Why do some countries forbid dual citizenship

One-two: Which rules apply where?


Can a person feel connected to two countries? Do two national identities hinder integration? Do you stand in the way of the authorities in the fight against terrorism? Months before the general election, the one-two-way pass has become a political bone of contention in Germany. The debate is picking up speed again with the dispute over Turkey.

In principle, the Federal Republic of Germany is rather restrictive when it comes to dual citizenship: the principle of "avoiding multiple citizenship" stipulates that Germans have to give up their citizenship if they want to take on another. Exceptions apply to EU and Swiss citizens and to the children and grandchildren of immigrants. The acquisition of German citizenship according to the place of birth principle ("ius soli -Recht des Boden") applies with restrictions.

Around 4.3 million people with two or more nationalities currently live in Germany. Around every fifth person of Turkish origin in Germany has a German and a Turkish passport.

The CDU wants to tighten citizenship law. Union politicians had already initiated a debate about possible restrictions on the one-two at the party congress in December. The subject of the dispute is the so-called option obligation: For a long time, children of foreign parents were given both nationalities at birth, but had to choose one at the age of 23. In 2014, the grand coalition agreed that those born and raised in Germany may keep both passports as adults.

"I don't think we're going to campaign over the one-two," Merkel said in December

Now, according to information from "Spiegel", the CDU wants to mobilize against dual citizenship in the federal election campaign. "We have to change the policy of the exception rules to a large extent," said the chairman of the CDU network integration, Cemile Giousouf, the magazine. A paper that is to be integrated into the election manifesto states that grandchildren of first-generation immigrants should only be given a German passport.

Chancellor Angela Merkel had rejected the demands in December. According to the "Spiegel" report, she is now ready to support a new regulation. The reasons for this include the attacks by Turkish President Erdogan on German politics and the fact that many Turks living in Germany identify with the president.


Most EU member states now allow dual citizenship - including France. French citizens have been able to have dual or multiple citizenship since 1973. In 2009 France opposed the first article of the European "Convention on the Reduction of Multiple Nationality and on the Conscription of Multiple Nationalities". The aim of the agreement is to "reduce the number of cases of multiple nationality between the contracting parties".

In France, the "ius soli", ie the "right of the land", applies without restriction: Anyone born in France receives French citizenship - regardless of the nationality of the parents.


For a long time, the principle of "avoiding dual citizenship" applied in the northern European immigration country - similar to Germany. However, since 2001 a law allows Swedish citizens to apply for another citizenship without losing their Swedish passport, provided that the law of the country in question allows this. Conversely, immigrants do not necessarily have to give up their foreign citizenship upon naturalization.

The sociologist Thomas Faist sees Sweden as a potential role model for other countries. Having two passports is "not seen as a problem, but rather as a contribution to integration," Faist told the integration media service. Other Scandinavian countries have similar regulations: Denmark passed a law in 2014 that allows dual citizenship. A corresponding regulation came into force in Finland as early as 2003. Norwegians, on the other hand, are only entitled to dual citizenship in exceptional cases.

Poland and more

In Poland, under the Nationality Act, Polish citizens cannot be recognized as citizens of other countries at the same time. However, the possession of a second passport will not be penalized. However, Polish citizens cannot circumvent their civic obligations by invoking foreign citizenship.

Ukraine does not recognize dual citizenship. Under current law, newly naturalized Ukrainian citizens must give up other citizenships within two years. Some countries in Eastern and Central Europe, on the other hand, are open to the double pass, such as the Czech Republic and Romania. Bulgarians, Serbs and Croats are allowed to have dual citizenship, but foreigners have to renounce their old citizenship when naturalizing.


In principle, Spain allows dual citizenship to immigrants from Portugal, Andorra, the Philippines, Equatorial Guinea and Latin American countries with which it has concluded appropriate contracts. According to the constitution, immigrants from other nations must renounce foreign citizenship if they want to obtain Spanish. Spanish citizens, on the other hand, are allowed dual citizenship if they confirm to the authorities within three years that they want to keep their Spanish passport.

Depending on the state, the rules in southern Europe are different. Monaco and Andorra, for example, prohibit dual citizenship, in Portugal it is allowed.