139
Child coaquisition
130
Special achievements
129
Adoption
122
Otherwise stateless (birth in country)
93
Birth in country
82
Birth in country (acq after birth)
60
Stateless
60
Spousal coacquisition
53
Cultural affinity
52
Citizen of specific country
50
Establishment of parentage
48
Refugees
42
Public service
40
No. of countries
Frequency of 20 selected acquisition grounds across 191 countries
| 2024
Source: GLOBALCIT Citizenship Law Dataset, v3, selected modes
Finally, in a smaller group of countries, the law opens up a
pathway to citizenship for economic investors, something
that is frequently considered a controversial ‘sale of passports’.
Ways to acquire citizenship
When a person becomes a citizen of a country other than
by birth, this is what we understand by ‘naturalisation’.
Ordinary immigrants living in a country other than the one
in which they were born can naturalise after some period
of residence in most, but not all, countries. Though, as we
discuss in further detail in section 3, the requirements vary
greatly country-by-country. Those who are married to a citizen often also benefit from facilitated access to citizenship,
in terms of shorter residence periods or fewer requirements.
However, several countries discriminate on the basis of
gender, with facilitated citizenship for wives but not husbands of citizens. We discuss discriminatory rules like these
in section 2 of the report.
In the Americas, where countries apply territorial birthright
to children born in their territory without any further conditions nearly universally, there is less need to formulate special
acquisition grounds. For example, in Uruguay, one can only
acquire citizenship by being born in the country or abroad
to a Uruguayan. In Europe, by contrast, being born in the
territory of a country typically does not entail an unconditional right to citizenship; at best, this will depend on the
residence status or place of birth of one’s parents. The laws
of European countries, therefore, often include compensatory clauses for a lack of territorial birthright that ensure that
the children of migrants have facilitated access to citizenship.
For example, children as young as three years old who have
lived in Sweden for that period can become Swedish, even if
they were not born there. This is considerably easier than in
Denmark, where one can only naturalise at the age of 18, if
they have lived there since their 15th birthday and had their
education in Denmark.
Beyond these general rules, some states facilitate citizenship
on ‘special’ grounds, such as the acquisition of citizenship by
former citizens (‘reacquisition’), adopted children, refugees,
stateless persons, as well as persons considered to have made
an extraordinary contribution to the country, for example in
sports, the arts or science (‘special achievements’).
8