528 S. POGONYI Recommendations acknowledge that states ‘may take preferred linguistic competencies and cultural, historical or familial ties into account in their decision to grant citizenship to individuals abroad’, unless non-resident citizenship is issued en masse (Bolzano/Bozen Recommendations on National Minorities in Inter-State Relations | OSCE, n.d., pt. art. III. para. 11). As a novelty, the Explanatory Report citing (and overstretching) the Nottebohm case explains that states should ‘refrain from granting citizenship without the existence of a genuine link between the State and the individual upon whom it is conferred’ (Nottebohm Case (Liechtenstein v. Guatemala); I.C.J 1955. 4. No. 18., n.d.; Peters, 2010; Sloane, 2008). In the HCNM’s 2012 Ljubljana Guidelines on Integration of Diverse Societies, the requirement of a genuine link recurs in a somewhat different context. According to this document, ‘citizenship should be based on a genuine link of the individual to the State’ (Ljubljana Guidelines on Integration of Diverse Societies | OSCE, n.d., para. 33.). It is also mentioned that international law limits states’ discretionary powers in citizenship policies, ‘including prohibiting discrimination when conferring citizenship’ (Ljubljana Guidelines on Integration of Diverse Societies | OSCE, n.d., para. 33.). While in the Bolzano Recommendations there was no indication of the possible interpretation of the normative principle, the Ljubljana Guidelines suggest that identity or residency can be regarded as legitimate proof of a genuine link between an individual and a state (Ljubljana Guidelines on Integration of Diverse Societies | OSCE, n.d., para. 32.). It is acknowledged that in addition to the ‘social dimension’, citizenship has an important symbolic value both for the state and the individual: ‘[i]t is a tangible signal of common belonging and of shared core values for both the holder of citizenship and the State granting it’ (Ljubljana Guidelines on Integration of Diverse Societies | OSCE, n.d., para. 32.). All of this suggests that genuine links entail either social bonds or symbolic ties between a citizen and the state. The Ljubljana Guidelines thus encourage states to facilitate the naturalization of individuals who have only symbolic, identitarian ties to the state. ‘The integration of society is facilitated by inclusive citizenship policies and rules that aim to welcome rather than exclude those who have a sense of belonging to that society.’ (Ljubljana Guidelines on Integration of Diverse Societies | OSCE, n.d., para. 32.) Due to this recognition of the subjective ‘sense of belonging’ as valid proof of genuine links, the Ljubljana document, probably contrary to its initial aims, opens up further possibilities for the naturalizing of individuals who have only symbolic ties rather than meaningful and tangible social attachments to the state. In line with the formulations of the ECN, the Ljubljana Guidelines stress the importance of non-discrimination, but add that the ‘facilitated acquisition of citizenship due to descent or place of birth’ should be considered a justified distinction. (Ljubljana Guidelines on Integration of Diverse Societies | OSCE, n.d., para. 32.). The Guidelines further expand legitimate favorable admission policies which can be used to include non-resident ethnic kin populations. In the document, the importance of non-discriminatory practices is mentioned only in connection with resident minorities. In the case of nonresident ethnic kin, however, preferential treatment is left unchallenged. The Ljubljana Guidelines state that the naturalization of non-resident individuals may be grounded not only in ‘preferred linguistic competencies’ but also in ‘cultural, historical or familial ties’ (Ljubljana Guidelines on Integration of Diverse Societies | OSCE, n.d., para. 36.). One can speculate that if the Europeanization of citizenship laws proceeds along the

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