How To Get EU Citizenship, Country By Country
by Mitch Edgeworth
One of the great things about New World countries like the USA, Canada and Australia is that we’re all melting pots of different races and cultures; most of our ancestors came by sea to start a new life in the land of opportunity. Many of us think that being the descendants of pioneers, convicts and refugees just means we have a grandparent with a funny accent and stories about the old country. Not so! Under the right circumstances, your heritage can be your ticket to European citizenship.
How does this work? New World countries tend to be founded on the ideal of multiculturalism: the principle that race is irrelevant when it comes to what makes a citizen. European countries, on the other hand, often have old-fashioned ideas about the importance of ethnicity to a community. In legal terms these differences are known as jus solis (right of soil) and jus sanguinis (right of blood). For example, I’m an Australian citizen who was able to register as an Irish citizen because my grandparents were born in Ireland. I have a certificate and a passport and everything, even though I’ve never been there. Obviously this is ridiculous, but I’m not complaining.
Maybe you don’t think your grandfather’s birth in East Gradzykystan is all that appealing; maybe you don’t want to go to East Gradzykystan and live in a Soviet housing block eating boiled potatoes. You may, however, find that your obscure European country of origin is a member of the European Union. And that opens all kinds of doors, since every citizen of every EU member state has the right to live and work in every other EU member state, which is how I’ve used my Irish passport to come and live in the nation of my grandparents’ brutal oppressors. I chose Britain because it has an okay economy and I only speak English, but legally speaking, I’m perfectly entitled to go study at the University of Stockholm or open a bar in Barcelona or retire on a Greek island.
The trouble is that when it comes to letting their emigrants’ offspring claim citizenship, every country has its own rules. Some are generous, some are jerks, and it’s luck of the draw as to which ingredient your ancestors were in the melting pot. Let’s take a look at some of the nations which the average New Worlder might find further up their family tree.
We’ll start with Ireland, because that’s the one I have direct experience with, not to mention one of the largest European diasporas: census data indicates that the US, Canada and Australia all have Irish heritage populations of above 10%.
Anybody whose parents were born in the Republic are automatically Irish citizens even if, like my Dad, they have to chase up some paperwork to prove it. Anybody whose parent is one of these automatic citizens can apply to become one, like I did. So, effectively, anybody with a single grandparent born in Ireland — including, in some cases, Northern Ireland — can easily become an Irish citizen. Just ask your consulate for the forms, and start hunting for three generations of documentation.
If you later have kids, you can register them as citizens too, creating a self-perpetuating chain of Irish citizens that have never been to Ireland. Just make sure you get your own citizenship before becoming a parent. It doesn’t work if they’re born beforehand.
THE UNITED KINGDOM
Before we start here, let me point out something that a lot of people, including British people, don’t seem to grasp: England, Wales, Scotland and Northern Ireland are not nations. They’re all part of the UK, which is a nation. Yes, I know each of them has its own laws and parliaments, but that’s irrelevant on the global stage. They all have the same prime minister, the same Queen, the same currency, the same passport, and they all get legal assistance from the same consulate in Thailand when they get caught with five kilos of hash in their backpack. The Republic of Ireland — that is to say, the southern part of Ireland — is not part of the UK. They fought a war over it and everything like a hundred years ago.
Anyway, that’s what spells bad news for people with British grandparents, because the Republic is way more generous than the UK when it comes to citizenship. British nationality law stipulates that you must have a British parent, and furthermore, that parent must be British-born, not a citizen by descent. Having lived in Britain for some time now I can assure you that this is the product of a feverish national imagination which believes itself to be far more attractive to foreign welfare vampires than it really is.
The only exception this is if your grandparent was born in Northern Ireland. As mentioned above, this may also make them a citizen of the Republic. They must have been born prior to 1922; if they were born after 1922, they must have a parent who was a citizen of the Republic.
Incidentally, the best part about being Irish is that thanks to the Common Travel Area, Irish and Brits have freedom of movement to each other’s countries entirely independent of the EU. So if the UK eventually follows through with the stupid in/out referendum certain politicians keep throwing a tantrum about, the Irish will suddenly have more freedom of movement rights than any other nation in Europe.
Probably the most common Continental heritage in North America and Australia. Unfortunately, Italy’s citizenship law makes Britain and Ireland’s look like microwave meal instructions. Italian nationality law is a frustrating and somewhat sexist minefield of dates and conditions largely because Italy is one of the few countries which, at least for a time, took issue with its emigrants adopting the citizenship of another nation. In other words, if Nonna and Poppy took the Pledge of Allegiance in New York back in the 1960s, you may be out of luck. Theoretically, anybody with a grandparent born in Italy can claim citizenship, just as a prospective Irish citizen can. In fact, Italy is even more generous: you can even claim citizenship through an Italian-born great-grandfather on either side. (But not a great-grandmother. See? Sexist.) In practice, the complicated tapestry of international emigration and nationality law might complicate things.
That’s what the law says on paper, anyway. The good news is that in practice, all my anecdotal evidence, ranging from forum posts to my Italian-Australian cousins, suggest you’ll have no trouble applying for Italian citizenship through your grandparents. Italy generally seems to be perceived along with Ireland as one of the easier countries in which to find a back door into Europe. Check with your grandparents and your local consulate. If you’re told you’re not eligible, maybe get a second opinion.
As with Ireland and Italy, anybody with a grandparent born in Greece is theoretically entitled to claim Greek citizenship. It’s just much more of a pain in the ass. Greece is one of those countries that’s pretty upfront about bloodlines and ethnicity and that sort of thing, and what they really want to see is lots of documentation. And unlike Ireland, the Greek government offices that deal with that stuff are way more localised and Balkanised. So instead of contacting a central government department in Athens, you’re going to be chasing up birth and marriage certificates from local municipality offices in remote mountain villages or sleepy islands.
If you succeed, a word of warning: Greece is one of the few European countries that still has mandatory military service for males aged 19–45. Protesting that you’re “really” an American or a Canadian isn’t going to cut much ice with the authorities when you’re holding a Greek passport; dual citizenship has both advantages and disadvantages. (Or “responsibilities,” as Greece would put it). I’m not sure what would happen if you simply used your Greek passport to access the rest of the EU and stayed out of Greece itself.
Having said that, if the idea of military service doesn’t put you off, it appears that any ethnic Greek — like, even if you’re a fifth-generation emigrant — can join the Greek military, and that this is a quick path to naturalisation and thus citizenship of the entire EU. Worth considering if you’re into that sort of thing. This also applies to any foreigners, even of non-Greek descent, who are accepted as a monk at any of the monasteries at Mt. Athos. But that sounds pretty stringent. Maybe stick with the army.
Like Britain, Germany is a nation which isn’t interested in your grandparents and will only give you citizenship if your mother or father was a citizen. It has one interesting exception, however, which involves bringing up Germany’s awkward past. Article 116 of Germany’s constitution is an allowance to make amends for the persecution of millions of Germans between 1933–1945:
Former German citizens who between January 30, 1933 and May 8, 1945 were deprived of their citizenship on political, racial, or religious grounds, and their descendants, shall on application have their citizenship restored. They shall be deemed never to have been deprived of their citizenship if they have established their domicile in Germany after May 8, 1945 and have not expressed a contrary intention.
In practice this is most likely to apply to the descendants of German Jews who successfully fled the Nazis and resettled in more welcoming countries, of which I imagine there are quite a few, especially in the United States. It can also theoretically apply to the descendants of German citizens who fled because of their sexuality, ethnicity or political alignment. The phrase “established their domicile in Germany” is concerning, suggesting you have to live there first, but Michel Lemberger wrote a piece about how she successfully reclaimed her right to German citizenship, via her grandparents, despite living in California.
Poland is much like Italy, in that it has a massive diaspora in the US (an estimated 3% of the population) and also has generous but quite complicated rules about claiming citizenship, revolving around “unbroken succession.” The key in Poland seems to be a fixation with military service, which was compulsory until 2009. Effectively, if your Polish ancestor became a naturalised citizen of another country after 1951, when a new law permitting dual citizenship was introduced, you should be eligible to claim citizenship. If they became a foreign citizen before 1951, it was considered to be a renunciation of their Polish citizenship, which breaks the line of succession. However, Poland also seems to have considered citizenship for its male citizens to be unrenounceable if they had military service obligations. So you may still be eligible to claim Polish citizenship even if Grandpa Kowalski helped Patton liberate France.
If you can get around this headache of conflicting laws and regulations, Poland is also, like Italy, fairly generous with the length of its succession. A great-grandparent born there can be enough to get you citizenship.
Hungary updated its nationality law in 2011 to permit anybody with Hungarian ancestry, including great-grandparents, to claim citizenship by descent. To the ire of the rest of the European Union, the vast majority of applicants were ethnic Hungarians living in neighbouring non-EU states like Serbia and Ukraine. But the opportunity is open to people anywhere in the world who can prove they had a Hungarian ancestor.
The catch is that you have to speak at least a rudimentary level of Hungarian and pass a language test. Hungarian probably wasn’t on your high school curriculum, and apparently it’s one of Europe’s more difficult languages. So it may depend on how badly you want to join all those Serbs and Ukrainians exploiting the law and violating Europe’s precious, precious borders.
Nominally one of those snooty countries that only hands citizenship out if your mother or father was Spanish-born, but with a guilty exception like Germany to atone for its fascist past. As usual there’s a lot of fine print, but if you have a Spanish ancestor who left Spain between 1936 and 1955 (i.e., during the years of the Spanish Civil War and the ensuing dictatorship), you’ve got a good chance of claiming Spanish citizenship.
LITHUANIA, LATVIA & ESTONIA
These smaller Baltic nations don’t have a lot of information on their nationality laws floating around the internet, because they don’t have a large diaspora and therefore a large contingent of foreigners talking about how to access the EU. I include them because they appear to have generous laws on citizenship by descent, especially Lithuania. Due to their former status as part of the Soviet Union, most information out there is geared towards Russian citizens, so it’s probably best to contact your nearest consulate for advice on your own situation.
This list is intended as a rough guide. It’s by no means exhaustive. Here are some things I’ve learned as an Irish-Australian living in the UK with a girlfriend on a youth mobility visa: immigration departments are clogged with bureaucracy, government websites are often misleading, countries don’t advertise routes across their borders, and different people can get different results. If you have grandparents or great-grandparents who were born in Europe, I urge you to do your own research and bug the hell out of your closest consulate.
The other critical thing is that laws can change. Take Hungary, as outlined above, which has only allowed ethnic Hungarians to claim citizenship since 2011. Your Macedonian or Slovakian ancestry might not be useful now, but check back again in a couple of years. Conversely, if you have the ability to claim European citizenship now, I’d urge you to get that big ball of red tape rolling as soon as you can: it can be a long and tedious process of gathering certificates, forms and apostilles, and with the immigration hysteria currently choking Europe you never know when a country might decide to tighten up its citizenship laws.
But once you finally have that citizenship, it’s in the bank, and can’t be revoked retroactively. I’m probably returning to Australia next year, because economically speaking it’s the land of milk and honey, but I still find it comforting to have that little red passport in my bedside drawer. It opens up an entire continent to me for the rest of my life. Who knows what the future might bring?