EU citizenship by descent lets Americans with European ancestry claim nationality in an EU member state based on a parent’s, grandparent’s, or in some countries a more distant ancestor’s citizenship. Most European countries follow jus sanguinis — the “right of blood” — meaning nationality passes down the family line rather than being granted by place of birth. Citizenship in any single member state gives you the right to live, work, study, and travel across all 27 EU countries without a visa or work permit.1European Union. Living in the European Union The catch is that every country writes its own rules, and a change to Italian law in 2025 has closed what was long the most popular path for Americans.
How the Right of Blood Actually Works
Unlike the U.S., which grants citizenship to almost anyone born on its soil, most European nations tie nationality to parentage. If your ancestor was a citizen when the next person in the line was born, that citizenship may have passed down, generation by generation, all the way to you. The question a consulate will ask is whether the chain stayed unbroken — whether every person in that line was still a citizen at the moment their child was born.
Countries draw the line in very different places. Ireland cuts off at grandchildren unless a parent already registered. Italy and Greece historically imposed no generational limit at all. Hungary treats descendants of pre-1929 emigrants as needing simplified naturalization with a language test, not automatic recognition. Two Americans with equally deep European roots can face completely different processes depending on which country their ancestor left.
Country-by-Country Rules
A handful of countries generate almost all descent claims from Americans. The rules below reflect the law as of 2026.
Italy
Italy was the most popular destination for American descent claims because its jus sanguinis tradition set no generational cutoff. That changed in early 2025. A new provision, Article 3-bis of Law 91/1992, states that a person born abroad who holds another citizenship is considered never to have automatically acquired Italian citizenship.2Consolato Generale d’Italia Chicago. Citizenship Jure Sanguinis / by Descent
Three exceptions survive. Applicants who submitted their claim to an Italian consulate — or received a confirmed appointment — by March 27, 2025 are still processed under the old rules. The restriction also doesn’t apply if your parent or grandparent held only Italian citizenship at the time of death. And it doesn’t apply if your Italian-citizen parent lived in Italy for at least two consecutive years before your birth.2Consolato Generale d’Italia Chicago. Citizenship Jure Sanguinis / by Descent If none of the three fits, the traditional administrative path is effectively closed for you.
A separate issue affects the maternal line. Italian women who married foreign citizens before January 1, 1948 automatically lost Italian citizenship, so their descendants cannot claim through the standard administrative process.3Consolato Generale d’Italia Londra. Citizenship Iure Sanguinis – Previous Regulatory Framework Italian courts have ruled that this discrimination violated the 1948 Constitution, and descendants can pursue “1948 cases” through a lawsuit in the Civil Court of Rome. Those cases require an Italian attorney and tend to succeed, but nothing is guaranteed.
Ireland
If a grandparent was born on the island of Ireland, you can become an Irish citizen through the Foreign Births Register. The process requires official documents spanning three generations, and current processing runs about 12 months once the file is complete.4Department of Foreign Affairs and Trade. Citizenship Incomplete submissions slow the whole queue.
Ireland’s generational limit is firm. If your connection runs through a great-grandparent, you cannot claim directly. The workaround is sequential: your parent has to register on the Foreign Births Register before your birth, which then makes you eligible as the next generation. If your parent never registered in time, the chain stops.
Germany
German citizenship passes automatically from parent to child under Section 4 of the Nationality Act. For children born abroad after December 31, 1999, automatic transmission does not occur if the German parent was also born abroad and lives outside Germany, unless the birth is registered with a German consulate within one year.5German Federal Ministry of Justice. Nationality Act Miss that window and the child does not acquire German citizenship, breaking the chain for every generation that follows.
Germany also runs a restitution program for descendants of victims of Nazi persecution. Under Section 15 of the Nationality Act, anyone who lost or was denied German citizenship between January 30, 1933 and May 8, 1945 for political, racial, or religious reasons, along with all their descendants, has a right to naturalization on application.5German Federal Ministry of Justice. Nationality Act A 2021 law expanded coverage to additional categories of persecution-related loss, including people excluded from citizenship through marriage or collective naturalization.6German Missions in the United Kingdom. Naturalisation of Victims of Nazi Persecution and Their Descendants
Poland
Polish law follows continuous descent with no generational limit. If your ancestor was a Polish citizen and never formally lost that status, you may be confirming existing Polish nationality rather than applying for something new. The process runs through Polish consulates and requires documents establishing your ancestor’s Polish origin, such as birth certificates, marriage records, or copies of Polish identity documents.7Republic of Poland. Confirming Polish Citizenship or Its Loss
Proving your ancestor didn’t lose Polish citizenship is the hard part. Poland’s citizenship laws shifted repeatedly through the 20th century, and wartime border changes mean some people who considered themselves Polish were legally citizens of somewhere else when they emigrated. Detailed research into the laws that governed your ancestor’s specific territory and time is usually necessary.
Hungary
Hungarian law follows jus sanguinis with no generational limit. But for most Americans there’s a practical catch: if your Hungarian ancestor emigrated before September 1, 1929, their descendants likely were not born as Hungarian citizens. You’d need simplified naturalization instead, which requires conversational Hungarian.8Embassy of Hungary Washington. About Hungarian Citizenship
Hungary also has a gender-based historical quirk. Before October 1, 1957, a child born to a Hungarian mother and a non-Hungarian father did not become Hungarian at birth. That child can now become a citizen by declaration, but the descendants have to go through simplified naturalization with the language requirement.
Greece
Greek law treats citizenship as an inherent right of anyone born to a Greek citizen parent. Consulates don’t grant citizenship so much as help you exercise a right you already hold.9Hellenic Republic Ministry of Foreign Affairs. Greek Citizenship The process centers on registration in the municipal records of the relevant Greek municipality. Both your parents’ marriage and your birth must be registered, and you’ll receive a Certificate of Registration as proof. Greece imposes no generational limit, which makes it one of the more accessible paths.
Austria
Austria’s ordinary descent rules are restrictive, but a 2019 law created a special path for descendants of Nazi persecution victims. Under Section 58c of the Austrian Citizenship Act, anyone whose ancestor was an Austrian citizen and fled persecution, or was deported or killed, before May 15, 1955 can acquire Austrian citizenship by declaration, without giving up their current nationality.10Austrian Federal Ministry for European and International Affairs. Citizenship for Persecuted Persons and Their Direct Descendants A 2022 expansion added categories including people who kept their main residence outside Austria between 1933 and 1945 because they would have faced persecution had they returned.
What You Actually Get
Citizenship in any one EU member state makes you an EU citizen, and that status carries rights across all 27 countries. The biggest is free movement: you can live, work, or start a business anywhere in the bloc without a work permit or residence visa.11European Union. Travelling in the EU Take a job in France, retire in Portugal, enroll in a Dutch university, none of it requires the immigration paperwork a non-EU citizen faces.
Healthcare travels with you through the European Health Insurance Card, which entitles you to the same public healthcare as locally insured residents during temporary stays in any other EU country.12European Commission. Health Cover for Temporary Stays in Another EU Country It covers medically necessary treatment, not planned procedures or private care. If you register as a resident of another member state, you become eligible for that country’s national health system on the same terms as its own citizens.
EU citizens also pay domestic tuition at public universities across the bloc, which in many countries means free or nearly free higher education. Voting rights in European Parliament elections and in local municipal elections where you live come with the package.
What Usually Breaks the Chain
The most common dealbreaker is an ancestor who naturalized as a citizen of another country before the next person in the line was born. Under the historical laws of most European nations, taking an oath of allegiance to a new country triggered automatic loss of the original nationality. If your Italian great-grandfather became a U.S. citizen in 1910 and your grandfather was born in 1915, the chain broke: your grandfather was never Italian, and neither is anyone after him.
The exact naturalization date is what matters, not the arrival date. Census records can hint at status because census forms asked about citizenship, and USCIS holds historical naturalization records that can confirm or rule out a naturalization event. You can request a Certificate of Non-Existence from USCIS using Form G-1566 to document that no naturalization record was found, which many European consulates require as part of the file.13U.S. Citizenship and Immigration Services. G-1566, Request for Certificate of Non-Existence
Gender-based restrictions create another category of broken chains. Italian women who married foreigners before 1948 lost citizenship. Hungarian women before 1957 couldn’t transmit to children fathered by non-Hungarians. Most of these bars have been addressed by legislation or court rulings, but resolving them usually means a special petition rather than a routine application.
Border changes after both world wars complicate things. An ancestor who left a region of the Austro-Hungarian Empire that later became part of Czechoslovakia, Yugoslavia, or Romania may not qualify under the country you’d expect. The question isn’t cultural identity but which nation’s law governed the territory when the ancestor left and when descendants were born.
Failure to register is a subtler barrier. Germany requires births of German citizens abroad after 1999 to be registered within one year or citizenship doesn’t transfer.5German Federal Ministry of Justice. Nationality Act Some countries historically required a declaration of intent to retain citizenship at the age of majority. Skipped steps like these are the kind of break that surfaces only during careful research.
Documents You’ll Need
Every descent claim requires an unbroken paper trail from your ancestor to you. At minimum, that means long-form birth certificates, marriage certificates, and death certificates for every person in the chain. They have to be official certified copies from government registries, not hospital records, church baptismal certificates, or photocopies. The documents need to show parents’ names, because that’s what establishes the biological link from one generation to the next.
Most European countries also require these documents to carry an Apostille, an international authentication certificate issued under the Hague Convention of 1961.14HCCH. Apostille Section In the U.S., apostilles come from the Secretary of State in the state that issued the document. Fees typically run from a few dollars up to around $25 per document, with processing times that vary by state.
Because U.S. records are in English, nearly every European consulate requires certified translations. Commercial translation services charge roughly $30 to $50 per page for certified legal translations, with notarization as an add-on. Multiplied across a dozen or more documents over multiple generations, the cost climbs quickly.
On the European side, you’ll often need records from the ancestor’s town of origin: birth records, baptismal records, or municipal registrations. Many still sit in physical ledgers in local town halls or parish offices. When a record can’t be found, secondary evidence like military service documents, old passports, or ship manifests may be accepted.
Beyond lineage documents, most consulates want a valid U.S. passport, proof of current address, and an FBI Identity History Summary — the background check. That involves fingerprints and a fee, and the result usually needs to be apostilled and translated like everything else.15U.S. Department of State. Criminal Records Checks
Name discrepancies are one of the most common causes of delays. An ancestor whose name was anglicized on arrival, a grandmother whose maiden name was recorded differently on her marriage certificate than her birth record, clerical errors in century-old handwritten ledgers, any of these can require legal amendments or sworn affidavits before a consulate will accept the file.
How the Application Runs
Once your documents are assembled, authenticated, and translated, you file either at the consulate covering your U.S. residence or, in some cases, directly with a government office in the ancestral country. Consulate appointments for popular countries like Italy have historically involved waits well beyond a year, and some consulates have suspended new additions to their waiting lists entirely.16Consolato Generale d’Italia New York. How to Apply for Citizenship by Descent (Iure Sanguinis) Ireland currently quotes about 12 months for a complete application.4Department of Foreign Affairs and Trade. Citizenship
At the appointment, a consular officer reviews your originals against the application and collects an administrative fee that varies by country, typically running from a couple hundred dollars to several hundred per adult. The consulate then cross-checks your records against national databases and archives. If anything doesn’t line up with what the home country has on file, the application stalls until the discrepancy is fixed.
Processing after submission runs from several months to several years depending on the country and how complex the claim is. During that time you may be asked for supplemental documents or clarifications. Approval usually arrives by registered mail or through a digital portal, along with a certificate of citizenship or naturalization. Getting the actual passport is normally a separate application and fee once citizenship is confirmed, and some countries also require an oath of allegiance.
What Happens to Your U.S. Status and Taxes
Acquiring EU citizenship through descent does not put your U.S. citizenship at risk. U.S. law does not require you to choose, and naturalizing in a foreign country does not itself trigger loss of American citizenship.17U.S. Department of State. Dual Nationality Loss requires performing a specific expatriating act with documented intent to relinquish.
Security clearances are different. Dual citizenship isn’t an automatic disqualifier for a U.S. clearance, but adjudicators look closely at how you exercise the foreign citizenship. Using a foreign passport when a U.S. one is available, accepting foreign government benefits, voting in foreign elections, or performing military service abroad can all raise concerns under the guidelines governing foreign preference and foreign influence. If you work in national security, defense, or intelligence, or plan to, talk to a clearance attorney before applying. Some EU countries also maintain military or civil defense obligations for citizens of certain ages; enforcement against foreign-resident citizens is uncommon, but it’s worth checking whether exemptions exist for dual nationals living abroad.
Taxes are where new dual citizens most often get blindsided. The United States taxes its citizens on worldwide income regardless of where they live. If you obtain EU citizenship and move abroad, you still owe annual U.S. returns reporting your global earnings.18Internal Revenue Service. U.S. Citizens and Residents Abroad Filing Requirements The U.S. is nearly alone in the world in this, and failing to comply carries real penalties even when you’d owe no actual tax after credits and exclusions.
Two reporting rules catch the most people. If your combined foreign bank account balances top $10,000 at any point during the year, you have to file a Report of Foreign Bank and Financial Accounts (FBAR) with FinCEN.19FinCEN. Report Foreign Bank and Financial Accounts Penalties for missing an FBAR start at $10,000 per violation even when the failure was unintentional. Separately, holdings above certain thresholds trigger Form 8938 with your tax return under FATCA, with higher thresholds for taxpayers living abroad.20Internal Revenue Service. Do I Need to File Form 8938, Statement of Specified Foreign Financial Assets
Tax treaties between the U.S. and most EU member states help reduce double taxation, generally by letting you credit tax paid to one country against tax owed to the other. A saving clause in most treaties preserves the U.S. right to tax its own citizens, though, so the treaties don’t eliminate your filing obligation; they just keep you from being taxed twice on the same income.21Internal Revenue Service. United States Income Tax Treaties