A child’s citizenship can be shaped by birthplace, ancestry, residence, language proficiency, or investment, but many of these pathways become unavailable or more costly once the child reaches adulthood. Planning early can preserve options that later close or become significantly harder to obtain.
Birthplace and descent at birth
- Birthright citizenship still exists in about 33 countries, almost all in the Americas.
- The United Kingdom ended unconditional birthright citizenship in 1983, Australia in 1986, and Ireland by referendum in the mid‑2000s.
- The United States reaffirmed birthright citizenship in June 2026, rejecting an executive order that sought to end it for children of temporary residents.
- Brazil grants citizenship to any child born on its soil, and the parents may naturalise after one year of residence.
Descent is often under‑utilised. A parent’s existing citizenship can be passed to a child, but eligibility may depend on the parent’s status at the time of the child’s birth, not on later naturalisation.
Ancestry‑based citizenship is narrowing
- Italy: Law 74/2025 (effective 2025) limits citizenship by descent to cases where the Italian ancestor held citizenship exclusively, or where a parent lived in Italy for at least two consecutive years after acquiring citizenship and before the child’s birth. The Constitutional Court upheld the law in March 2026. For children born after 24 May 2025, a declaration must be filed within three years of birth; a transitional deadline of 31 May 2029 applies to children already alive when the law took effect.
- Canada: In December 2025 the first‑generation limit was removed, but a child born abroad after 15 December 2025 requires the Canadian parent (who was also born abroad) to have at least 1,095 days of physical presence in Canada before the birth.
- The overall trend shows ancestry routes becoming more restrictive as governments tighten documentation requirements and limit generational transmission.
Residence, language, and investment routes
- Residence: Time spent in a country before age 18 creates “genuine” ties that adult applicants cannot replicate. Portugal’s revised nationality law (effective May 2026) requires at least five years of legal residence by a parent for a child born there to acquire Portuguese citizenship at birth; previously the threshold was one year. A child born before the parent meets the five‑year mark inherits the parent’s nationality and must naturalise later.
- Language: Portugal also demands an A2‑level proficiency in Portuguese for descent claims through grandparents, and a demonstrated genuine connection for great‑grandchild claims—requirements that are easily met by children educated locally but often block adult applicants.
- Citizenship‑by‑investment (CBI): Dependent children can be added to the primary applicant’s CBI at a reduced cost. For example, Grenada’s programme charges a USD 235,000 National Transformation Fund donation for a family of up to four, plus roughly USD 25,000 per additional child (excluding government and due‑diligence fees). Prospective investors should verify whether citizenship can be transmitted to subsequent generations, as some jurisdictions restrict onward transmission for naturalised citizens.
Additional obligations to consider
- Conscription: About 60 countries maintain mandatory military service; dual‑national children may be liable for conscription in a second country upon reaching the applicable age.
- Taxation: U.S. citizenship, whether obtained by birth or descent, imposes worldwide tax‑filing obligations for life, regardless of residence.
Early mapping of these factors helps families secure the most advantageous and sustainable citizenship options for their children before the relevant windows close.
Source article: knightsbridge.ae
