Citizenship by descent can hand you a second passport for the price of paperwork, but the rules tightened sharply in the last two years. Italy restricted its route in 2025, Spain’s grandchildren window closed in October 2025, and Portugal reworked its descendant rules in 2026. This guide explains how citizenship by descent works, which countries still offer it as of October 2026, and how to build a file that gets accepted.
Last checked against official sources in October 2026.
Weighing citizenship by descent against other routes? Take the free WhereToNomad quiz to see which visa or residence path fits your situation.
How Citizenship by Descent Works
Most countries that offer citizenship by descent recognize a status you already hold by law. You do not “apply” so much as prove an unbroken chain: you, your parent, and the ancestor who held the nationality. Each link needs official records, and a single break can end the claim.
Three questions decide almost every citizenship by descent case:
- How many generations back is allowed? Ireland stops at grandparents, Poland and Greece look further, and the UK stops at grandparents.
- Did the ancestor lose or give up the nationality? Naturalizing elsewhere before the next generation was born often breaks the chain.
- Does the country allow dual citizenship? Some, like Lithuania, allow it only in narrow cases, which limits citizenship by descent for many families.
Citizenship by descent is also different from a residence route. It is recognition of status, not a visa. Compare it with the investment option in our golden visa programs guide.
Citizenship by Descent in Italy After the 2025 Changes
Italy changed the rules by Decree-Law 36/2025, converted into Law 74/2025 and effective 24 May 2025. Under Article 3-bis, a person born abroad who holds another citizenship is treated as never having acquired Italian citizenship by descent, unless an exception applies. The exceptions listed by Italy’s Miami consulate are:
- A complete application or confirmed consular appointment by 11:59 pm Rome time on 27 March 2025, or a court case filed by that date.
- A parent or grandparent who held only Italian citizenship at death, or still does.
- A parent who lived in Italy for at least two continuous years after acquiring citizenship and before the child’s birth.
Italy’s Constitutional Court upheld the law in Judgment 63/2026, decided on 11 March 2026 and deposited on 30 April 2026. A consular fee of 600 euros applies, and the consulate warns that incomplete document sets are not processed. For other Italian options, see our Italy country page.
Citizenship by Descent in Spain, Portugal and Greece
Spain. The Democratic Memory Law window for grandchildren and others closed on 22 October 2025 at 23:59 local time, with no extension. Cases stay valid only if you obtained an online confirmation or receipt before the deadline, and consulate backlogs could run into 2027 or 2028. Spain’s ordinary rules still give nationality by origin if a parent was Spanish at your birth. See our Spain country page.
Portugal. A law firm summary says amended Article 6 of the Nationality Law has applied since 19 May 2026. Grandchildren of Portuguese nationals by origin can still apply, but must show an effective connection such as language skills. Great-grandchildren need five years of legal residence. Details are still being adapted, so check with the registry office.
Greece. Citizenship is a legal right of anyone with at least one Greek parent, but it is formally recognized only after registration in a Greek municipality. The ministry says claims through grandparents or great-grandparents can be reviewed using old registry entries and passports. Begin at the Greek consulate covering your residence.
Citizenship by Descent in Ireland, the UK and Germany
Ireland. If a grandparent was born on the island of Ireland, you can join the Foreign Births Register. You apply online at fbr.dfa.ie, and the Department says a complete application takes about 12 months. The fee is 278 euros for adults and 153 euros for under 18s. Great-grandchildren qualify only if their parent registered before they were born.
UK Ancestry visa. This is a visa, not citizenship. You must be a Commonwealth citizen aged 17 or over with a grandparent born in the UK, the Channel Islands, the Isle of Man, or Ireland before 31 March 1922. GOV.UK lists a 5-year visa at 726 pounds plus the health surcharge. Settlement needs five years of continuous residence, B1 English, and the Life in the UK test.
Germany. A child born abroad after 31 December 1999 to a German parent who was also born abroad after that date does not automatically become German, unless the birth is registered within one year. Children born after 23 May 1949 who were excluded by gender discrimination in the old law can claim by simple declaration, and Article 116(2) lets descendants of Nazi persecution victims restore citizenship. Since 27 June 2024, Germans can hold other citizenships without losing German citizenship.
Citizenship by Descent in Poland, Hungary and Lithuania
Poland. The state confirms that you already hold citizenship. The chain generally runs through parents, grandparents or great-grandparents who did not lose citizenship. You file through a Polish consulate or the voivode, decisions take roughly a year, and you can appeal to the Minister within 14 days. Foreign documents need a sworn Polish translation. Proposed reforms with a citizenship test would not apply to people confirming descent.
Hungary. Simplified naturalization is open if an ancestor was a Hungarian citizen. You must know Hungarian and have a clean record. Hungary allows dual citizenship, but forms and communications are in Hungarian only.
Lithuania. Descendants of citizens who held Lithuanian nationality before 15 June 1940 can apply, down to great-grandchildren. The Migration Department typically decides within about six months. Dual citizenship remains limited, and referendums to widen it failed in 2019 and again in May 2024 when turnout fell short of the threshold.
Citizenship by Descent: Comparison Table
| Country | Who qualifies | Generation limit | Main tests | Timeline |
|---|---|---|---|---|
| Italy | Descendants meeting an Article 3-bis exception | Exception based | Exclusive Italian ancestor or two-year residence | Backlogs, check consulate |
| Ireland | Grandparent born in Ireland | Grandparent | Foreign Births Register | About 12 months |
| UK (Ancestry) | Commonwealth citizen, UK-born grandparent | Grandparent | Work intent, funds | Decision about 3 weeks |
| Germany | Descendants of German citizens | Cutoff for births after 1999 | Register birth within a year | Varies |
| Spain | Parent Spanish at your birth | Parent | Origin rules | Window for grandchildren closed |
| Portugal | Parent or grandparent | Grandchild with ties | Effective connection | Check registry |
| Poland | Unbroken Polish line | Wide | No loss of citizenship | About 1 year |
| Hungary | Ancestor Hungarian | Wide | Language, clean record | Check embassy |
| Lithuania | Pre-1940 citizen ancestor | Great-grandchild | Pre-1940 proof | About 6 months |
| Greece | Greek parent or ancestor | No stated limit | Municipal registration | Varies |
Steps and Documents for Citizenship by Descent
A strong citizenship by descent file is built backward from the ancestor to you.
- Interview relatives and find records. Start with the oldest document: a birth, baptism or marriage record from the ancestor’s home country.
- Build the chain. Collect birth, marriage and death records for every person from ancestor to you, and keep an eye on spelling changes.
- Check for naturalization. Italy asks for proof the ancestor did not naturalize elsewhere before a descendant was born.
- Apostille and translate. Documents from outside the country usually need an apostille, then a certified or sworn translation. Italy demands originals, and Poland requires sworn translators.
- Choose consulate or court. Consulates handle most files. Italian court claims now depend on the March 2025 deadline.
- Submit a complete file. The Miami consulate does not pre-screen, so missing pages mean rejection. Ireland returns incomplete applications.
Cost figures here come only from official sources, and translator, apostille and archive fees vary by country, so budget for them separately in any citizenship by descent file. A passport does not change where you pay tax, so see our digital nomad taxes for Americans guide if you hold a US passport.
Frequently Asked Questions
Which countries offer citizenship by descent in 2026?
Ireland, Poland, Germany, Hungary, Lithuania, Greece, Portugal and a restricted Italian route all still offer citizenship by descent, while Spain’s grandchildren window closed in October 2025. The UK offers an Ancestry visa rather than citizenship.
Can I get Italian citizenship through a great-grandparent now?
Only if you fall within an Article 3-bis exception, such as a filing by 27 March 2025 or an Italian parent or grandparent who held only Italian citizenship. Most new claims through distant ancestors are no longer possible.
Does the UK Ancestry visa give me British citizenship?
No. It gives permission to live and work for five years, and you may qualify for settlement after five years of continuous residence. Settlement is a separate application.
Do I need to live in the country to claim citizenship by descent?
Usually not. Ireland, Poland, Greece and Hungary let you apply from abroad through consulates or registers. The UK Ancestry visa is different because you must move there.
Can I keep my passport if I claim citizenship by descent?
Often yes, but it depends on both countries. Germany and Hungary allow dual citizenship, while Lithuania restricts it to narrow cases.
Also read: Golden Visa Programs Compared for 2026 | Best Passports in the World 2026 | Digital Nomad Visa vs Tourist Visa: Why It Matters in 2026 | Best Digital Nomad Visa for Europe in 2026
Find your perfect digital nomad visa match
Answer 5 questions — personalized results in under 2 minutes. Free.
Take the Free Quiz →