Dual/Multiple Citizenship. Yes/No?

Passport Collector
3 min readMay 16, 2022
Vinko Thiov artwork

States historically disfavored dual citizenship. In the nineteenth century, the incidence of dual nationality threatened bilateral relations as states contested control over individuals. Although dual nationality persisted as states refused to harmonize nationality practice, states used expatriation, election, and renunciation as tools to suppress the status… More recently, many states have come to tolerate and even embrace dual citizenship as advancing state policies, especially among immigrant-source states. Individuals increasingly value their status for instrumental and sentimental reasons. Even though dual citizenship challenges equality norms, this acceptance is unlikely to be reversed (1).

1. Extract from Peter J. Spiro, Charles R. Weiner Professor of Law in the James E. Beasley School of Law at Temple University, United States. August 2017.

Today, multiple citizenships are controversial, and Spiro’s last sentence is more challenging than ever because of the Golden Passport business.

Holding multiple passports is like being a member of numerous political parties simultaneously. You are not a Democrat, Liberal, or Republican simultaneously. Because you believe in the one or the other.

Why should it be different with citizenship?

As the above statement confirms, the desire for multiple passports is more instrumental than sentimental.

Global trend on DUAL citizenship

Based on around 10 thousand country-year observations in the Dataset, in 1960, a traditional negative approach towards dual citizenship was still represented in most countries (62 percent) worldwide. In this restrictive approach, a citizen who voluntarily acquires the citizenship of another state loses their citizenship. By 2020, however, 76 percent of countries maintain a more accessible path towards dual citizenship and allow citizens to voluntarily acquire the citizenship of another country without automatic repercussions for the citizenship of origin.

Most of these states without a dual citizenship restriction allow citizens to voluntarily renounce their citizenship after acquiring another citizenship (66 percent of all states). In contrast, a minority does not let its citizens relinquish their citizenship (10 percent of all states). While the trend is broadly similar across world regions, dual citizenship acceptance has progressed faster in the Americas and Oceania and slower in Africa and Asia. Approval in Europe follows the global trend.

Over the past two decades, nearly all policy changes have been towards a tolerant approach, with only one notable exception, in Slovakia, which restricted its dual citizenship policy in response to changes in neighboring Hungary (2).

2. Vink, Maarten; De Groot, Gerard-Rene; Luk, Ngo Chun, 2015, “MACIMIDE Global Expatriate Dual Citizenship Dataset,” doi:10.7910/DVN/TTMZ08, Harvard Dataverse, V5 [2020].

* There are 64 states worldwide that permit dual citizenship, ONLY 33% of all countries!

*https://migronis.com/blog/countries-that-allow-dual-citizenship, April 25, 2022.

Another source analyzed data from 18 selected countries in 2011, showing the percentage of dual citizenship in the overall population. These shares were between 0.2% (Portugal) and 10.3% (Switzerland). The Swiss numbers are the exception and are incredibly high. A good average is probably +-1%. Again, these numbers might be different today, as said above.

Of course, there must be a different approach between dual and multiple citizenships! Gaining multiple citizenships indeed have an instrumental intent rather than a sentimental one.

Citizenship, hence passports, have become a commodity, and I believe this is wrong!

Dual/Multiple Citizenship

Traditionally, principles of citizenship refer to jus sanguinis, the right to belong by descent, and jus soli, the right to belong by place of birth (Brubaker 1992; 2010), and for me, that’s just fine.

More on passports and their history at passport-collector.com

--

--

Passport Collector

Tom Topol is a Passport History Expert, Passport Collector & Author. His website Passport-Collector.com is a Goldmine on the History of Passports.