Citizenship for Minor Children: Consent, Guardianship and What Happens When They Grow Up

When parents acquire a second citizenship through a CBI programme and include their children as dependants, or when they register a child's citizenship by descent, they are making a significant legal decision on behalf of someone who cannot meaningfully participate in it. The child — whether an infant or a teenager — has no real choice in the matter. They are added to an application, a citizenship is registered in their name, and they may not fully understand its implications until years later.

This aspect of citizenship planning raises a set of questions that are rarely addressed in mainstream CBI marketing material: what legal requirements apply to parental consent when including children in citizenship applications, what rights do children have to renounce or decline citizenship once they reach adulthood, and what obligations — including military service, tax reporting, and travel document use — attach to a citizenship acquired in childhood before the child was old enough to participate in the decision?

Parental Consent in CBI Applications

Who Can Consent

In virtually all CBI programmes, minor children (those under the age of 18) can be included in an application subject to the consent of their legal guardians or parents. The specific consent requirements vary by programme and by the family's legal circumstances:

Both parents alive and married: Both parents are typically required to consent to the child's inclusion in a CBI application. This reflects the general principle in most jurisdictions that parental responsibility is shared between married parents and that major decisions affecting a child's legal status require joint consent.

Single-parent applications: Where one parent is deceased, or where a parent has sole legal custody by court order, the living or custodial parent may consent alone. Documentation confirming the basis for sole consent — a death certificate, or a court order conferring sole parental responsibility — will typically be required.

Separated or divorced parents with shared custody: This is the most legally complex scenario. Where parental responsibility is shared by separated parents who are not cooperating in the CBI application — for example, where one parent is applying for citizenship and the other objects to the child's inclusion — the programme will require written consent from both parents. In practice, this can prevent a child from being included where the non-applying parent refuses.

In some jurisdictions, a parent who applies for CBI citizenship for a child without the other parent's knowledge or consent may face legal consequences in their home country, including potential liability for child abduction or for decisions affecting the child's status made without proper authority.

Age of Consent Provisions

Most CBI programmes require consent from the child themselves (in addition to parental consent) once the child reaches a specified age — typically 16 or 18. This means that an older teenager who objects to being included in a parent's CBI application cannot straightforwardly be added against their will. In practice, the level of meaningful assent that programmes require from older minors varies, but the principle that a child approaching adulthood has some say in their own citizenship acquisition is reflected in several programmes.

Special Circumstances: Children in Care and Guardianship Arrangements

Children who are not in the care of their biological parents — who are in foster care, who have been adopted, or who are subject to guardianship orders — may be included in CBI applications by their legal guardians, but the documentation establishing the guardian's legal authority over the child will be required and will be scrutinised carefully. Programmes are alert to arrangements that might conceal child trafficking or abuse.

What Citizenship Means for a Child: The Obligations That Attach

When a child is included in a CBI application and citizenship is granted, a range of obligations may attach from the date of grant, not from the date the child turns 18.

Military service. In countries that impose conscription, citizenship — even citizenship acquired through a CBI programme — can create military service obligations. These typically crystallise at or around the age of majority (18) and may be enforced when the child seeks to use travel documents, access public services, or physically enter the relevant country. Parents who acquire citizenship by investment for their children in a country with military service obligations should take independent legal advice on what those obligations mean in practice and how (if at all) they can be managed.

Tax reporting. US citizenship (whether acquired by CBI or otherwise) creates tax and reporting obligations from birth for US citizens born abroad, and from the date of acquisition for those who acquire citizenship later. A child who acquires US citizenship through an investment programme starts accumulating US tax filing obligations from the acquisition date. While the actual tax liability of a child with no independent income may be minimal, the filing obligations — and the FBAR and FATCA reporting obligations, if the child has accounts in their name — begin to apply.

Travel document rules. Many countries require their citizens to use that country's passport when entering or leaving. A child who acquires dual citizenship through a CBI programme and then attempts to travel to the CBI country using only their original nationality's passport may encounter immigration issues, because the CBI country may expect its own citizens to present the CBI passport.

Passport renewal. CBI passports typically expire after five or ten years and require renewal. The renewal process usually requires a fresh application and fee payment. For children who are included as dependants, passport renewals will be required at intervals throughout childhood and into adulthood.

When Children Reach Adulthood: Rights and Choices

The Right to Renounce

In most jurisdictions, a citizen who acquired citizenship as a minor has the right, upon reaching adulthood (typically 18), to formally renounce that citizenship if they choose to do so. This right exists precisely because citizenship acquired in childhood — whether by jus soli, jus sanguinis, or through a parent's CBI programme — was not chosen by the individual.

The renunciation process varies by country. In some countries, renunciation requires a formal application to a government authority; in others, it may require completion of an administrative procedure or payment of a fee. Some countries impose obligations (such as military service completion) as a precondition for renunciation — meaning that a young adult who has not yet completed required military service may not be permitted to renounce until after completion.

For Caribbean CBI countries — many of which have small or no military establishments — renunciation is typically straightforward and does not involve military service prerequisites.

Election Obligations in Countries That Require Them

Some countries require citizens who hold dual nationality to formally elect one citizenship upon reaching adulthood. Japan historically required election, though the practical enforcement of this has been inconsistent. Some civil law countries, particularly in continental Europe, have provisions requiring declaration of election between nationalities held at majority. Where a child acquires citizenship in a country with election provisions, the election process — and the consequences of failing to complete it — should be understood before the child reaches the age at which election is required.

Inheritance of Obligations

When a child-citizenship holder reaches adulthood, they become subject to the full range of obligations associated with that citizenship in their own right — not merely as an extension of their parent's status. This includes any ongoing compliance reporting, tax obligations, military service obligations, or renewal requirements. Parents who include their children in CBI applications should ensure that their adult children understand these obligations and are equipped to manage them independently.

Descent Transmission: What the Child's Citizenship Means for the Next Generation

A child who acquires citizenship through a parent's CBI programme typically acquires it by naturalisation (not by descent from an ancestor born in the CBI country). The rules around how this citizenship passes to the child's own future children — the grandchildren of the original CBI applicant — vary by CBI country:

Caribbean programmes. Children born to a CBI citizen after the CBI citizenship has been granted typically acquire Caribbean citizenship by descent. The specific rules vary by programme. In some programmes, the citizenship passes to children born thereafter as full citizens by descent; in others, the transmission may be limited to one generation born outside the country.

Malta. Malta formerly operated an investor-citizenship route, and Maltese citizenship — once granted — is Maltese (and therefore EU) citizenship in full, passing to children born thereafter in the same way as Maltese citizenship acquired by any other route. However, the Court of Justice of the European Union ruled on 29 April 2025 (Case C-181/23, Commission v Malta) that Malta's grant of citizenship in exchange for investment breached EU law, and there is no longer a direct EU citizenship-by-investment route. Families who acquired Maltese citizenship under the former programme retain it, but EU citizenship can no longer be obtained directly by investment; Malta now offers only residence-based routes.

For families whose primary motivation is the multigenerational benefit — securing rights for children and grandchildren — the descent-transmission rules of the specific programme should be verified carefully before the programme is selected, and any expectation of acquiring EU citizenship directly by investment should be reassessed in light of the C-181/23 ruling.

Practical Recommendations for Parents

Discuss citizenship with older children. While a seven-year-old cannot meaningfully participate in a citizenship decision, a fifteen-year-old can. Explaining the implications — travel document, possible military service, potential tax obligations — and obtaining the child's genuine assent (even if not legally required) reflects good parenting and reduces the risk of conflict later.

Document the consent properly. Ensure that the consent forms provided to the CBI programme are correctly completed, signed, and witnessed. Defective consent documentation is a common cause of application delay.

Address the custody/authority question proactively. If there is any ambiguity about parental authority (separated parents, sole custody, guardianship), resolve the documentation question before submitting.

Brief adult children on their obligations. When a child who was included as a dependant reaches adulthood, take time to ensure they understand what their new citizenship means for them: renewal requirements, any compliance obligations, travel document rules, and the renunciation option if they choose not to maintain it.

Plan for military service. If the CBI country has military service provisions that could apply to male children, take legal advice in the CBI country on how those provisions apply and what exemptions or alternatives exist.

How Global Investments Can Help

Global Investments advises families on the full lifecycle of citizenship planning, including the specific legal questions that arise when including minor children in CBI applications. We ensure that consent requirements are properly met, that parents understand the obligations that will attach to their children's new citizenship, and that the multigenerational planning dimensions — descent transmission, election obligations, renunciation rights — are fully assessed.

We work with specialist immigration lawyers in each programme country to provide accurate, current advice on child-citizenship issues.

Contact our team for a confidential family citizenship planning consultation.

This guide is for general educational information only. Laws governing parental consent, children's citizenship rights, military service, and tax obligations vary significantly by jurisdiction and are subject to change. Nothing in this guide constitutes legal advice. Independent legal advice in every relevant jurisdiction is essential before making any citizenship decision affecting a child.