Comparative Report
Trends in Birthright Citizenship in EU 28 2013-2020
Merve Erdilmen and Iseult Honohan
1. Introduction
Citizenship is an important status: it guarantees security of residence in and a right to re-enter
the state, and it is the ground for many social and political rights. While each country is
sovereign over its own citizenship laws, citizenship of an EU Member State also provides EU
citizenship and the additional rights and privileges that entails. How Member States provide
for acquisition of citizenship is thus of crucial importance.
The overwhelming majority of citizens of EU Member States acquire their citizenship
on the basis of birth. This is primarily through descent from a citizen (ius sanguinis), while
some Member States also award citizenship based on birth in the country (ius soli). The
distribution of, and trends in, birthright provision are thus important to identify, even if
birthright citizenship is currently less controversial than other modes of citizenship acquisition,
whether this be the long-standing procedure of immigrant naturalisation based on residence,
present in most countries, or more specific provisions, such as for investors, that some Member
States have recently introduced.
This report considers trends in birthright citizenship in the European Union Member
States from 2013 to 2020, taking the laws in force on 1 January 2013 and 1 January 2020.1 We
examine birthright citizenship in its two forms: first, through descent from a citizen and second,
through birth in the state. In each, citizenship can be awarded either unconditionally, or only if
certain conditions are met. The procedure for acquiring citizenship can be automatic, or it can
require registration or more complex procedures. While some Member States award citizenship
by birth almost exclusively through ius sanguinis, others combine this with some ius soli
provision, though this tend to be more conditional and less often to apply automatically.
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The EU Member States included here are: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic,
Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg,
Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom. Croatia
joined the EU on July 1 2013; its legislation is included on the same basis as the other countries. The United
Kingdom is included, as it was a member of the EU on 1 January 2020. The data is drawn from the 2020 update
of the GLOBALCIT Global Database on Modes of Acquisition of Citizenship for 2016: GLOBALCIT (2017).
Global Database on Modes of Acquisition of Citizenship, version 1.0. San Domenico di Fiesole: Global
Citizenship Observatory / Robert Schuman Centre for Advanced Studies / European University Institute. Last
accessed at: http://globalcit.eu/acquisition-citizenship/,19 February 2020. A comparative analysis of birthright
citizenship provisions among continents may be found I in Honohan, I. and Rougier, N. Global Birthright
Citizenship Laws: How Inclusive?.Neth Int Law Rev 65, 337–357 (2018). https://doi.org/10.1007/s40802-0180115-8
RSCAS/GLOBALCIT-Comp. 2020/2 - © 2020 Authors
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