Jus soli
Jus soli, commonly referred to as birthright citizenship in Canada and the United States, is the right of anyone born in the territory of a state to nationality or citizenship.
Jus soli was part of the English common law, in contrast to jus sanguinis, which derives from the Roman law that influenced the civil-law systems of continental Europe. Jus soli is the predominant rule in the Americas, but it is rare elsewhere. Since the Twenty-seventh Amendment of the Constitution of Ireland was enacted in 2004, no European country grants citizenship based on unconditional or near-unconditional jus soli.
Almost all states in Europe, Asia, Africa and Oceania grant citizenship at birth based upon the principle of jus sanguinis, in which citizenship is inherited through parents rather than birthplace, or a restricted version of jus soli in which citizenship by birthplace is automatic only for the children of certain immigrants.
Jus soli in many cases helps prevent statelessness. Countries that have acceded to the 1961 Convention on the Reduction of Statelessness are obligated to grant nationality to persons born in their territory who would otherwise become stateless persons. The American Convention on Human Rights similarly provides that "Every person has the right to the nationality of the state in whose territory he was born if he does not have the right to any other nationality."
National laws
Lex soli is a law used in practice to regulate who and under what circumstances an individual can assert the right of jus soli. Most states provide a specific lex soli—in application of the respective jus soli—and it is the most common means of acquiring nationality. However, a frequent exception to lex soli is imposed when a child is born to a parent in the diplomatic or consular service of another state on a mission to the state in question.Unrestricted ''jus soli''
Africa
- Chad
- : Per the Tanzania Citizenship Act of 1995, "any child born within the borders of the United Republic of Tanzania, on or after Union Day, 26 April 1964, is granted citizenship of Tanzania, except for children of foreign diplomats."
Americas
Caribbean Islands
- : Guaranteed by the Constitution.
- Barbados: Guaranteed by the Constitution. However, the Barbados Ministry of Labour & Immigration recently proposed ending automatic birthright citizenship.
- Cuba
Continental North America
- : Subsection 3 of the Act states that Canadian citizenship by birth in Canada granted to a child born in Canada even if neither parent was a Canadian citizen or permanent resident except if either parent was a diplomat, in service to a diplomat, or employed by an international agency of equal status to a diplomat. However, if neither parents were diplomats, the nationality or immigration status of the parents do not matter. Some Conservative Party members wish to end birthright citizenship in Canada to the children of tourists and unauthorized immigrants.
- Mexico
- United States: The Citizenship Clause of the 14th Amendment to the United States Constitution, ratified in 1868, provides: "All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside." The concept of birthright citizenship applying to the child born of a foreign national in the country without proper credentials has never been formally litigated, but the U.S. Supreme Court's decision in United States v. Wong Kim Ark allowed the government to deny citizenship to U.S.-born children only in the cases of children born to foreign diplomats and children born to enemy forces engaged in hostile occupation of the country's territory, and thus this decision is most often interpreted as barring the government from denying citizenship to a U.S.-born person based on the alienage of his or her parents..
Central America
- : Jus sangui requires registration with the Costa Rican government before the age of twenty-five.
Continental South America
- Argentina
- Brazil.
- Chile
- Paraguay
- Peru
- Uruguay
Oceania
Asia
- Pakistan
Restricted ''jus soli''
Africa
- : According to Article 4 of the Nationality Law of the Arab Republic of Egypt, children born in Egypt gain citizenship at birth if their father was also born in Egypt.
- : A person who was born in Morocco to parents also born in Morocco and whose immigration is legal, can register as a Moroccan two years prior to becoming adult.
- : A person born in Namibia to a Namibian citizen parent or a foreign parent who is ordinarily resident in Namibia, is a Namibian citizen at birth.
- : Since 6 October 1995, a person born in South Africa to South African citizens or permanent residents is automatically granted South African citizenship.
- : A person born before 1994 gains Sudanese nationality at birth if his father was also born in Sudan. If his father was not born in Sudan, he can apply to the Minister to be granted Sudanese nationality.
- : Individuals born in Tunisia are citizens by birth if their father and grandfather were born in Tunisia. Additionally, the person must declare before becoming an adult that he wants to be a citizen.
Americas
- : The constitution was amended on 26 January 2010. The amendment broadened the definition of the 2004 migration law – which excluded from citizenship children born to individuals that were "in transit" – to include "non-residents".
Asia
- : In 1996, Cambodia changed the law to only grant citizenship to children born to foreign parents living legally in the Kingdom of Cambodia.
- India: A person that was born in India from 26 January 1950 until 1 July 1987 is a citizen by birth, regardless of the parents' nationality. It began to be restricted in 1987. As of 2020, a person born in India is a citizen if at least one parent is a citizen, and the other parent is a citizen or a legal migrant. These measures were brought in largely in reaction to illegal migration from Bangladesh.
- : A person born in Malaysia on or after 16 September 1963 with at least one parent being a Malaysian citizen or permanent resident is automatically a Malaysian citizen.
- Hong Kong: Since the July 1997 transfer of sovereignty over Hong Kong, most political rights and eligibility for most benefits are conferred to permanent residents regardless of citizenship. Conversely, PRC citizens who are not permanent residents are not conferred these rights and privileges. The Basic Law provides that all citizens of the People's Republic of China born in the territory are permanent residents of the territory and have the right of abode in Hong Kong. The 2001 case Director of Immigration v. Chong Fung Yuen clarified that the parents need not have right of abode and as a consequence many women from Mainland China began coming to Hong Kong to give birth. By 2008, the number of babies in the territory born to Mainland China mothers had grown to twenty-five times the number five years prior. Furthermore, persons of Chinese ethnicity born in Hong Kong are PRC citizens with permanent residence, even if their parents are non-PRC citizens. Non-PRC citizens born to non-PRC citizen permanent resident parents in Hong Kong also receive permanent residence at birth. Other persons must have "ordinarily resided" in Hong Kong for seven continuous years in order to gain permanent residence and 24).
- : Thailand operated a system of pure jus soli prior to 1972. Due to illegal immigration from Burma, the Nationality Act was amended to require that both parents be legally resident and domiciled in Thailand for at least five years for their child to be granted Thai citizenship at birth. Furthermore, someone who has Thai citizenship by sole virtue of jus soli may be stripped of Thai citizenship under various conditions, which does not apply to people who have Thai citizenship by virtue of jus sanguinis.
Europe
- : Children born in France to at least one parent who is either a French citizen or born in France, automatically acquire French citizenship at birth. Children born to foreign parents who do not fulfil either of these two conditions may acquire citizenship from age 13 subject to residence conditions. A child born in France to foreign parents becomes a French citizen automatically upon turning 18, provided that they reside in France on their 18th birthday and have had their primary residence in France for a total period of at least 5 years since the age of 11.
- : prior to 2000 Germany's nationality law was based entirely on jus sanguinis, but now children born in Germany on or after 1 January 2000 to non-German parents acquire German citizenship at birth if at least one parent has a permanent residence permit and resided in Germany for at least eight years prior to the child's birth. However, jus soli citizens will lose their German citizenship upon turning 23 unless they: reside in Germany for at least 8 years during their first 21 years of life; or attend school in Germany for at least 6 years; or graduate from high school/college in Germany; or complete professional/vocational training in Germany.
- Greece: Apart from regulations in past and historic nationality laws of Greece granting nationality jus soli, Greek Nationality Code of 2004 states that "A person born in Greek territory acquires by birth the Greek nationality if not acquiring alien nationality or is of unknown nationality". Additionally, as from 2015's amendment of 2004 Cod, a child born in Greece by foreign parents, shall acquire the right of Greek nationality with a combination of preliminary school attendance and parents' legal residence in Greece. One year after the implementation of the law, 6,029 children had been granted Greek nationality, out of 27,720 submitted applications.
- : On 1 January 2005, the law was amended to require that at least one of the parents be an Irish citizen; a British citizen; a resident with a permanent right to reside in Ireland or in Northern Ireland; or a legal resident residing three of the last four years in the country . The amendment was prompted by the case of Man Chen, a Chinese woman living in mainland United Kingdom who travelled to Belfast to give birth in order to benefit from the previous rule whereby anyone born on any part of the island of Ireland was automatically granted Irish citizenship. The Chinese parents used their daughter's Irish citizenship to obtain permanent residence in the UK as parents of a dependent EU citizen. Ireland was the last country in Europe to abolish unrestricted jus soli..
- : A person born in Luxembourg is automatically a Luxembourg citizen if at least one of their parents was also born in Luxembourg. Additionally, a person born in Luxembourg to foreign, non-Luxembourg-born parents can become a Luxembourg citizen from the age of 12 if they have resided uninterrupted in Luxembourg for at least 5 years immediately prior to submitting the application, and if at least one of their parents lived in Luxembourg uninterrupted for at least 12 months immediately preceding their birth. Furthermore, a person born in Luxembourg to foreign, non-Luxembourg-born parents gains Luxembourg citizenship automatically upon reaching the age of 18, provided that they have lived uninterrupted in Luxembourg for the preceding 5 years and at least one of their parents lived uninterrupted in Luxembourg for at least 12 months immediately preceding their birth.
- : A child born in Portuguese territory to who does not possess another nationality is a Portuguese citizen. Also, a person born to foreign parents who were not serving their respective States at the time of birth is a Portuguese citizen if the person declares that they want to be Portuguese and provided that one of the parents has legally resided in Portugal for at least two years at the time of birth.
- : A child born in Spain to foreign parents may acquire Spanish citizenship jus soli if either one of the parents was also born in Spain or neither of the parents can transmit their nationality to the child.
- : Since 1 January 1983, at least one parent must be a British citizen or be legally "settled" in the country or upon the 10th birthday of the child regardless of their parent's citizenship status.
- : A person born in Malta on or after 1 August 2001 is automatically a Maltese citizen if at least one of their parents is Maltese or was born in Malta. Anyone born in Malta before 1 August 2001, regardless of their parents' circumstances, is automatically a Maltese citizen, as the country conferred unconditional jus soli until this date.
Middle East
- : Children born to a foreign father with valid residency permits who himself was born in Bahrain have right to citizenship.
- : Article 976 of the Civil Code of Iran grants citizenship at birth to persons born in Iran of foreign parents if one or both of the parents were themselves born in Iran. See Iranian nationality law.
- : Children born in Israel who have never acquired another citizenship are eligible to apply for Israeli citizenship between their 18th and 21st birthday if they have lived in Israel for over 5 years.
Oceania
- : Since 20 August 1986, a person born in Australia acquires Australian citizenship by birth only if at least one parent was an Australian citizen or permanent resident; or else after living the first ten years of their life in Australia, regardless of their parent's citizenship status.
- : Since 1 January 2006, a person born in New Zealand acquires New Zealand citizenship by birth only if at least one parent was a New Zealand citizen or permanent resident , or if to prevent being stateless.
- : As mentioned above, people born in American Samoa do not acquire U.S. citizenship at birth, unless one of their parents is a U.S. citizen.
Abolition of ''jus soli''
- Malta: Changed the principle of citizenship to jus sanguinis on 1 August 1989 in a move that also relaxed restrictions against multiple citizenship. However, anyone born in Malta before 1 August 2001 falls under unconditional jus soli and is a Maltese citizen.