Citizenship by descent: who actually qualifies

Citizenship by descent — jus sanguinis, "right of blood" — is a citizenship right you inherit from an ancestor. It sidesteps residency, investment, and naturalisation requirements entirely. But each country has its own rules on how far back the chain can go, what documentary proof is acceptable, and whether reforms have recently opened or closed doors. Here is what actually qualifies in 2025.

Italy — historically the most generous

Italy has no generational limit on jure sanguinis claims if you can document an unbroken chain of Italian citizenship from an ancestor forward. See Italian descent.

• The 1948 rule: female ancestors could only pass citizenship after 1 January 1948. Earlier claims through the maternal line require a court process ("1948 case").
• The "minor issue": a 2024 Ministry of Interior circular tightened the interpretation of whether children born to Italian parents who had naturalised as adults (particularly pre- 1992) can claim through those parents. Several consulates have issued denials on this basis.
• Backlogs: consulate processing commonly 2-5 years; Italian-court route often faster at ~12 months.

Ireland — clean grandparent rule

Foreign Birth Registration admits any foreign-born person with an Irish-born grandparent. No residency required. Great-grandparent claims require that your parent was already registered on the FBR before your birth — which is now impossible for most applicants. Current FBR backlog is approximately 30 months. See Irish descent.

Germany — Article 116(2) restoration (expanded 2021)

Restoration of German citizenship for descendants of people who lost it under Nazi-era persecution 1933-1945. The 2021 reform widened eligibility dramatically: maternal line now qualifies, out-of- wedlock children qualify, women who lost German citizenship by marrying a foreigner pre-1953 can restore it for their descendants, and the "cutoff generation" effectively disappears. No residence required. Combined with the June 2024 general dual-citizenship reform, restoration applicants no longer need to renounce their current nationality. See German descent.

Poland — unbroken chain, no generational cap

Confirmation of Polish citizenship is available to anyone with an unbroken chain of Polish citizenship from an ancestor, with no generational limit. The catch is documenting that the chain was never broken — Polish citizenship could be lost by emigration after 1920, naturalisation in certain countries before 1951, military service in foreign forces, and women who married foreigners before 1951. Dual citizenship has been permitted since 2009. Typical processing 12-18 months. See Polish descent.

Hungary — simplified naturalisation with a language bar

Act LV of 1993 (as amended 2010) permits any applicant with a Hungarian ancestor to naturalise by oath taken at consulate, provided they demonstrate Hungarian at a "conversational" level and "good moral character". No residency. Ashkenazi Jewish applicants often qualify via pre-WWII Hungarian ancestors. EU scrutiny has focused on this route for a decade without stopping it. See Hungarian descent.

Portuguese Sephardic — CLOSED January 2024

Portugal's Lei 26/2022 ended the Sephardic Jewish descent route for new applicants from January 2024. Applications lodged before the deadline continue to be processed. See Portuguese Sephardic.

Spanish Sephardic — CLOSED October 2019

Spain's Ley 12/2015 was time-limited for 4 years (once extended) and ended its programme in October 2019. No new applications. See Spanish Sephardic.

UK Ancestry — 5-year work route

Not strictly jus sanguinis — a work visa for Commonwealth citizens with a UK-born grandparent. Leads to ILR after 5 years and citizenship 1 year later. £637 application fee + £1,035/year Immigration Health Surcharge. Requires a work intent and a job offer by arrival. See UK Ancestry.

Greek — Article 14 for ethnic Greeks abroad

Greek citizenship for descendants of ethnic Greeks (omogeneis) requires "sufficient connection with Greece" and demonstration of Greek language and cultural knowledge. Case-by- case interpretation; consular discretion is significant. See Greek descent.

Lithuanian — restoration for pre-1940 citizens + descendants

Lithuania restores citizenship for those who held it before 1940 and their descendants (Article 9). Dual is permitted under this specific route despite Lithuania's general restriction on dual citizenship. Children born abroad under the restoration route must elect to retain Lithuanian by age 21. See Lithuanian descent.

Do you qualify? A practical sequence

1. Identify the ancestor and their country of birth. Note their emigration date and any naturalisation.
2. Gather primary records: birth, marriage, death certificates (apostilled + translated where required). Absence of a single record can derail the application.
3. Check country-specific cutoffs: Italy's 1948 rule, Poland's emigration-after-1920 problem, German Art 116(2) persecution documentation.
4. Check whether a court process is required or optional — court often faster but more expensive.
5. Confirm the destination country permits dual citizenship with your current one (see US, India, China nationality guides for examples of restrictive home-country regimes).

A descent claim done well is the cheapest and fastest path to a strong passport. A descent claim done badly — via a dodgy intermediary with a flaky document set — can take years and end in rejection. Invest in a qualified immigration lawyer in the destination country, not a broker.