Recent policy shifts across Europe are making dual citizenship increasingly difficult to obtain. Governments are introducing retroactive rules, higher fees, and stricter residency or integration requirements, effectively limiting the ability of foreign nationals—particularly high‑tax‑paying residents—to secure a second passport through investment or naturalisation.
Retroactive rule changes
- Retroactivity: Several countries are applying new eligibility criteria to applicants who began their processes under earlier, more permissive rules. This can invalidate investments or residency periods that were previously counted toward citizenship.
- Exit fees: Some states have doubled the cost of renouncing their nationality, adding a financial barrier for those wishing to switch citizenship.
Country‑specific updates
| Country | Recent change | Practical impact |
|---|---|---|
| Italy | Limits the number of generations that can claim citizenship by descent to two, down from a more generous allowance. | Applicants with Italian ancestry beyond grandparents are now ineligible. |
| Portugal | Extends the residency requirement for naturalisation from 5 to effectively 10‑15 years, due to longer processing times for the Golden Visa and citizenship applications. | The pathway to Portuguese citizenship can now take 15‑16 years, discouraging many investors. |
| Spain | Continues to restrict dual citizenship, allowing it only with a limited list of countries. | Most non‑Spanish applicants must renounce their original nationality. |
| Netherlands | Allows dual citizenship only in narrowly defined circumstances (e.g., marriage to a Dutch citizen). | Most foreign investors must give up their original passport. |
| France | Raises language proficiency standards and adds mandatory civic and integration tests. | Even applicants who have reached a certain language level may find the new thresholds unattainable. |
| Sweden | Proposes extending the residency period for naturalisation from 5 to 7 years. | Longer stay before eligibility, potentially delaying citizenship. |
| Poland | Ongoing reforms (details not specified) that are expected to tighten naturalisation criteria. | |
| Malta & Cyprus | Terminated their direct citizenship‑by‑investment (CBI) programmes. | Investors can no longer purchase citizenship outright; only merit‑based routes remain. |
| Albania | Offers a flexible visa regime and a merit‑based citizenship pathway that could become more valuable if the country joins the EU. | Early adopters may benefit from a future EU accession. |
| Montenegro | Shifts from a pure CBI model to a merit‑based approach, with a donation component and profile assessment. | |
| North Macedonia | Provides a hybrid programme that mixes investment with negotiated agreements, but lacks a pure CBI option. | |
| Serbia | Offers merit‑based citizenship, though the market is prone to fraud; careful vetting of providers is essential. |
Impact on high‑tax jurisdictions and U.S. nationals
- U.S. interest: Many Americans seek EU passports for tax optimisation and travel freedom. Recent tightening—especially Italy’s generational limit—means a growing number of U.S. applicants will be excluded from previously available routes.
- Other high‑tax residents: Similar pressures affect British, Canadian, and other affluent expatriates who previously relied on investment‑based citizenship schemes.
Emerging merit‑based pathways
- Merit‑based citizenship: Several Balkan states (Albania, Montenegro, North Macedonia, Serbia) now evaluate applicants on factors such as clean criminal records, financial contribution, and professional profile rather than offering a straightforward purchase.
- Hybrid strategies: Investors may combine a non‑EU “gateway” nationality (e.g., Albanian) with a future EU accession prospect, or pair a European passport with an African citizenship that offers additional travel or tax benefits.
- Verification: Securing a legitimate passport requires:
- Official embassy or consular verification of the applicant’s status.
- Confirmation from the host country’s Ministry of Justice or interior ministry that the citizenship documents are authentic and legally recognised.
Practical considerations
- Due diligence: Vet any citizenship‑by‑merit service to ensure it operates through official government channels and not via unofficial “pay‑for‑passport” schemes.
- Cost vs. benefit: Merit‑based programmes often involve donations or investment components, but they can be less expensive than traditional CBI schemes.
- Timeline: Expect longer processing periods—often 2‑3 years for residency visas followed by additional years for naturalisation.
- Risk of retroactive changes: Monitor legislative updates closely; a rule change can render an ongoing application invalid.
For individuals seeking a second passport, the current environment favours careful planning, reliance on verified legal channels, and an awareness that many previously accessible routes are now closed or significantly delayed.
