1In this article I explore Brexit as a moment of redefinition of national and EU citizenship, including citizenship by descent. I focus on the cases of British citizens in the UK and Belgium who have explored obtaining the Irish or the Italian citizenship, as well as on the tactics to ensure citizenship by descent to their children enacted by other British interviewees, and by EU27 citizens in the UK (that is, citizens of the EU member states that remained after the exit of the UK). I show that the decisions to pursue naturalisation are relational — i.e. influenced by others, and in some cases done to benefit others, in particular one’s children — but not necessarily collective, as in some cases there are disagreements among the family members involved, as well as disinterest from some of the beneficiaries. In relation to previous literature on the pursuit of descent-based citizenship, which often focused on static analyses of global inequality, I further discuss how the Brexit context shows that such pursuit is temporally contextual (Sredanovic, 2022). More generally, the reasons for naturalisation in the Brexit context include pragmatism, both individual and family-focused, as well as identity-based reasons, with the latter more based on relations with parents and others than on national identification.
2The literature on naturalisation decisions and on the uses of citizenship has been characterised by dichotomies between identification and instrumentality, as well as between individualism and family-based decisions. The traditional, prevalently quantitative, literature on naturalisation has worked on the assumption that naturalisation follows linearly a process of individual integration/assimilation that ends with permanence on the territory, identification with the new country of citizenship and acquisition of its cultural and political norms and skills (for a critical analysis, see Bloemraad, 2004). A number of studies have insisted on how the process of obtaining a citizenship can be instrumental and oriented to maximising mobility opportunities rather than permanence in the country (e.g. Ong, 1993; Harpaz and Mateos, 2019). Such an approach avoids adhering to the normative identification of the interests of the applicants for naturalisation with the interests of the State, but remains mostly within methodological individualism, and ends even reinforcing the rationalist approach, by referring to the maximisation of individual mobility capital. Other literature has insisted on the central role of family in guiding the decisions of naturalisation, including shared decision-making and naturalisations that prioritise the transmission of the citizenship to relatives, especially children (e.g. Street, 2014; Labussière and Vink, 2020; Soehl et al., 2020; Godin and Sigona, 2022). While this corrects the shortcomings of methodological individualism, the risk is the implicit continuation of a rationalist approach, in which family units, however defined, seem to simply take the place of the individual, either as unanimous rational units of decision-making, or at least as units that benefit from the decision, and that always agree on the preferences in relation to citizenship.
- 1 “Strategic” theories of citizenship acquisition (e.g. Ong, 1993; Harpaz and Mateos, 2019) argue tha (...)
3The solution that I propose is to consider naturalisation processes, especially when based on descent, as relational, i.e. located in and linked to different forms of family relations, but not necessarily collective or even collaborative. This means acknowledging how the decisions to naturalise are taken in contact with other relatives, and in some cases prioritising the interests of relatives (especially one’s children). At the same time, it means acknowledging that other relatives might be uninterested, or even refuse to collaborate to the naturalisation procedure. A relational approach can further incorporate previous findings on conflicts within families on citizenship acquisition decisions (Lamarche, 2019), on the relative weakness of instrumental attitudes (Finotelli et al., 2018), on how naturalisation is used both to move and to settle (Della Puppa and Sredanovic, 2017), and especially on the tactical, rather than strategic, nature of naturalisation (Sredanovic, 2022).1 While formal citizenship has several uses (e.g. Sredanovic, 2014; Della Puppa and Sredanovic, 2017; Sredanovic and Della Puppa, 2021), “instrumental” attitudes to naturalisation go against the prevalent attitude among States, to expect most candidates (the main exception being some wealthy investors — Džankić, 2019) to have a specific kind of engagement towards the country of naturalisation. The issue of “instrumental” citizenship has been used by political actors to restrict access for citizenship. In residence-based naturalisation, it has been one of the reasons for the introduction of integration requirements (e.g. Goodman, 2010; Rea et al., 2018; Pélabay et al., 2020). The idea of birth tourism has further been used by anti-immigration political forces to push back against the introduction of elements of ius soli, to question ius soli where it exists (such as in Canada — Harder, 2020), and has been behind at least one restriction of ius soli norms, in the Republic of Ireland (Ní Mhurchú, 2011).
4In this article I consider the Brexit process as a moment that has increased the attention towards national citizenships among groups — British citizens in the EU and UK and EU27 citizens in the UK — who, before Brexit, had a more limited interest in obtaining further national citizenships, as they relied on their EU citizenship. I will discuss how some of the British citizens I interviewed in the UK and Belgium have explored Irish and Italian citizenship by descent. I will further discuss how a larger group of interviewees has taken measures to have their children access different citizenships by descent, including British and EU member state citizenships, but also other citizenships such as the US one. In the analysis, I show how defensive citizenship measures co-exist with more identity-based reasons. A relational dimension can be found in several cases, both because the defensive approach is often focused on the applicants’ children rather than on the applicants themselves, and because the identity-based reasons can include an identification with different countries, but also a perception of citizenship as reaffirming family links. As mentioned, such relational dimension does not necessarily imply however a collective decision process, as I will also show cases in which the supposed beneficiaries show no interest in such procedures and more generally cases of disagreements between relatives.
5The Brexit process started with the Referendum on UK membership in the European Union in 2016, continued with prolonged negotiations, saw the UK officially leaving the EU in 2020, and the end of the transition period, during which a number of previous EU/UK norms had continued to apply, in 2021. Brexit represents a major re-nationalisation of migration and citizenship laws, as British citizens have lost their EU citizenship rights and EU norms have mostly stopped to apply in the UK, limiting the rights of EU27 citizens in the UK. The actual loss of rights has been compounded by the uncertainties that have characterised the negotiation process and that in part still continue. Moreover, beyond the loss of formal rights, the Brexit process has created preoccupations around the future of the British economy and about the rise of xenophobia in the UK (e.g. Guma and Jones, 2019; Rzepnikowska, 2019; Benson, 2020; Sredanovic, 2021). As a result, Brexit has been a strong stimulus for defensive naturalisations, that is, naturalisations that are enacted in response to a loss or potential loss of rights, in order to safeguard such rights (Coutin, 2003; Gilbertson and Singer, 2003); Godin and Sigona (2022) have distinguished between defensive approaches, oriented to safeguarding formal rights, and protective approaches, oriented to limiting discrimination. Previous research has shown the increase in the intention to naturalise (but also to migrate further) both among EU27 citizens in the UK and British citizens in the EU27 (Lulle et al., 2019; Moreh et al., 2020; Sredanovic, 2021 and 2022). Such intentions are stratified according to class, migratory background, age, length of enjoyment of EU freedom of movement, and family networks (Lulle et al., 2019; Sredanovic and Della Puppa, 2021), and the decisions on naturalisation are taken not only in answer to a specific evolution, but also without the possibility to anticipate the full evolution of Brexit and of the value of national citizenship (Sredanovic, 2022). Godin and Sigona (2022), in particular, have promoted a “household level” approach to the study of naturalisations in the UK in the context of Brexit, observing how many of the decisions prioritise the defence of the status of the applicants’ children (cf. also Sredanovic, 2022), and at the same time the presence of significant obstacles to such tactics, particularly considering the high fees of the British citizenship application. Beyond their study, however, the existing literature on Brexit and citizenship has considered in a limited fashion the specificities of citizenship by descent, and the interplay of pragmatic and relational reasons involved.
6The advantage of EU citizenship, when compared to each of the national citizenships from which it derives, is strongly linked to the EU freedom of movement. Such “EU bonus” has been identified already not only in the literature on descent-based citizenship (e.g. Lamarche, 2019; Blanchard, 2020; Jedlicki et al., 2020), but also, for example, in the literature on investment-based citizenship (Džankić, 2019; Surak, 2021). The Brexit context shows how this “EU bonus” does not only apply to citizens of third countries for whom becoming EU citizenship is an improvement to their condition, but also to British citizens who were losing EU citizenship, and for whom naturalisation meant safeguarding (some of) the existing rights. Further, compared to previous research on “strategic” citizenship, focusing on the Brexit context shows the value that EU citizenship acquires in dynamic and uncertain conditions (Sredanovic, 2022).
7The article is based on an ongoing research project started in 2018, on the impact of Brexit on the value and uses of national and EU formal citizenships. I have conducted in-depth qualitative interviews, in some cases face-to-face, in others by phone or voice-over-IP (increasingly since the start of the COVID-19 pandemic). The interviewees have included EU27 citizens in the UK, British citizens in Belgium, and British citizens in the UK who have explored obtaining other citizenships as a result of Brexit. The interviewees were contacted mostly through Facebook and Twitter, with some additional contacts through a snowball procedure, and were living in different areas of Great Britain and Belgium, with a larger representation of the Brussels region and of Greater Manchester. In the UK, I have conducted mostly interviews in England and Scotland; one EU27 interviewee, not included in this analysis, was living in Wales, while I have not conducted interviews in Northern Ireland. As my interviewees who have explored obtaining an Irish passport were not living nor born in Northern Ireland, this means that their relation to the Irish citizenship was potentially different from those living in Northern Ireland, where the issue of applying for an Irish passport is also linked to one’s position in the Nationalist/Unionist divide (see below). Of the larger group of sixty-three interviewees, I focus here on eight British citizens (three in Belgium and five in the UK) who have explored Irish and Italian citizenship, and twenty-one other interviewees (ten EU27 citizens in the UK, two British citizens in the UK, and nine British citizens in Belgium) who have not explored obtaining an EU27 citizenship by descent themselves, but have discussed tactics for ensuring their children’s access to different citizenships. These topics have emerged in the interviews in response to an interview guide that included questions about plans and experiences of citizenship acquisition, but included other topics such as the memory of the Referendum, the different impacts of Brexit, the mobility plans of the interviewees and of their relatives, and the relation to the UK and the EU during the Brexit process. The overall group of interviewees is balanced in terms of gender, but skewed towards the middle class, particularly for the British citizens. The EU27 interviewees in the UK are on the average younger than the British, especially than the Britons interviewed in Belgium, and, while most British interviewees had children, a majority of the EU27 interviewees did not. Among the EU27 citizens considered in this article, the nationalities include Germany, Italy, the Netherlands, Poland, Spain and a dual citizen of Croatia and Chile. All the names used in the article are pseudonyms.
8The opportunities to acquire an EU-member state citizenship through family links are dependent on specific configurations of the citizenship laws. In the case of citizenship by marriage, which many of my British interviewees with an EU27 partner considered, the central issue was the possibility of obtaining the citizenship without taking residence in the country of naturalisation (Sredanovic, 2022). In the case of citizenship by descent, the issue was the degree to which the citizenship could be passed down. Among my British interviewees, two EU27 citizenships were pursuable.
9Those of Irish descent could rely on legislation that allows Irish citizens born on the island of Ireland to pass down citizenship even without registering their children with the consular authorities at birth. Such approach can be understood within the context in which the Republic of Ireland maintains a claim over the population of Northern Ireland and of the Irish diaspora, maintaining extensive measures of citizenship attribution (Daly, 2001; Ní Mhurchú, 2011), despite some limitations to ius soli introduced in 2004 (Ní Mhurchú, 2011). Some of my interviewees indeed discovered only when contacting the Irish consulates after Brexit that they had been considered Irish since birth and could apply directly for a passport. This was the case of both the interviewees residing in Belgium, Nilay and Sarah, who told me of the surprise they felt when they contacted the consular authorities to naturalise and discovered they were already Irish.
10Most of those of Italian descent could also rely on a law that is generous towards descendants of Italian citizens, and has been reformed several times since 1992 to include a larger part of what the Italian governments have defined as “Italians abroad” (e.g. Pastore, 1994; Tintori, 2009; Sredanovic, 2017; Blanchard, 2020). Such category includes those with at least one Italian grandparent, but also a number of smaller groups who do not have a direct ancestor who held Italian citizenship, but are assimilated to the Italian diaspora as effect of their origin in territories that have become or been temporarily part of Italy during the 20th century (Sredanovic, 2017).
- 2 From a more practical point of view, my interviewees who applied for Irish citizenship had an easie (...)
11Compared to countries that limit the transmission of citizenship abroad, or that introduce further requirements, those of Irish and Italian descent have a facilitated access to citizenship. Beyond proving descent and the place of birth/citizenship of the qualifying relative, there are no other requirements, and, as mentioned, individuals of Irish citizenship can often directly apply for a passport.2 However, one of my interviewees residing in the UK, Clara, despite having an Italian mother, could not rely on citizenship by descent as her mother had lost her citizenship on marrying Clara’s British father:
“I’m not eligible to apply for Italian citizenship, unless I go to live there or marry an Italian, because when my mother married my British father in 1956, she renounced her citizenship. And now the chain is broken. I have checked with lawyers, and so on. So, I’m not eligible to do that, which saddens me enormously, because I still have a lot of family in Italy.” (Clara)
12According to the legislation in force at the time, Italian women were supposed to lose citizenship on marrying a non-citizen, the main aim being a single citizenship for the whole nuclear family. The norm has been repealed in 1975 and, more generally, gender asymmetries have been removed from the citizenship laws of most of Europe, but not all countries have introduced measures to remedy retrospectively to the loss of citizenship (cf. Knop, 2001; Sainsbury, 2018).
13As mentioned, the existing literature on family-based naturalisation has highlighted the role of family links, and in particular parent/child relations, in defining the decision to naturalise. The interviews I have conducted suggest the need to look at other links, including non-family relations and sibling/sibling relations, as well as the need to redefine the decision process as relational, that is, based on different relations with relatives and others that motivate, accelerate and help and/or hinder the process of citizenship acquisition, rather than necessarily collective.
14Two of the interviewees residing in the UK who have obtained an Irish passport have mentioned how the opportunity to have an Irish passport was encountered on social media and in media more in general.
“I wasn’t aware [I was an Irish citizen], there were a lot of discussions on Facebook from friends… you know, as soon as you got flagged up, if you are of Irish descent you can apply for an Irish passport. […] It was kind like everybody started… there was a kind of little groundswell of people going ‘oh, you’ve got an Irish name, you can apply for your passport.’” (Séamus)
“Years and years, even before the Referendum was put on the table, I thought about getting an Irish citizenship, because my mum has an Irish citizenship and a British citizenship. So, I knew that I was automatically an Irish citizen anyway, because of my mum, but I didn’t have my passport to prove it. And then, I suppose, when the Referendum happened… And I didn’t get it straight after, it was probably about a year after that I started thinking ‘OK’. Because there was all this talk in the media as well about ‘everybody is gonna be applying for their Irish citizenship’, you know, ‘you need to do it now, because they’re gonna be burdened with lots of applications.’” (Carys)
15Access to Irish passports in particular was a topic that made the news in the UK. The combination of a large population of Irish descent in the UK (not to mention the population born in Northern Ireland, which qualifies in most cases for the passport of the Republic of Ireland) and of the facilitated access to the passport, increased the awareness of the possibility. In this sense the uptake of Irish passports in response to Brexit was similar to the collective mobilisation dimension of the defensive naturalisations in the US in answer to laws limiting migrants’ rights, such as the restrictive 1996 welfare reform (Coutin, 2003; Gilbertson and Singer, 2003). However, while some waves of defensive naturalisations in the US were partly linked to initiatives of the US government, which promoted expedite procedures such as mass citizenship ceremonies (Coutin, 2003), in the case of the access to Irish passports in the UK this was rather driven by the awareness of a pre-existing structure of opportunities. The Irish diaspora in the UK, in particular, is served by a significant network of institutions funded by the Irish government, which had an involvement in facilitating the access to Irish passports. However, I have not encountered cases that suggest a determinant role of such institutions driving up the number of applications, as on the other hand has been shown for naturalisations in the US (Coutin, 2003) and more so in Canada (Bloemraad, 2006).
16Both Séamus and another interviewee living in the UK, Vanessa, also mentioned how the possibility of obtaining an Irish passport was discussed among their group of siblings, adding a further relational dimension to the decision to apply for a passport:
“Brexit was the litmus paper. Because, just on principle, being able to travel… I’ve got three brothers and three sisters and, you know, they’d be asking about getting Irish passports, my older sister has now done the application for the Irish passport, and she’s got hers too. We were kinda of all talking about it, but nobody was doing anything about it. So I thought “Well, I’ll ask something about it”. So, on the basis of needing it, I just kinda started a process.” (Séamus)
“There’s a couple of logistics… because we’ve got one set of documents and I’ve got three siblings, and we know that we need to get it all coordinated, and we’ve been trying to set up… rather than having to send the documents three times we kind of want to get a visit sorted out.” (Vanessa)
17This discussion among siblings and, in Vanessa’s case, the coordination of the application, shows indeed how citizenship decisions can go well beyond the individual dimension. A similar sibling dimension has been identified in Israel by Lamarche (2019). In that case, it was driven by the possibility to share part of the costs linked to recurring to a lawyer helping with the procedures for citizenship by descent. Further, Vanessa mentioned the “fragile” birth certificate emitted in the 1940s to her father, through which she and her siblings qualified for an Irish passport. The fragility of this document seemed one of the reasons why they were trying to apply collectively, to avoid endangering the document by including it in several applications, a situation that gave a material dimension to the citizenship “inheritance” of their late father. However, Vanessa’s case was rather exceptional in the degree of collaboration between the siblings; Séamus on the other hand explained how, after the initial stimulus given by his initiative, he was not aware of how much the other siblings had advanced in the application for an Irish passport.
18Naturalisation was further relational in the need for other people to get involved in the application. Even with a citizenship policy with limited requirements such as the Irish one, some interviewees had to look for the documentation establishing their parent’s birth and filiation. This was obviously easier with a living parent, but required more effort for the interviewees whose parent had passed away, including Sarah and Séamus, with the latter using the services of an ancestry website to obtain the necessary certificates pertaining to his Irish father.
19Another interviewee, Linda, was also being helped, in this case by a family friend, in obtaining the necessary documentation. Born in the UK from an Italian father, she had however no collaboration on her father’s part:
“I’m estranged from my dad, so we are at a stage where a family friend in […] has now got the documentation for me and a delega, a letter allowing him to approach the comune [municipality]. So he’s gonna get my dad’s birth certificate, once I’ve got that, then it’s worth making the overtures for an appointment to the Consulate.” (Linda)
- 3 A partial exception is Lamarche’s work on Israel (2019). In that case, procedures to obtain citizen (...)
20Linda’s case is one of the examples of why the relational nature of naturalisation does not automatically mean a collective process, as some of those involved might not collaborate at all. Lack of collaboration from relatives has been recognised as an issue in the literature on family-based migration (e.g. Kim et al., 2017), but has not received a comparable attention in the literature on descent-based citizenship.3 In Linda’s case, however, the obstacle seemed relatively easy to bypass, both because documentation, rather than her father’s involvement, was enough, and because she had other people in Italy to rely on for the procedures.
21Freedom of movement and, for the Britons in Belgium, certainty about the continuation of their rights in the country, were the main driving factors for pursuing an EU27 citizenship. In some cases, this was linked to specific plans beyond the UK and Belgium. For example, Sarah appreciated that through her Irish passport she could continue to imagine a post-retirement life elsewhere in the EU. For Séamus, the Irish passport was more concretely a way to continue to spend a significant part of each year in Hungary, something that he had been doing for several years before the Brexit Referendum, having bought a flat there, and having a brother who was living permanently in the country. In the Latin American context, in particular, descent-based citizenship has been recognised as a guarantee both to offer an escape route in case of economic crises in the country of residence and to allow a lifestyle including easy short-term travels, particularly to the US (Tintori, 2009; Mateos, 2019; Blanchard, 2020; Jedlicki et al., 2020). For some of my interviewees in the European context there was an element of lifestyle, although such lifestyle involved more time spent (or at least imagined) in the country of new mobility.
22For some interviewees the main reason was however relational and intergenerational, as the advantages of an EU27 citizenship were pursued for one’s children as much as for oneself, as in the case of Vanessa:
“For our children, one of the things I have been talking to my siblings about is that we want them to have the chance to travel the way that we’ve been used to. Things like the Erasmus programme, going to the university in the EU, all these things we just didn’t want to be taken from them, because there are opportunities that we really would like them to have. So, for all of us I think, we wanted it for our children, as much as for ourselves.” (Vanessa)
23One interviewee, Carys, mentioned first the possibility to travel, access EU funding, and possibly move for a longer period to the Netherlands (an aspiration of her Canadian partner in particular) as reasons for applying for the Irish passport, but then also explained her plans to have her daughter access an EU27 citizenship along with the British and the Canadian ones.
“We have a daughter who’s gonna be two in December, so we are trying to figure out her citizenship. She could still have an Irish passport, which is something that… she’s got a British passport […] which we did, ‘cause it was the easiest. I think that next we would get an Irish passport for her, so she can be a European citizen. […] That’s another reason I wanted to apply for mine as well, is to give my daughter the chance to be European citizen, rather than just British citizen. And then, of course, she can have Canadian.” (Carys)
24Such examples confirm another relational dimension of naturalisation already highlighted in the literature (e.g. Street, 2014; Soehl et al., 2020; Godin and Sigona, 2022), that is, having as motivation obtaining the advantages linked to citizenship for a relative, and in particular for one’s children. In some cases, the structure of citizenship legislation created specific deadlines, as in the case of Linda.
“I was aware I was eligible… I could be a dual citizen. But I never thought […] bothering, prior to Brexit, just didn’t seem necessary. […] But now I’m actively connecting with a friend in […], which is the birthplace of my father. And, really, it’s most for my son, he’ll be eighteen next year, and I feel he’s gonna miss out on all the opportunities of freedom of movement, studying in another country…” (Linda)
25With collective family naturalisation under Italian law ending when children reach eighteen years of age, with the already mentioned obstacles and the delays for Italian citizenship to be processed, Linda had a specific interest in obtaining her Italian citizenship quickly, in order to be able to pass it on to her son without needing a new procedure on his part.
26While the loss of rights and the wider uncertainty linked to Brexit put practical uses of citizenship at the forefront, most interviewees also made reference to emotional or symbolic reasons to apply for the citizenship or passport, including feelings of belonging and reaffirming a link with a parent, adding a further relational dimension also to the symbolic uses of citizenship.
“I could always go back to the UK, now I can go to Ireland, and thanks to the Irish passport I am still welcome, and I use that word because I will still have the right to go and move to wherever I want, be it a Greek island, be it, you know, Scandinavia somewhere, you know, be it former Eastern Europe […].
Giving that my father was from Ireland it seems a fitting tribute to him, because he was the one who ultimately was the immigrant into England.” (Sarah)
27The literature on descent-based citizenship has well explored the “roots” and “identity” dimensions of the experiences of such naturalisations (e.g. Pogonyi, 2019; Subašić, 2023). There has been somehow less attention to how applying for a citizenship can also be a way to feel closer to the parent through which the citizenship is accessed, particularly if the parent has already passed away. It is true that in most cases parental transmission of citizenship is completed at an early age. It is the specific context of EU citizenship, with a partial loss of salience of national citizenship, followed by Brexit and the renewed importance of national citizenship, that has caused some of these late applications for the citizenship of a parent.
28Finally, it is worth observing that none of the interviewees who explored becoming Irish discussed in detail the more explicit politics of the status of Northern Ireland. Most interviewees had ancestry in the Republic of Ireland, and had limited links with Northern Ireland. The exception was Carys, whose mother was from Northern Ireland. She, like her mother, was holding an Irish passport, but also recognised how, for other members of her extended family, applying for an Irish passport could be politically unappealing:
“That side [her mother’s] of my family, it would be against their belief to apply for an Irish passport, so… My mum is very Republican, she sees herself as Irish, but […] part of this family got a very staunch Loyalist… and applying for an Irish passport would be against everything…” (Carys)
29While there is an extensive literature on the impact of Brexit on Northern Ireland, including some ethnographic work across the Nationalist/Unionist divide (Wilson, 2019 and 2020; Dornschneider and Todd, 2021), there has been less academic inquiry into the use of Irish passports. One interesting aspect would be to understand to what degree those who identify with the Unionist position in Northern Ireland might be willing to take a Republic of Ireland passport for practical reasons (cf. Wood and Gilmartin, 2018).
30I have already mentioned how a number of interviewees pursued citizenship, both by descent and by naturalisation, specifically to pass the status to their children within the Brexit process. Procedures for citizenship by descent are usually rather simple even beyond the Irish and Italian cases, and involve registering the birth of the child with consular authorities. Interviewees who went through naturalisation, however, encountered more complex procedures, which often involved proving language and integration requirements and, in some cases, residence ones.
31The case of a British couple living in Belgium is helpful in showing how the Brexit process changed both the value and the perception of formal citizenships. Mira and Gordon had two Belgian-born daughters, and were aware that their daughters had a chance to become Belgian at eighteen by virtue of having been born and residing in the country. However, as the window of opportunity arrived some years before the Brexit Referendum, they opted not to pursue this possibility, reasoning that one EU citizenship (at the time the UK one) was enough.
Mira: “So, before it [having the Belgian nationality] didn’t matter, I said to them… in fact, we thought about it at eighteen, it was a kind of discussion. And I said ‘well it’s irrelevant, to be honest, for practical reasons you need one EU passport these days’. If you had an American passport, then that would be different, but with British I said ‘oh, just one EU passport is plenty.’”
Gordon: “… should be enough…”
Mira: “Not counting on the fact… that was not good advice.”
32This happened despite the fact that Mira in particular had first-hand experience of the relevance of citizenship, having naturalised as British while holding her Yugoslavian (at the time) citizenship. However, as a family, they did not feel the need to supplement the opportunities given by the British passport with a second EU citizenship. After the Brexit Referendum, with the daughters having moved in the meanwhile to the UK for their university studies, the missed opportunity became a source of worries, in particular that their children might be excluded from job opportunities in the EU. This is one of the examples of the time-specific meaning of citizenship, and in particular of how many interviewees gave value to pursuing additional citizenship only with the Brexit process.
33This does not mean that before the Brexit process EU citizenship made the national citizenships irrelevant for my interviewees. For example, an interviewee living in the UK, Inge, explored the citizenship options for her son as early as 1999, despite being able to rely on EU rights on the basis of Dutch citizenship:
- 4 The norm indeed changed with the introduction of “The British Nationality (Proof of Paternity) Regu (...)
“When I was pregnant, it came up, obviously with me being Dutch, the father was British, so I phoned to the Home Office when I was pregnant and asked: ‘Well what nationality will my child be?’ and they said: ‘Well, even though it would be born in Britain, and have a British father, it would only be Dutch.’ That was actually correct at the time.
I think this changed in 2006,4 I think, but at the time the fact that the father was British did not actually make the child British, so they said ‘unless you are married’. I said ‘well, we should just get married’. Which is why I got married when I was pregnant. That was because of the nationality issue really, which is the only reason, because I wanted a child born in Britain to have British nationality basically.” (Inge)
34Along with the gender asymmetries mentioned in the case of Clara and her mother, the equal transmission of citizenship to children born in or out of wedlock is another aspect on which citizenship laws across Europe have been made more inclusive only recently (cf. Knop, 2001; Sainsbury, 2018).
35While, as mentioned, some interviewees did explore citizenship options for their children before Brexit, the process increased greatly the attention to obtaining advantageous legal statuses. As Carys, who was planning for her daughter to obtain also the Canadian citizenship, Melissa also made sure her children could access the Italian citizenship of her husband, as well as her own British and US citizenships.
“I have dual nationality since birth between the US and the UK, because I was born in the United States and my mother is American. And my father was a British citizen, though his family background is German and Polish, however he was born in the UK so he had British citizenship. […]
I just wanted them [her children] to have all the citizenships that they qualified for. Then they can decide in the future if they want to give something up, I thought about it, it’s just easier to get the American citizenship when they are young.” (Melissa)
36For a number of my interviewees, naturalising was mostly discussed as a measure to ensure their children the access to citizenship, defend their status, and ensure they could access the same rights as their parents:
“Because […] my husband and I got [Belgian] nationality, then my daughter, who has actually only known Belgium, ‘cause we came when she was three months old […] she automatically got Belgian citizenship. […]
The big thing for us is making sure that our daughter still had access to Europe, and still had… some flexibility. I mean, she’s more Belgian now than she is British, in sense, this is what she’s known her whole life.” (Judy)
“I applied for citizenship not long after [the Referendum], partly because my youngest daughter was born in Belgium, and she’s never known living in Britain, and I wanted to protect her right to stay, because she gets it automatically. And my biggest regret is I didn’t do it before. […]
I was worried about my children, I think, that they wouldn’t have the same opportunities that I had, to live in Europe, to study, to work, to meet other people. Particularly my oldest daughter, who’s the one who lives in [the UK] because… she was over eighteen when I applied for citizenship, so she hasn’t got it automatically, and I worry what her opportunities will be.” (Annabelle)
37Judy and Annabelle were British interviewees in Belgium, and for both of them naturalisation was a priority to pass on the Belgian citizenship to their children (or at least to those under eighteen, as Annabelle pointed out), ensuring both their right to stay and to mobility within the EU. This was particularly emphasised when the children were either born in Belgium or spent almost their whole life there, as they were considered not to have links with the UK strong enough to make it acceptable to move to Britain. A third interviewee, Rhys, also evoked possible further restrictions to citizenship rights in the future as one of the reasons for applying.
“My kids were born here [in Belgium], I have got five-and-a-half years old twins who were born in 2014. And because of our nationality, even though they were born here, they were not automatically given a Belgian citizenship. If one of the parents decided to become a Belgian citizen, then they would automatically get citizenship. […] Currently, children can decide, if they were born here, they can decide if they want Belgian citizenship or not. […] That’s one of the reasons why I am applying for citizenship, so that the kids have the opportunity of working in Europe, ‘cause they currently are offered dual citizenship, who knows in fourteen years when they’re old enough to do it.” (Rhys)
38One of the effects of the Brexit experience has been the development of a pessimistic outlook about the future of rights for those who moved between the UK and the EU. While the interview with Rhys is rather exceptional in the presence of reflection on possibilities such as the end of dual citizenship toleration, other interviewees, both in Belgium and the UK, anticipated a loss of rights for non-citizens, both as part of the Brexit process and in the subsequent future (Sredanovic, 2021).
39While in all cases the relational dimension was central in the envisaged uses of citizenship, some differences of degree could be identified among the three groups here considered in their practical reasons for pursuing additional citizenships for their children. In all cases there was a defensive citizenship approach (Coutin, 2003; Gilbertson and Singer, 2003), as the aim was to avoid their children to have less rights than the parents experienced. For Britons in the UK this applied only to life opportunities, such as studying or working abroad, while for Britons in Belgium and EU27 citizens in the UK it was linked to more urgent issues of being able to stay and have equal rights in the country of residence. However, in all cases it was about defending existing rights more than acquiring new ones. Further, the life opportunities dimension was more relevant for Britons (both in Belgium and the UK), who, differently from EU27 citizens, were losing their freedom of movement. Another dimension, particularly for the few interviewees who could obtain non-European citizenships, was a sort of “citizenship hoarding”, partly prompted by Brexit. The realisation of the importance of citizenship brought some interviewees to explore more in depth how to ensure protection and opportunities for their children.
40While several interviewees naturalised for the sake of their children, one interviewee followed intergenerational objectives in choosing a tactical non-naturalisation (Pan, 2021) or, rather, a delayed naturalisation. William, a Briton resident in Belgium, while interested in Belgian nationality, delayed applying in order to keep his children enrolled in a British school in Belgium. Had he become Belgian in addition to British, indeed, his children would have stopped to qualify for reduced rates, with the full rates not being affordable for the family.
41Further, while most interviewees with children, and especially those with younger children, were pursuing actively citizenships for them, some of the interviewees with older children had an attitude more oriented to leaving them to decide on their own:
“My children are British, both, but they’re also Italian. What they will have to do is to inform the commune [municipality] that they no longer wish to be treated as British, but wish to be treated as Italian. […]
But that’s their business, they haven’t done it yet, I don’t know that they will…” (Walter)
42Further, there were cases in which the interviewee focussed on the relevance of formal citizenship, while their children showed a lack of interest for it, as in the case of the daughter of the aforementioned Clara and of her Dutch husband Piet:
Piet: “[our daughter] had to choose [between British and Dutch citizenships] at twenty-one.”
Clara: “She got both as a child […] At that point we didn’t know where we would settle. And because we were settled here [in the UK], she understandably made the decision to retain her UK passport. I mean, from what I’ve read, she could if she wanted to… looking to get her Dutch passport, as well. But I don’t think that’s a priority for her at the moment.”
43In particular, their daughter had limited interest in mobility across Europe, having at most interest in moving to non-European countries such as New Zealand, making the Dutch citizenship less interesting. Situations of this kind were not limited to differences of interest between parents and children — in some other cases the interviewee was trying to figure out a partner’s entitlement to a citizenship, while the partner was not interested. For example, Susanne, an Austrian interviewee living in the UK, was exploring the possibility for her British partner to apply for German citizenship on the basis of his German mother, but the British partner was not willing to consider the option.
44Examples of this kind show why we should avoid jumping from the evidence of a relational dimension of naturalisation, to assuming a collective decision process. Even when relatives clearly influence the naturalisation decision, this does not mean that there is a shared decision, or even a shared evaluation of the usefulness of citizenship, as some of the relatives involved might remain indifferent.
45In the interviews I collected, there were no clear differences among Britons in Belgium and the UK and EU27 citizens in terms of lack of interest. On the other hand, identity reasons for passing on one’s citizenship to one’s children seemed stronger among some EU27 interviewees in the UK. For José, who has a daughter from a previous marriage with a British woman, the option of the daughter keeping the Spanish citizenship was both an identity and relational issue and a practical one.
“She [his daughter] was born here to a British mum […] she has both nationalities. Once she is eighteen, if she wants to retain her Spanish nationality, she needs to go to the consulate and make a declaration of that. And in that case, she can keep the Spanish passport. I would hope that she does that. That this part of my identity, that she takes it forward. But, you know, she’s, I guess, 90% English and 10% Spanish, she’s grown up here. […]
If nothing else I would encourage that… I mean, I think that her mum would encourage that she keeps the Spanish passport, because it gives her the flexibility to have more choices in the future. […]
You know, my ex, she’s from Irish parents, so [she] was sort of thinking about getting the Irish passport.” (José)
46In the extract the symbolical continuity between José’s Spanish identity and his daughter opting to maintain the Spanish passport is what gets the first mention, followed however by a discussion on how the EU rights of such passport would keep the daughter’s mobility chances, and how the same chances might be pursued through the ex-wife’s Irish ancestry — one of the clearest examples of the coexistence of pragmatic and identity-based approaches to citizenship.
47Marcelo was an interviewee in the particular position of being Chilean-born and of Yugoslavian/Croatian ancestry. In addition to growing up in Chile with a Yugoslavian citizenship, he resided briefly in Croatia in the late 1990s and obtained the Croatian citizenship. That citizenship facilitated his move to the UK, and it also offered guarantees to his children who were able to have access to Croatian citizenship. However, his wife was “only” a Chilean citizen; while facilitated naturalisation as a spouse of a citizen was an option, other requirements, including a residence one, were an obstacle, which meant that her mobility to the UK saw difficulties (and costs) in terms of visa. Similarly, Rhys, along with pursuing Belgian citizenship for himself and his children, had explored the options given by his and his wife’s Irish ancestry, which was useful for her and, again, for the children, but not for Rhys himself:
“I poked around to see if I could dig up an Irish relative, and I couldn’t. My mother can get an Irish passport, but because she didn’t do it before I was born, it [the transmission] stopped. […] My partner, her mother was born in [Northern Ireland], so we already knew that she and my children could qualify for Irish passports.” (Rhys)
48The variable geometry of descent- and marriage-based transmission, as well as additional requirements such as being a minor, residence, or language knowledge, create complex situations for those pursuing an additional citizenship within their family. Within this complexity, however, a few of my interviewees had more than one possible citizenship they could apply for, and were able to choose the option that entailed less obstacles (Sredanovic, 2022).
49In this article I have shown how Brexit changes the value of formal citizenships, and in particular of the citizenships of EU member states, including in cases of citizenship by descent and citizenships acquired in order to pass them on to one’s children. On the one hand, this article confirms the need, already expressed in the existing literature, to go beyond methodological individualism, and recognise the different ways in which family (and other) links can influence the decision to pursue a citizenship, with the transmission of citizenship to one’s children being a major motivation. The interviewees I met show a combination of pragmatic, “just-in-case” and identity-based reasons for obtaining citizenship. On the other hand, some findings are more novel when compared with the existing literature on citizenship by descent, and others suggest the need to correct some of the implicit assumptions in such literature. While most literature on citizenship by descent focuses on intergenerational relations (grandparents/parents/children), I also show how relations between siblings, while not relevant for the right to naturalise, can have a role in the decision-making process. Further, I show how the relational dimension extends to symbolic reasons to naturalise, in particular reaffirming the relation with a parent. Further, my interviewees were not, as in much of the existing literature, exploring descent-based citizenships to improve their standing and create new opportunities, but rather to defend their standing and to contain the loss of rights. The main correction I suggest in this article to the assumptions implicit in the literature on family-based citizenship is that family units are often far from unanimous in pursuing citizenship or even in valuing it. The procedures for citizenship acquisition by descent in some cases see the non-collaboration, or the lack of interest, of one of the relatives involved. In this sense, the approach to citizenship can be better understood as relational, i.e. influenced in different ways by interaction with relatives and non-relatives, rather than simply aimed at maximising the resources of the family.
50I have also shown how the change in value of citizenship is event-specific and linked to the Brexit process. Some who already qualified before Brexit applied for a citizenship, and in some cases discovered such a possibility for the first time, as a result of Brexit itself. While this is partly due to the exceptional situation of Brexit, there are indications that citizenship decisions should be considered more as located in specific moments in time, something that the literature on citizenship by descent has not systematically done until now.
- 5 British citizens and EU27 migrants in the UK who have not accessed citizenship have respectively lo (...)
- 6 The difference the interviewees marked was largely political, and superimposable to a Left/Right co (...)
51In my data there are also different attitudes to the prestige that a specific citizenship entails. Research in Latin America and in Israel has shown how obtaining some citizenships, in particular those of EU member states, is also a way to strengthen one’s prestige by certifying oneself as “European” (Lamarche, 2019; Mateos, 2019; Jedlicki et al., 2020). In the interviews I have collected, there were hardly signs of pursuing a citizenship to mark one’s difference from the other, third-country, migrants, to whom British and EU27 citizens were being made similar.5 This contrasts with other research in France (Benson, 2020) in the context of Brexit, in which some of the White British interviewees showed a stronger sense of entitlement and a stronger rejection of the idea of being likened to third-country nationals. My research findings also contrast with earlier research on naturalisations in the UK (Monforte et al., 2019), in which some interviewees presented themselves as “deserving” Europeans in contrast with “non deserving” non-Europeans. This does not entail that the meaning of citizenship in my research is uniform: the expectations, the uses, and the resources available (formal qualifications, economic capital, etc.) in alternative to citizenship rights, are very much stratified by class, migratory history and age (Sredanovic and Della Puppa, 2020; 2021). However, I have found less signs than elsewhere that obtaining an additional citizenship is seen as reinforcing one’s place in a social hierarchy. The one group with whom some interviewees were seeming to mark a difference by naturalising were British “Brexiters”, seen as less mobile both in their lifestyles and in their perspectives.6
52The major difference between pursuing citizenship by descent and by naturalisation (the latter considered here when the aim was to pass the citizenship to one’s children) was in the much lower requirements of citizenship by descent. In addition, compared to other citizenships, acquiring Irish citizenship had some potential political meaning, especially for the interviewees living in the UK. There has been some debate on whether the significant increase of Irish passports held by British citizens might have a political impact (cf. Wood and Gilmartin, 2018). Brexit is very likely to have a significant repercussion for Northern Ireland, between the stronger effect of a hard(er) border with the Republic of Ireland, and the consequent political realignments (cf. Doyle et al., 2021), and in that region the increase in Irish passports’ possession might have a stronger impact. However, for the interviewees I met in Belgium and in Great Britain, Irish identity had a role, but was far less relevant than the practical advantages and even the identity of being an EU citizen. The emergence of a reactive European identity both among the EU27 citizens and among Britons in the UK and the EU, has indeed been one of the ironic results of Brexit in a country, the UK, which had long before Brexit shown little enthusiasm for the EU. While I have not explored this more in depth in the interviews, for my interviewees becoming Irish or Italian seemed a private fact, an affirmation of links with one’s parent and other relatives and friends. Remaining EU citizens was to a degree more political, as it relied on a relatively shared Remainer political discourse that opposed Brexit and its consequences. This does not mean that EU citizenship was not mostly pragmatic, or that wanting to be EU citizens was inherently a political act (although several interviewees did mobilise against Brexit), but simply that this component of citizenship tactics relied on a less private and more shared conception of having citizenship rights.
