The contested nature of de facto states and their acceptance of dual citizenship results in the overlap of multiple citizenship regimes, leading to individuals living in de facto states possessing multiple citizenship statuses. Using the Most Similar Systems Design, this article explores the factors that influence the (divergent) citizenship regimes of Abkhazia and Transnistria; the former allows dual citizenship only with Russia, while the latter places no restrictions. The primary reason for the adoption of dual citizenship is for pragmatic reasons, as the secondary citizenship can compensate for the lack of benefits (such as international travel, diplomatic protection) afforded by the de facto state’s citizenship. This said, having an ethnicised national identity, in contrast to a civic (state-centred) national identity, can produce (dual) citizenship laws that give preferential treatment to the titular group and its diaspora. Additionally, the influence exerted by the patron state (Russia) and the severity of the conflict with the parent state (Georgia/Moldova) influences dual citizenship in becoming conditional and thus more exclusive.

Ramesh Ganohariti, Dual Citizenship in De Facto States: Comparative Case Study of Abkhazia and Transnistria, Nationalities Papers, 2019.