What Is Citizenship by Descent?
Understanding jus sanguinis and how you may already be a European citizen
Citizenship by descent, known in Latin as jus sanguinis or "by right of blood," is the legal principle that citizenship can be inherited through family lineage rather than earned through residency or naturalization.
If your parents, grandparents, or more distant ancestors were citizens of a European country, many of those countries recognize your right to claim that citizenship as a birthright, regardless of where you were born, where you live, or how many generations have passed.
For millions of Americans, Canadians, and Australians whose families emigrated from Europe one, two, or three (or more) generations ago, often through Ellis Island and other ports of entry, citizenship by descent is the most direct and often the most overlooked path to a European passport.
Jus Sanguinis vs. Jus Soli: What's the Difference?
Most people are familiar with jus soli, the "right of soil." It is a legal principle that grants citizenship based on where you are born. The United States, Canada, and Australia all apply this principle (as well as many South American countries), which is why children born on American soil are automatically American citizens regardless of their parents' nationality.
Europe largely operates on the opposite principle. Most European countries grant citizenship based on who your parents are, not where you were born. This means that a child born in New York to an Irish citizen is, under Irish law, an Irish citizen from birth, even if they have never set foot in Ireland and have no intention of moving there. It also means that a child born to American parents in Italy is not automatically an Italian citizen, unless some other legal condition needs to be triggered to avoid that child from being stateless.
In a sense, jus sanguinis allows a citizenship to travel. If your great-grandmother was a Polish citizen and that citizenship passed through your grandmother and your mother to you, Polish law may consider you a Polish citizen today. You simply don't have a document proving it yet.
Which Countries Offer Citizenship by Descent?
Every European country structures its citizenship laws differently, and the rules governing who qualifies, how far back the line can extend, and what disqualifiers exist vary enormously from program to program. The countries we work with include:
Some programs, like Germany, Hungary, Luxembourg, Italy (until recently), and Poland, have no generational ceiling in theory, meaning citizenship can travel through great-grandparents and beyond if the chain holds at every link. Others like Ireland and Portugal will technically allow citizenship to pass on forever, as long as each generation seeks recognition before having children. Others, like Slovakia, set a specific generational limit of parent, grandparent, or great-grandparent.
The rules can also change over time. Italy significantly restricted its citizenship by descent program in 2025, limiting new applications to those with an Italian parent or grandparent. Germany expanded access in 2021 for descendants of those persecuted by the Nazi regime. Slovakia opened its program entirely in 2022. In 2025, Canada retroactively allowed citizenship by descent to be claimed through an unlimited number of generations (yes, we do Canada too, even though it's not European!). Staying current with these changes, and understanding how they affect your specific case, is a significant part of what we do.
What Are the Benefits of European Citizenship by Descent?
A European passport is one of the most valuable travel documents in the world, offering unparalleled freedom and opportunities.
Visa-Free Travel
Access to over 185 countries without visa requirements or with visa-on-arrival privileges. Learn more about our services.
Live & Work Anywhere in EU
The right to live, work, and study anywhere in the European Union without permits or visas.
Education & Healthcare
Access to European healthcare systems, education institutions, and social services.
Family Heritage
Pass citizenship to your children and future generations, creating lasting legacy value.
Global Opportunities
Enhanced career prospects, business opportunities, and retirement options across Europe.
Cultural Connection
Formal recognition of your family's heritage and a meaningful connection to your roots.
Frequently Asked Questions
How Roots Recovered Can Help
We are a boutique European citizenship by descent consultancy with deep expertise across every major European CBD program. Unlike single-country specialists, we work across the full landscape, which means we can assess your ancestry holistically, identify every program you may qualify for, and tell you which path is strongest for your specific family history.
We handle the heavy lifting: lineage research, vital records procurement, document translation, application assembly, and coordination with in-country counsel where required. What we bring is not just process knowledge. It is the kind of case-specific legal and genealogical expertise that turns a complicated family history into a successful application.
If you have European ancestry and have ever wondered whether a passport might be waiting for you, the answer is worth finding out.