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Citizenship by Descent: Unlocking Your Heritage

Published date:
August 31, 2025
Dean Fankhauser
Written by:
Dean Fankhauser
Reviewed by:
Radica Maneva
Citizenship by Descent: Unlocking Your Heritage
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In today’s uncertain world, having a second passport has become more than a luxury; it’s a safety net. From gaining full EU rights and global mobility to securing a reliable “Plan B” in times of political or economic instability, citizenship by descent is one of the most appealing pathways. Unlike other routes, it doesn’t require long years of residency or expensive investments; if your ancestry qualifies, it’s already your legal right.

Put simply, citizenship by descent (jus sanguinis, or “right of blood”) means you can claim nationality through your parents, grandparents, or in some cases even great-grandparents. For millions of people worldwide with Italian, Irish, Polish, Portuguese, or other European heritage, this possibility is closer than ever.

Interest in ancestral passports has surged dramatically recently. For example, searches for Irish citizenship by descent spiked in the United States by over 200% in 2020, and Italy, Portugal, and Poland have also reported record numbers of applications from their global diasporas. The trend is clear: more people are rediscovering their roots as a gateway to new opportunities.

What is Citizenship by Descent?

Citizenship by descent, also known as jus sanguinis (Latin for “right of blood”), is the principle that nationality can be passed down through family lineage rather than by place of birth.

In simple terms, if one of your parents, grandparents, or sometimes even great-grandparents was a citizen of a particular country, you may be entitled to reclaim that citizenship today.

Pathway Eligibility Timeframe Pros Cons
Citizenship by Descent Parent, grandparent or other ancestor was a citizen; proof of lineage required. Months to a few years (documentation). Low cost; no residency required; connects to heritage; often dual allowed. Limited to those with ancestry; can be paperwork-intensive; processing delays.
Jus Soli (Birthright) Born in the country’s territory. Automatic at birth. Instant citizenship; no process required. Not applicable retrospectively; only by place of birth.
Naturalisation Legal residence for 5–10+ years, language/integration tests. 5–10+ years (plus processing). Accessible to anyone; builds integration and community ties. Time-consuming; must relocate; may need to renounce original citizenship.
Investment (Golden Visa/CBI) Large investment or donation (amounts vary by country). 6 months (direct CBI) to 5–7 years (via golden visa). Fast-track for those with funds; no ancestry needed. Extremely expensive; subject to political change; reputational concerns.

It differs from jus soli (“right of the soil”), which grants citizenship automatically to anyone born on a nation’s territory, common in countries such as the United States or Canada.

Most European countries, on the other hand, follow jus sanguinis rules to preserve ties with their diaspora communities.

Historical & Legal Context

The idea of Jus sanguinis has its origins in centuries past, as European states implemented it to ensure that the children of emigrants would maintain a connection to their homeland.

This principle became especially important in the 19th and 20th centuries, when millions migrated to the Americas, Australia, and elsewhere.

Today, jus sanguinis remains enshrined in many nationality laws across Europe, underpinning modern “citizenship by descent” programmes.

Key Benefits of Citizenship by Descent

For many, applying for citizenship by descent is not only about paperwork; it’s about unlocking opportunities that would otherwise take years of residence or large financial investments to achieve. Whether practical freedoms or emotional ties entice you, the benefits are substantial.

Freedom of Movement Travel with fewer visa hurdles; many ancestral passports offer visa-free or visa-on-arrival access to 180+ countries (passport dependent).
EU Residency Rights If your ancestral citizenship is from an EU state, you can live, work, and study across the EU without work permits.
Education Opportunities Access world-class universities at domestic/EU tuition rates and benefit from qualifications recognised across Europe.
Career Growth Enter job markets abroad without visa sponsorship; employers can onboard you immediately as a citizen.
Healthcare & Social Security Eligibility for robust public healthcare and social protections, improving quality of life and long-term security.
Financial & Lifestyle Flexibility Open bank accounts, invest, or purchase property abroad with fewer restrictions; simplify relocation planning.
Heritage & Identity Re-establish ties to culture and community, and pass citizenship to your children as part of their story.
Plan B Security Gain an alternative home and consular protection — resilience for you and your family in uncertain times.

In short, citizenship by descent offers a rare combination of mobility, security, and belonging. It’s one of the most cost-effective ways to obtain a second nationality, making it an attractive option for both practical and personal reasons.

Country-by-Country Overview

50+ countries worldwide offer some form of citizenship by descent (ancestry). Below are the most sought-after options:

At-a-Glance Comparison

Country Generational reach Key requirements (headline) Typical timeline* Dual citizenship
Italy Parent or grandparent (post-2025) Prove direct line + “genuine link” under 2025 reform; special judicial route for pre-1948 maternal lines Months–years, often slowed by consular backlogs Allowed. ³
Greece Parent (automatic); grandchild if parent first registered as Greek Birth must be recorded in municipal roll (dimotologio); consulates liaise with local authorities Often lengthy due to municipal archive delays Allowed. ¹⁶
Ireland Up to grandparent via Foreign Births Register (FBR) Grandparent born on the island of Ireland; register on FBR Processing times fluctuate with demand Allowed.
Spain Children/grandchildren of exiles under Democratic Memory Law Proof of qualifying ancestor; deadline 22 Oct 2025 (appointments booked by then count) Consular queues vary by post Generally allowed; no renunciation required under DML guidance.
Portugal Grandchild of a Portuguese national (with ties) Show grandparent’s nationality + “effective connection” Variable by Conservatória Allowed. Sephardic route heavily tightened in 2024.
Malta Often to 3rd generation (registration) Direct-line descent, subject to statute conditions Months–year+ Allowed since 2000 reforms. ¹⁰
Germany Parent (standard) plus restitution for Nazi-era descendants (children → great-grandchildren) Standard descent rules or §116/§15 restitution Standard descent is administrative; restitution varies Dual citizenship allowed since 27 Jun 2024. ¹¹
Poland No fixed cap if proof since 1918/1920 Archival proof of status & continuity; heavy documentation Administrative; varies by voivodeship/consulate Permitted/tolerated. ¹² ¹³
Austria Parent (by descent); §58c restitution for Nazi-era victims’ descendants Proof of parent’s citizenship or qualifying persecution lineage Administrative; varies by post Generally no dual, except by birth and §58c. ¹⁴
UK (Ancestry Visa) Not citizenship — residency route for Commonwealth citizens with UK-born grandparent Age 17+, intend to work; 5 years to settlement, then citizenship 5 years to ILR + 12 months to naturalise UK allows dual nationality. ¹⁵

*Timelines are indicative and depend on consular loads, completeness of documents, and local processing rules.

Tier-1

Portuguese Citizenship by Descent (grandparent route; Sephardic notes)

  • Grandchildren of Portuguese citizens: May acquire nationality by descent if they demonstrate an effective connection to the Portuguese community (e.g., language, participation, parent’s registration).
  • Sephardic route: Significantly tightened in 2024; the current framework typically requires residence and no longer functions as a purely ancestry-based fast track. Treat older online guides with caution.
  • Dual citizenship: Explicitly allowed under Portuguese law.

Italian Citizenship by Descent (consular backlogs, “1948 cases”, 2025 reform)

  • What changed (2025): Italy enacted Law 36/2025, introducing an “effective connection” test and limiting routine jure sanguinis claims to the parent or grandparent level. Consulates are in the process of updating procedures; please anticipate more rigorous documentation requirements for your living ties to Italy (language, culture, registry events, etc.).
  • Maternal-line “1948 cases”: If your lineage passes through a woman before 1 Jan 1948, the administrative route is blocked; many applicants use the court (Tribunale) route to address historic gender discrimination.
  • Backlogs: Processing remains highly uneven across consulates; consider municipal filings in Italy where feasible and lawful.
  • Dual citizenship: Permitted under Italian law (since Law 91/1992).

Greece Citizenship by Descent (descent through parent; extended via registration)

  • Who qualifies: Children of at least one Greek parent are citizens automatically, even if born abroad. Grandchildren may qualify, but only if their parent first secured recognition as Greek before the grandchild’s birth.
  • Process: Births must be registered in the local municipal roll (dimotologio) and, for males, the military roll (mitroologio). Applications abroad go through Greek consulates, which liaise with municipal offices in Greece.
  • Challenges: Processing can be slow due to archival delays and strict checks on transliterations of Greek names. Missing or inconsistent records (especially older certificates) are a frequent hurdle.
  • Dual citizenship: Permitted under Greek law; citizens are considered solely Greek when in Greece.

Ireland Citizenship by Descent (FBR: grandparent rule)

  • Core rule: If you have a grandparent born on the island of Ireland, you can register on the Foreign Births Register and become an Irish citizen. Children born after you register can continue the line abroad.
  • Process: Evidence of the Irish-born grandparent (long-form birth certificate), civil records linking each generation, and your identity documents.
  • Dual citizenship: Ireland permits it.

Spain Citizenship by Descent  (Democratic Memory Law — deadline 22 October 2025)

  • Who qualifies: Children and grandchildren of Spaniards exiled or who lost nationality for political/ideological reasons (and other specific categories) can opt for nationality by origin under Law 20/2022.
  • The deadline is 22 October 2025, and you must book the consular appointment by this date to ensure coverage. Expect heavy demand in the Americas.
  • Renunciation: DML applicants are not required to renounce their current nationality.

Malta Citizenship by Descent (strong diaspora provisions; often workable to 3rd generation)

  • By registration (descent): The Maltese Citizenship Act (Cap. 188) provides for registration of direct-line descendants of Maltese-born citizens, subject to specific conditions (including parent/ancestor criteria). In practice, third-generation claims can be possible where the statutory conditions align.
  • Authority & guidance: Community Malta Agency oversees citizenship; Malta has recognised dual and multiple citizenship since 2000.

Germany Citizenship by Descent (standard descent + powerful restitution)

  • Standard descent: German citizenship passes from a German parent (subject to time-specific statutory rules).
  • Restitution: Descendants of people who lost citizenship due to Nazi persecution can (re)acquire citizenship in Germany under restored pathways, including children, grandchildren, and great-grandchildren.
  • Dual citizenship: Since June 27, 2024, Germany has accepted multiple nationalities for new citizens; Germans who naturalise elsewhere no longer automatically lose citizenship.

Poland Citizenship by Descent (documentation-heavy, but no fixed generational cap)

  • Principle: Poland recognises citizenship by blood; there is no statute-set generational limit, provided you prove uninterrupted citizenship after 1918/1920 (many cases hinge on military service, naturalisation abroad dates, and interwar laws).
  • Process: You usually apply for confirmation of possession of Polish citizenship; expect archival work across Polish and foreign registries.
  • Dual nationality: Permitted/tolerated; Polish citizens are treated as Polish within Poland (use a Polish passport at the border).

Austria Citizenship by Descent (strict generally; generous §58c restitution)

  • By descent: If a parent was an Austrian citizen at your birth, you’re typically Austrian by descent (subject to historic equal-treatment cut-offs).
  • Restitution (§58c StbG): Direct descendants (children, grandchildren, great-grandchildren) of victims of National Socialism can acquire Austrian citizenship by declaration without giving up existing citizenship.
  • Dual citizenship: Generally not permitted, except in certain cases (by birth, permitted retention, and §58c restitution).

Need guidance with your Citizenship by Descent?

The process can be overwhelming — from tracking ancestry records to submitting applications. Our experts can help you simplify each step and avoid costly mistakes.

✨ Get Expert Help with My Application

Personalised support • Ancestry-based citizenship made simple

Tier-2

Cyprus Citizenship by Descent

Citizenship normally passes from a Cypriot parent. Limited grandparent transmission exists in cases of diaspora children born abroad who would otherwise be stateless or excluded; rules are strict and tied to registration.

Croatia Citizenship by Descent

Ethnic Croats abroad and descendants of Croatian citizens can apply. Proof of Croatian ethnicity and cultural ties may be required alongside descent. Dual nationality is tolerated.

Lithuania / Latvia Citizenship by Descent

Both have restoration programmes for descendants of citizens pre-1940 Soviet annexation.

Generally extends to grandchildren and great-grandchildren, provided no voluntary renunciation occurred. Often popular with North American diaspora.

Israel Citizenship by Descent (Law of Return)

Not technically “citizenship by descent” but by ethnic/religious ancestry: any Jew (and children, grandchildren, and spouses) can obtain immediate immigration rights and citizenship under the Law of Return.

Hungary Citizenship by Descent

Ethnic Hungarians abroad may naturalise with a shortened residency path if they can prove ancestry and pass a basic Hungarian language exam.

The Americas

  • Mexico: Citizenship passes automatically to children of Mexican citizens, even if born abroad (registration required).
  • Argentina: Broad jus soli system, but descent also recognised for children born abroad to Argentine parents.
  • Brazil: Children of Brazilian citizens born abroad are considered Brazilian if registered at a consulate or if they later establish residence in Brazil.

UK Ancestry Visa

Who it’s for: Commonwealth citizens aged 17+ with a UK-born grandparent, who intend to work in the UK.

It’s not citizenship, but it can lead to Indefinite Leave to Remain (after 5 years) and later British citizenship through naturalisation.

Spouses/partners and dependent children can usually join.

How to Apply for Citizenship by Descent

The path to an ancestral passport may look daunting, but most applications follow the same universal steps. Here’s how to turn family history into legal nationality.

  1. Confirm Eligibility
    Map out your family line and check whether your parent, grandparent, or great-grandparent meets the country’s rules. Watch for cut-off years (e.g., Italy pre-1948 maternal lines) and naturalisations that might have broken the chain.
  2. Gather Vital Records
    Collect certified copies of birth, marriage, and death certificates for each generation. You may also need naturalisation records, census entries, or church documents to fill in gaps.
  3. Authenticate & Translate
    Most countries require documents to be legalised or apostilled and then translated by a sworn/certified translator into the national language. Accuracy matters — a date or name mismatch can delay the case.
  4. Submit the Application
    File your dossier at the relevant consulate, embassy, or ministry. Some allow applications inside the country (e.g., municipal registries in Italy), but most start abroad.
  5. Wait for Processing
    Timelines vary: some take a few months, others several years depending on demand and consular backlogs. Patience and persistence in following up is key.
  6. Finalise Citizenship & Passport
    Once approved, you’ll be added to the national registry. From there, you can apply for an identity card and passport. In many countries, your children automatically inherit citizenship once you're recognised.

Master Documentation Checklist

Ancestor’s Birth Certificate Proves that your parent, grandparent, or great-grandparent was a citizen at birth.
Ancestor’s Marriage Certificate Legally links each generation; often required even if the marriage later ended.
Naturalisation Records (or Proof of Non-Naturalisation) Shows whether your ancestor ever renounced or lost their citizenship; in some cases, a certificate stating no record exists is just as important.
Your Own Birth Certificate Connects you directly to the family line and is always required.
Name Change or Adoption Records Resolves discrepancies if names differ across documents (e.g. anglicised spellings or official adoptions).
Death Certificates (if applicable) May be needed to complete the family chain, especially when an ancestor is deceased.
Proof of Identity Your current passport, ID card, or equivalent to verify you as the applicant.
Apostilles and Certified Translations Ensure your documents are legally recognised abroad; apostilles are standard for Hague Convention countries, otherwise consular legalisation may be required.

Collecting these records can feel like detective work, but they form the backbone of a successful application. The more precise and complete your file, the smoother the process will be.

If gaps appear, such as missing certificates or conflicting names, professional genealogists, lawyers, and national archives can often help bridge the evidence. Taking time to build a watertight dossier now saves months, if not years, of delays later.

Comparing Citizenship by Descent vs. Other Routes

While citizenship by descent (jus sanguinis) is often the fastest and least expensive route if you qualify, it’s not the only pathway to a second passport.

Comparing it with naturalisation, investment (“Golden Visas”), and birthright (jus soli) highlights why descent is so attractive and where its limitations lie.

Pathway Basis of Claim Typical Timeline Average Cost Key Requirements Pros Cons
Citizenship by Descent Ancestry (parent, grandparent, sometimes further) 6 months – 3 years (mostly paperwork/consular backlogs) Low (admin fees, translations, legal help) Proof of unbroken lineage + ancestor’s citizenship Fast & cheap if eligible; often no residency or language test; strong heritage value Only for those with ancestry; documentation hurdles; some rules recently tightened (e.g. Italy 2025)
Naturalisation Long-term legal residence 5–10+ years residency + processing Moderate (legal fees, applications) Continuous residence, language, integration tests, sometimes renunciation Open to anyone willing to relocate; strong integration Slow; uprooting life required; stricter requirements
Investment / Golden Visa Financial contribution (direct donation or real estate/business investment) Direct CBI: 3–12 months; Golden Visa → citizenship: 5–7 years Very high (US$100k–2m+) Qualifying investment + due diligence Fast (CBI); minimal residence in some Golden Visas (e.g. Portugal 7 days/year) Extremely expensive; political scrutiny; programs can close suddenly
Birthright (Jus Soli) Born in the country’s territory Instant (at birth) None Birthplace itself Automatic and unconditional; dual citizenship common Only applies at birth; not a path for adults

Frequently Asked Questions

Usually not. Most nationality acts require an unbroken chain of citizenship status from ancestor to applicant. If a parent or grandparent formally renounced before the next generation’s birth, the right is often broken. Some countries have restitution laws (e.g., Germany, Austria) that make exceptions in cases of persecution.
Immigration authorities typically require official documents such as birth and marriage certificates and other civil records linking each generation. You may also need naturalisation files, census extracts, or church records. Discrepancies in names or dates often require affidavits or additional documentary evidence.
Usually no, since descent is a right of blood. Some systems (e.g., Hungary or specific naturalisation tracks linked to descent) may expect basic language skills. For pure descent claims, the emphasis is on proving lineage rather than integration.
Birthright (jus soli) grants nationality by being born on a country’s territory. Descent (jus sanguinis) requires proving lineage to a citizen ancestor. Each nationality act sets limits—some allow only parental transmission, others extend to grandparents or further back.
It depends on the specific law. Some countries recognise children legally adopted by a citizen, while others restrict descent rights to biological lines. Always check the country’s Nationality Act for how adoption and legal guardianship are treated.
Not always. Many EU countries permit dual citizenship, but some (e.g., Austria) are restrictive except in special cases (such as §58c restitution). Confirm rules in both your current nationality and the state you’re claiming.
It varies by country. Italy historically allowed transmission without generational limits (subject to 1948 cases and reforms), while Portugal typically extends to grandparents with proof of ties and effective connection. Claims through more distant ancestors require careful eligibility checks.
You can self-manage, but firms and genealogists help with document retrieval, up-to-date requirements, and dealing with authorities—useful when records are missing, archives are foreign, or you want oversight to ensure the certificate is issued smoothly.
In most systems, yes—nationality is automatic if at least one parent was a recognised citizen parent at the time of the child’s birth. Some states allow retrospective registration if the birth wasn’t recorded abroad.
Ireland requires registration on the Foreign Births Register for grandparent claims, while Italy often permits transmission indefinitely (subject to 1948 cases and recent reforms). Both require civil records and marriage certificates; Italy tends to demand more comprehensive evidence of ancestral connection.
Yes. Both routes can lead to full citizenship (including EU citizenship where applicable). Descent relies on proving an ancestral link; investment requires significant funding. Either way, you can gain visa-free travel, economic participation rights, and long-term security for future generations—with descent often being the most natural and cost-effective path.

Conclusion & When to Seek Professional Help

Applying for citizenship by descent can feel overwhelming, archives to chase, translations to commission, forms to complete. Yet for those who persevere, the reward is lasting: a second passport that opens doors for you and generations to come. It’s complex, but worth it.

If your case is straightforward and you have easy access to family records, you may be able to manage the process yourself with patience and persistence. But in situations where:

  • Records are missing, inconsistent, or written in unfamiliar languages,
  • Your family line involves historic legal quirks (such as Italy’s 1948 maternal line rule), or
  • You’re applying through a heavily backlogged consulate,

…it’s wise to seek professional help. Immigration lawyers, genealogists, and accredited translators can save months of frustration and prevent costly errors.

Need guidance with your Citizenship by Descent?

The process can be overwhelming — from tracking ancestry records to submitting applications. Our experts can help you simplify each step and avoid costly mistakes.

✨ Get Expert Help from MovingTo

Personalised support • Ancestry-based citizenship made simple

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