Every European Citizenship by Descent Pathway Compared and Ranked

If you have a parent, grandparent, or in some cases, a great-grandparent from another country, you may already be entitled to a second passport without making a financial investment. This legal framework, known as jus sanguinis, allows you to claim citizenship by birthright.

However, the legal landscape has shifted dramatically over the past year. In late 2025 and early 2026, three major ancestral routes changed direction: Canada removed its generational limits, Italy enacted a strict two-generation cap, and Spain permanently closed its popular "grandchildren" application window.

If you are evaluating your global mobility options, this master comparison maps out who qualifies under the current 2026 rules.

What is Citizenship by Descent?

Citizenship by descent is the legal acquisition of a country’s nationality based on the citizenship or ethnicity of your ancestors. It differs fundamentally from citizenship by birthplace (jus soli) and naturalisation, which requires long-term physical residency and language assimilation.

Key Distinction: True citizenship by descent means you are legally recognized as a citizen from birth; your application simply registers that pre-existing fact with the government. This is separate from ancestry-based fast-track residency schemes, which grant you a visa based on lineage but still require you to live in the country before applying for a passport.

Jus Sanguinis Explained

The legal engine behind these claims is jus sanguinis (Latin for "right of blood"). In our work advising global clients, we find that people often assume any ancestral link is enough. In reality, jus sanguinis relies on an unbroken line of citizenship.

To successfully claim nationality through this principle, you must prove that:

• Your ancestor was a citizen when the next generation in your line was born.

• No ancestor in your lineage voluntarily renounced their citizenship or naturalised in a foreign country before passing their nationality down.

• Your lineage complies with gender-specific historical laws (such as Italy’s pre-1948 maternal rule, which requires specific judicial handling).

Citizenship by Descent Countries Compared

The table below outlines the core requirements for the primary ancestral routes in 2026. These rules apply to new applications filed today.

Note: Lower-volume ancestral routes like Greece, Lithuania, Slovakia, Czechia, Latvia, and Mexico also maintain descent frameworks, which are summarised in our regional sub-guides.

Country Guides by Region

Western Europe & The UK

• Ireland: You automatically qualify if a parent was born in Ireland. If a grandparent was born there, you can claim citizenship by registering on the Foreign Births Register (FBR). Dual citizenship is fully accepted.

• United Kingdom: British citizenship is normally passed down to one generation born abroad. Double-descent claims (via grandparents) are exceptionally rare and restricted to specific historical or Crown service contexts.

• France: Governed strictly by jus sanguinis. If your parent was a French citizen at your birth, you qualify, but claims stretching back to grandparents require proving that the family line maintained active links (faculté de répudiation or perte par le non-usage rules apply).

Central & Eastern Europe

• Germany: Following Germany's landmark 2024 citizenship reform, dual citizenship is permitted. Descendants of individuals stripped of citizenship under Nazi persecution have a dedicated restoration path (StAG 15) available until 2031.

• Poland: Poland has no technical generational limit, meaning you can go back to great-great-grandparents. However, your ancestors must have lived in Poland after 1920, and the line must be entirely free of "loss events," such as an ancestor taking up public office or military service in another country before 1951.

• Hungary & Croatia: Both nations offer paths for the ethnic diaspora. Hungary’s simplified naturalisation route goes back multiple generations but carries a strict requirement: you must pass an interview in the Hungarian language. Croatia requires clear documentation of Croatian ethnicity.

What Changed in 2025 and 2026?

If you are relying on internet research from a few years ago, your information is likely outdated. Three critical amendments occurred over the last twelve months:

1. Canada Expanded Eligibility

On 15 December 2025, Bill C-3 officially came into force, striking down the old first-generation limit. Anyone born abroad to a Canadian parent before that date is now eligible, regardless of how many generations the family lived outside Canada. For children born after 15 December 2025, the Canadian parent must demonstrate at least 1,095 days of physical presence in Canada to pass nationality down.

2. Italy Enacted a Generational Cap

Italy closed its famous unlimited-generation loop. Law 74/2025 (which converted Decree-Law 36/2025) officially limits citizenship claims to two generations: parents or grandparents. Great-grandparent claims are no longer valid for new applicants. The Italian Constitutional Court definitively upheld this law on 12 March 2026, settling the matter.

3. Spain’s Grandchildren Window Closed

The popular Democratic Memory Law, which allowed grandchildren and adult children of Spanish descendants to claim passports without residing in Spain, expired. The Spanish consulate confirmed the final, un-extended closure of this window at 23:59 on 22 October 2025. New applications under this framework are summarily rejected.

How to Check If You Qualify

Evaluating an ancestral claim involves a structured diagnostic path:

• Map the Dates: Acquire the exact birth, marriage, and death dates for every person in the chain.

• Locate Naturalisation Records: The most critical document is often your ancestor's certificate of naturalisation in the country they moved to. If they naturalised before the next generation was born, the line is broken.

• Audit the Rules: Check the specific historical quirks of the country. For example, if you are claiming Italian citizenship via a female ancestor, and the next child in line was born before 1 January 1948, you must pursue a judicial case in the Italian courts rather than a standard consular application.

Do Not Qualify by Descent? Your Other Options

If your family line is broken, or if your lineage runs through an Italian great-grandparent or a Spanish grandparent who missed the 2025 deadline, you cannot claim a passport via jus sanguinis.

For individuals requiring global access or a secure second residency, alternative legal pathways exist:

• Fast-Track Residency via Ancestry: Some countries do not grant immediate citizenship to distant descendants but will issue an immediate residency visa. Spain offers accelerated citizenship after just two years of residency to citizens of Ibero-American countries and individuals of Sephardic descent.

• Residency and Citizenship by Investment: If no ancestral link exists, you can secure access to European and global jurisdictions through formal migration programs. Options include European Golden Visas (which offer residency via real estate or funds) or direct Citizenship by Investment (CBI) programs in the Caribbean, which provide complete global mobility within months.

How Savory & Partners Helps

If you are looking at your family tree right now and thinking, "I might actually qualify, but I have no idea how to find my grandfather’s birth certificate from a tiny European village," or "My line looks broken, what do I do now?", that is exactly where we come in.

Tracing old civil records, dealing with foreign consulates, and translating legal documents can feel completely overwhelming. We handle the heavy lifting for you. Our team runs a clear eligibility check to see exactly where you stand under the 2026 rules.

If you have a valid path to a passport by descent, we will help you secure it. If you don't, we will show you the best investment or residency alternatives to get you exactly where you want to be.

Reach out to us today to map out your lineage and plan your options.

FAQs on Citizenship by Descent

What is citizenship by descent?

It is the acquisition of a country's nationality based on the citizenship or ethnicity of your parents, grandparents, or more distant ancestors, rather than your physical place of birth.

What is jus sanguinis, and which countries use it?

Jus sanguinis is the legal principle that citizenship is determined by parental nationality. Most European nations, including Italy, Ireland, Germany, and Poland, use this as the foundation of their nationality laws.

Which countries offer citizenship by descent?

Dozens of nations offer it, including Ireland, Italy, Germany, Poland, Hungary, Portugal, Croatia, Canada, and the UK. Each country enforces distinct restrictions regarding generational limits and document verification.

Can I get citizenship through a grandparent or great-grandparent?

Yes, but it depends entirely on the country. Ireland and Portugal explicitly allow grandparent claims. Poland allows great-grandparent claims, whereas Italy legally terminated great-grandparent eligibility under Law 74/2025.

What is the difference between citizenship by descent and citizenship by ancestry?

Citizenship by descent recognizes you as a citizen from birth via an unbroken bloodline. Citizenship by ancestry often refers to fast-tracked naturalisation programs that require you to move to the country based on your heritage before obtaining a passport.

Is citizenship by descent the same as dual citizenship, and can I keep my current passport?

Not automatically. While most major descent-offering nations (like Ireland, Italy, and Germany) allow dual citizenship, some countries (like Spain, outside specific treaty nations) require you to renounce your original nationality upon acquisition.

Which citizenship by descent is easiest or fastest to claim?

Ireland and Canada are among the most straightforward if you meet their clear-cut criteria, as their systems are highly structured. Timelines generally vary from 6 to 24 months depending on consular backlogs.

How far back can you claim citizenship by descent?

Canada has no generational cap for those born before December 2025, and Poland allows you to go back to 1920 if the line remains unbroken. Conversely, countries like Italy and Ireland cap claims at two and three generations, respectively.

Did the rules change in 2025 or 2026?

Yes. Canada removed its first-generation limit for older descendants, Italy introduced a strict grandparent limit, and Spain’s temporary Democratic Memory Law window officially closed in October 2025.

What if my family line is broken or too distant?

If you are ineligible for an ancestral passport, you can explore fast-track residency routes based on heritage or look into formal corporate residency, investment visas, and Golden Visa options.

References

Government of Canada. Citizenship by Descent. Referred from: https://www.canada.ca/en/immigration-refugees-citizenship/services/canadian-citizenship/become-canadian-citizen/citizenship-descent.html

Irish Department of Foreign Affairs. Foreign Births Register. Referred from: https://www.ireland.ie/en/dfa/citizenship/

Italian Ministry of Foreign Affairs and International Cooperation. Citizenship by Descent (Jure Sanguinis). Referred from: https://www.esteri.it/

German Federal Ministry of the Interior. German Citizenship (Staatsangehörigkeitsrecht). Referred from: https://www.bmi.bund.de/

UK Government. British Citizenship. Referred from: https://www.gov.uk/british-citizenship