Citizenship by Descent: Tracing Your European Heritage

For millions of people worldwide with European ancestry, citizenship-by-descent represents the most accessible and cost-effective route to a European Union passport. Unlike citizenship-by-investment programmes that require significant financial outlay, descent-based citizenship is a right — not a purchase — flowing from documented family lineage. It cannot be bought but it can be claimed, provided the genealogical and documentary evidence is assembled correctly.

This guide provides an overview of the main European citizenship-by-descent routes, the general eligibility principles, and the practical steps involved in pursuing a claim.

Why European Citizenship by Descent Matters

A European Union passport is widely regarded as among the most powerful travel documents in the world. EU citizens enjoy:

• Free movement rights across all 27 EU member states — the right to live, work, study, and retire anywhere in the EU without a separate visa or permit
• Visa-free or visa-on-arrival access to 185-plus destinations globally
• Banking and property rights throughout the EU
• Access to EU healthcare systems under the European Health Insurance Card and reciprocal agreements
• Consular protection from any EU member state's embassy when one's own state is not represented abroad

For individuals with ancestry in Ireland, Italy, Poland, Greece, Portugal, Romania, or other EU member states, a citizenship-by-descent claim may deliver all of these benefits without any investment requirement, residency obligation, or programme fee beyond administrative costs.

General Principles of Citizenship by Descent

Citizenship-by-descent (known in law as jus sanguinis — "right of blood") operates differently in each country, but common principles apply:

Lineage length: Some countries recognise claims through multiple generations (grandparent or beyond), while others limit recognition to one generation (parent only). Ireland is among the more generous (parent or grandparent); Italy, historically the most expansive, limited new claims to a parent or grandparent born in Italy from 2025; Germany's rules are more restricted.

Transmission requirements: The ancestor who transmits citizenship must typically have held citizenship at the relevant time — not merely have been a national at birth without formal citizenship status. This distinction matters particularly for claims through ancestors born before the country's modern citizenship laws were enacted.

Gender discrimination: Some older citizenship laws only passed nationality through the male line. Post-war and later-era legal reforms addressed this, but for claims based on female ancestors in certain historical periods, the rules vary by country and time period.

Prior renunciation: If an ancestor formally renounced citizenship, the transmission chain is typically broken. Naturalisation in another country without renunciation does not necessarily break the chain, but this varies by country and the date of naturalisation.

Living claim requirement: Most countries require that a living person makes the application. Claims cannot be made on behalf of a deceased person, though a living descendant can apply through a chain including deceased intermediate generations.

Ireland: One of the Broadest Descent Rights in the World

Irish citizenship-by-descent is among the most accessible in Europe. If one of your parents or grandparents was born on the island of Ireland, you may have a right to Irish citizenship — and through it, EU citizenship.

Parent born in Ireland: If either of your parents was an Irish citizen at the time of your birth, you are an Irish citizen by birth. You simply need to register the birth with the relevant civil registration office and apply for an Irish passport.

Grandparent born in Ireland: If you have a grandparent born on the island of Ireland (including Northern Ireland, which is part of the United Kingdom), you may be eligible for citizenship through the Foreign Births Register. You must register before your own children can claim citizenship through you in the next generation. The Foreign Births Register process involves documentary proof of the grandparent's birth, the intermediate parent's birth and relationship, and your own documentation.

The Irish claim extends to the island of Ireland as defined before partition — Northern Ireland births qualify. The Foreign Births Register has a significant backlog as of 2026; processing times should be verified with the Irish Department of Foreign Affairs.

Generation limitation: Irish citizenship by descent beyond the grandparent generation is not automatically available. Great-grandchildren of Irish-born persons generally cannot claim unless the grandparent registered on the Foreign Births Register before the parent was born.

Italy: Jure Sanguinis — Now Limited to Two Generations

Italy's citizenship-by-descent rules, based on the principle of jure sanguinis, were historically among the broadest in the world: in theory, Italian citizenship passed through the generations without limit. That changed in 2025. Decree-Law No. 36/2025 (28 March 2025), converted into Law No. 74/2025 (23 May 2025), introduced a generational limit — new applicants must generally have a parent or grandparent who was born in Italy. Claims through great-grandparents and earlier ancestors are no longer available to new applicants under the ordinary rules. A grandfather clause preserves the old, unlimited-generation position for cases recognised, or applications/appointments filed and booked, before the cut-off (end of 27 March 2025, Rome time).

The other key conditions remain:

• An Italian-born ancestor must have emigrated after the Italian state was established (post-1861 for most purposes)
• The ancestor must not have naturalised in another country before passing citizenship to the next generation in the chain
• Female ancestors born before 1 January 1948 can only transmit citizenship in limited circumstances (this is the "1948 rule" — a complex area of Italian law that can sometimes be addressed through Italian court proceedings)

Italy's programme has historically been managed by Italian consulates worldwide. In recent years, an enormous backlog at consular offices has driven many applicants to pursue judicial routes, appearing before Italian courts to obtain recognition of citizenship. This is legal but more expensive and time-consuming than the consular route.

For those who still qualify under the post-2025 rules — descendants with an Italian-born parent or grandparent — the route remains a valuable path to EU citizenship. Those whose Italian ancestor is further back than a grandparent will, in most cases, no longer qualify. Verify the current position with a specialist Italian immigration lawyer before relying on it.

Poland: Citizenship by Descent and EU Rights

Polish citizenship-by-descent is governed by the Act on Polish Citizenship and may be claimed through Polish-born ancestors. Poland permits dual citizenship, meaning a successful claim does not require renunciation of existing nationality.

Eligibility generally requires:

• Evidence of an ancestor who held Polish citizenship (not merely was born in the territory of modern-day Poland — historical border changes are a significant complication)
• Evidence that the citizen ancestor did not lose Polish citizenship before the relevant transmission
• Documented lineage from that ancestor to the applicant

Polish citizenship history is complicated by the fact that Poland was partitioned for over a century (1795–1918), occupied during World War II, and subject to post-war emigration. Documents from this period may be held in archives in Poland, Belarus, Ukraine, Lithuania, or Germany. Genealogical research typically requires specialist assistance.

Poland's EU membership since 2004 makes a confirmed Polish citizenship claim highly valuable — it delivers full EU free movement rights alongside whatever other nationality the applicant holds.

Greece: Citizenship by Descent

Greek citizenship may be claimed by descendants of Greek citizens, though the process is more bureaucratically complex than Irish or Italian routes. Greece permits dual citizenship.

Eligibility requires documented proof of Greek ancestor's citizenship and the chain of descent. Records may be held in local municipal registries (dimotologio), the Greek Orthodox Church, or national archives. Greek diaspora communities in the United States, Australia, South Africa, and Germany are large; many individuals may have unclaimed Greek citizenship rights.

Military service obligations for male Greek citizens must be considered. Greek men between 19 and 45 are in principle subject to conscription. Non-resident Greeks typically seek exemptions or pay a levy in lieu of service; the mechanics vary and should be clarified with Greek legal advisers.

Portugal: Sephardic Jewish Descent

Portugal offers a distinctive citizenship-by-descent route for Sephardic Jews — descendants of Jews expelled from Portugal and Spain in the late 15th century. This route, enacted in 2015, requires evidence of Sephardic Jewish ancestry certified by a recognised Jewish community organisation in Portugal (the Jewish communities of Lisbon or Porto).

The route has been widely used but has also attracted scrutiny. Portugal tightened the programme requirements in 2023 following concerns about due diligence standards; applicants must now demonstrate a connection to Portugal or Portuguese culture beyond ancestry alone. Verify current requirements before initiating an application.

Portugal also offers citizenship to descendants of Portuguese citizens in the conventional manner, through the standard jus sanguinis route.

Other European Descent Routes

Several other EU member states offer citizenship-by-descent routes:

Hungary: Hungary offers citizenship to ethnic Hungarians living abroad whose ancestors held Hungarian citizenship in the historical Kingdom of Hungary. This covers areas now in Romania (Transylvania), Slovakia, Ukraine, Serbia, and Croatia, reflecting historical borders.

Romania: Romania offers citizenship to those who can demonstrate descent from former Romanian citizens and those who had citizenship revoked under communist rule. Large diaspora communities exist in Moldova, Ukraine, and the former Yugoslav states.

Lithuania, Latvia, Estonia: The Baltic states have specific restitution-based citizenship provisions for those whose families held citizenship before Soviet occupation, as well as descent-based routes. Post-Soviet citizenship legislation in this region is complex and varies by state.

Germany: Germany's post-war citizenship laws allow claims by descendants of persons persecuted by the Nazi regime who were stripped of German citizenship. This path — known as Article 116 of the Basic Law — is available to descendants of those expelled or persecuted and has been actively pursued by Jewish diaspora communities worldwide.

Building the Documentary Case

All descent-based citizenship claims rest on a documentary chain: birth certificates, marriage certificates, death certificates, and naturalisation records linking the applicant to the qualifying ancestor. These records may be in multiple countries, in languages including Latin, German, Italian, Polish, Russian, and Hebrew, and may require professional translation and authentication (apostille).

Gaps in records — common for families affected by wars, border changes, or poverty — can sometimes be bridged through alternative sources: church records, census data, emigration records, military records, and civil archive research. Specialist genealogists with expertise in specific countries and periods are invaluable.

The documentary preparation phase typically takes six months to two years depending on the country and the state of available records.

Seek Professional Guidance

Citizenship-by-descent claims involve complex legal analysis, archival research, and multi-country document processing. Errors in application — including presenting incomplete chains of evidence, missing procedural requirements, or misidentifying the applicable law — can result in rejection and, in some cases, make re-application more difficult. Professional immigration lawyers in the target country and qualified genealogists are essential advisers.

Laws vary by country and are subject to change. This guide reflects general principles as of mid-2026 and does not constitute legal advice.

How Global Investments Can Help

Global Investments helps clients identify, assess, and pursue citizenship-by-descent opportunities as part of broader passport and residency strategy. Our services include:

• Initial eligibility screening across Irish, Italian, Polish, Greek, Portuguese, and other European descent routes
• Coordination with specialist immigration lawyers and genealogical research firms
• Integration of descent-based citizenship into broader wealth and estate planning
• Ongoing support through the application process and beyond

Contact our citizenship planning team for a confidential assessment of your European ancestry and citizenship options.