More than half of the world’s states once stripped citizenship from anyone who acquired a foreign passport, but by 2019 that share had fallen to roughly a quarter. The gap between a law that bans dual nationality and the way it is actually enforced now determines whether a second passport is a minor inconvenience or a risk of losing one’s original nationality.
Nominal restrictions
- Poland appears on many dual‑citizenship ban lists, yet Polish law does not prohibit holding another passport. The law simply requires officials to treat a Polish citizen as Polish alone, a position confirmed by the Supreme Administrative Court.
Countries that enforce the ban in practice
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Japan: Legally, dual nationals must choose one citizenship and acquiring a foreign passport should automatically cancel Japanese nationality. In practice, filing a declaration in favour of Japan satisfies the Ministry of Justice, and the law only asks the person to “strive to renounce” the other passport. About 700 000 dual nationals over 22 live in Japan, and none have been forced to give up their foreign citizenship.
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Thailand: Since 1965 the law states that naturalising abroad ends Thai nationality, but no involuntary revocations have ever been published. Thai embassies even issue guidance on travelling with two passports, and the 2017 constitution bars revoking citizenship from anyone born Thai.
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India: Citizenship ends automatically when a person naturalises elsewhere. Continuing to travel on an Indian passport breaches the Passports Act, and consulates will not issue an Overseas Citizen of India (OCI) card or a visa without a surrender certificate. Fines are modest (₹10 000 per trip after a three‑month grace period, capped at ₹50 000; ₹25 000 per renewal) but are collected at the moment consular assistance is needed, creating a paper trail. In 2024, 206 000 Indians formally renounced citizenship; between 2020‑2024, close to 900 000 did so.
Discretionary enforcement
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Egypt: Citizens must obtain official permission before acquiring another nationality. Without permission, they remain Egyptian unless a cabinet decision revokes citizenship—practitioners report no such revocations.
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Saudi Arabia: Similar discretionary power; a dual national remains fully Saudi until the state decides otherwise.
Constitutional protections that limit bans
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Estonia: The Citizenship Act requires anyone holding a second nationality to surrender one within three years of turning 18, but the constitution prevents stripping citizenship from those who acquired it by birth. Consequently, birth‑right Estonians keep both passports for life, while naturalised citizens cannot.
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Zimbabwe: The Citizenship Act bans foreign nationality, but the 2013 constitution protects citizens by birth. The Constitutional Court’s Mawere decision (dual citizenship not prohibited for those born Zimbabwean) led to the restoration of citizenship for many diaspora members.
Light‑touch enforcement
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Kazakhstan: Identified 1 190 dual‑citizenship cases at its borders in 2024; 675 were penalised administratively. Fines are about US$2 200, with expulsion as an alternative. The government acknowledges that many citizens find ways around the rules. A 2025 parliamentary proposal to introduce criminal liability has not yet changed the regime.
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China: Historically, poor data sharing allowed people to retain a household registration (hukou) while holding a foreign passport. New exit and entry rules effective 15 September 2026 broaden the grounds on which citizens can be stopped from leaving the country.
Rapid policy reversal
- Kuwait: Dual nationality was an “open secret” until August 2024, when a revocation campaign based on a dormant rule began. Over 12 000 citizenships were withdrawn in three months, rising to ~50 000 by August 2025. An independent monitor counted more than 71 000 cases by mid‑April 2026—about 4.6 % of the citizen population. Including spouses and descendants, estimates range from 250 000 to 300 000 people. A hotline for anonymous reports and an April 2026 decree placing nationality decisions beyond judicial review underscore the speed of the shift.
Recent reforms shrinking the ban list
- Ukraine: Multiple‑citizenship law took effect 16 January 2026, initially permitting dual nationality with the United States, Canada, Germany, Poland and the Czech Republic, while still excluding Russia.
- Vietnam: Expanded categories of people allowed to retain a foreign nationality from 1 July 2025.
- South Africa: Constitutional Court struck down automatic loss of citizenship on 6 May 2025, back‑dating the ruling to 1995; affected individuals are treated as never having lost citizenship.
- Lithuania: A May 2024 referendum approved dual citizenship by a majority of votes cast, but the turnout fell short of the constitutional threshold, so the reform failed.
Practical takeaways for second‑passport planning
- Determine what action the government must take to enforce loss of citizenship. In the Netherlands and Austria, loss occurs automatically at passport renewal; in Egypt and Saudi Arabia, a ministerial decision is required.
- Check whether the constitution protects citizens by birth; this distinction separates Estonia and Zimbabwe (where birth‑right citizens keep both passports) from countries like India and Indonesia, where many have formally renounced citizenship (≈8 000 people over five years).
- Assess political volatility. Kuwait’s abrupt crackdown shows that a “quiet” rule can change rapidly. Nepal’s 2023 removal of a deputy prime minister over U.S. citizenship illustrates how political attention can trigger enforcement.
- Seek specialist advice before relying on a permissive‑on‑paper regime, especially if the home country has a history of discretionary or sudden enforcement.
Source article: knightsbridge.ae
