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
ed for committing a serious crime against Belgium, as long as
this would not make you stateless.
Service in a foreign army or other
service
If you serve in a foreign army, you risk losing your citizenship
in 70 countries. Citizens in 52 countries can lose citizenship
in this way, while in 18 countries, such deprivation only
applies to certain groups of citizens, typically those who acquired citizenship by naturalisation. For example, in Chad,
naturalised citizens can be stripped of their citizenship for
holding a position in a foreign army. In some countries, you
can lose your citizenship when you provide military service
to hostile states, while in others, service to any foreign military puts your citizenship status at risk. However, in most
cases, a person can only be deprived of their citizenship if a
warning has been issued, and they fail to abandon military
service after that. In the Chadian case, for example, citizens
can only lose citizenship on this ground if they keep their
position in a foreign military for more than six months after
being instructed to resign.
Providing other (non-military) services to a foreign state can
sometimes also lead to the loss of citizenship. Depending on
the country, such measures can be imposed for holding a foreign elected office, working for certain foreign state agencies,
or even accepting a civil service position in another country
in general. The loss provision is applicable to all citizens in
45 countries, while in 30 countries, it only applies to certain
groups of citizens, typically those who acquired citizenship
by naturalisation. Just as with military service, the provisions
often state that you can only be stripped of your citizenship
if a warning has been issued first that you must resign from
your position, and you subsequently fail to comply.
Disloyalty, state security, or other
offences
Citizens can have their status revoked for acts seen as disloyal to the state or acts that threaten national security or
a country’s constitutional order in many countries globally.
This includes crimes like treason, espionage, or attempting
to overthrow a country’s government. Joining a terrorist organisation is also a common example of the kind of conduct
that can trigger the revocation of citizenship. The provision
is applicable to all groups of citizens in 43 countries, while
in 89 countries it is restricted to certain groups of citizens
(usually citizens by naturalisation). For example, if you are
a Belgian national and you acquired your citizenship other
than by birth, you can be deprived of your citizenship if you
violated your duties as a national or if you have been convict27
Citizens can only lose their citizenship if a court has convicted them of a crime against the security of the state or a crime
against the interests of the state in a large share of countries.
In other states, harming state security or state interests can
be sufficient reason for loss of citizenship even without a
prior conviction. In some cases, it is specified which acts can
lead to citizenship stripping, such as in Germany, where you
can lose your citizenship if you have been actively fighting
for a terrorist militia abroad. However, in most cases, the
provisions are broad and rather ambiguous, referring to acts
as “serious crimes against the country” (Bulgaria) or acts that
“harm the country’s prestige” (Vietnam). These provisions
tend to be particularly broad in scope if only naturalised citizens are affected.
You can lose your citizenship due to criminal offences in 79
countries. Usually, this will be the case for those persons who
are convicted of a serious crime. In many of these countries,
a person can only be stripped of their citizenship if they have
been sentenced to imprisonment for a certain period, ranging from twelve months to ten years. This loss provision is
applicable to all citizens in four countries, while it is restricted to certain groups of citizens (usually citizens by naturalisation) in 75 countries. In the countries where the provision
is applicable only to naturalised citizens, the crime must
usually have been committed within a certain time period
after citizenship was acquired (e.g. five or ten years). Once
this period has passed, a criminal conviction can no longer
undermine one’s citizenship.
Citizenship stripping: A violation of
international standards?
Security-related deprivation of citizenship creates a risk of
arbitrary deprivation of citizenship, which is generally considered to be contrary to international customary law. An
analysis of the GLOBALCIT data raises concerns about the
possibility of citizenship stripping without due process, particularly in cases where the procedure is a lapse rather than
by an act of deprivation. The broad and ambiguous wordings of many provisions may also give way to citizenship
stripping without a legitimate purpose or disproportionate
effects. Contrary to international standards as outlined in
the Principles on Deprivation of Nationality as a National
Security Measure, many states’ loss provisions do not provide for adequate safeguards against statelessness. This can