Italy’s Citizenship Shift: How Stricter Ancestry Laws Impact Global Descendants

For decades, Italy’s citizenship-by-descent (CBD) policy has provided a legal pathway for millions of descendants of Italian emigrants to claim citizenship. However, a sweeping reform introduced in March 2025 has dramatically changed Italy’s historically inclusive approach and raised broader questions about citizenship policies across Europe.

Citizenship by descent (CBD), often referred to as citizenship by ancestry, provides a legal pathway for individuals to claim citizenship based on familial ties, provided they can prove a meaningful connection to their ancestors. Unlike citizenship based on birthplace (jus soli), CBD depends on the nationality of one’s parents, grandparents, or even great-grandparents. This process enables descendants to reclaim heritage-linked citizenship, bridging past and present.

Many countries implement CBD policies to strengthen cultural bonds with diaspora communities, honor historical migrations, and bolster national identity. By recognizing descendants of emigrants as citizens, nations foster a sense of belonging and encourage cultural exchange.

Several European countries grant CBD, including Ireland, Italy, Poland, Germany, Greece, Portugal, Hungary, etc.

Italy’s recent overhaul of its citizenship-by-descent laws has made it one of Europe’s stricter options, limiting eligibility to only two generations—parents and grandparents. This shift marks a sharp departure from more permissive systems like Poland and Hungary, which allow claims through distant ancestors, or Ireland and Portugal, which offer simpler processes without residency or cultural hurdles.

While Spain and Hungary require language and cultural tests, Germany has created special routes for descendants of Nazi-era refugees. Italy’s new rules now align more closely with Portugal and Ireland but remain more restrictive than Poland and Hungary. For further details, Global Citizen Solutions provides an overview of European CBD programs, highlighting differences in generational limits and documentation requirements (Global Citizen Solutions, 2025).

Historically, Italy’s citizenship-by-descent policy, as outlined in Law No. 91 of 1992, permitted anyone with an Italian ancestor who was alive after March 17, 1861 (the date of Italian unification) to apply for citizenship. Notably, there was no generational limit, allowing descendants to trace their lineage back through multiple generations—including great-grandchildren and great-great-grandchildren—provided they could prove their ancestry (Italian Ministry of Foreign Affairs, 2025).

Italy’s government has introduced new regulations on citizenship by descent (ius sanguinis), limiting eligibility to descendants of Italians for only two generations. Additionally, a stronger “effective link” with Italy is now required. To automatically acquire citizenship, individuals must be either born in Italy or have lived there for at least two years. The law also imposes stricter registration rules and the potential loss of citizenship for those who fail to maintain ties with Italy for 25 consecutive years (Italian Ministry of Labor and Social Policies, 2025).

However, there is a discussion among the legal community that the decree should be challenged in court. They contend that it lacks a strong constitutional foundation, as it was hastily implemented as an emergency measure, circumventing the usual democratic procedures. As a result, legal experts, the judiciary, and other stakeholders are expected to dispute its validity (CNN, 2025).

Italian government states CBD rules’ tightening is a response to an overwhelmed consular system and a surge in applications. In 2024 alone, Italy received 30,000 applications from Argentina and 20,000 from Brazil. According to Foreign Minister Antonio Tajani, the previous system was being “abused,” and the flood of passport requests was “swamping consulates abroad” (Reuters, 2025). The new law aims to ensure a genuine connection and reduce administrative strain.

This shift aligns with broader European Union (EU) concerns. The European Court of Justice (ECJ) and the European Commission have been examining CBD and citizenship-by-investment (CBI) schemes, highlighting risks such as security threats, money laundering, and circumvention of EU regulations. The European Commission’s 2019 report warned that such programs “pose risks for the Member States and the Union as a whole” (European Commission, 2019). This scrutiny led to infringement proceedings against Cyprus and Malta’s CBI programs in 2020. The 2022 Russian invasion of Ukraine further heightened concerns, prompting the European Parliament to urge Member States to halt CBI and residence-by-investment (RBI) schemes for Russian applicants and review citizenships granted to sanctioned individuals (European Parliament, 2025).

The ECJ’s pending decision on Malta’s CBI program is expected to influence Europe’s citizenship policies. As stated in a Global Citizen Solutions report, the ruling could either reinforce national sovereignty over citizenship criteria—bolstering Italy’s restrictive stance—or impose stricter EU oversight, potentially challenging Italy’s new limits if deemed inconsistent with EU security and integrity goals (Global Citizen Solutions, 2024).

Though Italy tightens its policies, in recent years there has also been a positive shift in CBD policies across the EU.

For instance, Slovakia expanded CBD in February 2022, allowing grandchildren and great-grandchildren of Slovak citizens to apply, potentially opening EU citizenship to up to 800,000 Americans with Slovak roots (IMI Daily, 2022). Germany followed suit in January 2024, reducing residency requirements for naturalization from eight to five years—or three years with “special integration accomplishments”—and embracing dual citizenship to enhance integration and attract talent (Euronews, 2024).

Similarly, Spain extended its “Grandchildren Law” in July 2024, allowing descendants of exiled Spaniards additional time to claim citizenship until October 2025 (Schengen News, 2024). These policy shifts highlight a growing divide: while Italy retreats, other nations expand their CBD frameworks, reshaping the European landscape.

Italy’s recent citizenship reforms mark a significant departure from its historically inclusive policies. This change could have long-term implications for Italy’s diaspora, particularly in countries like Argentina and Brazil, where large numbers of applicants now face more stringent requirements. Despite the new restrictions, CBD remains a viable path to European citizenship in many countries. Policies continue to evolve, balancing historical ties, administrative efficiency, and national interests. As some nations tighten their requirements, others are embracing a more inclusive approach, demonstrating that while laws may shift, the recognition of ancestral heritage in European citizenship policies endures.

CNN. (2025, April 1). Italy slams door on people hoping to claim citizenship through great-grandparents. https://edition.cnn.com/2025/04/01/travel/italy-law-halts-citizenship-through-great-grandparents/index.html

European Commission. (2019). Report on investor citizenship and residence schemes in the European Union. Retrieved from https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=COM:2019:0012:FIN

European Parliament. (2025). Acquisition and loss of Citizenship in EU member states. Retrieved from https://www.europarl.europa.eu/RegData/etudes/BRIE/2025/769502/EPRS_BRI(2025)769502_EN.pdf

Euronews. (2024). Germany eases citizenship rules, allowing dual nationality. Retrieved from https://www.euronews.com/2024/01/19/german-parliament-approves-easing-rules-to-get-citizenship-dropping-restrictions-on-dual-p?utm_source=chatgpt.com

Global Citizen Solutions. (2024). How the ECJ’s decision on Malta could impact Europe’s CBI programs. Retrieved from https://www.globalcitizensolutions.com/intelligence-unit/briefings/how-the-ecjs-decision-on-malta-could-impact-europes-cbi-programs/

Global Citizen Solutions. (2025). Overview of European citizenship-by-descent programs. Retrieved from https://www.globalcitizensolutions.com/eu-citizenship-by-descent/?utm_source=chatgpt.com

IMI Daily. (2022). Slovakia passes 3rd-gen citizenship-by-descent law. Retrieved from https://www.imidaily.com/europe/slovakia-passes-3rd-gen-citizenship-by-descent-law-enabling-eu-citizenship-for-up-to-800000-americans/?utm_source=chatgpt.com

Italian Ministry of Labor and Social Policies. Citizenship by Descent, Crackdown by the Government. (2025). Retrieved from https://integrazionemigranti.gov.it/it-it/Ricerca-news/Dettaglio-news/id/4212/Cittadinanza-per-discendenza-giro-di-vite-dal-governo

Italian Ministry of Foreign Affairs. Citizenship. Retrieved from https://www.esteri.it/en/servizi-consolari-e-visti/italiani-all-estero/cittadinanza/?utm_source

Reuters. (2025). Italy curbs citizenship rules to end tenuous descendant claims. Retrieved from https://www.reuters.com/world/europe/italy-curbs-citizenship-rules-end-tenuous-descendant-claims-2025-03-28/

Schengen News. (2024). Spain extends citizenship by descendant law until October 2025. Retrieved from https://schengen.news/spain-extends-citizenship-by-descendant-law-until-october-2025/?utm_source=chatgpt.com