Five Legal Pathways to Dual Citizenship

Most people take their citizenship for granted, but for many others, citizenship is not as simple as being born in a particular country. Take most of the GCC – a large percentage of babies born in the Arabian Gulf will never gain citizenship of the country they were born in.

Every country has its own rules and policies, regulations and eligibility criteria that allows it to legally grant citizenship to a person.

Due to these various different ways through which citizenship is granted, you may be eligible for dual citizenship and may not even be aware of it. This is especially true if your parents or grandparents originally hail from a nation other than the one in which you were born, and if your ancestor’s country grants citizenship on the basis of descent.

Wondering if you may be able to apply for a second citizenship?

Here’s a quick guide to some of the ways you (or your child) could obtain dual citizenship:

Place of Birth:

A common way for citizenship to be determined is by place of birth – called jus soli (a Latin term meaning ‘right of soil’). There are many countries that offer unrestricted jus soli – the most famous being the USA. Restricted jus soli is practised in a number of other nations, such as Australia, Egypt, Hong Kong and the UK, among others. While the rules differ from country to country, it is usually required that a parent (more commonly the father) is a national citizen in order for a child born in a country to also gain the same passport.

Right of Blood/ Via Descent: Jus sanguinis (meaning right of blood) is practiced by various countries in which citizenship is not necessarily determined by place of birth, but when one or both parents are citizens of the state. Several countries - many in Europe whose populations historically left home to explore other parts of the world - also grant citizenship by descent up to two generations of ancestorship.

The jus sanguinis rule can however work negatively against your future generations. For instance, if you or your spouse is British and have a baby abroad, citizenship by descent is only transferable to one generation down from the parent who is a British citizen otherwise than by descent. So, if your child grows up to have children also born abroad, your grandchildren may not automatically be guaranteed British citizenship.

By Naturalization:

If you have long been settled abroad, you may be eligible to apply to be naturalized in order to become a legally recognized citizen of a country. Many countries, such as New Zealand, offer this although there are specific requirements, such as having been a legal resident for a certain amount of time, having the intention to continue to live in the country, having a good command of the local language and being able to demonstrate possession of a good character.

By Legal Residency:

Obtaining legal residency in a country by investing in programs that permit applicants to purchase or rent residential real estate can be the first step in pursuing a second citizenship via naturalization. After obtaining permanent residency by meeting the legal requirements for a specified amount of years, applicants may then submit an application for citizenship. Many countries do not impose minimum stay requirements for permanent residency if the applicant can demonstrate “ties to the country” – ownership of residential real estate often serves this purpose.

Citizenship by Investment:

A small number of countries allow applicants with no previous family connection to qualify for citizenship through investment. In the Caribbean, the established programmes are Antigua and Barbuda, Dominica, St Kitts and Nevis, Grenada and St Lucia. Cyprus closed its investor-citizenship programme in 2020.

This is a formal legal route, but it is neither automatic nor identical across programmes. Current Caribbean options begin from a government minimum of US$200,000 for an investment option, with programme-specific family, due-diligence and processing fees added. Applicants must evidence identity, source of funds and their wider personal history, then pass government due diligence before any decision is made.

Citizenship by investment can broaden mobility, but destination access is not uniform and should never be reduced to a fixed country count. The United Kingdom now requires visas from Dominica and St Lucia nationals, while Schengen access remains subject to continuing European review. Applicants must also confirm that their existing nationality permits dual citizenship before proceeding.

If you would like to speak privately about whether a Citizenship by Investment programme fits your circumstances, reach a senior advisor at PassPro.