Citizenship by Descent in 2026: Which Countries Still Say Yes

Most online advice about ancestry passports is out of date. Italy cut its generation rule in 2025. Spain's grandchildren window closed the same year. Portugal added a language and culture test in 2026. If you read a guide from 2023, it may send you down a route that no longer exists.

This one is checked against official sources as of October 2026.

The short answer: As of October 2026, several countries still pass citizenship down through ancestors, but the rules got tighter. Italy now usually stops at a parent or grandparent, after Law 74/2025. Ireland still accepts anyone with an Irish-born grandparent through the Foreign Births Register (€278 for an adult). Poland, Hungary, Greece and Lithuania look further back if the paper trail is clean. Portugal still accepts grandchildren, but now with a language and culture test. Spain's grandchildren law closed on 22 October 2025. Germany restores citizenship to descendants of people persecuted by the Nazis. The UK Ancestry visa is a visa, not citizenship.

How far back each country goes

Each country counts generations its own way, and the small conditions decide most cases.

Italy: the big change after Law 74/2025

For decades, Italy had no generation limit. That ended in 2025. Decree-Law 36 of 28 March 2025 was converted into Law 74 of 23 May 2025. It added Article 3-bis to the citizenship law. Now, a person born abroad who holds another citizenship is treated as never having been Italian, unless one of these applies (Italian Consulate New York, 2026):

• You applied, or got an appointment, by 23:59 Rome time on 27 March 2025.
• A parent or grandparent holds, or held at death, only Italian citizenship.
• A parent lived in Italy for at least 2 continuous years after becoming Italian and before you were born or adopted.

The second point is the hard one. Many emigrant grandparents later became American, Argentine or Brazilian citizens. If your grandparent naturalised abroad, that route usually closes.

The consular fee is €600 for each adult application (Italian Consulate San Francisco, 2026).

What the courts did in 2026

Where the court cases stand, as of October 2026:

• Judgment 63/2026. The Constitutional Court heard the Turin court's challenge on 11 March 2026. It declared the questions partly inadmissible and partly unfounded. The ruling was filed on 30 April 2026 (Constitutional Court, 2026).
• Order 147/2026. On 23 July 2026, in cases from the Mantua and Campobasso courts, the Court sent a question to the EU Court of Justice. It asks whether EU treaty rules on EU citizenship stop a law like Article 3-bis (Constitutional Court press release, July 2026).

The law stays in force while the EU court decides. Nobody can promise how it will end.

A small door for children

If a child has an Italian parent but does not get citizenship automatically, there are declaration routes. A parent who is Italian by birth can make a declaration within 3 years of the child's birth. Children who were minors on 24 May 2025, with a parent recognised as Italian before 27 March 2025, can declare by 31 May 2029. These declarations are free from 1 January 2026 (Italian Consulate New York, 2026). Read more in our Italy migration guide.

Ireland: the grandparent route still works

Ireland is the clearest case. If one of your grandparents was born on the island of Ireland, you can become an Irish citizen through the Foreign Births Register. Once you are entered on the register, you are an Irish citizen and can apply for a passport (Department of Foreign Affairs, 2026).

If your parent was born on the island of Ireland and was an Irish citizen when you were born, you are already Irish. You do not need the register. You just apply for a passport.

What about a great-grandparent? It only works if your parent registered before you were born. If each generation registers before the next is born, citizenship keeps passing down (Citizens Information, 2026).

Sources: Department of Foreign Affairs, 2026; Citizens Information, 2026.

If you are not on the register when your child is born, that child cannot claim through you. Our Ireland guide covers life after the passport.

Poland, Hungary and Greece: older roots, more paperwork

No fixed generation cut-off here, but the paper trail must be strong.

Poland

Poland does not "give" you citizenship by descent. It confirms that you already have it. You must prove that your ancestors held Polish citizenship and that no event in their lives, or yours, made them lose it (Jewish Historical Institute interview with Mazovian Voivodeship and Interior Ministry officials).

The classic trap: until 19 January 1951, starting military service in a foreign army usually meant losing Polish citizenship. World War II service was an exception. So a great-grandfather who joined the US Army in 1925 may have broken the chain.

You apply to a regional governor (wojewoda), often through a consulate. Through the US consulates, the fee is USD 118. You have 14 days to appeal a refusal (Polish Consulate USA, gov.pl, 2026).

Hungary

Hungary uses simplified naturalisation. You qualify if one of your ancestors was, or was likely, a Hungarian citizen. You also need a clean criminal record and no security concerns (Embassy of Hungary, Brussels, 2026).

The real test is language. You must present your application in Hungarian, without help, and answer questions in short sentences. The New York consulate says plainly that without sufficient Hungarian, "you can't expect a positive decision" (Consulate General of Hungary, New York, 2026). You become a citizen when you take the oath.

Greece

Greek citizenship passes from a Greek parent. A grandparent or great-grandparent can work too, if the line is properly documented. The key is registration in a Greek municipality's records (the dimotologio). If that cannot be found, older records such as the Male Registry or old Greek passports may be considered case by case (Greek Embassy USA, 2026).

Greek consulates only check your file. The municipality and the Ministry of Interior in Greece decide.

Portugal: grandchildren can still apply, with new conditions

Portugal's Organic Law 1/2026 came into force on 19 May 2026 (Lei Orgânica 1/2026, Diário da República, May 2026).

The grandchildren route survives. If a grandparent was Portuguese by origin and never lost that nationality, you can declare you want to be Portuguese. You must show effective ties to the Portuguese community. Now you must also meet conditions taken from the naturalisation rules (Lei Orgânica 1/2026, new Article 1(3) of the Nationality Law):

• Prove, by test or certificate, enough knowledge of Portuguese language, culture, history and national symbols.
• Know the basic rights and duties of a citizen and how the state is organised.
• Make a formal declaration of support for democratic rule of law.
• Have no serious criminal convictions, pose no security risk, and not be under UN or EU sanctions.

Great-grandchildren have a different, slower route. After 5 years of legal residence in Portugal, the government may grant them naturalisation. Applications already pending on 19 May 2026 follow the old law. If you are thinking of moving first, see our Portugal migration guide.

Spain: the grandchildren law has closed

Spain's Democratic Memory Law (Law 20/2022) opened a window for children and grandchildren of Spanish exiles and emigrants. On the last days, some consulates stayed open longer and took applications without an appointment. The window closed on 22 October 2025 (Embassy of Spain, Budapest, 2025).

If you missed it, that route is gone. Ask a Spanish consulate whether any other route fits your family.

Germany: restoring what was taken

Under Article 116(2) of the Basic Law, people whose German citizenship was taken away on political, racial or religious grounds between 30 January 1933 and 8 May 1945, and their descendants, have a right to citizenship (German Federal Foreign Office, 2026).

Since 20 August 2021, Section 15 of the Nationality Act also covers people who lost or could not get German citizenship because of persecution, even if it was not formally taken away. This includes, for example, people who gave it up before 26 February 1955 or were excluded from naturalisation. It also covers all their descendants. The listed requirements do not include a language or citizenship test, and the procedure is free. Applicants aged 16 or over make a formal declaration of loyalty, and serious criminal convictions can block the application (Federal Office of Administration, BVA, 2026).

A separate declaration route (Section 5) helps children of German mothers who were excluded by old gender rules. It runs for 10 years from 20 August 2021.

Lithuania: up to great-grandchildren

People who held Lithuanian citizenship before 15 June 1940, and their descendants, have a lasting right to restore it. You may keep your other citizenship if your ancestor left Lithuania, or was exiled, before 11 March 1990. That dual citizenship right covers children, grandchildren and great-grandchildren (Lithuanian Consulate Los Angeles, 2025).

Birth in Lithuania alone does not prove citizenship. You need documents such as an interwar passport or an archive certificate. You apply through the online MIGRIS system.

The UK Ancestry visa: a visa, not citizenship

The UK does not give citizenship through a grandparent. It gives a visa.

You qualify if you are a Commonwealth citizen (or hold certain other statuses) and one grandparent was born in the UK, the Channel Islands or the Isle of Man. You must be 17 or over, plan to work, and support yourself without public funds (GOV.UK, 2026).

Sources: GOV.UK, 2026; GOV.UK health surcharge, 2026.

Five years of surcharge for one adult is £5,175, on top of the £726 fee. Compare costs in our visa cost tool and the UK migration guide.

Four steps before you spend money

Step 1: Write down the family line

Start with you and go back. Note each person's name, birth date, birthplace and any change of citizenship. Ask older relatives now. Memories fade faster than paper.

Step 2: Find the key event

Each country has one fact that decides most cases. For Italy: did the ancestor naturalise abroad? For Poland: foreign military service before 1951? For Lithuania: citizenship before 15 June 1940? Check that fact before you spend money.

Step 3: Get the civil records

You usually need birth, marriage and death records for every link, often full-length, with an apostille and an official translation. Collect proof for name changes too. "Giuseppe" may become "Joseph" on a ship list.

Step 4: Read your local consulate's page

Rules are national, but each consulate sets its own booking system and paperwork. Book early, and scan every page before you send it.

Know your "why" first

For many people this search is less about Europe than about a grandparent who never talked about the boat. Finding their name in an old register can feel like they are finally seen. Learning that the family "lost" citizenship through a war, a uniform or a signature can feel like a second loss.

Before you spend real money, decide what you want: a passport, a home, or the story. Would you actually live there? Are you ready to learn a language, as Hungary and now Portugal expect? Your answer tells you how far to go. If you are weighing citizenship against other status, our guide on permanent residency vs citizenship may help.

Seven ways ancestry claims fail

• Assuming old rules still apply. Many blogs still describe Italy with no generation limit. That ended in 2025.
• Ignoring naturalisation dates. The date your ancestor became a citizen of another country can decide everything.
• Thinking birthplace equals citizenship. Lithuania and Greece both say it is not.
• Missing the Irish timing rule. A parent must register before the next child is born.
• Confusing the UK Ancestry visa with citizenship. It is a 5-year visa with fees and conditions.
• Paying an agent who promises a sure result. Hungary's consulate warns against agents who say you can pass without Hungarian.
• Forgetting your current country. It may have its own rules on dual citizenship.

When a lawyer is worth it

Many people handle Ireland alone. Speak to a qualified lawyer in that country if:

• Your Italian claim depends on a court case or the outcome of the EU court question.
• An ancestor may have lost citizenship through military service, marriage or naturalisation.
• Records were destroyed in war, or the border has moved since your ancestor left.
• Your Polish or German claim involves pre-1951 laws or persecution cases.
• You have had a refusal before.

Choose a lawyer registered with that country's bar, ask for a written fee estimate, and avoid anyone who guarantees success.

Frequently asked questions

Can I still get Italian citizenship through a great-grandparent in 2026?

Usually not, unless you applied by 27 March 2025. You now generally need a parent or grandparent who held only Italian citizenship, or a parent who lived in Italy for 2 years before your birth. An EU Court of Justice case is pending, but the law stays in force.

Which country is easiest for citizenship by descent?

For many people, Ireland. If a grandparent was born on the island of Ireland, the Foreign Births Register costs €278 for an adult, and the official requirements do not include a language test. It takes about 12 months.

Is Spain's grandchildren law still open?

No. The Democratic Memory Law window closed on 22 October 2025. Ask a Spanish consulate whether another route fits your family.

Does Portugal still give citizenship to grandchildren?

Yes, but with new conditions since 19 May 2026. You need effective ties to Portugal and a test or certificate in Portuguese language, culture, history and national symbols. Applications pending before that date follow the old law.

Is the UK Ancestry visa the same as British citizenship?

No. It is a 5-year visa for Commonwealth citizens with a UK-born grandparent. The visa fee is £726, plus the health surcharge of £1,035 a year. After 5 years you may be able to settle.

Do I need to speak the language?

It depends on the country. Hungary requires spoken Hungarian, and Portugal now requires a language and culture test for grandchildren. Ireland's official list of Foreign Births Register requirements does not include a language test. Check the current list for any other country before you apply.

Start with the deciding fact

Every claim turns on one fact: a naturalisation date, a birthplace, a registration, a uniform. Find yours before you order a single certificate. Then take our free migration assessment to see how a second passport, or a move, fits your wider plans.

This article is general information, not legal advice. Citizenship rules change often. Always confirm with the official government source or your consulate before you act.