Report on Citizenship Law: Germany critique in the literature (Sturm 2008: 129) the Act contained 24 amendments to the nationality law. Critics argued that the combination of implementation of EU legislation with a somewhat controversial amendment to the nationality law was a tactical instrument to facilitate the adoption of a ‘package-deal’ which most deputies were neither willing nor able to raise openly (Sturm 2008: 129, 130). Some of the legislative changes were—although not required by changes to the immigration law—indirectly related to immigration law, such as increased integration requirements, which had been introduced by the immigration law reform of 2004. The focus of the legislative amendments was clearly on new provisions on the acquisition of German nationality by treatment as a German national for 12 years. According to the new Section 3 para. 2, German nationality is acquired by someone who has been treated by the German authorities for 12 years as a German national regardless of permanent domicile in Germany.21 The acquisition is valid ex tunc, dating back to the time at which German authorities for the first time treated a person as a German national, for instance at the occasion of a marriage, birth, adoption or naturalisation. Section 3 para. 2 mentions as relevant official acts the issuance of a nationality certificate or passport or identity card. The acquisition is also valid for descendants who derive their nationality from the person having acquired German nationality by way of being treated as a German national. A further requirement is that the person in question is not responsible for the error of the authorities.22 In order to acquire German nationality by factual treatment as a German national, it is necessary that the person in question did not intentionally or by negligence cause the error. The explanatory comments to the draft legislation23 mention as examples the deceit or the concealment of relevant facts such as the reacquisition of a former nationality without having permission to maintain the German nationality according to section 25 para. 2 of the nationality law. Descendants having acquired German nationality by factual treatment cannot be made responsible for deceit or concealment by their parents (Sturm 2008: 131). A second major topic was the change in the naturalisation requirements relating to standards of knowledge of the German language and the adoption of integration tests. The Federal Administrative Court in a judgment of 20 October 200524 decided that in order to fulfil naturalisation requirements an applicant did not need to be able to write German provided that he or she was able to understand a simple text of daily life and to dictate letters in German (for a critical review see Hailbronner 2007: 201; Münch, 2007: 236). The amendment now requires sufficient knowledge of the German language by providing a certificate in German at level B of the Common European Reference Framework for Languages. Thereby it has been clarified that certain standards of oral as well as writing capacities are necessary in order to prove sufficient knowledge of the German language.25 There are exceptions for older people and juveniles, for sick persons and disabled persons. Persons beyond 16 years of age need to prove only language knowledge corresponding to his or her age. Older people, sick and disabled persons may be dispensed of the requirement to prove sufficient knowledge of the German language if they are not able to participate at language courses or acquire the language certificate. New requirements are laid down in section 10 on the right to naturalisation. Whether corresponding requirements are also applicable with respect to a discretionary naturalisation 21 For a historical model in the Prussian nationality legislation of 2 July 1812 which, however, has based the acquisition of a status as a Prussian subject on persons who had been settled for at least ten years in one of the Prussian states see Sturm, Das Standesamt 2008, p. 130 at fn. 11. 22 In German: ‘und dies nicht zu vertreten hat.’ 23 BT-Drs. 16/5065, p. 227. 24 BVerwGE 124, 268, 273. 25 See Sect. 10 para. 4, 2. sentence of the nationality law. 10 RSCAS/GLOBALCIT-CR 2020/5- © 2020 Author(s)