Achievement-based acquisition of nationality (acquisition based on special achievements for the country under consideration)

Any mode of acquisition of nationality after birth based on special achievements (in sports, science, the arts, etc.) for the country under consideration in the past or expected achievements in the future

Acquisition of nationality

Any mode of becoming a national, i.e. by birth or at any time after birth, automatic or non-automatic, based on attribution, declaration, option or application

Acquisition of nationality after birth

Any mode of acquisition of nationality that does not take place:

• automatically and immediately at birth; or
• soon after birth by declaration, registration, making use of an option or similar action, on the basis of conditions for the acquisition that were met already at the time of birth.

Note that certain regulations will be classified as modes of acquisition after birth even though the target persons acquire nationality retrospectively, i.e. are treated as if they had been nationals since birth (or some other point in time in the past).
To be distinguished from: acquisition at birth.

Acquisition of nationality at birth

Any mode of acquisition of nationality that:
either occurs automatically (ex lege) and immediately at birth; or can occur immediately after birth by declaration, registration, making use of an option or similar action because all the conditions for acquisition had already been met at the time of birth.
To be distinguished from: acquisition after birth.
Note that certain regulations can be classified under both acquisition at birth and acquisition after birth, depending on whether the target person already meets the conditions at birth or only some time after (e.g. the rule that a child born in Belgium can acquire nationality by declaration within twelve years after birth if both parents have been resident for at least ten years).

Acquisition of nationality by adoption

Automatic acquisition of nationality as a result of the adoption of the target person by a reference person who is a national of the country under consideration.
To be distinguished from: adoption as a reason for a facilitated non-automatic acquisition (e.g. facilitated naturalisation or registration)

Acquisition of nationality by legitimation

Automatic acquisition of nationality by a child born out of wedlock based on legitimation by a father who is a national of the country under consideration.
To be distinguished from: legitimation for the purpose of facilitated non-automatic acquisition (e.g. facilitated naturalisation or registration)

Adoption (Acquisition of nationality by adoption)

See: acquisition of nationality by adoption

Application – Acquisition of nationality through application

Any mode of acquisition that requires an application by the target person or his or her legal agent that initiates a procedure during which the public authorities have to assess criteria for granting nationality.
This does not cover acquisition by declaration or option

Automatic acquisition of nationality

Any ex lege mode of acquisition of nationality, i.e. acquisition of nationality by an act of law that does not require some form of expression of intent (application, declaration, making use of an option or similar action) by the target person or his or her legal agent in order to acquire nationality

Automatic loss of nationality

Any ex lege mode of loss of nationality, i.e. loss of nationality by an act of law that requires neither explicit expression of intent (application, declaration, making use of an option or similar modalities) by the target person or his or her legal agent to renounce nationality, nor a decision or act by a public authority.
Used synonymously with lapse of nationality.
To be distinguished from: non-automatic loss of nationality, renunciation of nationality, withdrawal of nationality

Citizenship

A legal status and relation between an individual and a state that entails specific legal rights and duties.
Citizenship is generally used as a synonym for nationality (see: nationality). Where citizenship is used in a meaning that is different from nationality it refers to the legal rights and duties of individuals attached to nationality under domestic law. In some national laws, citizenship has a more specific meaning and refers to rights and duties that can only be exercised after the age of majority (such as voting rights) or to rights and duties that can only be exercised in the national territory.
Except where specifically stated, we do not use broader non-legal interpretations of citizenship, which refer to practices and virtues of individuals and organisations oriented towards the common good or to membership and activities of individuals in civil society associations.

Citizenship ceremony

Meeting organised by public authorities where newly naturalised persons are individually or collectively welcomed as new citizens of a state, which may include a sworn oath or pledge of loyalty.

Citizenship interview

An administrative procedure in which an official conducts an oral interview with persons applying for citizenship.

Citizenship test

A standardised oral or written exam that tests the knowledge of naturalisation applicants in any of the following areas: official or dominant languages, history, constitution, political institutions, public values, behavioural norms in civil society, or other characteristics aspects of the country of naturalisation.

Country C1

Country under consideration, i.e. country whose rules for acquiring or losing nationality are described

Country C2

Particular country which is not C1, but for which special regulations apply, e.g. EU Member States, member countries of other associations of states (e.g. Nordic countries), countries involved in bilateral or multilateral agreements affecting the rules for acquisition or loss of nationality

Country C3

Other country for which no special regulations apply

Conferment – acquisition of nationality by conferment

The term ‘conferment of nationality’ is used in some countries for certain modes of acquisition of nationality characterised by:

• non-automatic acquisition; and
• bilateral action requiring not only an expression of intent by the target person or his or her legal agent, but also specifically an act by the responsible public authority.

See also: grant of nationality (generally used as a synonym for conferment).

Cultural affinity-based acquisition (acquisition of nationality based on cultural affinity)

Any mode of acquisition of nationality after birth on the basis of a particular cultural background, e.g. for persons of a particular ethnicity, mother tongue or colloquial language and/or religious affiliation.

Declaration – acquisition of nationality by declaration

Acquisition of nationality by declaration is generally characterised by:

• a facilitated procedure and (substantially) facilitated conditions;
• voluntary (in contrast to automatic) acquisition; and/or
• the need for an oral or written declaration (by the target person or by a legal agent) addressed to the relevant public authorities;

and, in some countries,

• a unilateral act by the person making the declaration (unlike acquisition based on a decision by the authorities).

Related terms: option, registration

Descent– acquisition of nationality by descent

See: ius sanguinis

Denizenship

A set of rights for long-term resident foreign nationals that includes at least the following: long-term residence permit, access to employment, enhanced protection from deportation/expulsion (compared to short-term residents) and provisions for family reunification in the country of residence.
In several European states, denizens have additional rights, such as the right to vote and stand as candidate in local elections. See also: quasi-citizenship

Discretionary naturalisation – acquisition by discretionary naturalisation

Acquisition of nationality following a decision by the public authorities that is not based on a subjective entitlement by the target person. The target person may, but need not, be granted nationality if the conditions specified in the law have been met.

Dual nationality

See: multiple nationality

Entitlement – acquisition of nationality based on a legal entitlement

Any mode of acquisition of nationality based on a decision by the public authorities that must be granted by them if and when the relevant conditions specified by law have been met.
Whether or not the acquisition is based on a legal entitlement depends primarily on the mode of the authorities’ final decision, not on the actual contents or clarity of the conditions themselves. The conditions themselves may leave some room for discretion by the authorities (e.g. stable income) but, if the authorities come to the conclusion that the conditions specified by law are met, they have to grant nationality to the target person.

Expatriates

Nationals of the country under consideration residing abroad, including nationals who have acquired their nationality by ius sanguinis abroad and have never resided in their country of nationality.
To be distinguished from persons with special nationality status outside their country of nationality (special nationals residing abroad).

Extension of acquisition of nationality

Any mode of acquisition of nationality after birth (with or without consent) that is conditional upon or results automatically from the simultaneous acquisition of nationality by a reference person.
Extension of acquisition of nationality is to be distinguished from transfer of nationality. A transfer of nationality occurs if the reference person is already a national of the country under consideration; an extension of acquisition occurs if the reference person is just about to acquire this nationality.

External citizenship

A set of rights and duties nationals have vis-à-vis their country of nationality when residing outside its borders.
External citizenship rights include generally a right to return, to diplomatic protection and consular services. In many states external citizens can also vote in national elections.
See also: external quasi-citizenship

External quasi-citizenship

A set of rights granted to non-citizens residing abroad that approximates the rights of nationals residing abroad.
See generally: quasi-citizenship

Extraterritorial ius sanguinis

Ius sanguinis for target persons born outside the territory of the country under consideration.

Filial extension of acquisition of nationality (extension of acquisition of nationality to child)

Any mode of acquisition of nationality after birth (with or without consent) that is conditional upon or results automatically from the simultaneous acquisition of nationality by the target person’s parent(s).
To be distinguished from: filial transfer of nationality and ius sanguinis after birth.

Filial transfer of nationality (transfer of nationality to child)

Any mode of acquisition of nationality after birth based on the fact that the target person is a (natural, adopted or foster) child of a reference person who is already a national of the country under consideration.
To be distinguished from: filial extension of acquisition of nationality and ius sanguinis after birth.

Foundling

A child of unknown parentage found abandoned on the territory of a state.

General nationality status with restricted citizenship / General nationals with restricted citizenship

Persons who enjoy the same general legal status as other nationals but whose rights and/or duties are restricted because:

• they have acquired nationality via a certain mode (e.g. by naturalisation instead of by birth); or
• they have so far held this nationality for only a certain period.

In the EUDO CITIZENSHIP observatory, we do not deal with restricted citizenship for other groups of nationals, such as those who are temporarily or permanently deprived of certain citizenship rights and/or exempt from certain citizenship duties as a result of convictions under criminal law, because of their age, because of a disability, etc..
To be distinguished from: special nationality status with restricted citizenship (see respective entry).
Also to be distinguished from: expatriates currently exempt from some rights and duties of citizenship based on their residence abroad, but who have the right to enter their country of nationality and who would recover full citizenship upon taking up residence there.

Grant – acquisition of nationality by grant

The term ‘grant of nationality’ is used in some countries for certain modes of acquisition of nationality characterised by:

• non-automatic acquisition; and
• bilateral action, i.e. it requires not only an expression of intent by the target person or his or her legal agent, but also specifically an act by the responsible public authority.

See also: conferment of nationality (generally used as a synonym for grant)

Involuntary loss of nationality

Any loss of nationality that is not initiated by the target person or his or her legal agent. It can be either automatic (ex lege) or initiated by the responsible public authorities.

Ius sanguinis

The determination of a person’s nationality on the basis of the nationality of his or her parents (or one parent or one particular parent) at the time of the target person’s birth and at the time of acquisition of nationality by the target person (the two points in time are different in cases of acquisition after birth).
This concept is used in a broad way that covers not only automatic acquisition by birth, but also non-automatic acquisition by birth and after birth (see respective entries)

Ius sanguinis after birth

Any mode of acquisition after birth which is dependent on the fact that one or both of the target person’s parents already held nationality of the country under consideration at the time of the target person’s birth and still holds nationality of that country.
To be distinguished from: filial transfer of nationality and filial extension of acquisition of nationality

Ius soli

The principle that the nationality of a person is determined on the basis of his or her country of birth.
The EUDO CITIZENSHIP observatory uses this concept in a broad way that covers not only automatic acquisition at birth but also non-automatic acquisition at birth and after birth (see respective entries).

Lapse of nationality

See: automatic loss of nationality.

Legal agent

A person legally empowered to act on behalf of a target person, e.g. the parent of a minor child.

Legitimation (Acquisition of nationality by legitimation)

See: acquisition of nationality by legitimation.

Loss of nationality

Any mode of loss of the status as national of a country (voluntarily or involuntarily, automatically or by an act by the public authorities). The main types of loss are renunciation, withdrawal and lapse of nationality (see respective entries).

Mechanism of acquisition/loss of nationality

The mechanism of acquisition/loss refers to whether the acquisition or loss is automatic, i.e. becomes effective by act of law, or non-automatic, i.e. requiring an act by a public authority and/or an expression of will of some kind (application, declaration, etc.) by the target person or his or her legal agent.

Mode of acquisition / Mode of loss of nationality

Any manner of acquiring or losing nationality based on a distinct legal rule. Modes of acquisition and loss are comparable across countries and are defined in this glossary.
To be distinguished from type of acquisition and type of loss, which refer to the terminology used in national legislation for specific modes of acquisition or loss of nationality.

Money-based or investment-based acquisition of nationality (acquisition based on payment or investment of certain amounts of money)

Any mode of acquisition of nationality after birth based on payment or investment of a certain amount of money (not the regular naturalisation fees) in the country under consideration.

Multiple nationality

Legal status of nationality held by a person simultaneously in two (dual nationality) or more states. Multiple nationality may be acquired at birth or after birth and with or without the knowledge and consent of all the states involved. The term ‘multiple nationality’ refers only to the legal status and does not specify the rights and obligations a person holds vis-à-vis the state of second or third nationality where the person does not currently reside. (Some states distinguish between citizenship that can only be held by residents of the state and nationality that may also be held by expatriates.)

Nationality / Status as National

Legal relationship between a person and a state (country) as recognised in international law.
In some countries, the status may be called citizenship rather than nationality and the persons holding the status are referred to as citizens rather than nationals.
In the EUDO CITIZENSHIP observatory, we generally use nationality and citizenship as synonyms, except where citizenship refers specifically to the legal rights and duties of nationals (see: citizenship).
We do not deal with nationality in a non-legal sense, i.e. membership of a nation sharing a common history, culture, language or descent (which does not necessarily coincide with the totality of persons holding the nationality of a country in the legal sense defined above), or with nationality as referring to membership of a national minority living within a state and/or culturally linked to an external kin-state.

Nationality-based acquisition of nationality (acquisition based on a specific nationality)

Any mode of acquisition of nationality that is specific to persons who are nationals of a particular country or group of countries.

Naturalisation

Any mode of acquisition after birth of a nationality not previously held by the target person that requires an application by this person or his or her legal agent as well as an act of granting nationality by a public authority.
This definition does not include automatic acquisition that is not initiated by the individual concerned or his or her legal agent (even in cases where the individual has an option to decline this attribution of nationality) or acquisition of nationality based on a unilateral act by the target person (e.g. acquisition by declaration or option).

Non-automatic acquisition of nationality

Any mode of acquisition of nationality that requires an act by a public authority and/or some form of expression of intent (application, declaration, making use of an option or similar action) by the target person or his or her legal agent.

Non-automatic loss of nationality

Any mode of loss of nationality that requires either that a public authority initiate a procedure to withdraw nationality (rather than just issuing of an official notice that nationality has been lost ex lege) or some form of explicit expression of intent to renounce nationality (application, declaration, making use of an option or similar action) by the target person or his or her legal agent.
To be distinguished from: automatic loss of nationality (lapse of nationality).

Nullification of acquisition of nationality

The act of a public authority pronouncing the acquisition of nationality null and void because it is established ex post that conditions required for the acquisition were in fact not met at the time of application or declaration by the person in question or at the time of decision by the responsible authority (whichever is applicable).
As a result of this act, the target person is retrospectively deemed never to have been a national of the respective state.

Option – Acquisition of nationality by option

Acquisition of nationality by option is characterised by:

• a facilitated procedure and (substantially) facilitated conditions;
• voluntary (in contrast to automatic) acquisition;

and, in some countries:

• a unilateral act by the person making use of the option (unlike acquisition based on a decision by the authorities)
• the need for the target person or his or her legal agent to choose between two (or more) alternative nationalities; and

Related terms: declaration, registration.

Partner extension of acquisition of nationality (extension to unmarried partner)

Any mode of acquisition of nationality after birth (with or without consent) that is conditional upon or results automatically from the simultaneous acquisition of nationality by the target person’s unmarried partner.
To be distinguished from: partner transfer of nationality.

Partner transfer of nationality (transfer to unmarried partner)

Any mode of acquisition of nationality after birth based on the fact that the target person is the unmarried partner of a reference person who is already a national of the country under consideration.
To be distinguished from: partner extension of acquisition of nationality.

Quasi-citizenship

A set of rights for specific groups of foreign nationals that grants them special privileges compared to other foreign nationals and that approximates the rights of citizens.

Quasi-citizenship is most commonly derived from long-term residence (see: denizenship), but may also be granted to former nationals and their descendants, to nationals of a former colony, to nationals of other member states in a regional union of states (such as the EU or the Nordic Union), to nationals of specific other countries on grounds of reciprocity, or to foreign nationals who are seen to share a cultural, ethnic, linguistic, or religious affinity with the population of the country concerned (compare: cultural affinity-based acquisition).
See also: external quasi-citizenship

Reacquisition of nationality

Acquisition of nationality by a person who was previously a national of the country under consideration.

Recognised refugees

Persons who have been recognised as refugees and to whom the status of refugee has been conferred by the country under consideration according to the country’s asylum law and/or the Geneva Refugee Convention.

Reference person

Person to whom the target person holds a special relationship that serves as grounds for special rules concerning the acquisition of nationality by the target person. Reference persons are mostly close relatives, such as parents, spouses or grandparents.

Refugees

Any person who has fled another country, who is now resident in the country under consideration and who has not yet acquired its nationality.
This category includes recognised refugees (see above), persons with the status of de facto-refugees, persons enjoying temporary protection and asylum-seekers.

Registration – Acquisition of nationality by registration

Any acquisition of nationality that comes into effect through an act of registration with the public authorities by the target person or his or her legal agent. It is characterised by:

• a facilitated procedure and (substantially) facilitated conditions;
• voluntary (in contrast to automatic) acquisition; and
• a unilateral act by the person making use of the option (unlike acquisition based on a decision by the authorities).

Related terms: declaration, option.

Release from nationality

Loss of nationality initiated by an application from the target person or his or her legal agent, but requiring the approval of a public authority.
Release from nationality is a special form of renunciation of nationality (see respective entry).

Renunciation of nationality

Any loss of nationality initiated by a declaration or application by the target person or his or her legal agent addressed to the relevant authorities concerning his or her intention or desire to give up the nationality in question.
Renunciation can be

• either non-discretionary, in the sense that it has to be granted or that it becomes effective automatically once all the legal conditions are met (renunciation by declaration); or
• or subject to the approval of a public authority (renunciation by application or release from nationality, see respective entry).

Residence-based acquisition of nationality (acquisition based on a minimum duration of residence)

Any mode of acquisition of nationality after birth for which the main condition is a certain period of residence on the territory of the country under consideration.

Retrospective acquisition of nationality

Any mode of acquisition of nationality whereby the target person acquires nationality retrospectively so that he or she is treated as if he or she had been a national since a particular point in the past (in many cases, since birth) before the determination or granting of nationality by the authorities.

Revision of acquisition of nationality

See: nullification of acquisition.

Service-based acquisition of nationality (acquisition based on – military/non-military – service for the country concerned )

Any mode of acquisition of nationality after birth based on public service for the country under consideration, whether military service or civil service (e.g. as civil servant, teacher or university professor).

Socialisation-based acquisition of nationality (acquisition based on socialisation in the country concerned )

Any mode of acquisition of nationality after birth based on socialisation of the target person before the age of majority in the country under consideration, i.e. of persons who attended school (for some time) and/or who completed school there, who spent time there for certain years of their childhood or adolescence, etc..

Special nationality status with restricted citizenship / Special nationals with restricted citizenship

Any special nationality status distinct from the general nationality status that is defined in the respective country’s nationality law for specific groups of persons and which (in general) does not confer the full rights and/or duties of citizenship on its holder (e.g. British Overseas or Dependent Territories Citizens, British Overseas Nationals).
To be distinguished from: general nationality status with restricted citizenship (see respective entry).

Spousal extension of acquisition of nationality (extension to spouse )

Any mode of acquisition of nationality after birth (with or without consent) that is conditional upon or results from the simultaneous acquisition of nationality by the target person’s (married) spouse.
To be distinguished from: spousal transfer of nationality.

Spousal transfer of nationality (transfer to spouse)

Any mode of acquisition of nationality after birth based on the fact that the target person is the (married) spouse of a reference person who is already a national of the country under consideration. This includes not just automatic transfers of nationality by marriage, but also non-automatic acquisition by naturalisation, declaration or other modes, with special (mostly facilitated) conditions.
To be distinguished from: spousal extension of acquisition of nationality.

Stateless person

A person who is not considered as a national by any state under the operation of its internal law (Council of Europe definition).

Target person

Person to acquire or lose nationality

Territorial ius sanguinis

Ius sanguinis for target persons born on the territory of the country under consideration.

Third country national/citizen

A person who is not a national of an EU member state

Transfer of nationality

Any mode of acquisition of nationality after birth based on a family relationship with a reference person who is already a national of the country under consideration.
To be distinguished from: extension of acquisition of nationality. A transfer of nationality occurs if the reference person is already a national of the country under consideration; an extension of acquisition occurs if the reference person is just about to acquire this nationality.

Type of acquisition / Type of loss of nationality according to national law

In the EUDO CITIZENSHIP observatory, the terms ‘type of acquisition’ and ‘type of loss’ refer to the terminology for specific modes of acquisition or loss of nationality used in national legislation, e.g. acquisition by ‘option’ or ‘declaration’ or by ‘grant’.
To be distinguished from: mode of acquisition and mode of loss, which refer to distinct legal rules that can be compared across countries and are defined in this glossary.

Voluntary acquisition of nationality

Any acquisition of nationality which is not automatic (ex lege), and requires some expression of intent to acquire nationality (application, declaration, making use of an option or similar action) by the target person or his or her legal agent.

Withdrawal of nationality

Any mode of non-automatic loss of nationality based on a decision by a public authority to deprive the target person of his or her nationality. The simple issue of an official notice informing the target person of the fact that he or she has lost nationality ex lege does not count as a decision by the public authority.
To be distinguished from: lapse of nationality, renunciation of nationality