Some people buy passports. Others find one in a shoebox. Citizenship by descent (jus sanguinis) means your ancestor passed their nationality down to you – you only need to prove it, or use a special route for descendants.
This guide goes deeper than the overview in second passports. If nobody in your family tree qualifies, look at fastest naturalisation or citizenship by investment.
The comparison table (as of September 2026)#
| Country | Who qualifies (simplified) | Generation limit | Language | Keep your passport? |
|---|---|---|---|---|
| Italy | Born abroad with another citizenship: parent or grandparent who held only Italian citizenship (other conditions apply) | 2 generations for new cases since 27 March 2025 | None for recognition | Yes |
| Ireland | Grandparent born on the island of Ireland (via Foreign Births Register); parent born there = usually already a citizen | Grandparent; further only if each parent was registered in time | None | Yes |
| Poland | Ancestor held Polish citizenship after 1920 and it wasn’t lost under the rules of the time | None in principle | None for confirmation | Yes |
| Hungary | Ancestor was a Hungarian citizen (often: Kingdom of Hungary before 1920, or areas re-annexed 1938–1945) | None | Hungarian required (simplified naturalisation) | Yes |
| Lithuania | Ancestor held citizenship before 15 June 1940 and left before 11 March 1990 | Up to great-grandparent | None | Yes, for this group |
| Greece | Proven Greek descent (omogeneis) via registry records | Depends on records | Varies | Yes |
| Portugal | Grandchild of a Portuguese national by origin | Grandparent | Portuguese language and culture test since 19 May 2026 | Yes |
| Germany | Descendants excluded by old gender rules (§ 5) or of people persecuted 1933–1945 (Art. 116(2) GG, § 15) | Descendants | None | Yes |
| Spain | Sephardic route closed; Democratic Memory route (Law 20/2022) closed in October 2025 | – | – | – |
Italy: two generations since March 2025#
Italy used to recognise citizenship through ancestors born generations ago. Decree-Law 36/2025 of 28 March 2025, converted into Law 74/2025, changed that. Anyone born abroad who holds another citizenship is now generally considered never to have acquired Italian citizenship – unless an exception applies. The main one: a parent or grandparent who holds (or held at death) exclusively Italian citizenship. The requirement that the ancestor was born in Italy, which appeared in the first version of the decree, didn’t survive into the final law.
- Other exceptions: a parent who lived in Italy for at least two continuous years after becoming Italian and before your birth.
- Old cases are safe: applications or court cases filed before 27 March 2025 (23:59 Rome time) continue under the old rules.
- Minor children of citizens who qualify can still be added by a parental declaration – the deadline was extended to 31 May 2029.
- Constitutional Court: ruling no. 63/2026 (filed 30 April 2026) upheld the reform. In July 2026 the Court nevertheless referred questions from other cases to the EU Court of Justice (order no. 147/2026), so the last word isn’t spoken yet.
- Cost: the consular fee for adult recognition applications rose from €300 to €600 on 1 January 2025, payable whatever the outcome.
If your claim runs through a great-grandparent, it has probably closed. Get an Italian lawyer’s opinion before paying anyone for document hunts.
Ireland: the grandparent rule#
If one of your grandparents was born on the island of Ireland (including Northern Ireland), you can become an Irish citizen by entering your birth in the Foreign Births Register. If a parent was born there, you’re usually already Irish and just need a passport. The fee is €278 for adults, and the Department of Foreign Affairs processes applications in date order – plan on around a year. Citizenship takes effect from the date of registration, not birth.
Poland: confirmation, not a new grant#
Polish citizenship passes to children regardless of where they’re born, so it can run through several generations. The key question is whether your ancestor held Polish citizenship after the state was re-established (the 1920 citizenship act) and didn’t lose it – for example through service in a foreign army or naturalisation elsewhere under the rules in force at the time. You apply to the voivode (the Mazovian voivode if you never lived in Poland, also via a consulate) for confirmation that you already are Polish. The fee is PLN 277 and the authority has six months to decide – not counting the time spent waiting for documents. Archives are the hard part.
Hungary: simplified naturalisation, language included#
Hungary’s simplified naturalisation (Section 4(3) of Act LV of 1993) is open to people whose ancestor was a Hungarian citizen – in practice often someone from the pre-1920 Kingdom of Hungary or from areas re-annexed between 1938 and 1945 – and who speak Hungarian. There’s no residence requirement and no generation limit. The procedure itself is free, and consulates quote around 8–12 months for a complete file. The catch is the language: there’s no exam certificate, but the officer checks that you can hold a conversation in Hungarian, and there’s no exemption. If that sounds like a challenge, it is – but a learnable one.
Lithuania: restoration for descendants of those who left#
Lithuania generally doesn’t allow dual citizenship. A May 2024 referendum to change that won a large majority of votes cast but failed the turnout threshold. The big exception: people who held Lithuanian citizenship before 15 June 1940, and their children, grandchildren and great-grandchildren, if the ancestor left before 11 March 1990. They can restore citizenship and keep their other one.
Greece#
People of Greek descent can have their citizenship recognised if the ancestor’s registration in a Greek municipal register can be traced, or they can apply for naturalisation as omogeneis (ethnic Greeks) through a consulate. Records decide everything; the process is known for patience-testing timelines.
Portugal: grandchildren yes, Sephardic no#
Organic Law 1/2026, in force since 19 May 2026, keeps the route for grandchildren of Portuguese nationals by origin, who haven’t lost that nationality. It now requires the same knowledge of Portuguese language, culture, history and symbols as naturalisation, plus the security and criminal-record checks, and effective ties to the Portuguese community. The Sephardic Jewish descent route, already restricted in 2022, has been abolished. Pending applications filed before 19 May 2026 stay under the old rules.
Spain: closed windows#
Spain’s Sephardic law (Law 12/2015) stopped accepting applications in 2019. The “grandchildren’s law” under the Democratic Memory Law (Law 20/2022) had a limited window that ended in October 2025. For most people Spain now means naturalisation – 2 years for nationals of Ibero-American countries, 10 for others. Spain residence options are on the country page.
Germany: § 5 and § 15 StAG#
German citizenship generally passes from a German parent. Two special routes help descendants:
- Declaration under § 5 StAG: for children of German mothers (born before 1975) or unmarried German fathers (before 1993), and their descendants, who missed out under old discriminatory rules. The declaration is possible until 19 August 2031.
- Restoration under Article 116(2) Basic Law and § 15 StAG: for people deprived of citizenship on political, racial or religious grounds between 1933 and 1945 – and their descendants, including those who lost out indirectly (for example because they emigrated and naturalised abroad).
Both are handled by the Federal Office of Administration (BVA) for applicants abroad and are free of charge under § 38 StAG. No German language test, and you keep your current citizenship.
Scams and traps to avoid
“Guaranteed EU passport by ancestry.”
Nobody can guarantee a recognition. Serious lawyers check the documents first and quote after.
Outdated rules.
Many websites still sell Italian great-grandparent cases or Sephardic applications. Both closed.
Hidden losses.
An ancestor who naturalised abroad before the child was born may have broken the chain. Check the rules in force at the time, not today’s.
Fake documents and “fixers”.
Forged records mean refusal and possibly criminal charges. Only use official archives and registries.
Losing your current citizenship.
Your home country may not allow you to hold another passport. Check before you register.
FAQ#
Can I still get Italian citizenship through my great-grandparent?
For applications filed from 27 March 2025, generally no, if you were born abroad and hold another citizenship. Exceptions exist (for example a parent or grandparent who held only Italian citizenship). Cases filed before that date follow the old rules.
Which EU country is easiest by descent?
Ireland is the most straightforward if you have an Irish-born grandparent. Poland and Lithuania work over several generations but need archives. Hungary is open broadly – if you speak Hungarian.
Do I need to speak the language?
Not for Italy, Ireland, Poland, Lithuania or Germany’s § 5/§ 15 routes. Hungary requires Hungarian. Portugal’s grandchildren route now requires a language and culture test.
Can I keep my current passport?
All routes in the table let you keep it on their side. Your current country may still take its citizenship away if you acquire another – check that side, too.
Is the Sephardic route still open?
No. Spain closed it in 2019 (with processing until 2021) and Portugal formally abolished it with the law in force since 19 May 2026.
Does a passport by descent change my taxes?
No. Tax follows residence, not citizenship – with the exception of the US. See tax residency or use the Jurisdiction Finder to plan the residence part.
This guide is general information, not legal advice. Descent cases turn on documents and old laws – check the official sources below, and book a strategy session if you want help mapping passport, residence and tax together.
Sources#
- Italy – Ministry of Foreign Affairs, citizenship
- Italy – Gazzetta Ufficiale (Decree-Law 36/2025, Law 74/2025)
- Italy – Constitutional Court, judgment 63/2026
- Italy – Consulate General Philadelphia, minors’ deadline extended to 2029
- Ireland – Department of Foreign Affairs, registering a foreign birth
- Ireland – Citizens Information, Foreign Births Register
- Poland – Ministry of the Interior, confirmation of Polish citizenship
- Hungary – Consulate General Los Angeles, simplified naturalisation
- Lithuania – Embassy to the USA, reinstatement of citizenship
- Portugal – Organic Law 1/2026 (Diário da República)
- Spain – BOE, Law 12/2015 (Sephardic nationality)
- Spain – BOE, Law 20/2022 (Democratic Memory)
- Greece – Ministry of Interior, citizenship
- Germany – Nationality Act (StAG)
- Germany – Federal Office of Administration (BVA), citizenship
