UK Citizens as Former EU Citizens: Predicament and Remedies 157 European citizenship is more than a body of rights which, in themselves, could be granted even to those who do not possess it.’ Coupled with the Zambrano ratio (above), the question is: how can the predicament arising from UK citizens’ loss of EU citizenship status and rights be addressed?  utomatic/accelerated naturalisation of UK citizens (residing) A in other member states Politicians in Germany24 and Italy25 were reported to have suggested naturalisation of ‘young’ Britons residing in their respective states, and many Britons have (individually) started searching for a nationality link, most notably to Ireland26. Now, it is within the gift of Member States to determine their naturalisation criteria, and requires no treaty change; the UK tolerates acquisition of other nationalities. However, notwithstanding their well-intentioned premises, such proposals pose substantive challenges: First, they will inevitably lead to divergent treatment of UK citizens across the Union, as some states will not relax their naturalisation requirements to accommodate UK citizens. Second, relaxation of naturalisation requirements (which may include citizenship tests) on an ad hoc basis for one national group may be deemed unjustified. In this context, it is noteworthy that the Union generally encourages states that do not permit dual nationality to relax their objections in relation to the acquisition of the nationality of another Member State (Germany, for instance, generally requires its nationals to obtain permission before acquiring another nationality, save in the case of another EU Member State or Switzerland). In contradistinction, the Maltese ‘citizenship for sale’ (see EUDO debate27) caused a degree of discomfort; hence, doubts could be raised as to the 24 25 26 27 ‘German politicians propose offering young Britons dual citizenship’, The Guardian, 3 July 2016, available at https://www.theguardian.com/world/2016/ jul/03/german-politicians-propose-offering-young-britons-dual-citizenship. ‘Italy’s Renzi suggests “ad hoc” citizenship for young Britons abroad’, EBL News, 29 June 2016, available at https://eblnews.com//news/europe/ italys-renzi-suggests-ad-hoc-citizenship-young-britons-abroad-27245. ‘Huge rise in Britons applying for Irish citizenship after Brexit vote’, The Guardian, 13 October 2016, https://www.theguardian.com/world/2016/oct/13/ huge-rise-in-britons-applying-for-irish-citizenship-after-brexit-vote Shachar, A. & R. Bauböck (eds.) (2014), ‘Should Citizenship be for Sale?’, Robert Schuman Centre for Advanced Studies EUDO Citizenship Observatory Working Paper 2014/01, Florence: European University Institute, available at http://cadmus.eui.eu/bitstream/handle/1814/29318/RSCAS_2014_01. pdf?sequence=1.