Dual citizenship ban likely to be overturned

Change would come despite majority of voters saying they oppose the idea of allowing people to have citizenship in two countries

A majority in parliament say they are prepared to support a bill allowing dual citizenship, due to be presented by the Justice Ministry later this year. 

Dual citizenship is already permitted in certain situations, but Denmark is one of just seven EU countries not permitting all citizens to claim citizenship in another country if they qualify. 

Proposals to change the law come up at regular intervals, but this time around some of parliament’s more sceptical parties say they are willing to consider changing the rule. 

“More countries are accepting dual citizenship, and I won’t rule out that we won’t accept it in some form,” Lars Barfoed, the Conservative leader, told Berlingske newspaper.

Margrethe Vestagaer, leader of the Radikale party, which has been one of parliament’s strongest voices in favour of dual citizenship, called it “a gift” that foreigners would be allowed to retain their original citizenship and be afforded “full access to the country they will contribute to and where their children would grow up”. 

Just as important in the dual citizenship debate is that it will allow Danes living abroad to retain their citizenship. In 2008, some 17,000 Danes living abroad signed a petition urging parliament to change the law.

But while lawmakers say they are open to considering dual citizenship, over half of voters, according to a Gallup/Berlingske poll, said they were against it. One of the primary arguments against was that it would dilute the definition what it meant to be Danish. 

Respondents also said they felt it was unfair that dual citizens would be allowed to live in one country while at the same time being allowed to draw on the social services of another.

But according to Eva Ersbøll, of Institut for Menneskerettigheder, a human rights think tank, that objection could be overcome by requiring that individuals reside in Denmark in order to claim welfare benefits. 

Ersbøll said there were two major hurdles that had prevented dual citizenship from being permitted.  But while solutions to the practical hurdle – issues such as conscription and taxation – could be found, she said the survey showed that the other – people’s “emotional” hurdle – would be harder to overcome.

Anne Marie Dalgaard, secretary general of Danes Worldwide, an organisation representing Danes living and working abroad, reckons the law in its current form is the result of a debate revolving around the concept of 'loyalty'.

“Many previous governments and politicians," she said, "have refused to recognise dual citizenship because they thought you could only be loyal to one country at a time.”

However, for Dalgaard it is as easy to be loyal to different countries as it is to “love both of your parents”.

And many Danes have chosen different loyalties, she said, albeit merely by settling abroad: “Denmark has always been a nation of travellers. There are between 250,000 and 300,000 Danes living abroad,” – a significant number in proportion to the country's population of 5.5 million.

These scores of expatriates would benefit from the change in the law, as would those who wished to acquire Danish nationality.

“It is important to accept newcomers and welcome them in the same way we allow our nationals to integrate in other countries,” Dalgaard said.

Yet, Denmark is not the sole Nordic country keeping a lid on dual citizenships. Norway applies similar laws demanding foreigners to forfeit their previous citizenship when applying to become Norwegian. Likewise, its nationals must renounce their citizenship before acquiring another one.

Sweden and Finland both used to have similar laws, before overturning them in 2001 and 2003, respectively. 

Factfile | Dual Nationality in Europe: a myriad of models

As the European Union and the Schengen treaty guarantee mobility for European citizens, cases of dual nationality become ever more recurrent, and several states adapted their legislations on nationality and citizenship to recognise and in some cases even encourage dual citizens.

Currently, 20 EU states allow and recognise dual citizenship among their nationals. Some, however, have more relaxed rules than others.

Among the champions of plurinationality are France and the United Kingdom.

Neither ask their nationals to renounce their original citizenship when being granted a new one, nor do they ask candidates for naturalisation to relinquish their citizenship.

In France, estimates place the number of dual citizens at close to five million, out of a population of 65 million. However, the principle has often been criticised and, as recently as June 2011, the far right leader and 2012 presidential candidate, Marine Le Pen, asked for it to be revoked.

Others, like Ireland and Portugal, whose populations have been through episodes of mass emigration, are equally tolerant of dual citizenship both for their citizens and newcomers.

In certain cases, dual nationality has even been used as a political tool among diasporas.

This way, Hungarian prime minister, Viktor Orban, shortly after his election in 2010, granted access to Hungarian citizenship to close to 3.5 million Magyar-speaking people residing outside Hungary.

Since the latter resided mostly in neighbouring countries, such as Slovakia and Romania, the measure sparked tensions among governments in the region.

Governments, like that of Spain, can also approach dual citizenship through a historical lens. Spaniards have specific treaties with Latin American nations granting citizenship to descendants of Spanish nationals, going as far as three generations in certain cases.

Among the more restrictive countries in the EU is Germany. Though it allows dual-nationality for those who claim both a German and an EU or Swiss passport since 2007, it dies not uphold this principle for non-European candidates for citizenship.

This becomes somewhat problematic for the significant Turkish minority established in the country, whose members have to renounce their Turkish passport in order to become Germans.

Stricter measures apply in the Netherlands and Austria, where governments want to limit dual citizenship. Candidates for either Dutch or Austrian naturalisation are required to renounce their original citizenship.

The few exceptions include children born to parents of different nationality, or those born in countries that automatically grant citizenship to individuals whose birth takes place on their soil, such as France or the US.

These exceptions are also included in the current Danish legislation. For Danish citizens, this type of dual citizenship is only temporary, however: they must decide which nationality to retain before turning 22.