What is dual citizenship and how is it different from second citizenship? Is it legal to have dual citizenship? If it is, how can you obtain it? What benefits does dual citizenship bring? What about the benefits of second citizenship? We answer these and other related questions in the text below.
The difference between dual citizenship and second citizenship
The obvious common thing that these concepts have is as follows: if you have dual citizenship, you are a citizen of two countries at a time. If you have second citizenship, you are, again, a citizen of two countries at a time. However, there are some differences between the two concepts anyway.
Definition of dual citizenship
Dual citizenship is a legal concept that allows a person to be a bipatride, a citizen of two countries simultaneously. It is possible if the two countries have made a bilateral agreement on dual citizenship. A holder of dual citizenship has rights and obligations that citizens of both countries in question have.
The parties to the agreement exchange information about the bipatrides and regulate distribution of their rights and obligations. In other words, the civil status of a bipatride is regulated jointly by two countries.
Definition of second citizenship
Second citizenship is an opportunity to have two national passports at a time too. However, if the two countries have not signed an agreement on dual citizenship, then the holder of two passports is said to have second citizenship rather than dual citizenship. In this case, each of the countries considers the person its citizen and disregards his/ her citizenship of the other country.
If you obtain second citizenship of a foreign country, the authorities of your home country may well remain ignorant about the fact. At the same time, informing the authorities about acquiring second citizenship is mandatory in some national states.
So what’s the difference?
The differences are not great and they can be rendered down to the following two characteristics:
- Existence or non-existence of a bilateral agreement on dual citizenship;
- The treatment of holders of two passports: when you have second citizenship, each country considers you its citizen; if you have dual citizenship, each country will recognize the public duties that you have in the other country.
Advantages and disadvantages of dual and second citizenship
| Dual citizenship | |
| Advantages | Disadvantages |
| • Dual citizenship allows legally residing in any of the countries. • You can do business, purchase property, and perform any other legal operations in any of the countries without restrictions. • You can request assistance from a diplomatic mission of any of the countries when you are abroad. • You have to pay your public duties (such as paying the taxes or serving in the army) only in one of the two countries. | • A holder of dual citizenship cannot use the advantages available in the two countries at a time. He/ she has to abide by the laws of the country where he/ she lives. • Dual citizenship holders are often not allowed to take public office, to become members of Parliament, police officers, secret service agents, etc. |
| Second citizenship | |
| Advantages | Disadvantages |
| • The list of countries that have signed bilateral agreements on dual citizenship is rather short. This means that there are many more opportunities to obtain second citizenship rather than dual citizenship. Even if a foreign country has no diplomatic relations with your home country, you can still acquire second citizenship and a second passport there. Consequently, this option gives wider opportunities for tax planning and geographical diversification of your assets. • You can keep acquiring second citizenship confidential unless your home country’s legislation requires that you disclose this information. If it does not, a second passport will serve as good protection against possible political or economic turbulence in your country of residence. | • Some additional obligations may arise in case you have two passports and the countries do not have an agreement on dual citizenship. For example, you may have to join the army in both countries. A dual citizenship holder can never face such a problem. • Second passport holders often cannot take public office, work for law enforcement agencies, and gain access to state secrets. |
How can you acquire dual or second citizenship?
It is much simpler to obtain second citizenship rather than dual citizenship so we will start with this opportunity.
Ways of obtaining second citizenship
- By descent (right of blood). If one of your parents is a foreign citizen, you will normally be entitled for citizenship of the foreign country. Some countries (but not too many of them) will grant you citizenship if you can prove that a more remote relative of yours (your grandparent or your great grandparent) was their citizen.
- By birth (right of soil). Some countries grant their citizenship to anyone born on their territories even if the child is born to foreigners. Thus, you can have one passport ‘by blood’ and one more passport ‘by soil’. Some countries where the right of soil is applied:
- United States of America;
- Argentina;
- Brazil.
- By naturalization. You can acquire second citizenship by naturalization if you live in a foreign country for a long time (from 2 to 20 years depending on the country). As a rule, you have to pass a language and a history test to become a naturalized citizen of the foreign country. The process can be accelerated if you do one of the following:
- Attend a university in the foreign country;
- Join the army of the foreign country;
- Marry a citizen of the foreign country.
- By investment. You can also obtain second citizenship if you make a substantial monetary contribution to the economy of a foreign country. For instance, you can acquire foreign citizenship by investment in real estate, securities, business, a venture fund, etc. In some countries, you can qualify for citizenship if you make a non-returnable donation to the state fund or make a large bank deposit or create a few new jobs in the country. When you invest in some property to qualify for citizenship of a foreign country, you have to keep the property in your possession for several years if you are to keep your second passport. The timeframes of acquiring second citizenship by investment can be between 2 months and 3 years, depending on the particular country. Sometimes, foreign citizenship can be applied for remotely.
- By providing outstanding services to a foreign country. Many national governments are prepared to grant citizenship to outstanding foreign individuals. Scientists, artists, and sportsmen of exceptional talents can sometimes acquire foreign citizenship in an instant.
Ways of obtaining dual citizenship
In addition to naturalization, there are a few alternative routes to dual citizenship. These include the following ones:
- If a child is born to a dual citizenship holder, the child will normally qualify for dual citizenship too. Sometimes, he or she has to renounce citizenship of one of the countries when coming of age.
- If a child is born in an international marriage, he or she will also normally qualify for dual citizenship.
- If a child is adopted by a foreign family, he or she can also become a dual citizenship holder.
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Concealing information about second citizenship acquisition
The authorities of some countries don’t care how many passports you have. If you are a citizen of St Kitts and Nevis, for example, you can obtain citizenship of as many other countries as you wish and nobody’s ever going to ask you about it.
The authorities of some other countries, however, will want you to inform them about your acquiring foreign citizenship. If you fail to do it and you pretend that you ‘forgot’ when they find you out, you may be fined or just frowned upon. If you keep insisting that you don’t have second citizenship while you do, in fact, you are asking for trouble. The amount of trouble will depend on the particular country.
Besides, some countries disallow dual citizenship. If you live in one of these countries and you secretly acquire foreign citizenship, you will face a simple choice when you are found out. Namely, you will have to renounce your foreign citizenship or lose your home country’s passport.
Sometimes, however, the situation may not be so simple. Dual citizenship is prohibited in China but the Chinese are actively ‘buying’ citizenship of some Caribbean states such as Grenada, for example. How is this possible? We could not speak for the Chinese authorities but we assume that they don’t mind if some Chinese move somewhere else as the country is packed as it is.
Regulations on dual citizenship in different countries
Each national state will have its own attitude towards dual citizenship. Some countries allow it, some others disallow it, and still some others allow dual citizenship under certain conditions or with certain limitations. The table below describes where the things stand as far as dual citizenship regulations in different countries are concerned.
Regulations on dual citizenship in different countries
| Country | Legality of dual citizenship | Conditions/ restrictions/ exceptions |
| Australia | ✔ | |
| Austria | ✖ | Legal for people with dual citizenship at birth. Legal if it is in the interests of Austria. |
| Azerbaijan | ✖ | |
| Albania | ✔ | |
| Algeria | ✔ | |
| American Samoa | ✔ | The country follows the recommendations of the USA as far as allowing dual citizenship is concerned. |
| Angola | ✔ | |
| Andorra | ✖ | Spain recognizes dual citizenship with Andorra. |
| Antigua and Barbuda | ✔ | |
| Argentina | ✔ | |
| Armenia | ✔ | |
| Afghanistan | ✖ | An Afghani who has moved to another country due to the political and military instability in Afghanistan can ‘unofficially’ keep his/ her Afghani citizenship. |
| Bahamas | ✖ | Legal until the age of 18. |
| Bangladesh | ✖ | Citizens of Bangladesh who have foreign citizenship have to obtain dual citizenship certificates. |
| Barbados | ✔ | |
| Bahrain | ✖ | |
| Belarus | ✖ | |
| Belize | ✔ | |
| Belgium | ✔ | |
| Benin | ✔ | |
| Bulgaria | ✔ | |
| Bolivia | ✔ | |
| Bosnia and Herzegovina | ✔ | If a bilateral dual citizenship agreement is available. |
| Botswana | ✖ | Legal until the age of 21. |
| Brazil | ✔ | |
| British Virgin Islands | ✔ | |
| Brunei Darussalam | ✖ | Legal until the age of 18. |
| Burkina Faso | ✔ | |
| Burundi | ✔ | |
| Bhutan | ✖ | |
| Vanuatu | ✖ | |
| Vatican City | ✔ | |
| Great Britain | ✔ | |
| Hungary | ✔ | |
| Venezuela | ✔ | |
| East Timor | ✔ | |
| Vietnam | ✔ | |
| Gabon | No data | |
| Haiti | ✔ | |
| Guyana | ✖ | |
| Gambia | ✔ | |
| Ghana | ✔ | |
| Guatemala | ✔ | Legal if allowed by the other country. |
| Guinea | No data | |
| Guinea-Bissau | ✔ | Legal if the person has emigrated for economic reasons. |
| Germany | ✔ | Before a German citizen applies for foreign citizenship, he or she has to apply for retaining the German passport. |
| Honduras | ✔ | Legal if there is an agreement with the country of second citizenship. |
| Hong Kong | ✔ | |
| Grenada | ✔ | |
| Greece | ✔ | |
| Georgia | ✖ | Dual citizenship can be granted to a foreigner by the President of Georgia. |
| Denmark | ✔ | |
| Democratic Republic of the Congo (Kinshasa) | ✖ | Legal until the age of 21. |
| Djibouti | ✔ | |
| Dominica | ✔ | |
| Dominican Republic | ✔ | |
| Egypt | ✔ | |
| Zambia | ✔ | |
| Zimbabwe | ✔ | Legal only for native-born citizenship of Zimbabwe. |
| Togo | ✖ | |
| Israel | ✔ | |
| India | ✖ | |
| Indonesia | ✖ | |
| Jordan | ✔ | |
| Iraq | ✔ | |
| Iran | ✖ | |
| Ireland | ✔ | |
| Iceland | ✔ | Legal if the other country allows it. |
| Spain | ✔ | Legal if the application for retaining Spanish citizenship is filed within 3 years after obtaining foreign citizenship. |
| Italy | ✔ | |
| Yemen | ✔ | Legal only if permission has been granted in advance. |
| Cape Verde | ✔ | |
| Kazakhstan | ✖ | |
| Cambodia | ✔ | |
| Cameroon | ✖ | Legal until the age of 21. |
| Canada | ✔ | |
| Qatar | ✖ | |
| Kenya | ✔ | |
| Cyprus | ✔ | |
| Kiribati | ✖ | |
| China | ✖ | |
| Colombia | ✔ | |
| Comoros | ✔ | |
| Kosovo | ✔ | |
| Costa Rica | ✔ | |
| Côte d’Ivoire | ✔ | |
| Cuba | ✖ | |
| Kuwait | ✖ | |
| Kyrgyzstan | ✔ | |
| Laos | ✖ | |
| Latvia | ✔ | |
| Lesotho | ✖ | Legal until the age of 21. |
| Liberia | ✖ | Legal until legal age is reached. |
| Lebanon | ✔ | |
| Libya | ✖ | |
| Lithuania | ✔ | Legal only under certain conditions. |
| Liechtenstein | ✖ | |
| Luxembourg | ✔ | |
| Mauritius | ✔ | |
| Mauritania | ✖ | |
| Madagascar | ✖ | |
| Macao | ✔ | |
| Malawi | ✖ | Legal until the age of 22. |
| Malaysia | ✖ | |
| Mali | ✔ | |
| Maldives | ✖ | |
| Malta | ✔ | |
| Morocco | ✔ | |
| Marshall Islands | ✖ | |
| Mexico | ✔ | |
| Micronesia | ✖ | Legal until the age of 18. |
| Mozambique | ✖ | |
| Moldova | ✔ | |
| Monaco | ✖ | |
| Mongolia | ✖ | |
| Myanmar (Burma) | ✖ | |
| Namibia | ✔ | Legal only for native-born Namibians. |
| Nauru | ✔ | |
| Nepal | ✖ | |
| Niger | ✔ | |
| Nigeria | ✔ | Legal for native-born Nigerians. |
| Netherlands | ✖ | Legal if the person has acquired foreign citizenship by birth or by marriage. |
| Nicaragua | ✔ | |
| New Zealand | ✔ | |
| Norway | ✖ | Legal if the original citizenship cannot be renounced. |
| United Arab Emirates | ✖ | |
| Oman | ✖ | |
| Pakistan | ✔ | Legal only with 18 countries that have signed correspondent agreements with Pakistan. |
| Palau | ✖ | Legal until the age of 21. |
| Panama | ✔ | |
| Papua New Guinea | ✔ | |
| Paraguay | ✔ | Multiple citizenship is allowed if the person acquired foreign citizenship by birth or by descent and if there is a bilateral agreement with the foreign country. |
| Peru | ✔ | |
| Poland | ✔ | |
| Portugal | ✔ | |
| Republic of the Congo (Brazzaville) | ✔ | |
| Russian Federation | ✔ | |
| Rwanda | ✖ | |
| Romania | ✔ | |
| El Salvador | ✔ | |
| Samoa | ✔ | |
| Saint Lucia | ✔ | |
| San Marino | ✖ | |
| Sao Tome and Principe | ✖ | |
| Saudi Arabia | ✖ | |
| Saint Vincent and the Grenadines | ✔ | |
| North Korea | ✖ | |
| North Macedonia | ✔ | |
| Seychelles | ✔ | |
| Senegal | No data | |
| Saint Kitts and Nevis | ✔ | |
| Serbia | ✔ | |
| Singapore | ✖ | |
| Syria | ✔ | |
| Slovakia | ✖ | |
| Slovenia | ✔ | Legal if the person has acquired foreign citizenship by birth or descent. |
| United States of America | ✔ | |
| Solomon Islands | ✖ | Legal until the age of 18. |
| Somalia | ✔ | |
| Sudan | ✔ | |
| Suriname | ✖ | |
| Sierra Leone | ✔ | |
| Tajikistan | ✔ | Bipatrides are considered citizens of Tajikistan alone. |
| Thailand | ✔ | |
| Taiwan | ✔ | |
| Tanzania | ✖ | Legal until the age of 18. |
| Territories of Palestine | No data | |
| Tibet | ✔ | |
| Tonga | ✔ | |
| Trinidad and Tobago | ✔ | Legal only for citizens of Trinidad and Tobago by birth or descent. |
| Tuvalu | No data | |
| Tunisia | ✔ | |
| Turkmenistan | ✖ | |
| Turkey | ✔ | |
| Uganda | ✔ | |
| Uzbekistan | ✖ | |
| Ukraine | ✖ | |
| Uruguay | ✔ | |
| Fiji | ✔ | |
| Philippines | ✖ | |
| Finland | ✔ | |
| France | ✔ | |
| Croatia | ✔ | |
| Central African Republic | ✔ | |
| Chad | No data | |
| Montenegro | ✖ | Legal only if there is a bilateral agreement with the foreign country. An exception was made for the participants of the economic citizenship program that was in effect until January 1, 2023. |
| Czech Republic | ✔ | |
| Chile | ✔ | |
| Switzerland | ✔ | Legal if the foreign country does not require renouncing the original citizenship. |
| Sweden | ✔ | |
| Scotland | ✔ | |
| Sri Lanka | ✔ | An application for retaining citizenship of Sri Lanka has to be filed prior to applying for foreign citizenship. |
| Ecuador | ✔ | |
| Equatorial Guinea | ✔ | |
| Eritrea | ✖ | |
| Eswatini | ✖ | |
| Estonia | ✖ | |
| Ethiopia | ✖ | |
| South Africa | ✔ | Legal if permission is obtained prior to applying for foreign citizenship. |
| South Korea | ✔ | |
| South Sudan | ✔ | |
| Jamaica | ✔ | |
| Japan | ✖ | Legal until the age of 22. |
Open sources have been used to compile the list. Please note that some countries are missing. Please do not hesitate to contact us if you find that some information is outdated.
