Citizenship by descent—also known as jus sanguinis—allows individuals to acquire a European nationality through their parents, grandparents, or, in some cases, more distant ancestors. Unlike naturalisation, applicants generally do not need to reside in the country for several years; they must instead prove that citizenship has been transmitted through the family line under the relevant national law.
Why the pathway is gaining attention in 2026
- Traditional immigration routes are tightening: many states are extending residency periods for naturalisation and scrutinising investment‑migration schemes.
- Ancestry‑based claims can grant an EU passport, the right to live and work across the bloc, and the ability to pass citizenship to future generations.
- Recent legislative changes—Italy’s 2025 generational limits, Spain’s 2025 closure of its “Grandchildren’s Law,” and Portugal’s 2026 reform of the Sephardic and great‑grandchild routes—demonstrate that eligibility can shift quickly.
Countries that currently offer citizenship by descent
| Country | Main eligibility criteria | Recent changes (2025‑2026) |
|---|---|---|
| Ireland | Child of an Irish parent (automatic) or grandchild of an Irish‑born grandparent (register on the Foreign Births Register). | No major changes; process remains straightforward. |
| Italy | Previously allowed unlimited generational claims; now limited to those with an Italian‑born parent or grandparent, subject to detailed requirements. | 2025 reform introduced generational caps to curb application volumes. |
| Poland | Uninterrupted descent from a Polish citizen; focus on legal transmission rather than a fixed generational limit. | No recent reforms; documentation of continuous lineage remains key. |
| Hungary | Proof of Hungarian ancestry; procedural requirements may include language ability depending on the legal basis used. | No major changes reported. |
| Germany | Citizenship by descent primarily through parents; restoration pathways exist for descendants of victims of Nazi persecution or discriminatory laws. | Recent reforms focus on naturalisation, not ancestry. |
| Portugal | Children of Portuguese citizens qualify automatically; grandchildren may qualify with sufficient connection and A2‑level Portuguese. A 2026 law (Lei Orgânica n.º 1/2026) closed the Sephardic Jewish descent route and created a new great‑grandchild route requiring B1‑level Portuguese, five years legal residence, and proof of community connection. | 2026 reform introduced the great‑grandchild route and closed the Sephardic route. |
| Greece | Citizenship through Greek parents and, in many cases, grandparents; requires official civil‑registration records proving an unbroken line. | No recent changes noted. |
| Romania | Standard descent provisions plus restoration for former citizens whose ancestors lost nationality due to historic border changes. | No recent changes noted. |
| Bulgaria | Demonstrated Bulgarian ancestry with supporting civil documentation. | No recent changes noted. |
| Lithuania | Descent and restoration for descendants of former citizens who left before or during WWII; dual‑citizenship rules may vary. | No recent changes noted. |
| Latvia | Allows descendants of Latvian citizens, especially those who left during occupations, to reclaim nationality with proper documentation. | No recent changes noted. |
| Czech Republic | Citizenship through parents and, in some cases, grandparents; recent legislation expands opportunities for descendants of former Czechoslovak citizens. | Recent legislative expansions. |
| Croatia | Recognises citizenship for descendants of Croatian emigrants; applicants may need to prove lineage and cultural/legal connections. | No recent changes noted. |
Countries with more restrictive descent rules
France, Belgium, the Netherlands, Denmark, Finland, Sweden, and Austria generally limit citizenship by descent to children of citizens, making ancestry alone insufficient in those jurisdictions.
Typical documentation required
- Birth certificates for each generation involved
- Marriage certificates (where applicable)
- Death certificates of ancestors
- Naturalisation or citizenship records of ancestors
- Historical civil‑registration documents (e.g., baptismal, military, immigration records)
- Valid passports/identification for the applicant
- Official translations of all foreign‑language documents
- Apostilles or other legalisations as required by the destination country
A single missing document can delay or derail an application, especially when reconstructing multi‑generational family histories.
Processing times
- Simple cases (well‑documented recent lineage) – often completed within 12 months.
- Complex cases (historical archives, court decisions, extensive document reconstruction) – may take several years.
Consular appointment availability and national administrative workloads also affect timelines.
Common reasons for rejection
- Incomplete or missing family documentation
- Failure to prove continuous lineage (e.g., ancestor lost citizenship before transmission)
- Inconsistent or erroneous civil‑record data
- Non‑compliance with current nationality legislation (especially after recent reforms)
- Legislative changes introduced after the application was submitted
Early legal assessment is increasingly valuable given the speed of recent policy shifts.
Citizenship by descent vs. other immigration pathways
| Feature | Citizenship by descent | Naturalisation | Residency‑by‑investment | Citizenship‑by‑investment |
|---|---|---|---|---|
| Basis | Family lineage | Years of legal residence, language, integration | Financial investment for residence | Financial contribution for citizenship |
| Typical residence requirement | None | 5‑10 years (varies) | Varies (often 1‑5 years) | May be immediate or after a short residence period |
| Language/ integration tests | Usually not required (except for some routes, e.g., Portugal) | Required | May be minimal | May be required |
| Cost | Primarily legal and documentation fees | Low direct cost, but indirect (living expenses) | High (investment amounts) | High (investment amounts) |
| Speed | Potentially fastest if documentation is complete | Medium to long | Medium | Variable, often longer than descent routes |
For eligible applicants, descent‑based citizenship can be the most direct route to an EU passport.
Determining if the pathway is right for you
- Verify that you have a parent, grandparent, or, where permitted, a more distant ancestor who held the relevant citizenship.
- Assess the specific legal requirements of the target country, including any language or residence conditions.
- Conduct thorough genealogical research and gather all required documents before initiating the application.
- Consider obtaining professional legal advice to navigate recent legislative changes and avoid costly rejections.
Outlook
Ancestry‑based citizenship remains a valuable legal avenue to European nationality in 2026, but the regulatory environment is evolving rapidly. Italy’s 2025 reform narrowed eligibility to parents and grandparents; Spain’s 2025 closure ended a program that had processed over a million applications; Portugal’s 2026 law closed the Sephardic route while adding a conditional great‑grandchild pathway. While many countries continue to preserve their descent routes, each applies distinct legal standards and documentation demands, and none can be assumed to remain static.
Understanding the current rules—and the documentation needed—offers the first step for anyone with European roots to determine whether citizenship by descent remains a viable option.
Source article: outboundinvestment.com
