Descendants of migrants

Descendants of migrants constitute a broad and heterogeneous category, encompassing individuals born in Europe to foreign parents, as well as those whose families emigrated generations ago and who now seek to reclaim a legal or cultural connection with their ancestral country. Within this wider group, second-generation migrants represent a particularly significant component. In 2023, they accounted for 4% of the European population aged 0–74, with an additional 5% having a mixed background (one foreign-born and one native-born parent).

What ultimately structures the experience of these populations is citizenship. More than a legal status, citizenship defines access to rights and duties and operates as a key mechanism of inclusion and exclusion, distinguishing insiders from outsiders. Two core legal principles shape belonging and grant citizenship: jus sanguinis (“right of blood”), which confers citizenship based on parental nationality, and jus soli (“right of soil”), based on place of birth.

• Europeans without citizenship (born in Europe to foreign parents)

In European countries, citizenship is mostly based on the principle of jus sanguinis, meaning it is passed from parent to child. Although most European countries have large immigrant populations, none has a policy of unconditional jus soli. Some EU countries do, however, recognise conditional jus soli, granting citizenship to children born on their territory if certain requirements are met. Where jus sanguinis is strictly applied, as in Switzerland, children born and raised in the country may not automatically acquire citizenship. As a result, they can remain legally tied to a state they may never have experienced directly, which can generate tensions in terms of legal status and national identity. While they generally retain residence rights, their status may remain more precarious than that of citizens, and in specific circumstances they may be required to leave the country.

Italy provides a particularly clear example of the tensions inherent in this system. Its citizenship law, codified in Law No. 91/1992, is firmly grounded in jus sanguinis, reflecting a conception of national belonging based on lineage rather than territorial attachment. As a result, individuals born in Italy to foreign parents—commonly described as second-generation migrants—do not automatically acquire citizenship. They remain legally foreign throughout childhood and may apply only upon turning eighteen, provided they have resided continuously in the country since birth and submit their application within a limited time frame.

Recent reforms have reinforced this framework. Law No. 74/2025 confirmed jus sanguinis as the primary criterion while tightening the definition of descent: automatic citizenship for those born abroad is now conditional on demonstrating an “effective connection” to Italy if they already hold another citizenship. For minors with Italian ancestry, the reform creates a mechanism of acquisition through parental declaration after a period of legal residence. These changes have had immediate consequences for millions of descendants of Italian emigrants, especially in countries such as Argentina, Brazil and the United States.

• Post-migration generation (born in Europe to at least one migrant parent)

In several European countries, citizenship has increasingly incorporated elements linked to long-term residence, often described as forms of conditional jus soli rather than strict jus sanguinis. Countries such as France, Belgium and the Netherlands developed such approaches earlier, while Germany introduced significant reforms in 2000, followed by more limited changes in countries like Spain and Finland.
These models often include versions of “double jus soli”, whereby children born in the country to foreign parents—at least one of whom was also born there—may acquire citizenship at birth or under facilitated conditions. This represents a compromise between restrictive descent-based systems and fully automatic birthright citizenship, recognising the claims of second- and third-generation residents.
Other traditionally jus sanguinis countries, notably Germany, have thus taken cautious steps toward incorporating residence-based criteria, easing access to citizenship for individuals of immigrant origin.
In practice, access to citizenship across Europe remains highly uneven. In 2024, nearly 1.2 million people acquired citizenship in the EU country where they resided, a figure that has increased significantly over the past decade. However, 78% of these naturalisations were concentrated in just five countries—Spain, Italy, Germany, France and Sweden. Requirements also vary widely: residence periods range from three years in Poland to ten in Austria, Italy and Spain, and are often accompanied by language tests, civic knowledge exams and proof of economic stability. In some cases, these conditions have become more demanding, as illustrated by France’s 2024 decision to raise its required language level from B1 to B2.

• Returnees (arrived in Europe, not born in Europe, but descendants of European migrants)

At the same time, the principle of jus sanguinis has enabled a different phenomenon: the rise of “return migration” among descendants of earlier European emigrants. Millions of individuals, particularly in the Americas, are eligible to reclaim citizenship based on ancestry. Italy stands out in this regard, with an estimated 40 to 80 million potential descendants worldwide. In some cases, access to citizenship involves complex administrative or judicial procedures. Other countries have adopted more structured frameworks: Poland offers more stable pathways. Poland’s Karta Polaka, for example, has facilitated over 350,000 applications since 2008. The rise in “bloodline” naturalisation demonstrates that return migration now constitutes a significant demographic transformation rather than isolated family narratives. These processes highlight how citizenship can function not only as a tool of integration but also as a means of reconnecting diasporas with their historical origins.

For descendants of migrants, citizenship is rarely a straightforward inheritance. It is shaped by legal frameworks that vary enormously across borders and change over time—sometimes opening doors, sometimes closing them. Each model of citizenship embodies a different answer to the question of belonging—and behind each legal rule lies an individual navigating the uncertain boundary between inclusion and exclusion.