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
result in an extremely precarious situation for the affected
persons and their dependents.
stripped of his citizenship, as he only had Dutch citizenship.
The Dutch-Turkish citizen stated during the court hearings
that he intended to renounce his Turkish citizenship in an
attempt to make the loss of Dutch citizenship impossible.
Finally, the Dutch-Moroccan citizen would be unable to do
this, as Moroccan authorities rarely allow their citizens to
renounce their citizenship. The court ruled that the distinction between mono-nationals and dual nationals amounted
to a violation of the prohibition of discrimination based on
ethnic origin. For that reason, the Dutch government could
not revoke the citizenship of a person convicted of terrorism-related crimes. The Dutch government has announced
that it will appeal the decision.
Citizenship stripping provisions often target specific groups
– typically individuals who were not born as citizens – resulting in discriminatory treatment. This selective application effectively creates a hierarchy of citizenship, where
naturalised citizens are subjected to greater insecurity compared to citizens by birth. Such discriminatory treatment
remains widespread; provisions for loss of citizenship due
to disloyalty only apply to certain groups of citizens in 47%
of countries. Dual nationals face an additional form of discrimination in countries where revocation provisions apply
exclusively to them. While this limitation is intended to
prevent statelessness, it also means that only a segment of
citizens – predominantly with a migration background – is
exposed to the risk of citizenship deprivation. Moreover, the
dataset also makes clear that in several countries, renouncing
citizenship is either legally prohibited or practically unfeasible. For individuals who hold dual nationality involuntarily,
this imposed status may become a liability, as it increases
their vulnerability to citizenship stripping.
Recent changes
Countries regularly adapt citizenship stripping provisions in
response to perceived threats and shifting political or security contexts. A notable example is Latvia, where citizenship
can be revoked if an individual serves in the armed forces or
security services of a foreign state. In 2022, however, an exception was introduced to permit Latvian citizens to work
with Ukrainian military forces or governmental institutions
without risking loss of citizenship. This illustrates how citizenship revocation policies can evolve in response to international developments. Similarly, references to terrorism have
increasingly appeared in citizenship stripping provisions,
particularly across Europe. A new study shows that prior to
2001, such references were virtually absent; by 2022, however, over one-third of all European citizenship revocation
provisions explicitly mentioned terrorism-related grounds,
The Dutch citizenship stripping provisions have been criticised for this reason, as they only affect dual citizens. A recent
Amsterdam District Court case illustrates this perfectly. The
case concerned three persons who were convicted of similar (terrorism-related) crimes: a Dutch citizen without any
other nationality, a Dutch-Turkish citizen, and a Dutch-Moroccan citizen. After the three had served their sentences,
the Dutch authorities revoked the citizenship of the latter
two. The person with only Dutch citizenship could not be
4.3 DISCRIMINATION BY CITIZEN CATEGORIES, IN SELECTED MODES OF CITIZENSHIP DEPRIVATION
Share of countries with discriminator y provision in citizenship law | 191 countries | 2024
Service in foreign army
9%
Other service to a foreign country
16%
Other offences
39%
Disloyalty or state security
47%
18
30
75
89
No. of countries
Source: Caption: Source: GLOBALCIT Citizenship Law Dataset, v3 | modes L03-L04, L07-L08
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