Citizenship Loss and Deprivation in the European Union (27 + 1) diplomatic relations, and the Netherlands limits the scope to a “hostile state.” In half of the Member States providing for this mode of loss, it is nevertheless possible to enrol in the military forces of another country, either as long as the Member State does not ask the citizen to resign from the foreign army, such as France and Italy (liberal model), or if the Member State gives its express permission as in the case of Estonia, Germany, Latvia, and Lithuania (preventive model). The procedure is also equally divided between, on the one hand, lapse (i.e., by the sole effect of the law) in Austria, Germany, Italy, Netherlands, and Spain and, on the other hand, withdrawal in Cyprus, Estonia, France, Latvia, Lithuania, and Romania. Only Germany and the Netherlands formally forbid statelessness – Germany stating that the individual has to enrol in the army of a country whose nationality he or she possesses. Second, other services to a foreign country (L04) – mainly employment as a civil servant – are also a cause for loss of nationality in seven Member States (six of them among the eleven that already provide for the loss in case of military enrolment).77 Similarly, this mode of loss operates irrespectively of the mode of acquisition, except in Estonia and Spain which only apply this mode of loss to naturalised citizens. Working in the civil service of a foreign country is the operative event that triggers nationality loss in the majority of these Member States. Nevertheless, Spain limits the scope to political offices, Austria to services which “substantially damage [its] interests and reputation,” and Lithuania to an activity which “prejudices the state.” Yet, employment in a foreign state is permitted in France, Greece, Italy and Spain (liberal model) as long as the state does not ask the individual to resign. It is permitted if expressly authorised in Estonia and Lithuania (preventive model). The procedure applied is mainly withdrawal, only Italy and Spain allow for a lapse (i.e., automatic) procedure. There is no formal statelessness prohibition. (3) Legislation Regarding Lack of Merit or Disloyalty to the Country (L07 and L08) The second mode of loss of nationality relies on the disloyalty of citizens towards their state of nationality (behaviours related to the broad category of treason), but also on a certain idea of the moral value of citizenship, which causes a state to revoke the nationality of an individual in case of lack of merit (common crime for instance). 18 Member States revoke nationality in these situations.78 First, disloyalty (or treason) is the most frequent ground for nationality revocation (L07). This mode of loss is in force in 18 Member States, and this number is fast increasing (see above, 3.1.2.). Half of the Member States potentially target all citizens, regardless of the mode of nationality acquisition,79 and the other half target naturalised citizens, or more broadly citizens “other than by birth.”80 This distinction is mainly based on the long-standing idea that the loyalty of naturalised citizens (or even ‘naturalised aliens’) is always questionable (see above, 3.1.1.). Bulgaria and Slovenia, however, limit nationality revocation to dual nationals who habitually reside abroad. The operative event is crucial in this case: what does disloyalty mean for Member States? There is a clear distinction between administrative standards and criminal standards. An administrative standard is set by the government on the basis of vague notions and poor evidence, whereas a criminal standard means that the revocation is only allowed if the individual is first sentenced by a criminal court for a specific offence connected to the state, based on strong evidence (‘beyond reasonable doubt’). Some Member States such as Belgium and France have a mixed system with both administrative and criminal standards, where nationality revocation is possible both in case of conviction for a serious crime (e.g., terrorism), and in case of serious breach of the duties of a citizen (Belgium) or acts incompatible with the status of citizen (France), which are not related to criminal offences. Some Member States, such as 77 Austria, Estonia, France, Greece, Italy, Lithuania and Spain. 78 Belgium, Bulgaria, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Ireland, Italy, Latvia, Lithuania, Malta, the Netherlands, Romania, Slovenia, the United Kingdom. 79 Denmark, Finland, Germany, Greece, Latvia, the Netherlands, Romania, Slovenia and the United Kingdom. 80 Belgium, Bulgaria, Cyprus, Estonia, France, Ireland, Italy, Lithuania and Malta. European University Institute 19