The Citizenship debate around the world
United States
A child born in the US is entitled to US citizenship at birth. Having a US citizen child is no bar to deportation for the parents. The deportation can be challenged if the deportable non-national has been in the US for more than 10 years and the deportation would cause great harm to the citizen child. The child can exercise his or her independent right to citizenship at 18 and sponsor a parent's claim to citizenship at 21.
Australia
There is no right to citizenship at birth. A child acquires Australian citizenship if one of the parents is either an Australian citizen or a permanent resident. A child born in Australia to parents illegally in the country has no claim to citizenship and may be removed with the parents.
European Union
All EU countries grant nationality automatically to the children of their own nationals. However, none of them, except Ireland at the moment, do so to the children of non-nationals, who can acquire the nationality of the countries of birth after a time, subject to a number of conditions. The exceptions, in most states, are foundling children and those who would otherwise be stateless.
Austria
There is no automatic right to citizenship to non-nationals at birth, except for foundlings and stateless children. Children can only acquire Austrian nationality through the normal naturalisation procedure.
Belgium
There is no automatic right to citizenship to non-nationals at birth, apart from foundlings and those who would otherwise be stateless. Children who are second-generation migrants can acquire Belgian nationality. Children of the third generation born in Belgium who have a parent who was also born in Belgium and whose main place of residence was in Belgium for five years during the 10 years preceding the child's birth are automatically Belgian.
Denmark
There is no automatic right to citizenship at birth for non-nationals. Non-nationals aged between 18 and 23 who have had a minimum of 10 years' residency in the country since birth can request naturalisation if they have spent five of the previous six years in the country.
Finland
There is no automatic right to citizenship at birth for non-nationals. A child of non-nationals can apply for citizenship if he or she has lived for five years in Finland before the age of 16, and five years continuously after 16, by making a declaration, which must be made before the age of 23.
France
There is no automatic right to citizenship at birth to non-nationals. A child born to non-nationals who acquire French nationality is also granted citizenship. A child born in France to non-national parents automatically becomes a French citizen at 18. He or she may request to become a citizen at 16, or at 13 at parental request. A third-generation immigrant born on French soil is automatically entitled to French nationality.
Germany
There is no automatic right to citizenship at birth for non-nationals. Since 2000, if one non-national parent has been a permanent legal resident in Germany for at least eight years, and has a permanent resident permit, their children acquire German citizenship at the parent's request. However, they must choose between this and the foreign nationality before the age of 23. Otherwise they have the nationality of their parents. Dual nationality is only permitted in exceptional circumstances.
Greece
There is no right to citizenship at birth for non-nationals. A child born in Greece can apply for naturalisation at 18, but this is not automatic, it is discretionary. He or she must have lived for 10 out of the preceding 12 years in Greece.
Italy
There is no automatic right to citizenship at birth for non-nationals. A non-national child with continuous residence since birth can apply for Italian citizenship at the age of 21. An adult foreigner born in Italy can apply for citizenship after three years living there. A citizen of the EU can apply for citizenship after four years' residency in Italy, and stateless persons and refugees can apply after five years.
Luxembourg
There is no right of automatic citizenship to non-nationals at birth, apart from foundling children or those otherwise stateless. Children born in Luxembourg can be naturalised if their parents are naturalised.
Netherlands
There is no automatic right to citizenship to those born to non-national parents. People born in the Netherlands to non-national parents, or who would otherwise be stateless, may opt for Dutch nationality if they have lived in the Netherlands since birth, or for a continuous period of five years before the age of 18. The option can be exercised after the age of majority and before the age of 25.
Portugal
There is no automatic right to citizenship for non-national children at birth. Children born in Portugal to non-national parents, whose normal place of residence has been Portugal for at least six years, are Portuguese citizens if the parents are citizens of a country whose official language is Portuguese, or if they are from a country whose language is not Portuguese but have been resident for 10 years.
Spain
There is no automatic right to citizenship at birth for non-nationals. A child born in Spain can apply for citizenship between the ages of 18 and 20, following a minimum residence period of one year. A third-generation non-national is granted citizenship if one of the parents was also born in Spain.
Sweden
There is no right to citizenship at birth for non-nationals. An application can be made when the Swedish-born child is between 21 and 23 years of age. The child must have at least five years' residence before the age of 16 (this can include residence in another Nordic country) and additional permanent residence after that.
UK
The law was changed in the UK in 1983. Before that year every child born there was entitled to citizenship at birth, but following the enactment of the 1981 British Nationality Act this right became available only to a child with at least one citizen parent. There are special considerations for EU citizens exercising treaty rights under EU law.
EU Accession States
Cyprus
There is no automatic right to citizenship at birth for non-nationals, except for those of UK citizens of Cypriot origin who have resided in Cyprus for at least 12 months and intend to continue to do so. Otherwise everyone born after 1960 to a Cyprus national, or a person who would have qualified as a national, is entitled to nationality.
Czech Republic
There is no automatic right to citizenship at birth for non-nationals, apart from foundlings and those otherwise stateless, or if at least one parent has permanent residence in the Czech Republic. Children under 15 acquire the same nationality as their parents.
Estonia
There is no automatic right to citizenship at birth for non-nationals. A non-national may only apply for Estonian citizenship after the age of 15, must have lived there for at least five years, have knowledge of the Estonian language, constitution and the law on citizenship, and swear an oath of loyalty.
Hungary
There is no right of citizenship at birth for non-nationals. A non-national born in Hungary can acquire Hungarian nationality if he or she lived in Hungary for an unbroken period of five years and made an application before the age of 19.
Latvia
There is no right of citizenship at birth for non-nationals. Non-nationals can apply for naturalisation if they have lived in Latvia for five years, know the Latvian language, constitution, national anthem and Latvian history, have a legal source of income and swear an oath of loyalty.
Lithuania
There is no right of citizenship at birth for non-nationals. Non-nationals can apply for naturalisation after 10 years' permanent residence and after passing an examination in Lithuanian.
Malta
Until 1989, any person born in Malta automatically became a citizen of Malta. Since August 1989 a person born in Malta has only been entitled to automatic citizenship if one parent was Maltese or had been born in Malta and had emigrated. A non-national can be naturalised after residence in Malta for at least five years.
Poland
There is no automatic right to citizenship for non-nationals at birth. Non-national children can only acquire citizenship if their parents are naturalised. Non-nationals can apply for naturalisation after five years' residence. There is provision for waivers in exceptional cases.
Slovak Republic
There is no automatic right to citizenship at birth for non-nationals. Anyone who has resided in the Slovak Republic for a period of five years and speaks Slovakian can apply for naturalisation.
Slovenia
There is no automatic right to citizenship at birth for non-nationals. Anyone who has resided in Slovenia for 10 years, at least five of which are immediately prior to the application, and who passes an examination in the Slovenian language, can apply for naturalisation.