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Behind the Growing Global Demand for Dual Citizenship

PROF. PETER J. SPIRO

PROF. PETER J. SPIRO

Prof. Peter J. Spiro is Charles Weiner Professor of Law at Temple University Law School.

The availability of dual citizenship has expanded dramatically over the last 25 years. Demand for the status has also risen. Covid and recent political developments are unlikely to reverse acceptance of the status by states. But demand for additional citizenships is becoming more pervasive. No matter where you come from, dual citizenship now has insurance value. It is likely to be claimed by an increasing proportion of eligible individuals, and not just among those holding lower-ranked passports.

State perspectives: from total rejection to entrenched acceptance

Dual citizenship has ridden a dramatic historical trajectory. From intense antipathy to grudging tolerance and then growing acceptance, states shifted their stance on the status. Hard as it may be to comprehend today, dual nationality was long considered akin to bigamy, a moral abomination. At the turn of the 20th century, states moved to police the status by terminating the nationality of their citizens who naturalized in other countries and by requiring that those born with two nationalities chose one of them upon attaining majority (in a practice known as “election”). During the first half of the 20th century it was difficult to hold dual citizenship on an active basis. The status was also vaguely (though unjustifiably) associated with subversive activities.

With the decline of armed conflict in the wake of World War II, policing became less aggressive. It was possible to hold two citizenships — quietly. The end of the Cold War saw many states turning to acceptance of the status. Among source states in the global south, dual citizenship gained favor as a mechanism for cementing long-term relationships with economically powerful diasporas who demanded recognition of the status. State acceptance of dual citizenship has grown dramatically in recent years.

Important holdout states remain. Japan actively rejects dual citizenship, at least where native-born Japanese naturalize in other countries. But even Japan has relaxed its strict opposition with respect to increasing numbers of Japanese born with other citizenships. India does not recognize full dual citizenship but extends members of the Indian diaspora a form of semi-citizenship — Overseas Citizenship of India — which affords holders travel and employment authorization in the country. China is the most important — and complicated — example of a state that continues formally to bar dual citizenship. But many Chinese hold dual citizenship since China enforces the ban on a highly selective basis only.

Among other states, the vast majority of which accept dual citizenship, Covid has not changed the basic policy calculation, and there is no evidence of backtracking. On the contrary, trends point to increased acceptance. Germany, which has historically resisted dual citizenship, looks poised to fully regularize the status in the wake of recent elections there.

Growing individual appeal

Individual perceptions of dual citizenship have largely correlated with those of states. In the 19th and early 20th centuries, dual nationality was a millstone. Citizen obligations were burdensome, especially with respect to military service. Conscription was based on nationality, not residence, so many dual nationals faced the prospect of crushing duplicative obligations. Through the mid-20th century, states entered into a web of treaties that relieved dual nationals from duplicative service. But there were still few advantages to the status.

That changed with the revival of economic migration and the introduction of variable visa requirements during the 1990s. What citizenship you held translated into differential economic opportunity and travel freedom. Those with less favored passports now had a major incentive to acquire premium ones. For example, hundreds of thousands in Argentina and Chile, lucky enough to have the ‘right’ grandparents, acquired Italian or Spanish passports through ancestral qualification. Birth tourism to the USA became a thing. Others acquired second and third passports through citizenship by investment programs.

Among those already possessing a premium citizenship, demand for dual citizenship remained low. For example, a US citizen had little material incentive to acquire an EU citizenship. A US passport was getting you everywhere you needed to go. Some Americans acquired additional citizenships for sentimental reasons or as a curiosity, but even among those eligible for EU citizenship on the basis of ancestry, the possibility of dual citizenship seemed not worth the effort. Ditto for Brits and others from major developed states.

Pandemic and politics: steepening the demand curve

Covid has severely curtailed global leisure and business travel. To the extent that dual citizenship has facilitated visa-free travel for those with disadvantaged passports, one would expect lowered demand for multiple citizenships. One doesn’t need shorter passport lines if one isn’t getting on planes.

Covid has, however, magnified another citizenship benefit: absolute entry rights into a country in which one holds citizenship. As Covid spread in early 2020 states locked their borders down. But almost all of them continued to allow entry by citizens (in many cases permanent residents as well).

So dual citizenship now has value even to those holding premium passports. It has emerged as a kind of safeguard that has value regardless of one’s primary nationality. In the pandemic context it becomes a kind of health insurance. And not just dual citizenship — the more citizenships one holds, the more diversified one’s insurance will be. For a US citizen, for example, it now makes sense to have EU and other citizenships, just in case.

This pandemic-induced development has been reinforced by parallel political disruptions. Dual citizenship has long been used as a political hedge among those living in Latin America and other regions prone to instability. Until recently that would hardly have been understood as a motivation for acquiring alternative citizenships among those in stable democracies. Yet today, those democracies hardly seem invulnerable. Political and social polarization pose a real risk of societal disruptions even in longstanding democratic countries. Multiple citizenship has insurance value against that kind of risk too.

Multiple citizenship is thus likely to become even more prevalent than it already is. Of course, it will still only be available to those who are eligible. Some will qualify for free on the basis of ancestral ties, mixed parentage, or territorial resettlement. Others will pursue citizenship by investment, and not just Chinese, Middle Eastern, Russian, and other perennial consumers of investor citizenship programs. Citizenship has never been taken for granted. But one citizenship alone seems increasingly inadequate in the face of growing global turbulence.

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