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What Exactly is Citizenship by Descent?

Citizenship by descent is exactly what it sounds like: citizenship derived from ancestry. In other words, citizenship by descent is the citizenship you inherit through your parents, grandparents, great-grandparents, or in some cases more distant ancestors.

The legal principle behind citizenship by descent is called jus sanguinis, Latin for “right of blood.” If your family roots trace back to a jus sanguinis country, you may already hold a claim to citizenship there without realizing it.

How do people acquire citizenship?

Across the world, there are several ways a person can become a citizen of a country:

  • Naturalization: choosing to become a citizen of another country after meeting residency, language, and civics requirements
  • Marriage: acquiring citizenship through a spouse
  • Birth on the territory: automatic citizenship based on where the person was born, regardless of parental nationality
  • Special grant: citizenship awarded for extraordinary merit or at a government’s discretion
  • Descent: citizenship inherited through a parent’s (or further ancestor’s) nationality

Most countries assign citizenship at birth using one of two legal frameworks: jus soli or jus sanguinis.

Jus soli vs. jus sanguinis… what’s the difference?

Both are Latin terms, but they describe very different legal mechanisms for acquiring citizenship at birth.

Jus soli means “right of the soil.” A person born in a jus soli country is automatically a citizen at birth, regardless of parental nationality. Most New World countries follow jus soli, including the United States, Argentina, Brazil, Canada, and Mexico.

Jus sanguinis means “right of blood.” Children born in jus sanguinis countries receive citizenship based on their parents’ nationality, not their place of birth. A child born in a jus sanguinis country to foreign parents does not automatically become a citizen of that country. Most Old World countries operate on jus sanguinis principles, including Italy, Poland, Austria, Ireland, Germany, and Slovakia.

Note that these systems are fluid. Very few countries are completely jus sanguinis or jus soli. Most countries operate with a hybrid system which allows people to obtain citizenship in both ways, depending on that individual’s particular situation.

How jus soli and jus sanguinis work together

Here’s where citizenship by descent gets interesting: the two systems can overlap, and that overlap is exactly what makes citizenship by descent possible for so many people today.

If you were born in a jus soli country but your ancestors held citizenship in a jus sanguinis country, you may be eligible for dual citizenship in your ancestral homeland. For example, a baby born in the United States to two Irish parents is an American citizen at birth (under jus soli) and an Irish citizen at birth (under jus sanguinis). Both citizenships exist simultaneously from day one.

Jus sanguinis can also pass down through multiple generations without ever being formally claimed. Even when it sits unrecognized, it doesn’t disappear. It remains dormant, waiting to be acknowledged through a citizenship application. That’s why people who are several generations removed from their emigrant ancestor can still pursue recognition of their ancestral citizenship today.

Somewhere in your family tree, there may be an ancestor who entitles you to dual citizenship

Citizenship by descent: what this means for you

If you have ancestors from any jus sanguinis country, it is well worth checking that country’s citizenship laws. You may already be entitled to a second passport through citizenship by descent… you simply need to claim it.

Below, you’ll find a handy chart that lists jus sanguinis countries and a brief snippet about each one’s rules. You’ll notice some jus soli countries on the list as well, because jus soli countries often allow jus sanguinis too (the reverse is less often true).

This post is intended as a starting point. Citizenship laws change frequently, eligibility rules can be highly technical, and the documentary requirements vary widely from country to country. Always conduct your own independent research, and consider consulting a qualified citizenship by descent practitioner before beginning a formal application.

Frequently asked questions about citizenship by descent

Is citizenship by descent the same as jus sanguinis? Yes. Citizenship by descent is the practical term; jus sanguinis is the legal Latin term for the same underlying principle.

How many generations back can citizenship by descent go? It depends on the country. Some jus sanguinis countries place no generational limit, while others restrict eligibility to children or grandchildren of citizens. Recent legislative changes in several countries have tightened these rules, so always check the current law.

Do I lose my original citizenship if I claim citizenship by descent? Usually no, but it depends on both countries’ rules on dual citizenship. Many jus sanguinis countries permit dual or multiple citizenships.

Can I pass citizenship by descent on to my own children? In most cases, yes. Once you are formally recognized as a citizen, your minor children typically qualify as well, and your future children will inherit the citizenship automatically. In other cases, depending on how far you are removed from your original emigrant ancestor, you must become a recognized dual citizen prior to having children if you wish to pass it on.

Countries that Offer Citizenship by Descent

Africa

CountryBasis
AlgeriaArticle 6 of the Algerian nationality law confers citizenship at birth through a parent.
EgyptNationality law of the Arab Republic of Egypt (as amended) confers citizenship through a parent.
KenyaConstitution of Kenya 2010, Article 14(1): citizenship by descent through a Kenyan parent.
LiberiaConstitution restricts citizenship to persons of Negro descent (cultural or national origin).
MoroccoArticle 6 of the nationality code: citizenship to a child born to a Moroccan parent.
NigeriaConstitution, Chapter 3, Section 25(1)(c): citizenship by descent through a Nigerian parent.
RwandaConstitution: all persons originating from Rwanda and their descendants have a right to nationality.
South AfricaSection 2 of the Citizenship Act: a child born to a South African citizen acquires citizenship.
TunisiaNationality law: when one parent is Tunisian, the child is Tunisian.

Americas

CountryBasis
ArgentinaArgentine nationality law provides citizenship by descent through a parent.
BrazilConstitution Article 12, paragraph I(b) and (c): citizenship to children born abroad to Brazilian parent(s).
CanadaCitizenship by descent under the Citizenship Act; Bill C-3 (in force December 15, 2025) extends descent beyond the first generation.
ChileChilean nationality law: citizenship by descent through a Chilean parent.
ColombiaColombian nationality law: citizenship by descent through a Colombian parent.
Dominican RepublicConstitution: a child born abroad to at least one Dominican parent is a citizen.
HaitiNationality law: every child born to a Haitian father or mother is Haitian.
MexicoConstitution Article 30: persons born abroad to at least one Mexican parent are Mexican by birth.
SurinameSurinamese nationality law: citizenship by descent through a Surinamese parent.
United StatesU.S. nationality law: a child born abroad to U.S. citizen parent(s) acquires citizenship, subject to parental residency or physical-presence requirements.
VenezuelaConstitution Articles 32 through 42 establish citizenship by descent.

Asia

CountryBasis
AfghanistanCitizenship tied to connection with the Afghan diaspora; ethnic-origin provisions have been proposed.
ArmeniaConstitution Article 47 (descent) plus Article 14: individuals of Armenian ethnic origin acquire citizenship through a simplified process.
AzerbaijanConstitution Article 52: citizenship by descent through an Azerbaijani parent.
CambodiaLaw on Nationality, Article 4: a child born to a Khmer parent (mother or father) is a citizen.
ChinaNationality law Article 5: a child born abroad to a Chinese parent is a citizen, with limits where the parent has settled abroad or holds foreign nationality.
IndiaIndian nationality law: a child born outside India on or after December 3, 2004 to an Indian parent is a citizen by descent (registration required in some cases).
IndonesiaNationality law: a child born anywhere to one Indonesian parent acquires citizenship.
IranIranian nationality law: citizenship by descent through a parent (historically patrilineal, with recent reforms expanding maternal transmission).
IsraelNationality law confers citizenship on all children of Israeli citizens; the Law of Return separately grants citizenship to Jews and certain non-Jewish relatives.
JapanNationality law: a child born to a Japanese parent acquires Japanese nationality.
MalaysiaPrior to 2025, only overseas-born children of Malaysian fathers qualified; the 2025 Constitution (Amendment) Act expanded transmission rules.
MongoliaNationality Act of Mongolia: a child of a Mongolian citizen acquires Mongolian nationality.
MyanmarBurma Citizenship Law 1982: nationality restricted to recognized ethnic groups (Kachin, Kayah, Karen, Chin, Burman, Mon, Rakhine, Shan).
NepalNepal Citizenship Act 2063 (2006): citizenship by descent through a Nepali parent.
PakistanPakistani nationality law: a child born outside Pakistan to a Pakistani parent acquires citizenship.
PhilippinesPhilippine nationality law is grounded in jus sanguinis; citizenship passes through a Filipino parent.
SingaporeNationality law allows overseas-born children of Singaporean parent(s) to acquire citizenship by descent.
South KoreaNationality law: citizenship through a Korean parent; special facilitated status for ethnic Koreans and their descendants abroad.
TaiwanNationality Act, Article 2: a child of a national of the Republic of China is a Chinese national.
ThailandThai nationality law: any person who is a child of a Thai mother or father is Thai by birth.
United Arab EmiratesUAE Federal Law No. 17 of 1972: Emirati nationality acquired through descent.
VietnamVietnamese nationality law: nationality conferred through a Vietnamese parent.

Europe

CountryBasis
AustriaAustrian nationality law: citizenship by descent through an Austrian parent. 
BelgiumBelgian nationality law: citizenship by descent through a Belgian parent.
BulgariaConstitution Article 25 (1991): a person of Bulgarian origin acquires Bulgarian citizenship on a facilitated basis.
CroatiaLaw on Croatian Citizenship, Article 11: emigrants and their descendants are entitled to citizenship.
Czech RepublicChildren, and in some cases grandchildren, of Czech citizens automatically acquire citizenship.
DenmarkDanish nationality law: citizenship by descent through a Danish parent.
EstoniaConstitution Article 8: every child with at least one Estonian parent is an Estonian citizen.
FinlandFinnish nationality law (descent) plus a right of return for ethnic Finns from the former Soviet Union.
FranceFrench nationality law: citizenship by descent through a French parent.
GermanyCitizenship through a German parent; Basic Law Article 116(1) confers citizenship on ethnic Germans (Aussiedler) and certain persecuted descendants.
GreeceCode of Greek Nationality: ethnic Greeks can obtain citizenship through two recognized methods.
HungaryCitizenship acquired at birth if at least one parent is Hungarian; simplified naturalization is available to ethnic Hungarians abroad.
IcelandIcelandic nationality law: citizenship by descent through an Icelandic parent.
IrelandCitizenship automatic for a child born in Ireland with at least one Irish parent; foreign-born descendants may register via the Foreign Births Register.
ItalyItalian nationality law historically grants jus sanguinis with no generational limit; Decree-Law 36/2025 (converted into Law 74/2025) introduced significant generational restrictions effective March 27, 2025.
LithuaniaConstitution grants a right to citizenship to foreigners of ethnic Lithuanian descent.
MaltaMaltese nationality law: citizenship to any person descended from a Maltese ascendant.
NetherlandsDutch nationality law: citizenship by descent through a Dutch parent.
NorwayNorwegian nationality law: citizenship by descent through a Norwegian parent.
PolandPolish nationality law: Polish citizenship has long been defined principally by descent.
PortugalNationality to children and grandchildren of Portuguese citizens; Organic Laws 2/2006, 9/2015, and 2/2018 cover descendants of Sephardic Jews.
RomaniaRomanian nationality law: citizenship by descent, including for ethnic Romanians from neighboring states.
RussiaRussian nationality law: citizenship by descent through a Russian parent.
Serbia2004 citizenship law, Article 23: descendants of Serbian emigrants may acquire citizenship.
SlovakiaFull Slovak citizenship to children where one or both parents are Slovak.
SpainSpanish nationality law (descent); a 2015 law allowed descendants of expelled Sephardic Jews to apply, with the application window now closed.
SwedenSwedish nationality law: citizenship by descent through a Swedish parent.
SwitzerlandSwiss nationality law is descent-based and unusually restrictive; ordinary naturalization requires lengthy residency and stringent conditions.
TurkeyCitizenship by descent through a Turkish parent; facilitated naturalization for people of Turkish origin and their spouses and children.
UkraineLaw on Citizenship of Ukraine, Article 8: any person with at least one Ukrainian parent.
United KingdomBirth abroad confers British citizenship ‘by descent’ where one parent is a British citizen otherwise than by descent.

Oceania

CountryBasis
KiribatiConstitution Articles 19 and 23: every person of I-Kiribati descent has a right to citizenship.