Citizenship is a multidimensional concept that means membership in a specific nation-state and the formal rights and obligations that this membership entails. Citizenship can also be understood as a status and an identity. The principle premise of citizenship is that nation-states can set and control the parameters of membership.
The words citizenship and nationality are often used interchangeably (i.e., dual nationality, dual citizenship). However, nationality is often used to signify membership in a community on the basis of common cultural characteristics while citizenship refers to membership conferred by a state. Citizens of a nation-state may include those who see themselves as part of a single nation based on a common culture or ethnicity, but more often include some groups who are seen as outside of national culture and incapable of belonging.
Since the 1970s, increased flows of goods, services, money, ideas, and people across national borders have led to economic integration and interdependence among nation-states. This shift from an autonomous nation-state to a world of blurred boundaries has helped change the traditional notion of citizenship.
While the vast majority of people still have membership in a single nation-state, the number of people who hold membership in more than one nation-state is growing. As a result, citizenship has become contested both in Europe and North America.
The concept of citizenship dates back to the Roman Republic. Then, as a result of the emergence of the modern state during the Renaissance, citizenship grew from a local into a statewide institution.
In the 20th century, the expansion of citizenship occurred through the elaboration of rights accorded to citizens, including not only political rights, but civil and social rights. The expansion of social rights has been associated with the growth of the welfare state and was the basis for incorporating new groups into the state.
Citizenship laws and naturalization policies are the means through which nation-states determine who remains inside and outside the circle of formal, legal membership. Formal, legal members are almost always entitled to social, economic, and political rights; these rights are balanced by certain duties or obligations to the state.
The attribution of citizenship refers to the nation-state's basis for allocating citizenship. The acquisition of citizenship (also known as naturalization) refers to the process through which a person who does not have membership can become a formal, legal member of the nation-state. Acquiring citizenship is structured by naturalization policies and procedures that vary by country.
Attribution and acquisition of citizenship are structured on two principles: jus soli (the conferral of citizenship to persons born in the state's territory, or soil) and jus sanguinis (the conferral of citizenship to persons with a citizen parent or parents, or blood). Most nation-states base their citizenship laws on a combination of jus soli and jus sanguinis.
Countries of immigrants such as the United States, Canada, Australia, and most Latin American countries attribute citizenship unconditionally to all persons born in their territory (jus soli) as well as to the children of their citizens who are born abroad (jus sanguinis).
Citizenship and naturalization policies based mainly on jus sanguinis are restricted to ethnics and their descendants. Most European countries emphasize jus sanguinis principles, which has made citizenship more difficult to acquire.
However, many observers agree that citizenship laws and naturalization policies in Europe have become more inclusive, meaning that access to citizenship has been opened to long-term residents and their children who were previously excluded from citizenship. For example, in 1999, Germany liberalized its conservative jus sanguinis laws with a more liberal jus soli policy.
No European country grants unconditional birthright citizenship to the children of immigrants. The children of immigrants (second generation) in many European countries also must acquire citizenship; access to citizenship occurs only after fulfilling certain residency or age requirements. For example, second-generation children born in France of two non-French parents cannot become French citizens until they turn 18, provided they have resided in France for at least five years.
Although the trend toward liberalizing citizenship and naturalization policies has received much attention, it is characteristic of countries with formerly restrictive naturalization policies. As political scientist Patrick Weil points out, some countries whose nationality laws were predicated upon jus soli and that have attracted large numbers of immigrants — such as the UK and Ireland — have adopted more restrictive citizenship policies.
For example, the UK allowed the people living in its former colonies to have British Commonwealth Citizenship, which gave them the right to settle in the UK without first acquiring work or residence permits. With the British Nationality Act of 1981, the country abolished this status and created a multitiered citizenship system. In 2004, Ireland's citizens passed a referendum that eliminates an Irish-born child's automatic right to citizenship when both parents are not Irish nationals.
Worldwide, the number of stateless persons is rising. The United Nations defines a stateless person as someone who is not considered a national by any state. The rigid practice of jus sanguinis policies can result in statelessness. In other cases, a child with a non-national father born in their mother's country of nationality may be denied that nationality as a result of gender restrictions on the transmission of nationality.
Statelessness also occurs when long-residing ethnic populations have been denied citizenship or have been stripped of citizenship as a result of their racial or ethnic origins.
Temporary Admissions and Pathways to Citizenship
Although someone may enter a country on a nonimmigrant visa, the person may be able to become a permanent resident and even a citizen by fulfilling requirements. For example, Australia permits foreign students who graduate from Australian universities to apply for the skilled migration program; through that program, they can become permanent residents and eventually citizens.
A person who marries a citizen of a different country can usually obtain citizenship of the spouse's country by meeting requirements regarding length of marriage and residency.
It is important to emphasize that numerous temporary admission policies do not permit the eventual acquisition of citizenship. Many people migrate under intergovernmental agreements or visas that formally dictate that they must leave the host country after a specified time. Guest workers and contract laborers — an important source of labor in the Middle East and in some Asian countries — are often legally prohibited from settling, forming families, or becoming citizens.
Although the United States has a relatively small numbers of temporary workers, recent proposals by members of Congress indicate that the country may create a new temporary-worker status aimed at reducing the number of unauthorized migrants. However, not all proposals would allow such workers to eventually become US citizens.
The Growth of Multiple Citizenship
Today, holding citizenship in more than one country has become more common. People may have dual citizenship by operation of different laws rather than by choice. For example, a child born in a foreign country to US citizen parents may be both a US citizen and a citizen of the country of birth.
Historically, most countries tried to discourage dual citizenship by requiring newcomers to renounce their country of origin citizenship in order to naturalize, and origin countries took away citizenship if emigrants became naturalized citizens of other states. However, such policies were not always enforced.
The increase in mobility, the ability of children to acquire the citizenship of not only their father but their mother, the development of new norms and human rights standards, and changing policies have contributed to the growth of dual and sometimes multiple citizenship.
"Immigrant dual citizenship" permits immigrants to maintain their origin citizenship while becoming a citizen of the settlement country. An increasing number of migrant-sending states — Colombia, the Dominican Republic, Ecuador, Italy, Mexico, and Turkey — have changed their policies to allow dual citizenship. These policies are beneficial to sending states, especially in light of the growing importance of remittances and investment from nationals living abroad.
Long-standing jus sanguinis policies allow ethnic descendents of countries such as Germany, Greece, Ireland, Italy, the Netherlands, Portugal, Spain, and the United Kingdom to either maintain or claim the citizenship of their parents and grandparents. These policies facilitated the claim to European citizenship by thousands of descendents of Italians, Spanish, Poles, and others who migrated to Latin America in the early 20th century.
In response to deteriorating economic conditions at home, Argentines in particular have used ethnic claims to Italian and Spanish citizenship to legally migrate to the European Union (EU) in search of better economic opportunities. As EU citizens, they are able to reside and work anywhere in the EU, not only the country for which they have citizenship.
There is little reliable data on the numbers of dual or plural nationals around the world. According to some reports, about half of all countries allow dual citizenship. Of 15 EU countries studied by political scientist Marc Howard, 10 allow immigrants who naturalize to hold dual citizenship.
Australia, Canada, and the United States do not require new citizens to officially renounce their citizenship of origin, but a US citizen who acquires a foreign citizenship by applying for it could lose US citizenship, which would not happen to an Australian or Canadian citizen in the same situation.
Although many countries have liberalized policies related to dual citizenship, since the September 11 terrorist attacks, some have questioned this policy, especially in cases where a dual citizen has been involved in suspect activity.
In some countries, Germany in particular, dual citizenship has been subject to a great deal of political debate because some see it as weakening citizenship and/or loyalty to Germany. Others argue that immigrant dual citizenship facilitates integration in the receiving community by encouraging immigrants to naturalize.
The Growth of Quasi-Citizenship
Immigrants today are more likely be members of two states, either as citizens of one and settled migrants (also known as quasi-citizens or denizens) of another, or as citizens of both. The rights of quasi-citizens can include long-term or permanent security of residence status; protection from deportation (except in exceptional circumstances); the right to work and seek employment; voting in local elections; and entitlements to some social benefits. In the United States, legal permanent residents, or green card holders, are quasi-citizens who can live and work permanently anywhere in the country; they can become naturalized citizens once they are eligible.
In Europe, the growth of quasi-citizenship is linked partly to restrictive naturalization policies and the growing importance of international human rights standards to which many European countries are signatories (for more on rights and migration, click here).
Internationally protected civil, political, economic, and social rights may not lessen the importance of national citizenship rights, but they do serve as an alternative source of some rights and decouple rights from the national context. However, many states do not adhere to them, and individuals face constraints in successfully claiming these rights.
Supranational rights have developed over the past half century in Europe and characterize EU citizenship. British Commonwealth Citizenship is an example of a supranational membership or citizenship system that predates modern regional and political associations such as the EU.
EU citizenship embodies the idea of a common citizenship across all EU Member States and could eventually serve as the basis for a European identity. EU citizenship transforms the notion and practices associated with state sovereignty, a key principle underlying citizenship. Freedom of movement, the most widely known right of EU citizenship, restrains the ability of states to exclude foreigners, thereby weakening national sovereignty.
Although some have hailed EU citizenship as a new, post-national form of membership, it remains subordinate to national citizenship. It is linked to the citizenship of a Member State, and Member States still control who can receive their citizenship.
Naturalization Rates, Practices, and Policies
Naturalization often depends on a period of legal (and sometimes continuous) residence, proficiency in the national language, and knowledge of the country's history and/or culture. Many countries demand that candidates for naturalization be "of good character," meaning they cannot have been convicted of a crime. Because of such requirements, not all immigrants who apply for naturalization are successful. Some countries, including the United States, require citizenship applicants to make a formal oath of allegiance at a public ceremony.
Naturalization rates among the world's major receiving countries vary greatly. The following are the number of naturalizations per thousand foreign residents in 1995 and should be interpreted with caution because not all foreign residents are eligible to naturalize. Sociologists Stephen Castles and Alastair Davidson found that rates were still very low in Germany (5), likewise in Switzerland (12). The rates for France (17), Belgium (29), and the UK (19) were higher, and Sweden (60) and the Netherlands (98) had the highest rates. The rate for Australia was 74.
Rates for the US and Canada could not be calculated due to lack of data on the total number of foreign residents. However, the large numbers naturalizing (over a quarter of a million in Canada and nearly a half a million in the United States in 1995) suggested high rates in these countries, too. Moreover, the number of persons naturalizing in the US jumped sharply in the mid 1990s with over one million naturalizing in 1996.
Western European scholarship on formal citizenship has focused on the legal structures of citizenship and the rights accorded to citizens versus non-citizens, while US research tends to focus on naturalization rates. Much of the US literature attempts to explain differences in rates based on, for example, country of origin, age at arrival, time in the United States, class of admission, and various demographic characteristics. Comparable studies are starting to be seen in Europe as the number of naturalizations has increased.
Although naturalization in jus solis countries such as Canada, the United States, and Australia is relatively easy compared to the naturalization requirements of some European countries, naturalization has rarely been a straightforward decision for immigrants, even in countries where citizenship is relatively easy to acquire. Becoming a citizen is generally less important to an immigrant or potential immigrant than gaining initial admission and permission to work.
In the US case, immigrants historically have varied widely in their willingness to become citizens, and naturalization rates remained low for many groups throughout the 20th century for reasons that are complex and not always well understood.
In traditional immigrant-receiving countries, the ideology of naturalization has been strongly assimilationist. The reality is that immigrants often approach naturalization with some concerns or with practical interests in mind that run counter to traditional membership norms. These include the notion that immigrants should be members of a single state, rather than multiple states; that membership should be earned through assimilation, rather than acquired as a right; and that citizenship requires sacrifice on the part of its holders, rather than involving calculations of personal advantage.
Laws that restrict benefits to legal permanent residents can encourage eligible immigrants to naturalize. In response to such legislation in the United States in the mid 1990s, some states established centers to help eligible immigrants naturalize; the state's desire to preserve residents' federal benefits therefore also played a role. This example underscores the importance of naturalization and citizenship policies and how they are administered on the ground level.
The Broadening of Citizenship in a Globalized World
With the rise of globalization, the concept of citizenship as a form of membership and identity in one nation-state has changed. The increase in the number of countries allowing dual citizenship and noncitizen rights has made the acquisition of citizenship less pressing.
In addition, migrants' transnational behavior has made national citizenship less relevant. As legal scholar Linda Bosniak has written, national affiliations do matter, but they are not necessarily paramount in many people's experiences.
On the other hand, the rise of nativism, in part the result of globalization and concerns about the risks of immigration linked to terrorism, has reinvigorated debates about national membership and loyalty to one state. What these trends mean, both for states and for immigrants, is the subject of present and future research.
Bosniak, Linda. 2001. "Denationalizing Citzenship," p. 237-252 in, Eds. Aleinikoff, Alexander and Douglas Klusmeyer. Citizenship Today: Global Perspectives and Practices. Carnegie Endowment for International Peace: 2001.
Castles, Stephen and Alastair Davidson. 2001. Citizenship and Migration: Globalization and the Politics of Belonging. New York: Routledge
Howard, Marc Morje. 2005. "Variation in Dual Citizen Policies in the Countries of the EU." International Migration Review 39.
Weil, Patrick. "Access to Citizenship: A Comparison of Twenty-Five Nationality Laws," in, Aleinikoff, Alexander and Douglas Klusmeyer (Eds.). Citizenship Today: Global Perspectives and Practices. Carnegie Endowment for International Peace: 2001.