We run through the rules in European countries where Britons are seeking to escape Brexit
•UK applicants for Irish passports ‘face excessive delays and costs’
When Guardian Money surveyed other major EU countries, it emerges that Ireland is taking the brunt of applications from British citizens, with remarkably few requests going to other EU nations.
About 300,000 UK citizens live in Spain, yet few have applied for citizenship. Spain’s ministry of justice told Guardian Money that “the latest data we have of Britons who have applied for Spanish citizenship are very low”.
It says that in 2016, the year of the EU referendum, 33 British citizens applied for Spanish nationality. In 2017, that rose to 181, then rose again to 209 in 2018.
One major stumbling block is that Spain does not recognise dual nationality, so applicants from the UK are supposed to renounce their British citizenship – though in practice many keep their British passports, as they do not have to be given up. Applicants have to pass a Spanish language test and culture exam, as well as pay fees adding up to about €300. Spanish nationality can be obtained through residence, but the person must have lived continuously in the country for 10 years.
Estimates vary, but there are thought to be about 160,000 UK citizens in France, making it the third most popular location after Spain and Ireland. It permits dual nationality, and the numbers of Brits applying for citizenship are reported to have jumped 10-fold since the EU referendum, from 375 in 2015 to 3,211 in 2018.
Having a grandparent born in France isn’t enough to get you a French passport. Photograph: Tatiana Koroleva/Alamy
If you have a grandparent born in France, then bad luck – that doesn’t qualify you for citizenship, with nationality by descent only extending back to parents.
But French citizenship through naturalisation can be obtained after just five years of living in the country, falling to just two years if you complete a postgraduate course at a French university. If you marry a French citizen, you qualify after four years.
You have to prove a good command of French language and culture, and will be interviewed at the local prefecture, with the expectation that you can show you are integrated into French society.
There are about 96,000 UK citizens living in Germany and it allows dual citizenship for citizens of some countries, including the UK.
Germany has traditionally been a “ius sanguinis” country, where citizenship is passed on to the next generation through the bloodline, irrespective of the place of birth. As of 2000, “ius soli” also applies, which means a child born in Germany automatically receives German citizenship, even if both parents have foreign citizenship.
Eight years of residence are usually required for naturalisation, although there are exceptions (for example, if applicants have very good German language skills or have worked for a charity in Germany, the period is reduced to six years). Applicants have to take a language test and a citizenship exam. They must not be dependent on the German welfare system (with some exceptions) and hold no criminal record.
There are about 30,000 to 50,000 UK citizens living in Italy, and the country allows dual nationality. The Italian consulate general says: “In the first semester of 2019, we have received nearly 400 citizenship requests which include both applications by lineage/ancestry as well as by marriage. Of this total, British citizens rank as the largest portion of those requesting Italian citizenship. However, we are unable to provide an exact figure.”
Italy allows other countries citizens to have dual nationality. Photograph: Andrew Walters/Alamy
Anyone with an Italian-born parent is eligible for citizenship, and in theory applicants can go further back through the generations to the point when Italy became a nation in 1861 if they can prove their paternal “iure sanguinis” (right of bloodline). But you have to prove that the line of citizenship was uninterrupted and that none of your ancestors renounced their Italian citizenship.
Citizenship via naturalisation is generally after 10 years of residence, while through marriage it takes two years (three if you are living outside Italy but married to an Italian).
Portugal is the only EU country that has promised easy entry to British citizens irrespective of a no-deal Brexit. It also allows dual nationality and, like Ireland, grants citizenship to people who can prove a grandparent born in the country. The fee is €250.
It says that 495 British citizens applied for Portuguese citizenship in 2018 – a big rise from the 50 to 60 applications it used to receive each year before the EU referendum. It is estimated that about 20,000-30,000 UK citizens live in the country.
Naturalisation is also easier than some other countries, with six years of residence required, though applicants will have to take a language test.
Other EU countries
There are 28 EU countries each with their own rules on citizenship.
The Netherlands does not permit dual citizenship.
There are reports of a surge in applications in Sweden, home to about 20,000 British citizens. The country requires five years’ residence for naturalisation, dropping to three years if the person is living with a Swedish citizen. Through birth you can only apply if one of your parents, not grandparents, is Swedish.
The Polish embassy says it had only received two applications from UK citizens this year.