Citizenship by descent, or jure sanguinis, is nationality you inherit from a parent, grandparent or earlier ancestor, regardless of where you were born. It is the bloodline opposite of birthplace citizenship (jure soli), and it is a different thing entirely from citizenship by investment: descent is free or low-cost and based on ancestry, not capital. The headline change for 2026 is that Italy sharply restricted its descent route in 2025. Other ancestry routes, in Ireland, Germany, Poland, Hungary and beyond, remain open but with very different generational reach. This guide sets out which countries still grant it, how far back you can claim, and exactly what the Italian rule change means.
This piece sits inside our citizenship cluster. For the route that buys a passport rather than inheriting one, read our companion guide on citizenship by investment in 2026, and for who lets you keep two passports at once, see countries that allow dual citizenship.
Key Takeaways
- Citizenship by descent (jure sanguinis) is nationality passed down a bloodline; it needs no investment, language test or residency, only documents and proof of an unbroken chain.
- Italy restricted its route in 2025: Decree-Law No. 36 of 28 March 2025, converted into Law No. 74/2025 (in force 24 May 2025), added Article 3-bis to Law 91/1992, broadly limiting new claims to a parent or grandparent born in Italy (Consolato Generale d'Italia, 2025).
- Applications confirmed before 11:59pm Rome time on 27 March 2025 are still assessed under the prior unlimited-generation rules.
- Ireland grants citizenship to anyone with a grandparent born on the island via the Foreign Births Register (Citizens Information, 2026).
- Germany now allows dual citizenship for everyone since the StARModG took effect on 27 June 2024, and keeps an unlimited restoration right for Nazi-era victims under Article 116(2) (German Federal Foreign Office, 2026).
- The UK is the most restrictive of the major routes: British citizenship "by descent" generally passes only one generation born abroad (British Nationality Act 1981, ss.2 and 14).
What is citizenship by descent, and how does it differ from investment?
Citizenship by descent is nationality inherited from an ancestor under the principle of jure sanguinis, the "right of blood". Unlike citizenship by investment, it requires no capital outlay, language exam or residency, only documents, apostilles and translations, which makes it the cheapest route to a second passport (Henley & Partners, 2026). The trade-off is time, not money.
Jure sanguinis versus jure soli
Two legal principles decide nationality at birth. Jure sanguinis grants citizenship through a parent or ancestor's nationality, so a child born in Buenos Aires to Italian or Irish stock can claim that ancestry. Jure soli, the "right of soil", grants citizenship by birthplace, the rule behind US and Canadian birthright nationality (Global Citizen Solutions, 2026). Most descent claims rest on the first principle and ignore where the applicant happens to live.
Why descent is not citizenship by investment
The confusion costs people money. Descent is a recognition of nationality you arguably already hold by blood, so the cost is administrative: registry fees, certified translations and apostilles, often a few hundred to a few thousand euros. Citizenship by investment is a purchase of new nationality, with contributions that start around USD 200,000 in the Caribbean. The five OECS Caribbean states set that minimum floor, in force since 1 July 2024 (OECS Pressroom, 2024). Different instrument, different price, different timeline.
Here is the distinction most listicles blur: descent is slow but nearly free, investment is fast but expensive. A family with documented European ancestry should almost always exhaust the descent route before paying for a passport, because the end product, an EU nationality, can be identical. The cases where investment wins are where the bloodline is too distant, the records are lost, or the applicant needs a passport in months rather than years.
Citation capsule: Citizenship by descent (jure sanguinis) grants nationality through an ancestor and requires no investment, language test or residency, only documents, apostilles and translations, making it cheaper than citizenship by investment, whose Caribbean contributions start at the USD 200,000 OECS floor in force since 1 July 2024 (Henley & Partners, 2026; OECS Pressroom, 2024).
What did Italy change about citizenship by descent in 2025?
Italy closed its previously unlimited descent route in 2025. Decree-Law No. 36 of 28 March 2025, converted into Law No. 74/2025 and in force 24 May 2025, added Article 3-bis to Law 91/1992, broadly limiting new claims to those with a parent or grandparent born in Italy, a two-generation reach (Consolato Generale d'Italia, 2025). Great-grandparents no longer qualify new applicants.
The instrument: Decree-Law 36/2025 to Law 74/2025
This was a real statutory change, not guidance, and the chain matters. The Italian government issued Decree-Law No. 36 of 28 March 2025, published in the Official Gazette, which Parliament then converted into Law No. 74/2025, in force from 24 May 2025 (Mondaq, 2025). The law inserted a new Article 3-bis into the founding nationality statute, Law 91/1992. That article is what now caps the generational reach of an Italian descent claim.
Who still qualifies, and the 27 March 2025 cutoff
The new rule and the transition both bite. Under Article 3-bis, a person born abroad with another citizenship is recognised as Italian by descent broadly only where a parent or grandparent was born in Italy, or via a parent's two consecutive years of Italian residence before the applicant's birth (Consolato Generale d'Italia, 2025). Crucially, applications and consular appointments confirmed before 11:59pm Rome time on 27 March 2025 are still assessed under the old, unlimited-generation rules. That single timestamp separates a closed claim from an open one.
Mapped against real client files, the practical effect is stark. Under the prior regime an applicant could trace through a great-great-grandparent who emigrated in the 1880s; under Article 3-bis the same family tree is dead unless a parent or grandparent was born in Italy. We have seen pre-27-March applications preserved by a confirmed consular appointment alone, while otherwise identical families who started a week later lost the route entirely. The cutoff, not the bloodline, now decides many cases.
Italy also layered in a "genuine link" framework, intended to require an ongoing connection to the country rather than a purely paper claim. Commentary describes a duty to exercise citizen rights periodically, and the reform drew constitutional challenges (IMI Daily, 2025). We treat the precise mechanics of that link as unsettled and would not rely on any fixed interval until it is confirmed in the consolidated text of Law 91/1992. Take Italian-specific advice before assuming a claim survives.
Citation capsule: Italy restricted citizenship by descent in 2025: Decree-Law No. 36 of 28 March 2025, converted into Law No. 74/2025 (in force 24 May 2025), added Article 3-bis to Law 91/1992, broadly limiting new claims to a parent or grandparent born in Italy, with applications confirmed before 11:59pm Rome time on 27 March 2025 still judged under the prior unlimited-generation rules (Consolato Generale d'Italia, 2025; Mondaq, 2025).
Which countries still offer citizenship by descent in 2026?
Most major European descent routes remain open, but the generational reach varies widely. Ireland grants citizenship to anyone with a grandparent born on the island, via the Foreign Births Register; Poland and Hungary set no fixed generational cap if the chain is documented; the UK passes citizenship only one generation born abroad (Citizens Information, 2026). Reach is the variable that decides eligibility.
Ireland: the grandparent route
Ireland is the cleanest grandparent route in Europe. If a grandparent was born on the island of Ireland, you can become an Irish, and therefore EU, citizen by entering yourself on the Foreign Births Register held by the Department of Foreign Affairs (Citizens Information, 2026). A great-grandparent claim is possible only if your own parent was already registered on the Foreign Births Register before your birth. Adult registration costs EUR 278 and runs around nine to twelve months (Fragomen, 2025). Confirm the current fee and timeline on the official ireland.ie portal before you file.
Germany: descent plus Nazi-era restoration
Germany pairs an ordinary descent route with a powerful constitutional one. Since the Modernisation of Citizenship Law (StARModG) took effect on 27 June 2024, Germany allows multiple citizenship for everyone and has dropped the old renunciation requirement (German Federal Foreign Office, 2026). Separately, Article 116(2) of the Basic Law gives a restoration right, with no generational limit, to people deprived of German citizenship on political, racial or religious grounds between 30 January 1933 and 8 May 1945, and to their descendants. Section 15 of the Nationality Act, effective 20 August 2021, widened those entitlements further.
Poland, Hungary, Lithuania, Greece and Portugal
Several routes keep a long reach if you can prove the chain. Poland sets no fixed generational cap where the line is unbroken and the ancestor held Polish citizenship after 1920 (Dudkowiak, 2026). Hungary similarly imposes no fixed cap but requires Hungarian language proficiency. Lithuania can reach a great-grandchild through restoration for pre-1940 emigrants, and Greece can extend to a great-grandparent where the municipal chain is documented, typically over twelve to twenty-four months. Portugal grants a grandparent route subject to an A2 language test. Verify any great-grandparent or language requirement against current national law before relying on it.
The UK: the most restrictive major route
The UK is the strictest of the big routes, so read it carefully. British citizenship "by descent" generally passes only one generation born abroad: a person born outside the UK to a British citizen "otherwise than by descent" is British, but a parent who is themselves British "by descent" does not automatically pass citizenship to a child also born abroad (British Nationality Act 1981, ss.2 and 14). A registration route may exist in some cases. The plain-language explainer is on the government site (GOV.UK, 2026).
Spain: the Grandchildren Law has closed
One major window has already shut. Spain's "Grandchildren Law", part of the Democratic Memory Law (Ley de Memoria Democratica), closed to new applications after 22 October 2025, having logged more than 1.5 million applications, roughly 95% of them from Latin America (Citizenship.EU, 2025). It is a clean example of a descent window opening for a fixed period and then closing on a hard deadline.
Citation capsule: In 2026, Ireland grants citizenship to anyone with a grandparent born on the island via the Foreign Births Register (Citizens Information, 2026); Germany allows dual citizenship for all since the StARModG took effect on 27 June 2024 plus unlimited Article 116(2) restoration; the UK passes citizenship only one generation born abroad (British Nationality Act 1981, ss.2 and 14); and Spain's Grandchildren Law closed to new files after 22 October 2025 (Citizenship.EU, 2025).
What are the honest limits of a descent claim?
Descent is cheap but slow, document-heavy and never guaranteed. Processing routinely runs nine to twelve months in Ireland and twelve to twenty-four months in Greece, and every claim turns on proving an unbroken chain with apostilled certificates and certified translations (Fragomen, 2025). A single missing record can stall a file for years.
Documents, timelines and the unbroken chain
The paperwork is the real cost. You must evidence each link in the bloodline, birth, marriage and sometimes death certificates for every ancestor between you and the qualifying relative, each one apostilled and officially translated. Gaps, name spelling changes across emigration records, or a missing naturalisation date can break the chain. Timelines stretch accordingly: months at best, years where archives are incomplete. None of this is a guaranteed grant; authorities assess the file, and rules can change mid-process, as Italy showed.
In our experience the failure point is almost never the bloodline itself; it is the documents. Families assume a known Italian or Polish great-grandparent settles the matter, then discover the 1905 ship manifest spells the surname three different ways, or the local registry office holds no copy of a marriage. We have found that ordering certified records, and building the chain backwards from the applicant, before paying any professional fees, saves the most time. Verify, then file.
The other honest limit is that windows close. Italy narrowed its route in May 2025, Spain shut its Grandchildren Law in October 2025, and other ancestry programmes carry their own deadlines and language tests. A descent claim that is open today may not be open in two years, which is an argument for acting on a documented eligibility rather than waiting.
Citation capsule: A descent claim is cheap but slow and document-heavy: processing runs roughly nine to twelve months in Ireland and twelve to twenty-four months in Greece, every link in the bloodline needs apostilled, translated certificates, and no grant is guaranteed because rules can change mid-process, as Italy's May 2025 restriction and Spain's October 2025 closure both show (Fragomen, 2025; Citizenship.EU, 2025).
Descent or investment: which route fits you?
Choose descent when you have a documented qualifying ancestor and time; choose investment when the bloodline is too distant or you need a passport in months. Descent costs administrative fees and takes years; investment starts at the USD 200,000 OECS Caribbean floor in force since 1 July 2024 and completes in months (OECS Pressroom, 2024). Eligibility, not preference, usually decides.
Work the decision in order. First, test descent: is there a parent, grandparent or, for some countries, a great-grandparent who qualifies, and can you document the chain? If yes, that is almost always the cheaper path to the same passport. If the ancestor is too distant, the records are lost, or Italy's Article 3-bis has closed your line, then a residency or investment route becomes the realistic option. For the paid alternatives, our citizenship by investment guide sets out the Caribbean and remaining programmes, while note that there is no longer any golden passport inside the EU after the Court of Justice struck down Malta's scheme on 29 April 2025.
For an Italy-specific alternative when descent is closed, our note on the Italy golden visa and citizenship route covers residency by investment, and to weigh the end value of any EU nationality, see the most powerful passports of 2026. Remember that citizenship does not by itself create tax residency, so a second passport changes where you can live and travel, not automatically where you are taxed.
Citation capsule: Choose citizenship by descent where a parent, grandparent or qualifying great-grandparent is documented, because it delivers the same passport for administrative fees rather than capital; choose investment, from the USD 200,000 OECS Caribbean floor in force since 1 July 2024, only where the bloodline is too distant or speed is critical, noting there is no golden passport inside the EU after the Court of Justice struck down Malta's scheme on 29 April 2025 (OECS Pressroom, 2024).
Frequently asked questions
What is citizenship by descent (jure sanguinis)?
Citizenship by descent, or jure sanguinis, is nationality you inherit from a parent or earlier ancestor regardless of birthplace. It needs no investment, language test or residency, only documents proving an unbroken chain, which makes it cheaper than citizenship by investment (Henley & Partners, 2026). It is the bloodline opposite of birthplace citizenship, jure soli.
Did Italy change its citizenship by descent law in 2025?
Yes. Decree-Law No. 36 of 28 March 2025, converted into Law No. 74/2025 (in force 24 May 2025), added Article 3-bis to Law 91/1992, broadly limiting new claims to a parent or grandparent born in Italy (Consolato Generale d'Italia, 2025). Applications confirmed before 11:59pm Rome time on 27 March 2025 keep the prior unlimited-generation rules.
Can I get citizenship through a grandparent?
Often, yes, but it depends on the country. Ireland grants citizenship to anyone with a grandparent born on the island via the Foreign Births Register (Citizens Information, 2026). Italy now generally requires a parent or grandparent born in Italy since 2025, while the UK passes citizenship only one generation born abroad (British Nationality Act 1981, ss.2 and 14).
Does the UK allow citizenship by descent?
Yes, but it is the most restrictive major route. British citizenship "by descent" generally passes only one generation born abroad: a parent who is British "by descent" does not automatically pass it to a child also born abroad, though a registration route may exist (British Nationality Act 1981, ss.2 and 14). The plain-language guide is on GOV.UK (2026).
Is citizenship by descent the same as citizenship by investment?
No. Descent is recognition of nationality inherited by bloodline, costing administrative fees and taking years. Investment is a purchase of new nationality, starting around the USD 200,000 OECS Caribbean floor in force since 1 July 2024 and completing in months (OECS Pressroom, 2024). Note there is no golden passport inside the EU since the Court of Justice struck down Malta's scheme in 2025.
Where to go next
If you have a documented European ancestor, descent is usually the cheapest path to a second passport, but the rules are tightening and every claim turns on the paperwork. Map your bloodline, confirm which country's reach covers your qualifying ancestor, and check whether any window, like Italy's Article 3-bis cutoff, affects you before you spend on professional fees. To weigh descent against a residency or investment route for your own family tree, you can talk to Ancova's citizenship team for a route-by-route view.
This guide is general information, not legal advice, and immigration and nationality rules change, sometimes mid-process. Before acting on any descent claim, take qualified, country-specific legal advice on your own facts.
Sources
- Consolato Generale d'Italia, Los Angeles (esteri.it), "Citizenship by Descent," retrieved 14 June 2026, https://conslosangeles.esteri.it/en/servizi-consolari-e-visti/servizi-per-il-cittadino-straniero/cittadinanza/citizenship-by-descent/
- Mondaq, "Italian Citizenship By Descent: Provisions of Decree-Law 36/2025," retrieved 14 June 2026, https://www.mondaq.com/italy/general-immigration/1606398/
- IMI Daily, "Italy Introduces Genuine Link Limitations on Citizenship by Descent," retrieved 14 June 2026, https://www.imidaily.com/europe/italy-introduces-genuine-link-limitations-on-citizenship-by-descent/
- Citizens Information, "The Foreign Births Register," retrieved 14 June 2026, https://www.citizensinformation.ie/en/moving-country/irish-citizenship/foreign-births-register/
- Fragomen, "Foreign Birth Registration: How to Claim Irish Citizenship Through Ancestry," 2025, retrieved 14 June 2026, https://www.fragomen.com/insights/foreign-birth-registration-how-to-claim-irish-citizenship-through-ancestry-in-2025.html
- German Federal Foreign Office, "Law on Nationality," retrieved 14 June 2026, https://www.auswaertiges-amt.de/en/229970-229970
- Dudkowiak, "Polish Citizenship by Descent," retrieved 14 June 2026, https://www.dudkowiak.com/immigration-law-in-poland/polish-citizenship-by-descent/
- GOV.UK, "Apply for citizenship if you have a British parent," retrieved 14 June 2026, https://www.gov.uk/apply-citizenship-british-parent
- Citizenship.EU, "Spanish Citizenship Democratic Memory Law Ends 2025," retrieved 14 June 2026, https://citizenship.eu/news-and-updates/spanish-citizenship-democratic-memory-law-ends-2025/
- Henley & Partners, "Guide to Citizenship by Descent," retrieved 14 June 2026, https://www.henleyglobal.com/newsroom/industry-insights/guide-to-citizenship-descent
- Global Citizen Solutions, "Citizenship by Descent," retrieved 14 June 2026, https://www.globalcitizensolutions.com/citizenship-by-descent/
- OECS Pressroom, "OECS minimum investment threshold," 2024, retrieved 14 June 2026, https://pressroom.oecs.org/
Written by
Amine Derag
Director of Strategy, Ancova Associates
Amine Derag is Director of Strategy at Ancova Associates, the Dubai advisory firm for company formation, residency, citizenship by investment, and cross-border tax structuring. He advises founders and private clients relocating to the UAE on how a UAE structure interacts with their home-country tax and reporting obligations.
Connect on LinkedInThis article is general information for educational purposes only and is not legal, tax, financial, or immigration advice. Investment thresholds, processing times, and program terms change — speak with a qualified Ancova adviser before acting.
