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OPINION: Critics need to wake up to the reality of dual citizenship in Germany

Aaron Burnett
Aaron Burnett - [email protected]
OPINION: Critics need to wake up to the reality of dual citizenship in Germany
A British and a German passport. Photo: picture alliance / dpa | Britta Pedersen

The conservative German Christian Democrats have opposed dual citizenship at almost every available opportunity over the last decades – but like it or not, new law or no new law – dual citizenship is already a German reality.


The German government’s draft law liberalising citizenship should still hit the Bundestag this month and pass by July, according to parliamentary sources. But that hasn’t stopped readers of The Local Germany from voicing their fears that the long-awaited possibility of dual citizenship could die at the last minute.

Whether on social media or in-person, we at The Local have gotten used to hearing certain questions and comments ever since we broke the government’s planned citizenship reform timeline last October.

They range from “Will the FDP change their mind?” to “Can the CDU block it in the Bundesrat?” referring to Germany’s upper legislative chamber representing state governments.


Our responses are that the FDP still seems committed, the CDU is in opposition in the Bundestag for the first time in over 15 years and – for the first time in over 20 years – it also doesn’t have enough Bundesrat votes to stop citizenship legislation. If there was a time to pass dual citizenship – it’s now.


“I’ll believe it when it happens” is an oft-heard response from readers. And who can blame them?

The CDU has resolutely opposed dual citizenship for decades, famously killing a 1999 dual citizenship proposal in the Bundesrat after it had already passed in the Bundestag.

Nearly a quarter century later, their opposition remains steadfast – even as the world changes.


“We as a Union are of the opinion that Germany already has a liberal legal framework when it comes to nationality law,” Stefan Heck, the CDU/CSU’s main critic on immigration and citizenship in the Bundestag, recently told The Local.

But that just doesn’t stack up against the evidence.

CDU Doppelpass Campaign
The German Christian Democrats have a history of opposing citizenship reform, and blocked a 1999 proposal to allow it in the Bundesrat after spearheading a petition against it.
Photo: picture-alliance / dpa | Arne_Dedert

Almost a decade ago, Denmark changed its law to allow dual citizenship – even as it generally continues to require nine years of residence before applying to become Danish. The US, UK, Australia, Ireland and France all allow dual citizenship. What’s more, Germany competes will all these countries for skilled international workers, to fill a need of 400,000 new workers a year. These countries generally allow someone to apply for citizenship after five to six years altogether – in contrast to Germany’s current eight.

The German traffic light government’s proposed citizenship reform merely brings Germany in line with these countries. For the most part, it’s not generally a liberal regime – at least when compared to these peer countries. The residence requirement is slated to be reduced to five years and dual citizenship is to be allowed. A few provisions are certainly more liberal than Germany’s peer countries, such as the right of especially well-integrated people – such as those with C1 level German – to naturalise after three years, or abolishing language tests for people who are 67 or older. But these are likely to affect only a minority of applicants.

READ ALSO: PODCAST: Who's against German dual citizenship plans and why?


Dual citizenship is already a part of German life

For many internationals in Germany though, reducing the waiting period often isn’t as important as allowing dual citizenship.

Some have been here for years – even decades. Many are well-integrated, speak good German, Are married to German partners, and send their kids to German-speaking schools – and have yet to apply for German citizenship because doing so means giving up a vital link with home. In a globalised world, such links are more important than ever – whether for livelihoods or family – as people may have to shuttle back and forth for everything from work to caring for aging parents.

“If a dual passport becomes the norm, I see a danger of loyalty conflicts, since citizens with two nationalities may be confronted with contrasting positions between the two countries on certain issues. This danger exists particularly in times of crisis and during international conflicts,” the CDU’s Heck told The Local. “Dual citizenship should not be the rule, but the exception – justified by special circumstances.”

Yet so many exceptions now exist that dual citizenship is already – de facto at least – the rule. Some 91,000 people – or two-thirds of all applicants for German citizenship in 2021 – applied to become German while retaining their previous nationality. By contrast, 41,000 gave up their previous passport.

Stefan Heck CDU critic of German nationality law

Dr. Stefan Heck, CDU spokesperson on citizenship and immigration. Photo: Tobias Koch

READ ALSO: EXPLAINED: Who are the people taking German citizenship?

Those who inherited dual citizenship by descent – as I did with both my Canadian and German passports – are allowed dual citizenship. So too are other EU citizens, which prompted the rush of Brits applying for German citizenship before Brexit. So are refugees.

Citizens of Iran – for example – are allowed to become German and keep Iranian citizenship because Iran is one of several countries that simply doesn’t allow its nationals to ever renounce Iranian citizenship. Iran is certainly a country that finds itself at odds with Germany and could provoke what German conservatives would call a “loyalty conflict.” Yet its nationals are allowed dual nationality in Germany and nationals of allied countries – like the US, the UK after Brexit, and Canada – currently are not.

Germany’s current restrictions on dual citizenship don’t prevent “loyalty conflicts.” And that’s not simply because many of Germany’s adversaries don’t allow renunciation. It’s also ridiculous to think that someone would necessarily stop identifying with where they came from just because they’ve given up their passport. I’d wager too that my German neighbours would still refer to me as “our Canadian neighbour” even if I gave up my Canadian passport. Furthermore, plenty of people who’ve betrayed their country to spy for the enemy did so without having the enemy’s passport.


Dual citizenship for the privileged

Certain people can currently apply for an exception to the current requirement to renounce. This may be because they need to continue to have both nationalities for work purposes. German-American supermodel Heidi Klum – who hosts Germany’s Next Top Model in addition to numerous US-based gigs – is perhaps the most famous example of this.

Heidi Klum

Heidi Klum is one of the most famous German dual nationals, holding both German and American citizenship and continuing to work in both countries. Photo: picture alliance/dpa/Invision/AP | Chris Pizzello

But acquiring this permission can be a lengthy process that slows down applications for everyone. This too, at a time when some Berlin districts are taking two years to process citizenship applications. It can also often involve steep legal bills as lawyers helps applicants justify why they should be able to become German and keep their other passport.

For those who are not refugees or from EU countries, dual citizenship under Germany’s existing law remains something the privileged are more likely to be able to access.

READ ALSO: Why German citizenship applications in Berlin are facing delays

Whatever the objections of conservatives, dual citizenship looks very likely to finally pass this year. Out of touch on this as they may be, the CDU has made it repeatedly clear that dual citizenship isn’t passing if they have anything to say about it. The next federal election is in two years and the CDU leads the polls. Passing dual citizenship legislation could hardly be more pressing.

Yet its arrival in the Bundestag has seen several delays. Originally scheduled to come to parliament in December, parliamentarians now say they “hope” they’ll finally see the draft law hit the Bundestag floor this month.

If the government parties are serious about modernising German citizenship, they’ll need to act quickly before the window of opportunity shuts.



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Terrence 2023/03/03 15:03
I love and fully agree with this opinion article. I'm curious to know what is causing the delay in getting the draft law to the Bundestag?

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