Citizenship by descent is the most underused route in this field

A recurring feature of engagements is the discovery, three-quarters of the way through a paid plan, that the client was already eligible for a second citizenship and did not know. Citizenship by descent — through a parent, grandparent, or in some cases a great-grandparent — is frequently available, usually far cheaper than any investment route, and almost always faster.

It is also the one route in this field where the correct advice can be that you do not need to buy anything. That should be the first question asked of every new client, and it usually is not, because nobody earns a commission on it.

Where it exists

Descent-based citizenship is common across Europe, though the rules vary dramatically — not just in how many generations they reach, but in what they do with a single naturalisation date. Some states transmit citizenship without limit through generations. Others require registration within a generation, or impose a retention step that a parent had to satisfy. Some allow dual citizenship freely; others restrict it.

• Ireland reaches a grandparent, and the entitlement is generally established rather than discretionary — but the Foreign Births Register has to be joined in sequence.
• Italy is nominally unlimited, yet the pre-1948 rule on women passing citizenship, and the restrictions introduced in 2025, turn almost entirely on dates.
• Germany splits the same family history across the §5 descent provision, the §15 restoration provision and Article 116 of the Basic Law, depending on when your ancestor left.
• Poland, Hungary, Lithuania, Slovakia and Czechia each handle border changes, deportations and Soviet-era naturalisation differently — the same village can produce five different answers.
• Portugal and Spain both operate narrower windows, and in Spain the exile and democratic-memory provisions are usually the whole case.

The trap: registration order

The most consequential thing in a descent file is almost never the ancestry itself. It is the order in which the generations were registered — and this is where people lose claims they genuinely had.

Take Ireland as the clearest example. If your grandparent was born in Ireland, your parent is entitled to Irish citizenship. But if your parent was not entered on the Foreign Births Register before you were born, your own claim through that grandparent is generally lost — the chain was never registered in sequence. A parent registering first is sometimes not a formality but the entire plan, and it can cascade down another generation for your children.

The same structural problem appears in different clothing elsewhere. In some states a woman could not pass citizenship at the time your ancestor gave birth, which creates a broken link that a later statute may or may not repair. In others, an ancestor’s voluntary naturalisation in a new country before the next generation was born severs the chain — and whether it does depends on the exact year, not the principle.

The documentation problem

Descent claims live or die on civil records: birth, marriage and death certificates, often from jurisdictions that no longer exist, in languages that require certified translation, with name spellings that changed across borders. This is slow work, and it is the reason many people abandon a claim that was genuinely available.

It is also why the sequencing question applies here too. A descent claim does not prevent you from pursuing another route, but if it is viable it usually changes which route you should pursue — and it is worth establishing before, not after, you commit to an investment programme. An EU passport removes the need for a residency permit in twenty-seven countries, which can make the rest of the plan materially cheaper.

One further point that catches people out: a citizenship acquired by descent generally does not lapse. Residencies must be maintained — presence days, renewals, property held. A passport registered through a grandparent can sit unused for thirty years and still be there. And it passes down, which a golden visa bought today usually does not.

An afternoon with civil records has saved more than one client six figures.