Unveiling dual citizenship policies in a globalized world

Nationalities hold identities, but who gets to have more than one?

Luis Felipe Mussalém
The Black Hole
Published in
4 min readSep 25, 2023

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Photo from Migronis

As someone who has studied and worked in different countries and had to deal with all of the extensive paperwork, the topic of permanent visas and dual citizenship constantly lives in my mind. We don’t often think of how humans made immigration such a procedural experience, and especially how this varies around the world.

According to the Migration Data Portal, as of 2020, there were 280.6 million immigrants all across the globe. The nuances of those diasporas are more fascinating than many would think, with questions like “What took them there?” and most importantly: “Do they wish to stay?”

This leads us to reflect on the most privileged form of nationality: citizenship. A relationship between a being and their state is a concept that started in Ancient Greece. Citizens of Athens were only free men over the age of 21, born from Athenian parents. This would give them the right to be active participants in government decisions (a privilege these days too!).

But with so many of us moving in and out of countries, how does the relationship with the state remain? What is the tolerance for it?

In 2008, the Migration Policy Institute did research on dual citizenship policies in the modern world. The project identified that in the past, policymakers saw dual nationalities as a problem for a nation. Back then, citizenship had strong ties to loyalty, but a lot changed in the 21st century. Specialists sought to unveil why this became a growing trend. It started as an attempt to close the gap between the resident and the voting populations, but nowadays, it means much more than that.

What makes a dual citizen?

Ideally, a dual citizen holds two nationalities, meaning they are “part” of two different countries. Decades ago, those were seen as a threat to a country’s identity, as mentioned in this 1930 statement by the League of Nations: “All persons are entitled to possess one nationality, but one nationality only.” In a world marked by conflict, they represented potential space for treason, espionage, and other activities against political leaders. Today, it’s even possible to find people with more than two citizenships.

The study focuses on how European countries made citizenship laws “less conditional,” creating policies both for locals who moved abroad and for the immigrants they received. For them, two factors can explain the increase in dual citizenship acceptance across the globe: the relationships between countries, and the one between nations and their citizens.

The rise of human rights also had an impact on the issue once many saw that “liberal democratic” states should give people the freedom to belong to more than one place. Of course, political interests have a huge say in this. Without a governmental institution, there are no citizens. You might have heard before that essentially, citizens have the right to vote, to arrive and leave freely, and to access basic human rights. That’s not always the case, and don’t even get me started with passport privilege.

The two principles of [officially] belonging to a nation

International law gives countries the freedom to outline their own citizenship policies. Nowadays, there are multiple ways of becoming a citizen of a nation: naturalization, birth, marriage, heritage, and so on… These can vary a lot, and here we’ll explore two essential principles that shaped citizenship policies across the world: jus sanguinis and jus soli.

Jus sanguinis, the rule of blood, follows the idea that a person’s nationality is given by descent, meaning that they get it from their parents or grandparents. It’s given regardless of the place of birth and values ethnic conceptions rather than geographic. It follows the mindset that a nation’s strength is in its ancestry.

The other, jus soli , is the rule of land. It’s also called birthright citizenship, valuing where one is born. It comes from a strong connection to the land, and clearly more common in the countries of the American continent. These were heavily influenced by European colonial powers and the displacement of its Indigenous populations, which explains why cultural relations might be seen differently. It’s a “New World Philosophy,” Eyder Peralta reports.

The process of receiving or revoking a citizenship can differ vastly. Yet, I noticed a pattern in the countries that go by the rule of blood: most of them make exceptions for children born there to stateless parents. Meanwhile, children of diplomats born when the parent is on duty are rarely eligible for right of land nationalities.

Countries (mostly in the Global North) receive immigrants to solve issues like the underpopulation crisis. On the other hand, some nations are still concerned with the lack of political integration and loyalty of people who hold more than one nationality.

Enhancing and challenging citizenship policies

Jus soli is highly debatable, and former U.S. president Donald Trump made part of his campaign to limit birthright citizenship in the country if he is elected in 2024. In a very different wave, some specialists are against the idea of citizenship as a whole, pointing out its discriminatory origins.

Also, defining an “age of mobility” is quite challenging in a world marked by constant migration. These patterns have always happened, but the rise of visas and citizenship policies illustrates that it was never so institutionalized and to a certain extent, “picky.”

For many, to be a citizen is to feel a sense of belonging. This was very tied to a feeling of pride that many of us have in regard to our cultures. Like it or not, coming from somewhere is part of our history, and many would be opposed to erasing that.

The study also highlighted how in some cases, dual citizens can mediate conflict between nations. The results included policy recommendations that involved investing in education around citizenship rights and widening the scope of citizenship ceremonies to foster political engagement.

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Luis Felipe Mussalém
The Black Hole

Award-winning journalist. I like telling stories, except the one about how I got here because I have no idea.