Books in Dialogue: GLOBALCIT Review Symposium on Yossi Harpaz, Citizenship 2.0 and Jelena Džankić, The Global Market for Investor Citizenship


Yossi Harpaz, Tel-Aviv University

For most of the 20th century, citizenship was typically an exclusive and sanctified bond between an individual and a state. Countries prohibited dual nationality and made vigorous attempts to eliminate it (Spiro 1997). In 1990, only a quarter of countries in Europe and the Americas permitted dual citizenship. Over the past three decades, however, this norm has been abandoned, as dozens of countries changed their citizenship laws. As Figure 1 shows, by 2016, over 80 percent of countries in those regions permitted dual citizenship (see also Vink et al. 2019).

This legal shift is the point of departure for Citizenship 2.0: Dual Nationality as a Global Asset. The growing toleration of dual citizenship may appear as a small, technical change. In fact, this shift is creating new realities on the ground, reshaping patterns of international migration, political participation, global security and ethnic and national identity. The book aimed to explore some of these consequences. What happens to the institution of citizenship when the basic rules governing it change, permitting new forms of membership that are flexible, overlapping and non-territorial?

Figure 1: World regions by percentage of countries that permitted dual citizenship at naturalisation in 1990, 2016

Note: The bars show the percentage of countries in each world region that permitted dual citizenship at naturalisation in 1990 (lighter bar) and 2016 (darker bar). The sample includes 72 countries in 1990 and 88 in 2016.

Dual citizenship was traditionally studied in the context of immigration to Western Europe and North America. In Citizenship 2.0, I focused instead on the strategic acquisition of dual citizenship by non-immigrants outside the West. Once we shift the empirical focus, a crucial but overlooked aspect comes into sharp relief: the disparity in the value of the ‘citizenship packages’ that different countries provide, and the tremendous practical usefulness of having a second, higher-tier citizenship. Analysing the rise of dual citizenship through the prism of global inequality highlights a mostly-overlooked consequence of this shift: the creation of new opportunities for citizens of countries outside Western Europe and North America to strategically acquire a second, premium citizenship from highly-developed countries.

This perspective highlights the role of citizenship as a stratifying mechanism in a highly unequal global system (Shachar 2009; Brubaker 2015; Bauböck 2019). Individuals who are born with high-value citizenship – say, Swedish or Canadian – gain access to a formidable package of opportunities, rights and security that is nearly unimaginable to persons born with Somali or Syrian citizenship. Citizens in highly developed countries have per capita incomes that are about five times higher than the global average, while also enjoying extensive political rights and personal safety. Another key dimension of the global citizenship hierarchy consists in travel freedom: the passports of rich, democratic countries provide extensive opportunities for visa-free mobility, while travellers from less developed countries are subjected to onerous visa restrictions. Passports and citizenship from developed Western countries are not just practically useful – they also convey prestige and high status. 

In the book, I constructed a model of global inequality in citizenship value that includes measures of development, democracy, security and travel freedom. The model divides the world’s citizenship into three tiers: a top tier of rich, democratic and secure countries, including Western Europe, North America, Australia, New Zealand, Japan and South Korea; a middle tier composed of Eastern European and Latin American countries, in addition to Israel, Singapore, UAE and others; a third tier composed of most Asian and African nations, including China and India. Figure 2 below presents a map of the world, divided into citizenship tiers.

Figure 2: World map with citizenship tiers

Note: the map shows the world’s countries according to their tier position. The dark-coloured countries are first tier and the light-coloured ones are third tier. Middle-tier countries are coloured in medium grey. No data were available for Somalia, South Sudan, Western Sahara, North Korea and Iceland.

Dual citizenship provides people with an opportunity to improve their position within in this global hierarchy. Increased acceptance of dual citizenship led to the growth of a phenomenon I call compensatory citizenship: individuals from outside the West who obtain a second citizenship from a Western or EU country. The second citizenship is ‘compensatory’ in the sense that it is typically used to complete the primary, resident citizenship rather than replace it. Most individuals who obtain this kind of citizenship do not emigrate: instead, they wish to secure an ‘insurance policy’, a premium passport and improved opportunities that their primary resident citizenship cannot offer them.

The three largest pathways to compensatory citizenship draw on ancestry or ethnicity, or on strategic cross-border birth. Millions of people from middle-tier countries have acquired compensatory citizenship through one of these pathways. For example, about one million Argentineans and Brazilians drew on their Spanish, Italian or Portuguese roots to acquire EU citizenship from abroad. In Eastern Europe, citizens of non-EU countries with ethnic ties to EU member countries draw on these ties to acquire dual citizenship. Hundreds of thousands of Moldovans, Ukrainians, Serbians and North Macedonians have secured citizenship from countries like Hungary, Romania and Bulgaria. Another key strategy is cross-border birth (or ‘birth tourism’), which involves travelling to the United States to give birth, with the aim of providing the newborn babies with automatic birthright citizenship. It is practiced by wealthy families from China, Russia, Mexico, Turkey, Nigeria and other countries. Yet another avenue, which I do not discuss in the book, involves citizenship-by-investment programs, which allow millionaires from developing countries to obtain a second passport in exchange for a hefty sum. That phenomenon stands at the focus of Jelena Džankić’s (2019) The Global Market for Investor Citizenship.

The core of Citizenship 2.0 consists in three case studies that represent the three major pathways to compensatory citizenship, on the basis of ancestry, ethnicity and birth. I studied the case of Serbian citizens who acquire Hungarian (EU) dual citizenship to learn about co-ethnic dual citizenship. A second case consisted of Israelis who applied for ancestry-based dual citizenship from European origin countries, including Germany, Poland and Romania. The third case included middle- and upper-class Mexicans who travelled to the U.S. to give birth there, in order to secure dual nationality for their children. In spite of the geographical, cultural and historical distance between the three countries, I found comparable dynamics in the relation to citizenship. I will briefly present three of these patterns: destigmatization of dual citizenship, commodification of citizenship and interaction with pre-existing structures of inequality. 

First, the cases represent combinations of dual citizenship that would have been highly controversial twenty or thirty years earlier. Until 1998, dual citizenship was legally prohibited in Mexico, and there was a social stigma against emigrants who left for the United States – or, worse, took up American citizenship. In Israel, dual citizenship was always permitted by law. However, for decades after the Holocaust, citizenship from Germany or Poland was considered taboo. Today, Israelis often view EU citizenship as a status symbol and, in an ironic twist, the German passport is especially prestigious. In the Hungarian-Serbian case, Hungary offers citizenship to members of the Hungarian minority in northern Serbia – a move that could appear highly provocative, given the long historical struggle over the region between the two nations. Today, in all three countries, these once-provocative citizenship dyads are legally and socially tolerated. Critical voices do exist, but they remain marginal. In all three cases, dual citizens face little social criticism, even when the partner nation is a historical rival or victimizer.

A second pattern concerns the commodification of citizenship. This expression likely brings to mind the world-spanning, glitzy industry of ‘passports for sale’ that Jelena Džankić (2019) has explored. Commodification also occurs in more modest settings, however. In fact, local, small scale industries emerge wherever dual citizenship becomes available. In the cases that I studied, these industries included professionals who specialized in citizenship-relevant services, such as lawyers, translators, bureaucratic fixers, and language instructors. Those specialists not only made it easier for eligible individuals to apply for citizenship, but also played an important role in propagating a new way of thinking about citizenship as a commodity. For example, lawyers in Israel put up kiosks in malls that promote Portuguese citizenship (Figure 3). The signs on the kiosk list the practical advantages of a ‘European passport,’ as if it were yet another commodity.

Figure 3: Kiosk marketing EU citizenship at a mall in Tel-Aviv, Israel 

Note: the photo, taken in 2018 at a mall in central Tel-Aviv, shows sales representatives working for a law office that specialises in the acquisition of Portuguese citizenship. The sign says: ‘You, too, deserve a European passport’. Photo by author.

Citizenship applicants themselves also tended to discuss citizenship using the language of private property and economic interests. Mexicans described strategic birth as a long-term investment in their children’s future, weighing its costs (not just the delivery itself but also a lifelong obligation to global taxation as U.S. citizens) against the expected benefits. In Israel, respondents often claimed that their citizenship application was a form of property restitution, after their grandparents were stripped of their citizenship unfairly and illegally. Israelis typically referred to German or Polish citizenship as a ‘European passport,’ a terminology that diminishes the full meaning of citizenship as well as the connection to a specific European nation. In Serbia, thousands of ethnic Serbs embarked on studying the Hungarian language – considered one of the most difficult languages in the world – with the aim of securing an EU citizenship and gaining access to lucrative jobs in Germany or Austria. Others acquired their Hungarian passports by way of fraud; such people were careful never to use their Hungarian passports when visiting Hungary, for fear of being caught and stripped of their citizenship. In all those cases, people decouple the status of citizenship from the national identity to which it is supposedly attached. 

Third, I found that compensatory dual citizenship interacted with within-nation inequality in complex ways. Often, the opportunities to benefit from compensatory citizenship accrue to those who are already privileged. In Israel, European-origin Jews were historically the most privileged group, and ancestry-based EU passports offered yet another way to consolidate this advantage (at least until 2015, when Spain and Portugal began offering citizenship to Middle Eastern Jews). In Mexico, strategic birth is mostly available to upper-class families from the north of the country, who can afford to spend thousands of dollars on a backup nationality for their children. In Serbia, the situation is quite different. Hungarian dual citizenship actually elevated the relatively low status of the country’s Hungarian minority and improved their lacklustre material conditions. On the other hand, leaders in Serbia’s Hungarian community complained that with EU passports widely available, young Hungarians would emigrate from Serbia en masse, posing a risk to the community’s continued existence. 

In conclusion, my findings show that when people face an opportunity to acquire a second citizenship, their decisions are guided by their position in the global hierarchy of citizenship value. Individuals act in a strategic manner to secure citizenship that would provide higher levels of rights, opportunities and entitlements – even if it makes them members of a nation with which they do not identify, or which they may even despise. Rather than perceive nationality through the prism of a sacred national identity, seekers of compensatory citizenship see it as an instrumental asset. These results are consistent with findings from other studies of dual citizenship (e.g. Cook-Martin 2013; Pogonyi 2017; Harpaz and Mateos 2019; Altan-Olcay and Balta 2020).

Dual citizens constitute a small minority of the population in most countries, and such attitudes are not necessarily shared by the entire population. However, the fact that such citizenship strategies are now legally permissible and socially legitimate hints at a broader revaluation of values, one that aligns with the trend that Christian Joppke (2019) has called ‘citizenship light’: a weakening of the sacred dimension in state-individual relations, that that leaves greater room for individualistic, instrumental action (see Harpaz and Mateos 2019). The legitimisation and proliferation of dual citizenship contributes to a shift in citizenship, from an ascribed status – an unchanging trait assigned at birth – to an achieved status that is flexible and subject to competitive striving.