What Is Citizenship by Descent? Jus Sanguinis Explained

What is citizenship by descent?

Citizenship by descent is exactly what it sounds like: citizenship derived from ancestry. In other words, citizenship by descent is the citizenship you inherit through your parents, grandparents, great-grandparents, or in some cases more distant ancestors.

The legal principle behind citizenship by descent is called jus sanguinis, Latin for "right of blood." If your family roots trace back to a jus sanguinis country, you may already hold a claim to citizenship there without realizing it.

How do people acquire citizenship?

Across the world, there are several ways a person can become a citizen of a country:

Naturalization: choosing to become a citizen of another country after meeting residency, language, and civics requirements
Marriage: acquiring citizenship through a spouse
Birth on the territory: automatic citizenship based on where the person was born, regardless of parental nationality
Special grant: citizenship awarded for extraordinary merit or at a government's discretion
Descent: citizenship inherited through a parent's (or further ancestor's) nationality

Most countries assign citizenship at birth using one of two legal frameworks: jus soli or jus sanguinis.

Jus soli vs. jus sanguinis... what's the difference?

Both are Latin terms, but they describe very different legal mechanisms for acquiring citizenship at birth.

Jus soli means "right of the soil." A person born in a jus soli country is automatically a citizen at birth, regardless of parental nationality. Most New World countries follow jus soli, including the United States, Argentina, Brazil, Canada, and Mexico.

Jus sanguinis means "right of blood." Children born in jus sanguinis countries receive citizenship based on their parents' nationality, not their place of birth. A child born in a jus sanguinis country to foreign parents does not automatically become a citizen of that country. Most Old World countries operate on jus sanguinis principles, including Italy, Poland, Austria, Ireland, Germany, and Slovakia.

Note that these systems are fluid. Very few countries are completely jus sanguinis or jus soli. Most countries operate with a hybrid system which allows people to obtain citizenship in both ways, depending on that individual's particular situation.

How jus soli and jus sanguinis work together

Here's where citizenship by descent gets interesting: the two systems can overlap, and that overlap is exactly what makes citizenship by descent possible for so many people today.

If you were born in a jus soli country but your ancestors held citizenship in a jus sanguinis country, you may be eligible for dual citizenship in your ancestral homeland. For example, a baby born in the United States to two Irish parents is an American citizen at birth (under jus soli) and an Irish citizen at birth (under jus sanguinis). Both citizenships exist simultaneously from day one.

Jus sanguinis can also pass down through multiple generations without ever being formally claimed. Even when it sits unrecognized, it doesn't disappear. It remains dormant, waiting to be acknowledged through a citizenship application. That's why people who are several generations removed from their emigrant ancestor can still pursue recognition of their ancestral citizenship today.

Citizenship by descent: what this means for you

If you have ancestors from any jus sanguinis country, it is well worth checking that country's citizenship laws. You may already be entitled to a second passport through citizenship by descent... you simply need to claim it.

Below, you'll find a handy chart that lists jus sanguinis countries and a brief snippet about each one's rules. You'll notice some jus soli countries on the list as well, because jus soli countries often allow jus sanguinis too (the reverse is less often true).

This post is intended as a starting point. Citizenship laws change frequently, eligibility rules can be highly technical, and the documentary requirements vary widely from country to country. Always conduct your own independent research, and consider consulting a qualified citizenship by descent practitioner before beginning a formal application.

Frequently asked questions about citizenship by descent

Is citizenship by descent the same as jus sanguinis? Yes. Citizenship by descent is the practical term; jus sanguinis is the legal Latin term for the same underlying principle.

How many generations back can citizenship by descent go? It depends on the country. Some jus sanguinis countries place no generational limit, while others restrict eligibility to children or grandchildren of citizens. Recent legislative changes in several countries have tightened these rules, so always check the current law.

Do I lose my original citizenship if I claim citizenship by descent? Usually no, but it depends on both countries' rules on dual citizenship. Many jus sanguinis countries permit dual or multiple citizenships.

Can I pass citizenship by descent on to my own children? In most cases, yes. Once you are formally recognized as a citizen, your minor children typically qualify as well, and your future children will inherit the citizenship automatically. In other cases, depending on how far you are removed from your original emigrant ancestor, you must become a recognized dual citizen prior to having children if you wish to pass it on.

Africa

Country	Basis
Algeria	Article 6 of the Algerian nationality law confers citizenship at birth through a parent.
Egypt	Nationality law of the Arab Republic of Egypt (as amended) confers citizenship through a parent.
Kenya	Constitution of Kenya 2010, Article 14(1): citizenship by descent through a Kenyan parent.
Liberia	Constitution restricts citizenship to persons of Negro descent (cultural or national origin).
Morocco	Article 6 of the nationality code: citizenship to a child born to a Moroccan parent.
Nigeria	Constitution, Chapter 3, Section 25(1)(c): citizenship by descent through a Nigerian parent.
Rwanda	Constitution: all persons originating from Rwanda and their descendants have a right to nationality.
South Africa	Section 2 of the Citizenship Act: a child born to a South African citizen acquires citizenship.
Tunisia	Nationality law: when one parent is Tunisian, the child is Tunisian.

Americas

Country	Basis
Argentina	Argentine nationality law provides citizenship by descent through a parent.
Brazil	Constitution Article 12, paragraph I(b) and (c): citizenship to children born abroad to Brazilian parent(s).
Canada	Citizenship by descent under the Citizenship Act; Bill C-3 (in force December 15, 2025) extends descent beyond the first generation.
Chile	Chilean nationality law: citizenship by descent through a Chilean parent.
Colombia	Colombian nationality law: citizenship by descent through a Colombian parent.
Dominican Republic	Constitution: a child born abroad to at least one Dominican parent is a citizen.
Haiti	Nationality law: every child born to a Haitian father or mother is Haitian.
Mexico	Constitution Article 30: persons born abroad to at least one Mexican parent are Mexican by birth.
Suriname	Surinamese nationality law: citizenship by descent through a Surinamese parent.
United States	U.S. nationality law: a child born abroad to U.S. citizen parent(s) acquires citizenship, subject to parental residency or physical-presence requirements.
Venezuela	Constitution Articles 32 through 42 establish citizenship by descent.

Asia

Country	Basis
Afghanistan	Citizenship tied to connection with the Afghan diaspora; ethnic-origin provisions have been proposed.
Armenia	Constitution Article 47 (descent) plus Article 14: individuals of Armenian ethnic origin acquire citizenship through a simplified process.
Azerbaijan	Constitution Article 52: citizenship by descent through an Azerbaijani parent.
Cambodia	Law on Nationality, Article 4: a child born to a Khmer parent (mother or father) is a citizen.
China	Nationality law Article 5: a child born abroad to a Chinese parent is a citizen, with limits where the parent has settled abroad or holds foreign nationality.
India	Indian nationality law: a child born outside India on or after December 3, 2004 to an Indian parent is a citizen by descent (registration required in some cases).
Indonesia	Nationality law: a child born anywhere to one Indonesian parent acquires citizenship.
Iran	Iranian nationality law: citizenship by descent through a parent (historically patrilineal, with recent reforms expanding maternal transmission).
Israel	Nationality law confers citizenship on all children of Israeli citizens; the Law of Return separately grants citizenship to Jews and certain non-Jewish relatives.
Japan	Nationality law: a child born to a Japanese parent acquires Japanese nationality.
Malaysia	Prior to 2025, only overseas-born children of Malaysian fathers qualified; the 2025 Constitution (Amendment) Act expanded transmission rules.
Mongolia	Nationality Act of Mongolia: a child of a Mongolian citizen acquires Mongolian nationality.
Myanmar	Burma Citizenship Law 1982: nationality restricted to recognized ethnic groups (Kachin, Kayah, Karen, Chin, Burman, Mon, Rakhine, Shan).
Nepal	Nepal Citizenship Act 2063 (2006): citizenship by descent through a Nepali parent.
Pakistan	Pakistani nationality law: a child born outside Pakistan to a Pakistani parent acquires citizenship.
Philippines	Philippine nationality law is grounded in jus sanguinis; citizenship passes through a Filipino parent.
Singapore	Nationality law allows overseas-born children of Singaporean parent(s) to acquire citizenship by descent.
South Korea	Nationality law: citizenship through a Korean parent; special facilitated status for ethnic Koreans and their descendants abroad.
Taiwan	Nationality Act, Article 2: a child of a national of the Republic of China is a Chinese national.
Thailand	Thai nationality law: any person who is a child of a Thai mother or father is Thai by birth.
United Arab Emirates	UAE Federal Law No. 17 of 1972: Emirati nationality acquired through descent.
Vietnam	Vietnamese nationality law: nationality conferred through a Vietnamese parent.

Europe

Country	Basis
Austria	Austrian nationality law: citizenship by descent through an Austrian parent.
Belgium	Belgian nationality law: citizenship by descent through a Belgian parent.
Bulgaria	Constitution Article 25 (1991): a person of Bulgarian origin acquires Bulgarian citizenship on a facilitated basis.
Croatia	Law on Croatian Citizenship, Article 11: emigrants and their descendants are entitled to citizenship.
Czech Republic	Children, and in some cases grandchildren, of Czech citizens automatically acquire citizenship.
Denmark	Danish nationality law: citizenship by descent through a Danish parent.
Estonia	Constitution Article 8: every child with at least one Estonian parent is an Estonian citizen.
Finland	Finnish nationality law (descent) plus a right of return for ethnic Finns from the former Soviet Union.
France	French nationality law: citizenship by descent through a French parent.
Germany	Citizenship through a German parent; Basic Law Article 116(1) confers citizenship on ethnic Germans (Aussiedler) and certain persecuted descendants.
Greece	Code of Greek Nationality: ethnic Greeks can obtain citizenship through two recognized methods.
Hungary	Citizenship acquired at birth if at least one parent is Hungarian; simplified naturalization is available to ethnic Hungarians abroad.
Iceland	Icelandic nationality law: citizenship by descent through an Icelandic parent.
Ireland	Citizenship automatic for a child born in Ireland with at least one Irish parent; foreign-born descendants may register via the Foreign Births Register.
Italy	Italian nationality law historically grants jus sanguinis with no generational limit; Decree-Law 36/2025 (converted into Law 74/2025) introduced significant generational restrictions effective March 27, 2025.
Lithuania	Constitution grants a right to citizenship to foreigners of ethnic Lithuanian descent.
Malta	Maltese nationality law: citizenship to any person descended from a Maltese ascendant.
Netherlands	Dutch nationality law: citizenship by descent through a Dutch parent.
Norway	Norwegian nationality law: citizenship by descent through a Norwegian parent.
Poland	Polish nationality law: Polish citizenship has long been defined principally by descent.
Portugal	Nationality to children and grandchildren of Portuguese citizens; Organic Laws 2/2006, 9/2015, and 2/2018 cover descendants of Sephardic Jews.
Romania	Romanian nationality law: citizenship by descent, including for ethnic Romanians from neighboring states.
Russia	Russian nationality law: citizenship by descent through a Russian parent.
Serbia	2004 citizenship law, Article 23: descendants of Serbian emigrants may acquire citizenship.
Slovakia	Full Slovak citizenship to children where one or both parents are Slovak.
Spain	Spanish nationality law (descent); a 2015 law allowed descendants of expelled Sephardic Jews to apply, with the application window now closed.
Sweden	Swedish nationality law: citizenship by descent through a Swedish parent.
Switzerland	Swiss nationality law is descent-based and unusually restrictive; ordinary naturalization requires lengthy residency and stringent conditions.
Turkey	Citizenship by descent through a Turkish parent; facilitated naturalization for people of Turkish origin and their spouses and children.
Ukraine	Law on Citizenship of Ukraine, Article 8: any person with at least one Ukrainian parent.
United Kingdom	Birth abroad confers British citizenship 'by descent' where one parent is a British citizen otherwise than by descent.

Oceania

Country	Basis
Kiribati	Constitution Articles 19 and 23: every person of I-Kiribati descent has a right to citizenship.