Citizenship and migration
Citizenship is a core feature of the international state system. Through laws on citizenship and electoral rights, states determine who belongs to the people in whose name they govern and for whom they assume responsibility vis-à-vis other states. This page highlights key differences between national laws regulating access to citizenship status and voting rights with a focus on how they affect international migrants.
Attribution of citizenship at birth varies around the world, as do the rules for naturalisation. A large majority of countries today accept dual citizenship either for immigrants, for emigrants, or for both. Especially in Europe and South America, voting rights are often granted to non-citizen residents in supra- and sub-national elections in their country of residence. However, there are only 5 countries worldwide that grant them also voting rights in national elections and none of these allows them to stand as candidates.
The first set of indicators below reflects the conditions for the acquisition of citizenship through descent (ius sanguinis) or birth in the country (ius soli) in 177 countries around the world, as well as for ordinary, i.e. residence-based, naturalisation in 41 European countries. The second set of indicators shows the variation in local voting and candidacy rights of non-citizen residents in the EU-28 states, Switzerland, the Americas and Oceania. The final indicator shows patterns and trends of dual citizenship acceptance for expatriates from 1960 to 2018.
Definition
The following definitions have been adapted from the Global Citizenship Observatory (GLOBALCIT) Glossary on Citizenship and 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.1 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.
Dual citizenship - Legal status of citizenship held by a person simultaneously in two (dual citizenship) or more states (multiple citizenship). Multiple citizenship may be acquired at birth or after birth and with or without the knowledge and consent of all the states involved.
The term 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.
Ius sanguinis - The determination of a person’s citizenship on the basis of the citizenship of his or her parent(s) at the time of the person’s birth or at a later time.
Used in a broad way, ius sanguinis covers not only automatic acquisition at birth, but also non-automatic acquisition at birth and after birth.
Ius soli - The determination of a person’s citizenship on the basis of his or her country of birth.
Used in a broad way, ius soli covers not only automatic acquisition at birth but also non-automatic acquisition at birth and after birth.
Voting rights - Refers to "active voting rights", i.e., the right to cast a vote in an election.
Candidacy rights - Refers to “passive voting rights”, i.e. the right to stand as a candidate in an election.
Recent trends
All states award citizenship through the basic rules of ius soli and ius sanguinis. Most states mix elements of both rules. All states where ius soli predominates provide at least the first generation born abroad to emigrant citizens with birthright citizenship by descent. 51 per cent of states globally include a special ius soli provision for children born in their territory who would otherwise be stateless. In Europe, these are 88 per cent of states, in Asia 60 per cent and in Africa only 32 per cent. Since ius sanguinis dominates in these three continents, the absence of ius soli contributes to statelessness there (Bauböck, Honohan and Vink, 2018).
Dual citizenship toleration – a global trend
Migrant voting rights in national, subnational and supranational elections
Voting rights in the Americas, the EU-28 states, Oceania and Switzerland have become more universal over the past two centuries as restrictions based on criteria such as race, sex or property have been lifted. Yet migrants are often still excluded either on grounds of citizenship or residence. There is a strong global trend to grant non-resident citizens voting rights in national elections, but immigrants who have not acquired citizenship can vote in national elections only in Chile, Ecuador, Malawi, New Zealand, and Uruguay. However, in Europe and the Americas non-citizen residents often have the right to vote in supranational and subnational elections held in their country of residence. In the European Union, citizens of other Member States can vote in local elections. 12 EU states, Norway, Iceland and 8 Latin American countries grant all local residents voting rights independently of their citizenship (Schmid, Piccoli and Arrighi, 2019).
Data sources
Global
The following data sources have been compiled by GLOBALCIT at the European University Institute (EUI) in Fiesole, Italy, on the basis of customised questionnaires completed by country experts. The GLOBALCIT databases, providing comprehensive information on citizenship and electoral rights to policy makers, researchers, and the general public are available in open access.
GLOBALCIT provides the most comprehensive source of information on the acquisition and loss of citizenship in Europe for policy makers, NGOs and academic researchers. Its website hosts a number of databases on domestic and international legal norms, naturalisation statistics, citizenship and electoral rights indicators.
Modes of acquisition and loss of citizenship
GLOBALCIT’s datasets on modes of acquisition and loss of citizenship provide standardised descriptions of citizenship laws that allow for international comparison. The database breaks down citizenship laws into 27 modes of acquiring citizenship by birth or naturalisation and 15 modes of losing citizenship by renunciation or withdrawal. It currently covers 175 states for 2016 and covers also the years 2013, 2014 and 2015 for Europe and the Americas.
Ius sanguinis and ius soli data
GLOBALCIT’s Global Birthright Indicators dataset offers indicators calculated for 177 countries for 2016, including the 42 countries covered by the Citizenship Law Indicators. These are based on citizenship laws on 1 January 2016. They include all indicators for ius sanguinis and for ius soli at birth, but exclude ius soli after birth, i.e. acquisition of citizenship based on birth in the territory at the age of majority or after some time of residence. A score of 0 means that a mode of birthright acquisition does not exist; a score of 1 means that there are no restrictions for this mode of birthright acquisition. Scores between 0 and 1 represent degrees of restrictions or conditionality for acquiring citizenship by birth.
"Ordinary naturalisation" data
GLOBALCIT’s Citizenship law indicators (CITLAW) (2017). Version 3.0 - CITLAW indicators measure the degree of inclusion and freedom of choice for the target group of a legal provision. For birthright, naturalisation and conditions for renunciation the absence of a provision or the most restrictive conditions result in an indicator score of 0, whereas unconditional entitlements or the most inclusive provisions get a score of 1. For involuntary loss through withdrawal or automatic lapse, the absence of a provision results in a score of 1 and the most extensive state powers to withdraw citizenship in a score of 0.
How to Measure the Purposes of Citizenship Laws: Explanatory Report for the CITLAW Indicators (Version 3.0) – GLOBALCIT’s Citizenship law indicators (CITLAW) assign scores and weights to specific legal provisions in countries’ citizenship laws to measure the purposes of citizenship law provisions. This explanatory note explains the coding rules and potential uses of the CITLAW indicators.
Voting and candidacy rights data
ELECLAW Indicators: Measuring voting and candidacy rights of resident citizens, non-resident citizens and non-citizen residents. Version 5.1 - Based on the qualitative database on electoral rights, the ELECLAW indicators measure the degree of inclusion of voting rights (VOTLAW) and candidacy rights (CANLAW) for three different categories of potential voters: resident citizens, non-resident citizens, and non-citizen residents. The most recent version includes the EU-28 and Switzerland based on the electoral laws in 2013 and 2015, the Americas and Oceania based on electoral laws in 2015.
Dual citizenship data
MACIMIDE Global Expatriate Dual Citizenship Dataset, Harvard Dataverse, V3 – this dataset charts the rules in 200 countries from 1960 (or since independence) to 2018 with regard to the loss or renunciation of citizenship when a citizen of a state voluntarily acquires the citizenship of another state. The Extended Codebook refers to the relevant citizenship legislation.
Strengths & limits of the data
Data compiled by GLOBALCIT are based on primary research done by country experts examining national citizenship and electoral legislation. They cover the content of the legislative provisions for the acquisition of citizenship and electoral rights in a comprehensive and detailed way. The expatriate dual citizenship dataset presents categorical data and has global coverage from 1960 to 2018, allowing for global comparison and analysis of patterns and trends. The datasets on modes of acquisition and loss of citizenship and on voting and candidacy rights allow users to go several steps beyond the indicators by linking directly to country reports, concise explanations and full text of the relevant legal provisions (both in the original language and in the English translation).
At present, the GLOBALCIT data on ius sanguinis and ius soli are not longitudinal and are only available for 2011 (27 EU member states plus 8 European Economic Area (EEA) and EU accession candidate states) and 2016 (Global Birthright Indicators for 177 states). The dataset on ordinary naturalisation covers 41 European countries (27 EU member states plus 8 EEA and EU accession candidate states) for 2011 and 2016. Datasets on voting and candidacy rights cover the 28 EU member states for 2013 and the EU-28, Switzerland, the Americas, and Oceania for 2015, thus are not global in coverage.
Further reading
2013 "Citizenship configurations: Analysing the multiple purposes of citizenship regimes in Europe." Comparative European Politics 11, no. 5: 621-648.
Shachar, A., Bauböck, R., Bloemraad, I. and Vink, M., eds.
2017 The Oxford Handbook of Citizenship. Oxford University Press.
Honohan, I. and Rougier, N.
2018 "Global Birthright Citizenship Laws: How Inclusive?" Netherlands International Law Review 65, no. 3 : 337-357.
Schmid, S. D., Piccoli, L. and Arrighi, J.
2019 "Non-universal suffrage: measuring electoral inclusion in contemporary democracies." European Political Science: 1-19.
Arrighi, J. and Bauböck, R.
2017 "A multilevel puzzle: Migrants’ voting rights in national and local elections." European Journal of Political Research 56, no. 3: 619-639.
This page was authored as a thematic contribution to the Global Migration Data Portal by GLOBALCIT, coordinated at the Robert Schuman Centre for Advanced Studies, European University Institute, with input from Rainer Bauböck, Jelena Dzankic, Lorenzo Piccoli and Maarten Vink.
More information about GLOBALCIT: http://globalcit.eu | Twitter @_GlobalCIT
- 1. The IOM Glossary refers to "nationality" instead of citizenship because it is the term more often used in international law. However, at the national level, both the terms "nationality" and "citizenship" are used and sometimes with different meanings. See IOM Glossary at https://publications.iom.int/system/files/pdf/iml_34_glossary.pdf. The GLOBALCIT glossary recognizes that the terms can be synonyms but this thematic page refers to "citizenship" instead of "nationality” in order to emphasise that the legal relationship between a person and state as recognised in international law (nationality) also entails specific legal rights and duties.
