Birthright citizenship, or jus soli (“right of the soil”), grants automatic citizenship to individuals born within a country’s territory, regardless of their parents’ nationality or immigration status. This policy varies widely across the globe—and understanding where it applies can shape decisions for families, foreign parents, dual nationals, and emigrants navigating immigration policies and nationality laws.
Which Countries Offer Birthright Citizenship?
Some of the most well-known countries that offer unconditional birthright citizenship include:
- United States
- Canada
- Mexico
- Argentina
- Brazil
These nations grant citizenship to nearly anyone born on their soil – even if their parents are non-citizens, foreign diplomats, or undocumented individuals, unless specific legal codes restrict exceptions. Such systems often have roots in colonial history and liberal interpretations of the birthright component in their citizenship law.
Countries With Conditional Birthright Citizenship
Many countries apply limited or conditional jus soli, meaning:
- One or both parents must have legal status or residency
- The child must remain in the country for a certain period
- The law only applies to second-generation children
Examples include:
- Australia: Only if at least one parent is a citizen or permanent resident
- UK: Requires one parent to be settled or a citizen
- France: Citizenship can be claimed later in childhood under specific conditions
These distinctions often arise from political debate and reforms in birthright regimes, where Social-Democratic parties, executive orders, and federal judges influence evolving immigration permits and migrant integration frameworks.
Countries That Don’t Recognize Birthright Citizenship
Most European countries, as well as Japan, China, and many parts of the Middle East, do not grant citizenship automatically at birth. Instead, they follow citizenship by descent (jus sanguinis).
Such countries rely on migration systems and policy indicators to balance citizenship access with integration goals, often connecting birthright rules to residency requirements or proof of lineage through a birth certificate.
What Is Citizenship by Descent?
Citizenship by descent (or jus sanguinis, “right of blood”) is a legal pathway that allows individuals to claim citizenship based on their ancestry—typically through a parent, grandparent, or sometimes even a more distant relative.
How Does It Work?
If a country’s laws recognize citizenship by descent, you may qualify if:
- You can prove a biological link to a citizen (via official records)
- The ancestor did not lose or renounce their citizenship before it could be passed on
- You meet other specific legal criteria under that nation’s citizenship law, such as background checks, age limits, permanent residency, documentation standards or a documented application process
Each country has different rules, especially when it comes to generational limits or the citizenship status of the parent at the time of birth.
Why Consider It?
- Reconnection with heritage: Many descendants seek a deeper link with their family’s culture and history.
- Freedom of movement: Especially within the EU, reclaiming citizenship can unlock the right to live, work, and travel without visas.
- Economic and educational opportunities: Citizens often gain access to jobs, healthcare, and university systems.
- Alternative routes: Some pursue citizenship by investment or citizenship by marriage as other legal options under European nationality laws.
At Citizenship.eu, we help you determine whether you’re eligible—and guide you through the paperwork and complexity of the process.
How Does Citizenship by Descent Work in Europe?
In many European countries, your ancestry might be the key to acquiring citizenship—even if you or your parents have never lived there. This concept, known as citizenship by descent, allows individuals to legally reclaim nationality based on their bloodline, reconnecting with their heritage and unlocking the rights of EU citizenship within EU Member States.
The Principle of Jus Sanguinis
Most European countries operate under jus sanguinis (Latin for “right of blood”), meaning citizenship is passed down from parent to child – even across borders and generations.
Unlike birthright citizenship (common in the Americas), European countries rarely grant citizenship based solely on being born on their soil. Instead, your eligibility depends on:
- The nationality of your parent(s), and sometimes grandparents or great-grandparents
- Whether they retained citizenship at the time of your birth
- Specific laws that apply to the country you’re claiming from
Common Requirements Across Europe
Each country has its own rules, but here are typical conditions:
- Documented lineage: You’ll need official birth, marriage, and citizenship records showing your connection to a former or current citizen.
- Continuity of citizenship: Your ancestor must not have renounced or lost their citizenship before it could be passed on.
- Generational limits: Some countries allow claims through great-grandparents (e.g. Ireland, Italy), while others limit it to parents or grandparents.
- Language or residency: A few countries may require language tests, cultural knowledge, or brief residency—though many waive this for ancestral claims.
Countries in Europe Offering Citizenship by Descent
Several European nations have well-established programs:
- Ireland: Through a parent or grandparent (even great-grandparent in some cases via registration)
- Italy: Through a parent or grandparent
- Germany: Now includes broader eligibility thanks to 2024 legal reforms
- Poland: If your ancestor was a Polish citizen after 1920
- Hungary: Often includes a language requirement
- Lithuania, Latvia, Slovakia, Croatia, and others: Each has unique criteria for descendants
Why Pursue European Citizenship by Descent?
- Live and work across the EU: Once you obtain citizenship in an EU member state, you gain freedom of movement and employment across the entire European Union.
- Reconnect with heritage: Many applicants feel a strong cultural or familial tie to their ancestral homeland.
- Educational and healthcare access: Citizens often enjoy subsidized tuition and public healthcare within the EU.
- Pass it on: Most European citizenships acquired by descent can be passed to your children.
Find Out If Your Eligible Now
At Citizenship.EU, we specialize in helping people assess their eligibility and navigate the often-complex path to European citizenship by descent. From initial research to final documentation, our experts combine data analysis with policy insight to simplify your application process – so you can reconnect with your roots confidently.
Sign up now to obtain our EU dual citizenship eligibility assessment.
2 Responses
I was born in italy, came to the US and became a US citizen but had to give up my Italian citizenship. Can I become a dual citizen?
Hello Rocca,
Thank you for reaching out to Citizenship.EU and for your interest in Italian citizenship through ancestry!
It may be possible for you to become a dual Italian-US citizen again, but it will depend on a number of factors, including the year in which you renounced your Italian citizenship.
Our team focuses on citizenship through ancestry, but we do have trusted Italian citizenship contacts who also process these kinds of cases. If you would be interested in setting up a consultation with one of our experts, we highly recommend that you create an account on our app and request to be connected with a citizenship expert.
Please note that this is a paid service that requires that you have a paid Citizenship.EU app account to access our marketplace services. You can explore our subscription options from your app account at https://app.citizenship.eu/pricing
Please also note that due to a number of recent changes to citizenship through ancestry requirements in Italy, many of our Italian citizenship specialists have a waitlist to move forward with consultations and application procedures. If you wish to move forward with an initial consultation, our team will work to connect you with a specialist, but it could take some time before their availability opens up again.
If you have any additional questions on how to get started, please do not hesitate to contact our team, as we would be happy to further advise you!