How alarmed should we be about Europe’s tightening citizenship rules?

In recent months, several countries in Europe have announced plans, or said they are at least considering, new rules on obtaining citizenship.

In Sweden, an inquiry recently proposed extending the residency requirement to eight years from the current five, and since April 1st, the Migration Agency has toughened security checks on applicants, which led to a temporary freeze on the processing of applications. Sweden has also talked of introducing language and civics tests for citizenship applicants.

Last year, Finland extended the required residency period for naturalisation from five to eight years and shortened the time limits for allowed absence.

In Germany, the new government has  passed a bill to scrap the fast-track path to citizenship, which requires only three years of residence for people considered “highly integrated”. The bill, which still needs the approval of the Bundestag, reverses part of the citizenship reform adopted in 2024.

In Italy, a referendum aiming to reduce the residency requirement to get citizenship didn’t receive enough participation to be valid. Separately, the parliament recently adopted new rules that limit to two generations the possibility to obtain citizenship by ancestry.

In Denmark authorities hiked the citizenship fee by 50 percent on May 1st. Months earlier the country’s Immigration Ministry also appointed an expert panel to look into the possibility of screening applicants for views considered “antidemocratic”.

Elsewhere in the Nordics, Norway will hold a general election in September, and both the Conservative Party and Progress Party, which could form a right-wing coalition, said they want to tighten citizenship requirements.

In France, where the anti-immigration far-right has been growing in popularity in recent years, the country’s Interior Minister Bruno Retailleau talked of his plans to ‘toughen up’ the citizenship regime, including the possible addition of a history and civic test.

Nationality reforms were also at the centre of the political agenda in the Netherlands, where the far-right government, which has recently collapsed, wanted to increase the residence requirement from five to ten years. A similar plan to lengthen the residency qualification period has been taken by the Labour government in the UK, as part of proposals to further tighten immigration rules.

Why so many changes?

Professor Maarten Vink, Chair of Citizenship Studies at the Robert Schuman Centre, European University Institute in Florence, warned the measures will impact the number of foreign residents gaining citizenship.

“Even if the trend is mixed, I am concerned about the proposed tightening of the rules, such as the increase in the residence requirement in Sweden and the UK to 10 years, and about the fee hike in Denmark.

“Such measures will only slow down the rates at which immigrants acquire citizenship, especially among marginalised groups, whereas all available evidence indicates that both migrants and receiving societies benefit from an expedient pathway to citizenship.”

Vink added that it was “quite common countries change citizenship rules every couple of years.”

“We are in a democracy, so if in elections the political balance shifts, it is normal that this is reflected in legislation. When migration is a very important topic in politics, issues that are related to migration, such as citizenship, are also part of this dynamic,” he said.

Professor Vink said that citizenship laws in Europe have recently been “more dynamic than in other parts of the world”, although “changes go in different directions.”

Dual citizenship

The most significant trend that has emerged, and is “unidirectional”, he argued, is the acceptance of dual citizenship.

“Back in the 1960s, most countries around the world restricted dual citizenship because this was seen as a problem of loyalty and allegiance, especially at times of more warfare and military conscription,” said Vink.

Although exceptions remain in Austria, the Netherlands, the Baltic countries and several Eastern European states, this is an area that has seen “a very clear liberalisation trend globally and in Europe”.

Vink said this was partly driven by migration as more people moved and built a life in another country and maintained family ties to the country where they came from, or where their parents and grandparents came from.

Another factor was gender equality.

“In the past, a woman marrying a man from another country would automatically become a citizen of that country, or lose hers, and the children would be only citizen of the father’s country. Recognising a woman and a man as both independent in citizenship law, as it happened in all European countries, allowed for the creation of mixed citizenship families,” he explained.

Vink points out that even the new German government, which has proposed a step back on the “modernisation’” of citizenship laws by removing a fast-track procedure, has agreed to maintain the main elements of the landmark 2024 reform – the acceptance of dual citizenship and the reduction of the residency requirement from eight to five years.

Developments in family law also affect citizenship, for example with the right to transmit citizenship from the non-biological parent to a child in a same-sex family.

“Scandinavian countries have been very proactive in incorporating these family law elements in citizenship law, while in countries like Italy there are still restrictions,” Vink said.

There are also other hurdles facing some European countries if they want to change citizenship laws.

In most European countries the area is also regulated via the European Convention on Nationality, signed in 1997 under the Council of Europe (not an EU institution). Some 29 European countries signed the Convention, but 8 (Croatia, France, Greece, Italy, Latvia, Malta, Poland and Russia) have not ratified it.

For example under the rules set by the convention, the residence requirement for citizenship cannot exceed 10 years, an upper limit that is met by all European countries, with the most common requirement set at 5 years.