Exploring the Interface Between Birth Registration and Citizenship Determination: A Scoping Study in Seven Countries in Southern Africa i. Citizenship Legal Concepts Principles of Citizenship: Jus Soli and Jus Sanguinis The two main principles of citizenship are jus sanguinis (right of blood) and jus soli (right of the soil). Under the principle of jus sanguinis, citizenship is determined based on the citizenship of one or both parents. If a country follows jus sanguinis, a child may acquire citizenship through their parent or parents. In some countries that follow jus sanguinis, citizenship may also be based on the citizenship of grandparents. In countries that follow the principle of jus sanguinis, the constitution or citizenship law commonly set out the conditions that must be met in addition to the citizenship of the parent. For example, children born abroad may need to establish or demonstrate certain ties to the country. Under the principle of jus soli, citizenship is granted based on the place of birth. If a country follows jus soli, a child born within the territory of that country is automatically a citizen of the country, regardless of the citizenship of the child’s parents. Many countries use a combination of both principles, with different rules and exceptions. For example, some countries have rules where children born to foreign parents can acquire citizenship at birth if their parents have resided in the country for a certain period (e.g., 3-10 years). This is referred to as conditional jus soli. In some countries, children born to foreign parents can acquire citizenship at birth if at least one of their parents was also born in the country, which is referred to as double jus soli. Modes of Citizenship Acquisition Two major modes of citizenship acquisition exist: acquisition of citizenship at birth and acquisition of citizenship through various naturalization procedures. The first mode of acquisition, "citizenship at birth," refers to the legal principle where citizenship is automatically granted to individuals when they are born,11 either based on their place of birth (jus soli) or the citizenship of their parents (jus sanguinis). In legal terms, this is referred to as attribution of citizenship at birth. Citizenship at birth usually occurs through the “operation of law,” which means that the process is automatic and there is no application process required.12 As there is no application process to establish citizenship at birth, birth registration is needed as evidence of the attributes that convey automatic acquisition of citizenship, including information about place of birth and parentage. Later in life, other authorities merely affirm citizenship status when providing documents such as a passport, voter registration card, or other document exclusive to citizens.13 The second mode of citizenship acquisition is naturalization, which is the legal process by which a person who is not a citizen of a country becomes a citizen of that country. This usually occurs later in life and is based on an application process with the requirements set out in national law, which may involve having a strong connection to the country, such as marriage to a national or long-term residence. National laws may differentiate between “attribution” of citizenship (automatic at birth) and “acquisition” of citizenship (naturalization based on an application). This distinction between “attribution” and “acquisition” is explicit in the language used in the laws of some countries. 11