SHARE
COPY LINK
For members

FRENCH CITIZENSHIP

COMPARE: Which European countries have the strictest rules on dual citizenship?

Being a citizen of your country of long-term residence brings a lot of advantages, especially when it comes to peace of mind, but some countries in Europe have far stricter rules than others.

COMPARE: Which European countries have the strictest rules on dual citizenship?
COMPARE: Which European countries have the strictest rules on dual citizenship? Photo by ConvertKit on Unsplash

However, gaining citizenship in another state is not a walk in the park. Beyond the bureaucratic headache, and varying residency rules and exceptions, some countries may require to give up the nationality of origin as a result of the process.

Few countries in Europe require foreign nationals to do this, but some do. Here is an overview of how the countries covered by The Local deal with dual citizenship, starting with the ones with the strictest rules.

‘Special circumstances’

Austria, Germany and Spain generally do not allow dual citizenship, except in some special circumstances. This means that foreign nationals who obtain the citizenship of one of these countries have to give up their nationality of origin.

Austria

“In principle, anyone who acquires Austrian citizenship by conferral loses their foreign citizenship,” says the Austrian government website. This also applies to Austrian citizens who acquire a foreign citizenship.

Austria only waives the requirement to renounce previous citizenship if this is in the special interest of the state on the basis of “extraordinary achievements” in the past or expected in the future.

Austrians at birth can maintain citizenship if they apply to do so before acquiring another nationality and if this is justified by “special circumstances”, for instance if losing it would have “a severe detrimental impact on their ability to work” or, in the case of minors, if this is in their best interest.

Children with at least one Austrian parent are Austrian and can have dual citizenship. “The child does not have to decide on their (sole) nationality upon reaching the age of majority. However, the other state involved may require them to make such a decision,” the website adds.

Thanks to a recent law, Austrians who left the country before 15 May 1955 because of persecutions by the Nazi regime, and their descendants, can have their citizenship restored and retain any other citizenship they have since acquired.

Germany

Only EU and Swiss nationals can retain their citizenship of origin when they naturalise as German, and so can German citizens with these countries. British citizens were allowed to retain dual citizenship if they applied for naturalisation until the end of the Brexit transition period, but now they also have to renounce it.

Children with a German parent acquire German citizenship at birth and can keep dual citizenship permanently.

It is possible to retain dual citizenship if the country of origin does not allowed to renounce it or this is not possible for other reasons (for instance in case of conflict). 

German citizens who wish to naturalise in another country and keep German nationality can apply for a retention permit. In this case they will have to provide evidence of “continuing ties with Germany” and of “substantial reasons” for acquiring the other nationality.

Individiuals who between 30 January 1933 and 8 May 1945 were deprived of their German citizenship on political, racial or religious grounds, and their descendants, may have their citizenship restored and retain any other citizenship they have since acquired.

The current government coalition has promised in its programme a “modern citizenship law” allowing for multiple nationalities, but this is yet to materialise.

While in Austria applying for citizenship requires at least 10 years of continuous residence in (six for EEA citizens), as well as knowledge of the language and a ‘positive attitude’ towards the country, in Germany the requirement is 8 years. But foreigners who complete an ‘integration course’ can apply after 7 years. People who apply for German citizenship also need to know the German language and take a naturalisation test to prove they are familiar with the legal system, society and living conditions. Spouses or registered same-sex partners of German citizens can apply for naturalization after 3 years of legal residence.

Spain

As a general rule, people naturalising as Spanish citizens have to renounce their previous nationality. This is not required of nationals of Latin American countries, Andorra, the Philippines, Equatorial Guinea, Portugal or Sephardic Jews of Spanish origin.

This refers to a law that allowed Sephardic Jews descendants of those expelled from Spain in the 15th century to acquire citizenship. However, the deadline to apply for citizenship via this route has expired in 2021 (a similar citizenship route is open in Portugal).

For citizens from these countries the residency requirement to apply for naturalisation is 2 years. It is otherwise one year for people married to a Spanish national, 5 years for refugees or 10 years in other situations. 

Spain has also recently signed an agreement that allows dual citizenship with France.

Spanish citizens by origin can naturalise in another country and retain their citizenship if they require so within 3 years of acquiring the other nationality.

Children born in Spain can acquire citizenship if the parents are from a country that does not recognise the nationality of children born abroad.

Dual citizenship permitted

In many other countries, such as France, Italy and Sweden, as well as Belgium, Ireland, Switzerland and the UK, dual citizenship is permitted.

In France the residency requirement for naturalisation is generally 5 years, showing integration into the French way of life and knowledge of the French language.

In Italy it is possible to apply for citizenship after 10 years of residence, or 4 for EU citizens and 2 for a resident married to an Italian citizen. A language test is also required.

Sweden is one of the few countries where a language test is not needed. The general rule is 5 consecutive years of residence, with absences of more than six weeks during a year subtracted from the total. People married, in a registered partnership or cohabiting partners with a Swedish citizen can apply after three years.

On the other hand, Denmark has one of the strictest citizenship laws. Naturalisation requires an extra waiting period of two years after obtaining a permanent residence permit, which usually takes eight years. There is also a citizenship test.

Denmark allows dual citizenship after the law changed in 2015. Former Danish who lost their citizenship by acquiring a foreign one before 1 September 2015 can reacquire it by making a declaration to the Ministry of Immigration and Integration by 30 June 2026.

After a recent change in regulations, dual citizenship is also allowed in Norway. Those who lost their Norwegian citizenship before 2020 can reacquire it by submitting a notification of citizenship.

There are stricter rules, however, in the Netherlands. Foreign nationals acquiring Dutch citizenship, or Dutch nationals acquiring a foreign one, need to give up their citizenship of origin, except in some specific circumstances – for example, for those acquiring their spouse’s or partner’s citizenship or those holding an asylum residence permit.

Restrictions also exist in many Eastern European countries.

This article was produced by the team at Europe Street news.

Member comments

Log in here to leave a comment.
Become a Member to leave a comment.
For members

FRENCH CITIZENSHIP

EXPLAINED: How to use France’s new online portal for citizenship

The French government has opened a new online system for foreigners applying for citizenship. Loire-based journalist and wannabe Frenchman John Walton takes a look at how to use the new NATALI citizenship portal.

EXPLAINED: How to use France's new online portal for citizenship

Since I’ve lived in France, I’ve by and large been impressed by the country’s digital public services, especially compared with the US and UK, and that was also the case with applying for nationality using the NATALI online portal

Submitting my dossier was an entirely digital process using the new nationality portal. Since there are many pathways to apply for nationality (marriage to a French citizen, descent from a French person, and so on), the service-public.fr website has a special simulateur widget that helps you narrow down the pathway suitable to you.

There’s also a specific simulation that then provides you a list of documents based on your situation.

As a célibataire, full-time employed salarié US-UK dual national homeowner without children, born outside France, applying based solely on five years of residence with the special Brexit-flavoured titre de séjour residence permit, mine narrowed down a total 15 documents I needed to provide:

  • Passport;
  • ID photos;
  • €55 in timbre fiscale;
  • Titre de séjour;
  • Birth certificate (plus approved translations);
  • Parents’ birth and marriage certificates (plus approved translations);
  • Casier judiciaire and overseas equivalents (plus approved translations);
  • House title (acte de propriété);
  • Tax returns (avis) for 3 years;
  • P237 bordereau de situation fiscale covering 3 years (available via the tax office);
  • Certificat de travail (this is an attestation from your employer, in the standard format “I the undersigned, Mme X of company Y at address Z, certify that Mr A of address B with Sécu number C, is employed as with a CDI as a job title D since date E, and he’s not on any probation nor has he resigned) 
  • Employment contract;
  • Last 3 pay slips;
  • Pay slips for November and December of the last 3 years;
  • Language qualification to at least B1 level

READ ALSO The ultimate guide for how to get French citizenship

As it turns out I wasn’t asked for an ID photo — perhaps because I have an existing titre de séjour. Note that you will also have to input your every one of your home addresses over the last 10 years down to the specific day that you moved in and out, although no documentary evidence was required online.

Best to ensure that you have that information to hand, and I absolutely plan to bring a couple of bank statements, utility bills and similar to my assimilation interview.

The site also asked for a recent proof of address — the usual phone bill seemed to suffice. I found that the key to making this simple is collating all the information you’ll need and figuring out what accompanying documentation (or, indeed, in the case of the language tests, what exams) you can upload to provide it.

Tips for the process

You can either create a new login or use a FranceConnect login from another government service (such as the health service’s ameli.fr or the tax office’s impots.gouv.fr — I used the latter).

Pleasingly, this prefills all the information that the service already holds on you. I’m a millennial digital native with a reputation as a spreadsheet fancier, so I organised the process with a one-page spreadsheet to track the documentation. I also numbered each of the types of information, with a corresponding folder number on my computer, both for tracking and for the upload process.

That meant it took really only a few minutes to work through the submission site and upload my documents one by one. I plan to file the paper originals and printouts of these documents in a tabbed file when, fingers crossed, I’m called to the assimilation interview.

READ ALSO QUIZ: Could you pass the French citizenship interview?

I was very impressed by the uploading process: the site allows for multiple uploads at the same time (so you can select all of the payslips you’ve carefully put into a folder at once, for example) and file size limits are a very reasonable 10MB so there’s no need to resize your smartphone picture scans.

If you’re an iPhone user and have used your phone to scan pictures, they may be saved as HEIC files rather than JPGs. You’ll need to convert them (I used the Preview app on my computer) to upload.

I’d highly recommend having very clear filenames for your documentation, including translations — “certificat de naissance – mère – original”, “certificat de naissance – mère – traduction”, and so on — rather than leaving it as “IMG1234” or whatever.

I did this in French to make it as easy as possible for whoever reviews my file. Note also that where translations are needed that there is a separate upload button for translations.

I was glad that I’d had the foresight to add the word “traduction” to the names of these files!

Lessons learned

The time and effort in this process was mainly around squaring away my overseas documentation, which took a couple of months. Given that language exams are only held a few times a year, these is probably the first thing to arrange.

As someone with grade A French at A-level, who uses French on a daily basis in my local village, I popped over to my nearest centre for a morning of exams, and took the B1 level test. 

READ ALSO TEST: Is your level of French good enough for citizenship and residency?

Once you’ve booked in the language exam, start on your overseas documentation. This, especially from the UK, can be expensive, complicated and can take months.

(The UK’s police certificate website here is a particular shocker: it looks like it is a scam website, the processing time is outrageously slow and it only sends out physical forms. The French casier judiciaire version is free, online and immediate.)

By contrast, I found that securing every piece of French documentation, from the P237 form I’d never heard of, to the casier judiciaire police check that I’d never needed, all the way down to getting an electronic timbre fiscale, was easy, digitised, free and usually instantaneous.

READ ALSO Reader question: Will a criminal record stop you getting French citizenship?

Do take a good look at example documents to understand exactly what you’re being asked for before you apply for them from your country of origin, or where you may have lived over the past 10 years. For example: my parents’ marriage certificate from the UK didn’t include their dates and places of birth, just their ages at the time of marriage.

I found an excellent and very responsive local translator “agréé” (aka a translator “assermenté-e” or approved translator) from the official list of certified translators (provided). It is best to approach a translator at an early stage to ensure availability and check pricing.

They may also be helpful with some of the finer details of what documents are needed. Mine was happy to review, make minor edits to, and then stamp some earlier, non-agrée translations of several of my documents, which cut the cost somewhat.

READ ALSO How much does it cost to get French citizenship?

Overall, and certainly in contrast with the horror stories I’ve heard from friends applying for US and UK nationality, the process of submitting my dossier for French citizenship was simple, inexpensive and straightforward. If you’re not a confident online operator, you might find the website slightly overwhelming, but there is a national network of digital help points if you’re concerned. 

Now, I wait… Wish me luck at the interview.

Next steps

Submitting your dossier online is step one of applying for French citizenship, a process that takes on average between 18 months and two years. Find the full process outlined HERE

Photo: John Walton

John Walton is a joint US-UK national who lives in the département of Loire in central France. He works as a journalist specialising in travel and aviation and tweets as @thatjohn – find more of his work here

SHOW COMMENTS