UK/EU joint citizenship.

[BJames]

Message me if you want any help with it.

Thanks, much appreciated! I'm going to get my Uni exams done this month and then I hope to have some time to clear some of these outstanding things so I will likely get back to you then

 

[MattA7]

Ireland's rules are quite generous partly because it hasn't been an independent nation for very long, and until fairly recently there were quite a few people around who were born when it was part of the UK. Scotland plans a similar policy if it becomes independent (which would allow me a third passport, assuming you could keep UK citizenship).

This is my worry regarding the Scottish independence thing as someone who does have tied with the England the thought of being subject to immigration restrictions at the border and losing right to live and work in England and Wales horrifies me. If Scottish residents (pre independence) got to keep their UK citizenship it wouldn’t be quite as bad. I suppose Scottish citizenship would be citizenship/passport number 4 but Scots getting to keep their UK citizenship is by no means a guarantee. As far as EU membership goes I’m not really bothered about that as I can’t see myself ever wanting to live/work in continental Europe.

 

[Journeyman]

This is my worry regarding the Scottish independence thing as someone who does have tied with the England the thought of being subject to immigration restrictions at the border and losing right to live and work in England and Wales horrifies me. If Scottish residents (pre independence) got to keep their UK citizenship it wouldn’t be quite as bad. I suppose Scottish citizenship would be citizenship/passport number 4 but Scots getting to keep their UK citizenship is by no means a guarantee. As far as EU membership goes I’m not really bothered about that as I can’t see myself ever wanting to live/work in continental Europe.

I'm an Englishman living in Scotland and I'm opposed to independence for exactly those reasons. If Scotland aspires to EU membership, or even just CU/SM membership, all trade with England will be subject to the deal we've just signed with the EU, and the consequences of that are horrendous. At the very least there would be a customs border between Scotland and England.

Although I now have an Irish passport which I now consider more valuable than my UK one, I am essentially both English and British, and there's no way I'd give up my UK citizenship.

 

[Chester1]

I'm an Englishman living in Scotland and I'm opposed to independence for exactly those reasons. If Scotland aspires to EU membership, or even just CU/SM membership, all trade with England will be subject to the deal we've just signed with the EU, and the consequences of that are horrendous. At the very least there would be a customs border between Scotland and England.

Although I now have an Irish passport which I now consider more valuable than my UK one, I am essentially both English and British, and there's no way I'd give up my UK citizenship.

Officially there were no announcements but in 2014 Theresa May hinted that UK Citizenship ie English-Welsh-Northern Irish Citizenship would replace the current British Citizenship. The SNP said it was threatening Scots! Why SNP think its reasonable to expect 5.5 million people to have citizenship of what would effectively be a successor state is beyond me. You would be fine, as would any Scot with an English parent (assuming UK kept current rules).

This is my worry regarding the Scottish independence thing as someone who does have tied with the England the thought of being subject to immigration restrictions at the border and losing right to live and work in England and Wales horrifies me. If Scottish residents (pre independence) got to keep their UK citizenship it wouldn’t be quite as bad. I suppose Scottish citizenship would be citizenship/passport number 4 but Scots getting to keep their UK citizenship is by no means a guarantee. As far as EU membership goes I’m not really bothered about that as I can’t see myself ever wanting to live/work in continental Europe.

I think there is more or less zero chance of Scots keeping UK Citizenship long after independence unless they had a parent from one of the three remaining countries in the UK or naturalised there. The Soviet Union is a good comparison. There were transition laws and changes until Russia restricted Citizenship to people with a personal link to Russia. If UK broke up further the chances of England not creating English Citizenship is virtually nil.

I think the most that unionist minded Scots would get long term would be a British National Overseas (Hong Konger) style travel document. Irish Citizens are more or less treated as British Citizens (and vice versa) a century after independence. I think a similar reciprocal arrangement would be extremely likely. It would have to get very nasty for one side to require the others citizens to get visas but it is possible.

Its certainly worthwhile getting a second passport if you can. I have repeatedly nudged a few friends to sort it out. My Irish ancestry is too far back but I am not bothered. I wouldn't consider moving to the continent until retirement because of the language barrier. I would consider Ireland before then and if I did I'd naturalise but I don't think it's very likely.

 

[XAM2175]

This is my worry regarding the Scottish independence thing as someone who does have tied with the England the thought of being subject to immigration restrictions at the border and losing right to live and work in England and Wales horrifies me...

I'm an Englishman living in Scotland and I'm opposed to independence for exactly those reasons...

Officially there were no announcements but in 2014 Theresa May hinted that UK Citizenship ie English-Welsh-Northern Irish Citizenship would replace the current British Citizenship...

To avoid unnecessary duplication could I suggest that this is continued in the existing thread? I've already made an answer to MattA7's post here:

Scotland post-Brexit - what happens next?

I am not forgetting any history - but that was in a different time and different circumstances. I don't think there should be an assumption that the same would happen again. 1609587583 I don't think the English do 'sensitive' very well, governing classes or not. I don't see Westminster...

www.railforums.co.uk

 

[Mag_seven]

Just a gentle reminder that we have a thread on Scotland post Brexit here:

(1) Scotland post-Brexit - what happens next? | RailUK Forums (railforums.co.uk)

Discussion on this thread should be limited to discussing UK-EU joint citizenship.

thanks

 

[jonty14]

I had British and Irish from before Brexit vote and last year applied for German citizenship by descent. Out of interest how long did your German citizenship application take, mine has been 18 months so far.

It took me about half a year. The authorities in my town fast tracked citizenship applications for British people. I didn't have to do the language test because I have been here half my life and can speak the language. This was two years ago now.

 

[ILikeTrains75]

It took me about half a year. The authorities in my town fast tracked citizenship applications for British people. I didn't have to do the language test because I have been here half my life and can speak the language. This was two years ago now.

Thanks - sounds like the Naturalisation process for Brits was really fast tracked; I assume so that Brits could keep British Citizenship as well prior to Brexit, and give you some certainty for the future.

I have applied through my German Grandfather to obtain my Staatsangehörigkeitsausweis, which according to the German Mission could take 2-3 years to process, but I was hoping for a quicker timescale as my application is pretty straightforward.

 

[jonty14]

Thanks - sounds like the Naturalisation process for Brits was really fast tracked; I assume so that Brits could keep British Citizenship as well prior to Brexit, and give you some certainty for the future.

I have applied through my German Grandfather to obtain my Staatsangehörigkeitsausweis, which according to the German Mission could take 2-3 years to process, but I was hoping for a quicker timescale as my application is pretty straightforward.

That is true. It had to be done while the UK was in the EU to be able to have dual citizenship. I don't think dual citizenship is possible now the UK has left the EU unless the rules have changed.

 

[MattA7]

I wonder if there is anyone on this forum with 4+ citizenships. So far the highest seems to be 3

 

[Journeyman]

I wonder if there is anyone on this forum with 4+ citizenships. So far the highest seems to be 3

That's bit of a Bourne Identity thing going on!

 

[Elwyn]

That is true. It had to be done while the UK was in the EU to be able to have dual citizenship. I don't think dual citizenship is possible now the UK has left the EU unless the rules have changed.

The UK leaving the EU has made no difference to dual citizenship. It pre-dates the EU and just applies where someone's circumstances are such that they qualify for more than one nationality by virtue of birth, descent, or naturalisation. You don't have to be a member of an EU country.

 

[JamesT]

The UK leaving the EU has made no difference to dual citizenship. It pre-dates the EU and just applies where someone's circumstances are such that they qualify for more than one nationality by virtue of birth, descent, or naturalisation. You don't have to be a member of an EU country.

I think that was in relation to Germany, which does have rules on dual citizenship which rely on EU membership.

Dual citizenship - multiple nationality

Is it possible to have another citizenship in addition to German citizenship?

www.bmi.bund.de

That says if you naturalise as a German citizen you have to give up your previous nationality, except if you are an EU citizen.

 

[Elwyn]

I stand corrected.

 

[ILikeTrains75]

I think that was in relation to Germany, which does have rules on dual citizenship which rely on EU membership.

Dual citizenship - multiple nationality

Is it possible to have another citizenship in addition to German citizenship?

www.bmi.bund.de

That says if you naturalise as a German citizen you have to give up your previous nationality, except if you are an EU citizen.

Correct - for completeness, in case anybody was wondering, it appears that the rule actually changed on 1st Jan - anybody who got an application in prior to that was ok.

"After 31 December 2020, the end of the transition period following the United Kingdom’s exit from the European Union, British nationals will only be eligible for naturalisation if they first give up their British citizenship. However, this rule does not apply if the naturalisation application was filed before 1 January 2021 and all other naturalisation criteria were met (legal basis: Section 3 (1) Brexit-Übergangsgesetz (Transitional Brexit Act))."

German Embassy London and Consulate General Edinburgh

Federal Foreign Office website

uk.diplo.de

Interestingly, and I hadn't realised this before, the same is now true for German citizens - if they now apply for British citizenship (after 1st Jan) then they loose German citizenship .

"German citizens who acquire British citizenship after December 31, 2020, generally lose their German citizenship. However, German citizenship is not lost if the application for acquisition of British citizenship has been submitted to the British authorities by December 31, 2020. Legal basis: Section 3 ( 2) of the Brexit Transitional Act"

https://www.bva.bund.de/DE/Services...igkeit/_documents/Meldung/Meldung_Brexit.html

 

[RT4038]

Correct - for completeness, in case anybody was wondering, it appears that the rule actually changed on 1st Jan - anybody who got an application in prior to that was ok.

"After 31 December 2020, the end of the transition period following the United Kingdom’s exit from the European Union, British nationals will only be eligible for naturalisation if they first give up their British citizenship. However, this rule does not apply if the naturalisation application was filed before 1 January 2021 and all other naturalisation criteria were met (legal basis: Section 3 (1) Brexit-Übergangsgesetz (Transitional Brexit Act))."

German Embassy London and Consulate General Edinburgh

Federal Foreign Office website

uk.diplo.de

Interestingly, and I hadn't realised this before, the same is now true for German citizens - if they now apply for British citizenship (after 1st Jan) then they loose German citizenship .

"German citizens who acquire British citizenship after December 31, 2020, generally lose their German citizenship. However, German citizenship is not lost if the application for acquisition of British citizenship has been submitted to the British authorities by December 31, 2020. Legal basis: Section 3 ( 2) of the Brexit Transitional Act"

https://www.bva.bund.de/DE/Services...igkeit/_documents/Meldung/Meldung_Brexit.html

I believe Austria does not permit dual citizenship either.

There are other countries around the world that do not permit it, or restrict it (South Africa for instance).

 

[johncrossley]

I've just seen this thread

www.railforums.co.uk/threads/uk-eu-joint-citizenship.212794

This post was wondering whether he needed another passport:

www.railforums.co.uk/threads/uk-eu-joint-citizenship.212794/#post-4929222

I also have dual nationality, but have not actually bothered to renew my UK passport for many years. There was no point having two.

Last time I applied, they couldn't even find my details and the application timed out so I lost my money. I have since found an old passport (it's blue - and not the new shade of blue; it's nearer black!) and may now be forced to apply again so I can have both when travelling - even though I hate the fact I now need to pay for two passports AND that I've always felt uncomfortable about carrying two passports as I can imagine some countries (especially the USA!) being very suspicious.

I have been wondering what happens if I travel on my EU passport and then get hassle returning to the UK having to prove that I'm a UK citizen. Am I supposed to seek settled status to have this added to my foreign passport? Can a UK citizen even apply for settled status?!

It's all a mess IMO.

EU citizens can still enter the UK without a visa using their passport, so why would dual nationals need a UK passport, or a certificate of entitlement?

 

[najaB]

EU citizens can still enter the UK without a visa using their passport, so why would dual nationals need a UK passport, or a certificate of entitlement?

At the moment, yes. But that is going to change soon with a ESTA-type scheme, unless plans have changed.

 

[westv]

No dual citizenship for me. I'm stuck with what the 52% decided I didn't want.

 

[THC]

I was born in England but have only ever held an Irish passport - both parents are from Connacht. I identify as London Irish, not English, not British. For that reason getting a UK passport just wouldn't feel right


THC

 

[johncrossley]

I was born in England but have only ever held an Irish passport - both parents are from Connacht. I identify as London Irish, not English, not British. For that reason getting a UK passport just wouldn't feel right


THC

There's no point getting a British passport when you have a Irish one. A British passport is useless by comparison.

 

[JamesT]

EU citizens can still enter the UK without a visa using their passport, so why would dual nationals need a UK passport, or a certificate of entitlement?

I’m fairly sure that a (non-UK) EU citizen without settled status requires a visa if they’re coming to the UK to do anything beyond being a tourist for a relatively short visit, in the same way a non-EU citizen has always had to.

The problem is UK Border Force if they think someone entering the country is doing so for a reason that would need a visa if you’re not otherwise exempt. So you need to prove to them that you’re entitled to be here, which for a UK citizen would usually mean a UK passport. Or as the thread has mentioned, a certificate in a non-UK passport stating your UK citizenship.

 

[johncrossley]

How does the border official know if the EU citizen is coming for a short trip or not? Don't the ePassport gates still accept EU passports?

 

[JamesT]

How does the border official know if the EU citizen is coming for a short trip or not? Don't the ePassport gates still accept EU passports?

There is a certain level of trust, in that you’re not eligible to use epassport gates if you require a stamp in your passport. The settled status scheme is tied to passports, so they may reject EU passports that aren’t linked.
Though I’m fairly sure that going through the gates doesn’t preclude a random stop by a border official if they want further information.

 

[plugwash]

How does the border official know if the EU citizen is coming for a short trip or not?

While the UK doesn't have government run exit controls, they do receive information on exits from transport providers. It would be reasonable to assume that they feed this information back into whatever risk assessment process they use for both manned and electronic gates.

Border control is not an exact science, some undesirables will be allowed in and some legitimate visitors will be refused. They don't publish the exact critera they use to assess risk because if they did people would use that critera to game the system. That is why it's a huge advantage to have a passport that gives you the right to enter a country rather than a passport for which entry is a privilege.