Jus sanguinis – or ‘blood right’ – might entitle you to citizenship in Europe

By Terry Ward, CNN

(CNN) — New York City author Lisa Wixon always knew she had a path to EU citizenship through her maternal great-grandfather, who arrived in the United States in 1906 from Rijeka in western Croatia.

Croatia is one of many countries in the European Union to recognize jus sanguinis (the “right of blood”), which can be used to acquire citizenship by descent, as opposed to jus solis (the “right of soil”), which grants citizenship solely on a person’s place of birth.

But until some of the country’s stricter requirements were simplified on January 1, 2020, Croatian citizenship wasn’t something Wixon thought she’d be able to acquire without some major hurdles.

Before then, Croatia required applicants who could trace their heritage to Croatia to take a language test, among other qualifications, to apply for citizenship.

“As a busy mom and someone who doesn’t have time to go live in Croatia, there was no way I could imagine becoming fluent in Croatian. It felt too daunting to me,” said Wixon, who spends five to six weeks a year in Europe.

Then, earlier this year, after returning from a trip to Ireland and France and once again feeling the itch to find a way to stay longer in Europe, Wixon went online and discovered Croatia had dropped its language requirement for jus sanguinis applicants.

“My brain lit up, and I thought, ‘OK, this is great, we’re going to do this right away,’ ” said Wixon. She has hired a lawyer to ensure the paperwork will be submitted correctly to avoid any delays in the process.

Many pathways to EU citizenship

If you can trace your ancestors to their birthplaces in a range of European countries, you might have a path to citizenship, too. But keep in mind that if maintaining your US or other original citizenship is important to you, you’ll want to make sure any pathway you find allows dual citizenship.

“Most EU countries will allow for citizenship through ancestry, but the exact eligibility requirements vary hugely country to country,” said Sophie Jo Wasson, private client supervisor in the London office of immigration law firm Fragomen, in an email to CNN.

“In our experience, the busiest routes are Italy, Spain, Austria, Poland, Ireland and Romania,” she said, noting that Czechia, Hungary and Croatia are among the other countries offering pathways to citizenship through jus sanguinis. Each country has its own eligibility criteria for citizenship through ancestry, and applications might take a year or two – or more – to process.

And while there are no generational limits to how far you trace your ancestry straight back to be considered for Croatian citizenship, Wasson said that if an applicant’s ancestor emigrated from Croatia after October 8, 1991, or moved to the countries that formed from the breakup of Yugoslavia, they are ineligible for Croatian citizenship.

Some countries are fairly straightforward about their requirements for citizenship through jus sanguinis.

Ireland allows for citizenship by descent through a parent or grandparent born on the island of Ireland. “This includes Northern Ireland, even if your ancestor never held Irish citizenship,” said Wasson.

Children of parents born in Ireland are automatically eligible to apply for an Irish passport and can simply apply online, she said. Grandchildren of people born in Ireland need to apply for Irish citizenship first through a process called Foreign Birth Registration. Applications are filed directly with the Department of Foreign Affairs and can take upwards of 8 months to process.

Making up for the past

Some countries make amends for past atrocities through citizenship programs, the most obvious of which might be Germany.

It offers citizenship to people who can prove their ancestors were former German citizens persecuted by the Nazis between January 30, 1933, and May 8, 1945, and thus deprived of their citizenship.

Austria, too, offers a streamlined route to citizenship for descendants of people who were forced to flee during the Nazi regime, said Wasson.

“The relevant ancestor does not have to have been Austrian themselves but will need to have been resident in Austria before fleeing and have been a citizen of the former Austro-Hungarian empire,” she said.

Romania offers two ancestral routes to citizenship, she said, both to “those who are children or grandchildren of victims of the Nazi regime, or children, grandchildren or great-grandchildren of Romanians who were born in modern-Romania or its former territories.”

Wasson said Fragomen has also helped clients gain citizenship in Spain through the country’s Democratic Memory Law. It allows for citizenship through a Spanish parent or grandparent as well as for children or grandchildren of people forced to flee Spain for political, ideological or belief reasons during the Spanish Civil War in the late 1930s, when the Franco dictatorial regime forced exiles to flee the country.

The law was introduced in October 2022 and has a temporary application window currently set to close in October 2025, Wasson said.

“Applications are filed at your local Spanish consulate by appointment and can take anywhere from several weeks to over a year to process, depending on your local consulate’s workload,” she said.

Hungary offers citizenship based on jus sanguinis with some caveats, too. Hungary’s jus sanguinis law was simplified in 2011 to expand eligibility for people living in regions that were formerly part of Hungary and descendants of Hungarians who speak the Hungarian language and can provide proof of Hungarian ancestry.

That’s when Ferenc G. Koszorus, an American citizen from Washington, DC, who grew up speaking Hungarian, realized he had a more straightforward pathway to Hungarian citizenship.

Koszorus’ paternal grandfather, after whom he was named, was born in Hungary and served as a colonel in the Hungarian army.

He was forced to flee the country during World War II after his First Armored Division prevented a coup by pro-Nazi forces. He is credited with saving thousands of Hungarian Jews from deportation to Nazi death camps. He then fled to West Germany, where Koszorus’ father was born. The family later left for the United States.

“When both of my parents got their Hungarian citizenship around four years ago, it made it easier for me to get it,” said Koszorus, 41, who received his Hungarian citizenship this summer, less than a year after he started the paperwork and application process.

Koszorus said he wanted to become a dual Hungarian and American citizen to honor his Hungarian heritage and ancestry.

“My grandparents had to leave the country forcibly,” he said. “To have that connection to my ancestral homeland was very important to me and keeping that heritage and culture.”

One of the most requested citizenships

For people with Italian ancestors, Italy is one of the most requested citizenships in Europe because the country does not place a generational limit when it comes to how far you can trace your relatives back in a direct line, said Marco Permunian of Italian Citizenship Assistance (ICA).

The firm, with a team of roughly 300 people in offices in the United States and Italy, has worked with more than 20,000 clients to date, he said.

The only requirement to apply is that your ancestor was born or already alive in Italy after March 17, 1861, when the modern Italian state came into existence. That relative also must have still been an Italian citizen before giving birth to the next relative in your family line. They also cannot have naturalized — the legal process of becoming a citizen of a country after birth — to become an American citizen (or a citizen of any other country) before the next relative in your family line was born for you to have a path to citizenship.

Permunian said most cases for Italian citizenship that his company is working on take an average of two to three years from start to finish. Inquiries have steadily increased since ICA’s 2014 founding, he said.

ICA offers a free eligibility assessment for potential would-be Italians to fill out on its website. And a private Facebook group called Dual US-Italian Citizenship has more than 70,000 members and is among many other resources available to people who think they might have a blood right path to Italian citizenship.

The Baltic countries

Some Baltic countries offer a path to citizenship, too, as Colorado resident Janna Graber, editor of Go World Travel Magazine, found out.

“My grandfather was born in Riga, Latvia, and grew up there. During World War I, when the war came to Riga, he was separated from his mother and sister at the age of 14 when the bridge they were crossing was shelled,” Graber said. “He fell into the water, and when he made it to the other side of the river, he was alone. He never found them.”

Her grandfather made it to the United States in 1919, said Graber, and died in 1968 before the restoration of Latvia’s independence in 1991.

When Graber decided to pursue her Latvian citizenship – a daunting undertaking, she says, considering the paperwork that had been lost, name changes and other factors – part of her motivation was to make peace with the past.

“It feels like it would be like righting a wrong for our family and for his language and his culture,” she said, adding that it’s not an easy process.

People pursuing Latvian or Lithuanian citizenship must demonstrate they have at least one parent, grandparent or great-grandparent who was a citizen or born in those countries, said Richard Orbidans, a partner with Baltic Migration.

“Usually, the biggest obstacle is gathering and verifying the necessary documents. Clients often struggle to obtain accurate and complete birth, marriage or other personal documents, especially if the records are old or were lost,” he said, adding that 80% of his firm’s cases require an archive search to look for such documents.

Orbidans has been contacted by people who have received DNA testing that shows that a “large part of their DNA is from Lithuania,” he said in an email to CNN. “Unfortunately, in such cases we can’t help them if they don`t have any information or documents regarding their ancestors.”

How to tackle the ancestry search

If you know your ancestry has roots in Europe but don’t know where to start, Wasson has some tips.

“Citizenship by ancestry is a very detailed process that requires a lot of input from the applicant,” she said.

“Our best advice for those starting the process is to spend time researching your lineage, or even engaging with a genealogist. For a citizenship lawyer to be able to give an opinion on your eligibility for citizenship, we will need to know as much information as possible,” she said.

Details such as the exact place and date of birth, details of your ancestors’ emigration, whether they ever naturalized as a US citizen or formally renounced their nationality and copies of documents are just the beginning, Wasson said.

“We can search local registry offices and town halls for copies of vital records, but without the correct information, those searches won’t be successful,” she said. “So the more we can get from you, the better.”

The upside of all that hard work might go beyond a second passport – you might end up learning a lot about yourself in the process.

Florida-based travel writer Terry Ward lives in Tampa and has the blood right to Italian citizenship through her paternal great-great-grandfather.

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