European Citizenship by Descent: Ireland, Italy, Germany, Poland and More

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Photo: Annie Spratt / Unsplash

European citizenship by descent is the fastest route to living in Europe if you qualify, because an EU passport gives you the right to live and work in any EU country with no visa. The rules differ sharply. Ireland is the most accessible, with a grandparent born in Ireland enough to register as a citizen. Italy tightened its rules in 2025 and now limits claims to two generations in most cases. Germany's routes are narrow and mostly tied to Nazi-era persecution or gender-discrimination rules. Poland and Hungary have their own conditions, and several other countries run limited programmes.

This guide explains each, with the dates that matter. It is general information, not legal advice. Citizenship law is technical, changes through court decisions, and each case depends on documents, so check the official page for your country and consider a specialist lawyer before you pay for records.

First: why check descent before a visa

If you qualify, citizenship avoids income tests, visa renewals, the Schengen 90/180 limit and the wait for naturalization. You can then live anywhere in the EU. It also changes your tax and reporting situation only slightly if you are already a US citizen: you remain subject to US rules. The price is time and paperwork, not capital.

Compare with visa routes in how to move to Europe and golden visas.

Ireland: the most accessible

Ireland offers two main routes:

  • Born to an Irish-born parent. If your parent was born on the island of Ireland, you are an Irish citizen automatically, and can apply for a passport after registering your birth if needed.
  • Foreign Births Register. If your grandparent was born in Ireland, you can apply to the Foreign Births Register run by the Department of Foreign Affairs. The Irish immigration portal describes this as being available to those with an "Irish national grandparent born in Ireland". There are also special cases involving great-grandparents who registered a parent before your birth.

Searches for Irish citizenship by descent are among the highest in our keyword research, so expect heavy demand. Processing times change and the official site gives current waiting information. You need civil records for each generation, such as birth, marriage and death certificates. Irish citizenship also gives you access to the UK's Common Travel Area rights. Read our Ireland guide, and see Dublin and Cork.

Italy: 2025 changes

Italy's jure sanguinis claim was once open to descendants of any generation. That changed with Decree-Law 36/2025, converted into Law 74/2025 and in force from 24 May 2025. According to an Italian consulate's published summary:

  • Transmission now runs parent to child for a maximum of two generations. You generally need an Italian parent or grandparent, and the ancestor must not have renounced citizenship or been naturalized elsewhere in a way that broke the line.
  • People born in Italy, and those born abroad who hold no other citizenship, are treated under the old rules.
  • Applicants born abroad must also meet an extra test: for example, a parent or grandparent who held only Italian citizenship, or a citizen parent who lived in Italy for two consecutive years before the applicant's birth.
  • The consulate's summary says women transmit citizenship only from 1 January 1948, so check carefully if your line runs through a woman born earlier.
  • Transitional exception: those who booked and confirmed a consular appointment by 11:59 pm Rome time on 27 March 2025 can be treated under the earlier rules.
  • The standard consular fee is โ‚ฌ600, and processing can take up to 730 days at consulates.

Some courts have been asked to review the law, so check the current position before you rely on a pre-2025 theory. Many people with great-grandparent claims are now excluded. Alternatives include Italy's digital nomad visa, and a claim through other ancestry. See Italy.

Germany: narrow, but real

Germany does not grant citizenship simply because an ancestor was German. The main routes for descendants are:

  • Article 116(2) of the Basic Law, for descendants of people who were stripped of German citizenship on political, racial or religious grounds between 1933 and 1945. No time limit and no fee.
  • Section 15 of the Citizenship Act (since 20 August 2021), covering people who lost or never acquired citizenship because of Nazi persecution.
  • Section 5 of the Citizenship Act, for people born after 23 May 1949 who were excluded by gender-discriminatory rules, for example children of German mothers born in wedlock before 1 January 1975. The deadline to file is 19 August 2031.

Generation cut-off rules for those born abroad after 31 December 1999 require birth reporting within a year. No German language test or residence is required under these routes, and dual citizenship is allowed. Ordinary naturalization rules were changed in 2024 and have been adjusted since, so check the current version if you are not on a descent route. See Germany and the EU Blue Card for work-based routes. Confirm with the Federal Office of Administration (BVA).

Poland

Poland recognises citizenship if one of your ancestors was a Polish citizen and the line was never legally broken. The "confirmation of citizenship" process looks at whether the ancestor held Polish citizenship under the laws of the time, and often depends on emigration dates (1951 is a key cut-off in some cases), military service in a foreign army, and naturalization elsewhere. Documents are demanding and the filing may need Polish-language forms and sworn translations. Apply through the nearest Polish consulate or a voivode in Poland. See Poland and Warsaw.

Hungary

Hungary offers simplified naturalization to descendants of Hungarian citizens, with Hungarian language knowledge required. There is no residence requirement for the simplified process, but you must show Hungarian ancestry and pass a language interview. Check the government page for current conditions. See Hungary and Budapest.

Other countries to check

Rules for these change frequently, so verify each one before you spend money:

  • Spain: the Democratic Memory Law created a window for descendants of Spanish exiles, which ran for roughly three years from October 2022. Confirm its current status.
  • Portugal: the Sephardic Jewish descendant route was tightened in recent years, and the 2026 nationality law revisions changed residency timelines. Check the official source.
  • Greece, Lithuania, Latvia, Slovakia and Croatia: have descent-based or heritage routes under conditions that vary by case.
  • Austria: has a route for descendants of Nazi persecution victims.

How to find out if you qualify

  1. Draw the family tree to the generation born in Europe. Note names, dates and places.
  2. Collect records: birth, marriage, death, naturalization records for each person. Look for naturalization dates, which can break lines.
  3. Check the rules on the official site for the country.
  4. Order certified copies and apostilles. See the moving checklist for apostille steps.
  5. Apply and wait. Waiting times can be long.
  6. Consider a specialist if records are missing or the line is complex.

Beware of paid "citizenship in weeks" schemes. The official processes are usually low-cost; most expense is records and translations.

UK, Canadian and Australian applicants

The EU nationality route works regardless of your current passport, as long as your family line is intact. British citizens with an Irish grandparent can use the Foreign Births Register. Italian descent is a popular route for Canadians, Australians and Americans; the 2025 limits apply to all. Dual citizenship is permitted by Ireland, Italy and Germany for descent claims, but check your current country's rules.

Citizenship vs residence: what to do while you wait

While your claim is pending you might still need a residence route. Nomad visas and passive-income visas can bridge the wait; see digital nomad visas and retire in Europe. US citizens should think about US tax: US expat taxes.

Frequently asked questions

Can I get Irish citizenship through my grandparent?

Yes, if your grandparent was born in Ireland. You apply to the Foreign Births Register, with certified civil records for each generation. If your parent was born in Ireland you may already be a citizen. Check the Department of Foreign Affairs for current waiting times.

Did Italy end citizenship by descent?

No, but it limited it. Law 74/2025 restricts claims to roughly two generations, with extra tests for people born abroad. There were transitional exceptions for those with consular appointments confirmed by 27 March 2025. Confirm the current rules with an Italian consulate.

Can I get German citizenship through a German grandparent?

Not simply because of ancestry. Germany's descent routes mostly apply to descendants of people persecuted in the Nazi era (Article 116(2) and Section 15) or affected by gender-discriminatory rules (Section 5, with a 19 August 2031 deadline). Other cases generally need naturalization.

Can I get Polish or Hungarian citizenship through ancestry?

Possibly. Poland confirms citizenship if an ancestor was a Polish citizen and the line was never broken. Hungary offers simplified naturalization to descendants of Hungarian citizens who speak Hungarian. Both require detailed records, so check the official consular sites.

How long does citizenship by descent take?

It varies a lot. Gathering records can take months, and consulates quote waits from months to years. Italy's consular guidance mentions processing times of up to 730 days, and German applications can take up to two years or more.

Do I need to live in the country to claim citizenship by descent?

Usually not. Ireland, Italy, Germany and Poland process descent claims from abroad, though Italy's 2025 rules added some residence-based tests for certain cases. You may need to live there later to keep or use certain rights, so read the rules.