Dual Citizenship Laws by Country: Where It Is and Isn't Allowed

One of the most common questions in international mobility planning is deceptively simple: can I hold two passports at once? The answer depends entirely on which countries are involved — and in several cases, on your specific family history, profession, or the method by which you acquired the second citizenship.

This guide provides a broad country-by-country overview of dual citizenship laws as of 2026. It is intended as a general orientation; the rules are complex, exceptions are numerous, and laws change. Professional legal advice in both countries of citizenship is essential before making any decisions.

Why Dual Citizenship Laws Vary So Widely

Countries' attitudes toward dual citizenship reflect their history, national identity, and practical interests. Some states — particularly those with large diaspora populations — actively encourage dual citizenship to maintain ties with emigrants. Others view dual nationality as incompatible with the exclusive loyalty they expect of citizens, or as a security or tax-avoidance concern.

Three broad categories exist:

1. Permissive: The country accepts or tolerates dual citizenship without restriction.
2. Conditionally permissive: Dual citizenship is permitted in some circumstances — for example, by birth or descent — but not when citizenship is acquired voluntarily.
3. Restrictive: The country generally prohibits dual citizenship and may revoke nationality if a second citizenship is acquired.

Permissive Countries (Dual Citizenship Generally Allowed)

Many of the world's major English-speaking and Western European countries permit dual citizenship either explicitly or in practice.

United Kingdom: The UK allows dual and multiple citizenship without restriction. British citizens may acquire foreign citizenship without losing their British nationality. Foreign nationals naturalising as British are not required to renounce previous citizenship, though the country of origin may have its own rules.

Ireland: Ireland permits dual citizenship. Irish citizens acquiring foreign nationality do not lose Irish citizenship. Ireland's citizenship-by-descent programme means many people hold Irish citizenship alongside another nationality by right of birth.

Australia: Australia allows dual citizenship. Australian citizens may hold passports from other countries, and foreign nationals naturalising in Australia are not required to renounce previous citizenship. (Note: some countries, such as India, do require renunciation on Australian naturalisation — the obligation flows from the other country.)

Canada: Canada permits dual and multiple citizenship. There is no renunciation requirement upon Canadian naturalisation, and Canadian citizens may freely hold other nationalities.

United States: The US government does not formally recognise dual citizenship but does not prohibit it in practice. US citizens who acquire a second citizenship do not automatically lose US nationality (unless they specifically intend to relinquish it, a high legal bar). However, US persons abroad face significant ongoing tax compliance obligations under FATCA and FBAR regardless of where they live. Acquiring a second citizenship does not relieve US tax filing obligations.

France: France permits dual citizenship without restriction.

Italy: Italy permits dual citizenship. Italy's Jure Sanguinis citizenship-by-descent rules are among the most expansive in the world, and many Italians abroad hold dual or triple nationality.

Portugal: Portugal permits dual citizenship.

Spain: Spain's position is complex — see conditional section below.

Greece: Greece permits dual citizenship, though Greek law imposes military service obligations on male Greek nationals that may affect practical planning.

Sweden, Denmark, Finland, Belgium: All permit dual citizenship as of 2026. Several of these countries liberalised their rules relatively recently. The Netherlands is a notable exception among its neighbours and remains comparatively restrictive — see the conditional section below.

New Zealand: New Zealand permits dual citizenship.

Israel: Israel permits dual citizenship. The Law of Return provides a path to citizenship for Jews and qualifying family members regardless of current nationality.

Conditionally Permissive Countries

Spain: Spain's approach is nuanced. Spanish nationals who voluntarily acquire certain foreign citizenships are required to renounce Spanish nationality within three years, or lose it. However, Spain has bilateral agreements with many Latin American countries, Andorra, the Philippines, Portugal, Equatorial Guinea, and France, under which dual citizenship is mutually tolerated. Spanish nationals becoming nationals of these treaty countries may retain Spanish nationality. Spain also permits dual citizenship for those who acquire foreign citizenship by birth or descent.

India: India does not permit dual citizenship. Indian nationals who naturalise in a foreign country must surrender their Indian passport. However, India offers Overseas Citizenship of India (OCI) status — a long-term multi-entry visa and certain residency rights — to persons of Indian origin and their spouses, as an alternative. OCI is not citizenship; it does not confer voting rights or the right to hold certain public offices.

China: China does not recognise dual citizenship. Chinese nationals who acquire foreign citizenship automatically lose Chinese citizenship under Chinese law. In practice, enforcement varies, particularly for Hong Kong and overseas Chinese communities, but the legal position is clear. Individuals of Chinese origin considering CBI programmes should take specialist advice on the implications.

Japan: Japan has historically required citizens to choose one nationality by age 22 if they hold dual citizenship by birth. In practice, enforcement has been inconsistent and the subject of ongoing domestic debate. Japan's laws on this point may evolve; verify current rules with legal advisers.

Singapore: Singapore does not generally permit dual citizenship for adults. Citizens who acquire foreign nationality must renounce Singaporean citizenship. Exceptions apply for children with dual citizenship by birth, who must choose by age 21.

Malaysia: Malaysia does not permit dual citizenship for adults. Malaysians who acquire foreign nationality lose Malaysian citizenship.

Indonesia: Indonesia does not generally permit dual citizenship for adults. Limited exceptions apply to children born with dual citizenship, who must elect one nationality by age 21. This is a significant consideration for Indonesians exploring CBI programmes.

Pakistan: Pakistan's position is complex. Dual citizenship is permitted with a specific list of countries with which Pakistan has bilateral agreements. These include the US, UK, Canada, Australia, France, Sweden, Italy, Belgium, Switzerland, Iceland, Jordan, Syria, and Egypt, among others. Citizens acquiring nationalities not on the approved list may face complications.

Restrictive Countries (Dual Citizenship Generally Not Permitted)

Germany: Germany historically did not permit dual citizenship for adults who voluntarily acquired a second nationality. As of 2024, Germany reformed its citizenship law significantly: dual citizenship is now generally permitted. German nationals may acquire foreign citizenship, and foreigners naturalising as German are no longer required to renounce their previous citizenship in most cases. This is a major change from the previous regime; verify current rules.

Austria: Austria has strict rules against dual citizenship. Austrians who voluntarily acquire a foreign citizenship typically lose Austrian nationality. Very limited exceptions apply — including in cases of hardship or where renunciation is not possible. Austria also operates a citizenship-by-exceptional-merit programme for certain high-achieving individuals who may be granted Austrian citizenship without renouncing prior nationality.

Netherlands: The Netherlands remains one of Europe's more restrictive regimes. Foreign nationals naturalising as Dutch are, in most cases, required to renounce their previous nationality, with limited exceptions (for example, those married to a Dutch national, those acquiring Dutch nationality by birth, recognised refugees, and certain other categories). Dutch nationals can also lose Dutch nationality by voluntarily acquiring another in some circumstances. Reform proposals to relax these rules have been debated but, as of 2026, have not been enacted, and the government has indicated it does not currently plan to broaden dual nationality. Verify the current position before acting.

Saudi Arabia, UAE, Kuwait, Qatar, Bahrain, Oman: Gulf Cooperation Council states generally do not permit dual citizenship for their nationals. Some have very limited exceptional citizenship grants (UAE has offered citizenship to certain distinguished individuals), but these do not create a general dual-citizenship regime. Nationals considering foreign CBI or naturalisation programmes must consider the risk of losing GCC citizenship.

Norway: Norway permits dual citizenship from 2020 onwards, following a change in law.

Practical note on enforcement: In many restrictive countries, the practical question is whether the country of origin knows — and whether it cares — when a national acquires foreign citizenship. Some countries have limited mechanisms to detect this. However, relying on non-disclosure is not a sound legal strategy: it may constitute fraud, and passport applications, banking, and tax processes increasingly create cross-border information flows that can surface dual citizenship even years later.

Implications for Investment Migration Planning

Understanding the dual citizenship landscape is foundational to programme selection. Key implications:

• If you are a national of a restrictive country (Saudi Arabia, UAE, Japan, India, Indonesia), acquiring a second citizenship may carry significant consequences including loss of original nationality.
• If you are American, acquiring a second citizenship does not trigger automatic loss of US citizenship — but the ongoing tax compliance burden (FATCA, FBAR, Form 8938) continues regardless.
• If you are German, the 2024 reform has opened significant new possibilities for dual nationality that were previously unavailable.
• If you are Spanish, the bilateral treaty network determines whether retention of Spanish nationality is possible alongside the target citizenship.

In all cases, the analysis must be conducted in both jurisdictions — the country of existing citizenship and the target country. The rules interact, and the consequences of miscalculation (losing a citizenship unintentionally) are serious and sometimes irreversible.

Seek professional legal advice in all relevant jurisdictions before making any citizenship decisions. Laws change, and the above overview reflects the general position as understood in mid-2026; it is not legal advice.

How Global Investments Can Help

Global Investments works with internationally mobile high-net-worth clients on citizenship and residency planning across all major jurisdictions. Our advisory services include:

• Multi-jurisdictional dual citizenship analysis covering your specific nationalities and target programmes
• Coordination with specialist immigration lawyers in relevant countries
• Programme selection advice that takes dual citizenship constraints fully into account
• Ongoing monitoring of legislative changes affecting your citizenship portfolio

Contact our citizenship planning team for a confidential consultation tailored to your personal and family circumstances.