The landscape for acquiring dual citizenship in Europe has shifted dramatically in 2025‑2026. A wave of restrictions on citizenship‑by‑descent, extensions of natural‑isation residency periods, and the shutdown of investment‑based programmes are reshaping how and when applicants can obtain an EU passport.
What changed in 2025‑2026
| Country | Policy change | Status |
|---|---|---|
| Italy | Emergency decree (Dec 2025) limits citizenship by descent to two generations — the applicant’s parent or grandparent must have been born in Italy and died as an Italian citizen. The change is retroactive, affecting pending applications. | In force; constitutional challenge scheduled for March 2026. |
| Portugal | Proposed increase of residency requirement from 5 → 10 years for naturalisation; constitutional court blocked the amendment but a revised proposal is expected. | Blocked (pending revision). |
| Sweden | Proposal to raise residency requirement from 5 → 7 years. | Proposed. |
| Poland | Proposal to raise residency requirement from 3 → 8 years. | Proposed. |
| France | Effective Jan 2026: stricter language proficiency and mandatory civic test for naturalisation. | In force. |
| Spain | Ended its “golden visa” investment programme (date not specified). | Closed. |
| Malta | Completely shut down its citizenship‑by‑investment scheme. | Closed. |
| Cyprus & Bulgaria | Followed the trend of ending investment‑based citizenship routes. | Closed. |
| Ireland, Belgium, Netherlands | No recent changes to naturalisation or descent rules. | Unchanged. |
The overall pattern is clear: descent programmes are being narrowed, naturalisation timelines are being lengthened, and investment routes are disappearing.
Why the crackdown now?
-
Shift in demand – Citizens of traditionally stable Western nations are increasingly seeking additional passports.
- A Gallup survey reports that 1 in 5 Americans now intend to immigrate.
- Post‑Brexit, British nationals rank among the top five nationalities applying for dual citizenship (CNN).
-
Fiscal and security concerns – Large potential pools of new citizens raise questions about the cost of consular services, health‑care, and benefit claims.
- Italy estimated that over 60 million descendants could qualify under the old rules, roughly doubling its citizen base.
- Italy floated a €2,000 annual fee for non‑resident citizens to access health care, signalling fiscal pressure.
-
Political backlash – “Paper citizens” who never integrate but still claim benefits are generating resentment.
- Legislative proposals, such as a U.S. Senate bill to ban Americans from holding dual citizenship, illustrate the growing politicisation of the issue.
These factors combine to make citizenship policy a volatile arena, with governments willing to test restrictive measures even if they face constitutional challenges.
Practical implications for applicants
- Eligibility is no longer stable – A rule that applies today may be altered or revoked before an application is processed.
- Longer residency periods – Expect naturalisation timelines of 5–10 years, with possible mid‑process extensions.
- Integration requirements – Countries are emphasizing genuine societal integration: language proficiency, cultural knowledge, community ties, and continuous residence.
Decision‑making checklist
- Residency length – Compare required years (e.g., Ireland 5, Netherlands 5, Spain 10, Portugal currently 5 but may become 10).
- Language & cultural integration – Assess your ability to learn the official language and meet civic‑test standards.
- Industry fit – Identify where your profession thrives (tech in Amsterdam, finance in Zurich, creative sectors in Copenhagen).
- Financial buffer – Plan for extra visa renewals, possible fee increases, and longer processing times (citizenship applications can add 1–3 years).
- Legal stability – Monitor constitutional court decisions that may overturn recent reforms (e.g., Italy, Portugal).
Benefits that continue to drive demand
- Freedom of movement – EU citizenship grants the right to live, work, and study in 27 EU states plus Norway, Iceland, Liechtenstein, and Switzerland (31 countries total).
- Education – Access to local tuition rates, often free or heavily subsidised (e.g., German universities).
- Healthcare – Eligibility for national health systems without the higher costs faced by non‑EU residents.
- Career flexibility – No visa caps or employer sponsorship needed for intra‑EU employment.
These advantages remain unchanged despite tighter entry rules, making the long‑term payoff substantial for many applicants.
U.S. citizens: additional considerations
- Citizenship‑based taxation – The United States taxes worldwide income, requiring annual FBAR, FATCA, and potential double‑taxation filings, even after acquiring EU citizenship.
- Treaty relief – Tax treaties can mitigate double taxation, but compliance remains administratively burdensome.
- Travel limits with a U.S. passport – Without an EU passport, U.S. citizens are limited to 90‑day stays in the Schengen area per 180‑day period. EU citizenship removes this restriction entirely.
Despite the tax complexity, many Americans view the trade‑off as worthwhile for the expanded residency rights and long‑term security.
Strategic approach
- Map the timeline – Residency → maintenance → citizenship application → processing. Add a safety margin of at least 1–2 years to each stage.
- Select a country that aligns with personal and professional goals – Consider language difficulty, industry presence, and quality of life.
- Prepare for integration – Enroll in language courses early, engage with local communities, and document cultural participation.
- Maintain financial flexibility – Keep reserves for unexpected fees, longer residency, or legal challenges.
The “easy era” of quick, low‑commitment citizenship routes is ending. Successful applicants will need to treat naturalisation as a genuine relocation project, committing to several years of residence, language acquisition, and societal participation. The payoff—unrestricted access to a continent of 500 million people and a robust set of social benefits—remains compelling for those willing to meet the new standards.
