Citizenship Loss and Deprivation in the European Union (27 + 1) with the armed forces or a comparable armed organization of a foreign State whose citizenship he or she possesses.” This very limited possibility to revoke someone’s nationality for lack of loyalty comes from a firm liberal commitment of the German Federal Republic in the aftermath of the Second World War, during which the Nazi regime massively resorted to nationality revocation.47 But this liberal and restrictive approach to citizenship deprivation was recently abandoned. This limited provision for nationality revocation in case of enlistment in a foreign army did not allow German authorities to revoke the nationality of those who engage in terrorist activities with non-state actors. This is why the German government decided to propose the extension of the provisions of the German Nationality Act in order to allow for the revocation of the nationality of disloyal citizens, especially in case of terrorist activities.48 The legislator amended section 28 of the 2019 Third Act Amending Nationality Law49 by adding a new paragraph stating that the German citizen “who actively participates in fighting with a terror organization abroad loses German citizenship unless he or she would thereby become stateless.” Similarly to the United Kingdom, it was precisely the intent of the government to use nationality revocation to prevent citizens currently abroad from returning to national soil. The general observations accompanying the bill drafted by the federal government stated explicitly that the loss of nationality was designed to target “fighters [who] are still in the remaining bastions or retreats of IS.”50 It seems, however, that German authorities have not yet used this new possibility. Contrary to Germany, France did not succeed in reforming its laws on nationality revocation. France’s legislation already allows the government to revoke the nationality of a citizen who has been convicted of terrorist acts. However, this provision, laid down in article 25 of the civil code, only targets naturalised citizens. In 2015, following the Paris attacks, President Hollande proposed to amend the constitution to authorise the revocation not only of naturalised citizens, but also of birthright citizens, in order to achieve full equality between citizens. Again, following the United Kingdom’s lead, French authorities planned to amplify banishment measures. The government’s observations accompanying the constitutional reform specifically stated that “[t]he extension of French nationality revocation cases will contribute furthermore to reinforce the protection of French society by allowing, inter alia, a long-term removal, through expulsion measures, of persons with a proven dangerous character […] and to forbid their return to the territory.”51 This reform, however, did not pass. The Assemblée Nationale, the French lower chamber, accepted the idea of nationality revocation targeting both naturalised and birthright citizens. The majority considered this reform as a suitable tool to no longer discriminate naturalised citizens in this respect and, consequently, as a major step towards equality among citizens. The majority also refused to provide for any safeguards against statelessness in the constitutional reform, because to do otherwise would have created another inequality, this time between people with dual and single citizenship. To achieve full equality – i.e., not only between naturalised and birthright citizens, but also between individuals with single and dual citizenship – the deputies were thus ready to pass a constitutional law without any formal safeguard against statelessness.52 The Senate, the French upper chamber, whose agreement is needed to pass a 47 A second important protection was the so-called “Inlandsklausel” that was in force until 1999 and did not allow for the revocation of nationality of Germans residing in Germany, see below 3.2.3.(2). 48 Gärditz, K.-F. and A. Wallrabenstein (16 June 2019). “Staatsangehörigkeit in Geiselhaft.” VerfBlog. Retrieved from here. 49 Drittes Gesetz zur Änderung des Staatsangehörigkeitsgesetzes, Federal German Law Gazette (BGBl), 8 August 2019 I(29), 1124. 50 Deutscher Bundestag (29 April 2019). Gesetzentwurf der Bundesregierung. Entwurf eines Dritten Gesetzes zur Änderung des Staatsangehörigkeitsgesetzes (Report No. Drucksache 19/9736), 7. Retrieved from here. 51 Assemblée Nationale (23 December 2015). Projet de Loi Constitutionnelle de Protection de la Nation. Exposé des Motifs (Report No. 3381), 6-7. Retrieved from here. 52 The Prime Minister Manuel Valls promised, in the eventuality of the adoption of the constitutional reform, that the government would launch the ratification process of the 1997 European Convention on Nationality (which fully prohibits statelessness in case of nationality revocation). European University Institute 11