For travelers who love exploring different countries, visa requirements often become a time-consuming, tiring, and costly obstacle. Imagine being able to skip long immigration lines, gain visa-free access to dozens of additional countries, and enjoy full flexibility to live and work in two different nations. These are the extraordinary benefits that dual citizenship offers to global explorers.
What is Dual Citizenship?
Dual citizenship is a legal status in which a person is officially recognized as a citizen by two or more countries at the same time. In other words, the individual has citizenship ties with more than one country and is entitled to hold passports from those countries.
Dual citizenship is also known as bipatride or dual citizenship. This status occurs when a person is simultaneously claimed as a citizen by two different governments, granting full rights and obligations in both countries.
A person can acquire dual citizenship in several ways, such as being born in a country under the ius soli principle, having parents from different countries under ius sanguinis, through naturalization, or by marrying a foreign citizen.
Understanding Ius Sanguinis and Ius Soli: The Basis of Dual Citizenship
To understand how someone can have dual citizenship, it’s important to know the two main principles countries use to determine citizenship: ius sanguinis and ius soli.
What is Ius Sanguinis?
Ius sanguinis is a principle of citizenship that determines a person’s status based on parentage or bloodline, not the place of birth. The term comes from Latin, meaning law of the blood.
Under this principle, a child automatically inherits the citizenship of their parents, even if born in another country. For example, a child born in Malaysia to Indonesian parents is still considered an Indonesian citizen. Countries like Indonesia, Japan, Germany, Italy, and many others in Europe and Asia adopt ius sanguinis to preserve national lineage.
What is Ius Soli?
Ius soli is a principle of citizenship determined by the country of birth, not parentage. The term comes from Latin, meaning law of the soil, which emphasizes the birth territory as the basis of citizenship.
Under this principle, anyone born in a country automatically becomes a citizen of that country, regardless of the parents’ nationality. For instance, a child born in the United States to Indonesian parents automatically gains U.S. citizenship. Countries like the U.S., Canada, Brazil, and many in the Americas adopt ius soli, often to encourage population growth.
How Ius Sanguinis and Ius Soli Create Dual Citizenship
Dual citizenship occurs when a child is born in a country that follows the ius soli principle, while the parents come from a country that follows the ius sanguinis principle. In this situation, the child automatically acquires citizenship from both countries.
For example, a child born in the United States (which follows ius soli) to Indonesian parents (who follow ius sanguinis) will gain U.S. citizenship by birth and Indonesian citizenship through their parents.
The opposite scenario can also happen, resulting in statelessness. This occurs when a child is born in a country that follows ius sanguinis to parents from a country that follows ius soli, meaning the child does not automatically qualify for citizenship in either country.
Limited Dual Citizenship in Indonesia
Indonesia follows the principle of single citizenship and does not allow permanent dual citizenship, as regulated in Law No. 12 of 2006 on Citizenship of the Republic of Indonesia. However, there is an exception in the form of limited dual citizenship for children born from mixed marriages between Indonesian citizens (WNI) and foreign nationals (WNA). This status is temporary and valid only up to a certain age according to legal provisions.
What is Limited Dual Citizenship?
Limited dual citizenship is a citizenship status granted to children from mixed marriages, allowing them to hold two citizenships simultaneously, but only until a certain age limit.
According to Article 6 of Law No. 12 of 2006, children eligible for limited dual citizenship are:
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Children born from a legal marriage between an Indonesian father (WNI) and a foreign mother (WNA)
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Children born from a legal marriage between a foreign father (WNA) and an Indonesian mother (WNI)
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Children born outside a country that follows ius soli to Indonesian parents (WNI)
This limited dual citizenship status is valid only until the child reaches 18 years old or gets married before that age. After reaching the age limit, the child must declare a choice to become either an Indonesian citizen or a foreign citizen.
Countries That Allow Dual Citizenship
Not all countries allow their citizens to hold dual citizenship. According to data from Immigrant Invest, around 49% of countries worldwide permit dual citizenship, though some have specific conditions. Here are the countries that allow their citizens to hold dual passports:
Europe
- United kingdom
- French
- Germany
- Italy
- Spain
- Portugal
- Belgium
- Sweden
- Norway
- Denmark
- Finland
- Ireland
- Poland
- Greece
- Turkye
- Russia
America
- United States of America
- Canada
- Mexico
- Brasil
- Argentina
- Chile
- Peru
- Colombia
- Dominican Republic
- Jamaica
Asia
- Philippines
- Pakistan
- Bangladesh
- Sri Lanka
Africa
- South Africa
- Nigeria
- Egypt
- Tunisia
- Morocco
Oceania
- Australia
- New Zealand
Countries That Do Not Allow Dual Citizenship
Some countries do not recognize dual citizenship at all, though certain exceptions apply:
- Indonesia: Limited dual citizenship for children up to 18 years old; must choose one citizenship by age 21.
- Japan: Limited dual citizenship for children up to 20 years old; must choose one citizenship by age 22.
- Netherlands: Exceptions for those married to a Dutch citizen, born in the Netherlands, refugees, or if the original country does not allow renunciation of citizenship.
- Austria: Allowed only for cases of "exceptional interest," such as Olympic athletes, renowned scientists, or extraordinary contributions to the country.
- South Korea: Exceptions for ethnic Koreans born abroad (gyopo), individuals with extraordinary contributions, or famous athletes/artists.
- India: Overseas Citizen of India (OCI) – not full citizenship, but grants lifelong visa benefits and other privileges.
Full Prohibition
The following countries do not allow dual citizenship at all:
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China
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Singapore
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Myanmar
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Thailand
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Malaysia
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Vietnam
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Laos
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Brunei
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Saudi Arabia
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United Arab Emirates
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Kuwait
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Qatar
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Bahrain
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Oman
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Kazakhstan
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Azerbaijan
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Uzbekistan
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Turkmenistan
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Tajikistan
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Kyrgyzstan
Citizens of these countries are required to renounce their original citizenship if they wish to become a citizen of another country through naturalization.
Benefits of Dual Citizenship for Traveling
For travelers and digital nomads, dual citizenship offers remarkable advantages that make global mobility much easier. Here are the main benefits:
Visa-Free Access to More Countries
One of the biggest benefits of dual citizenship is significantly broader travel access, whether visa-free or visa on arrival. According to Patricia Casaburi, Managing Director of Global Citizen Solutions, holding more than one passport greatly increases flexibility and global mobility compared to relying on a single citizenship.
For example, the Indonesian passport ranks 64th on the Henley Passport Index, granting access to 76 countries, while passports from Singapore, Japan, or the European Union provide access to over 190 countries. Combining an Indonesian passport with a European one allows travel to nearly anywhere in the world without complicated visa procedures.
Faster Immigration Lines
Dual citizens can choose which passport to use to their advantage when entering a country. In many international airports, local citizens or citizens of certain countries have access to faster immigration lanes.
For instance, if you hold Indonesian and U.S. citizenship, you can use your U.S. passport when entering countries with special agreements with the U.S., or your Indonesian passport when entering ASEAN countries that provide easier access for fellow members.
Avoid Complicated and Expensive Visa Processes
Visa applications are often complicated, time-consuming, and costly, requiring documents like bank statements, employment letters, itineraries, and even embassy interviews. With dual citizenship, many of these procedures can be bypassed thanks to visa-free access to more countries—so you can just book tickets, pack, and travel without waiting days for visa approval.
Flexibility to Live and Work in Two Countries
Dual citizens have the right to live, work, and travel freely in both countries without additional visas or work permits. This flexibility is highly beneficial for digital nomads and remote workers, allowing them to move between countries without staying duration limits. For example, holding Indonesian and Portuguese citizenship provides the right to live and work anywhere in the European Union using the Portuguese passport.
Tips for Maximizing Dual Citizenship While Traveling
If you are lucky to have, or plan to obtain dual citizenship, here are some tips to make the most of it while traveling:
Choose the Right Passport for Each Destination
Research which passport provides easier access to your destination. Use the passport that offers visa-free entry or the fastest immigration process. For example, if you hold Indonesian and British passports, use the British passport when traveling to European Union countries to enjoy visa-free access and faster EU citizen immigration lanes.
Be Consistent with Entry and Exit Passports
Some countries require you to use the same passport when entering and leaving their territory. Make sure to be consistent to avoid administrative issues at immigration. For children with dual citizenship in Indonesia, this rule is strict—they must use the same passport when entering and exiting Indonesia according to the Affidavit requirement.
Always Carry Both Passports
Even if you plan to use only one passport to enter a country, always carry both. This provides flexibility in case of issues with one passport or if you change your travel plans. Having a second passport also makes replacement easier if one is lost or stolen, ensuring your journey can continue smoothly.
Understand Tax Obligations in Both Countries
Consult an international tax expert to understand your tax obligations in both countries. Take advantage of existing double taxation agreements and report income correctly to avoid legal issues. Some countries, like the United States, require citizens to report global income even if living abroad. Ignorance is not a valid excuse for failing to meet tax obligations.
Keep Documents Updated
Ensure both passports are valid, especially considering the six-month validity requirement many countries enforce. Don’t wait until your passports are about to expire to renew them. Also, update other personal documents, such as ID cards, family cards, or children’s birth certificates, if there are changes in status or personal information.
Register at Embassies of Both Countries
If you plan to stay long-term in a third country, register at the embassies or consulates of both countries of your citizenship. This facilitates communication in emergencies and ensures you receive important updates from both governments.
Stay Informed About Immigration Regulations
Immigration and visa rules can change at any time. Keep up with updates from both of your countries of citizenship and the countries you frequently visit to avoid unpleasant surprises. Official websites of the foreign ministries and immigration departments are reliable sources to monitor regularly.
Conclusion
Dual citizenship offers remarkable advantages for travelers, especially in terms of easier visa access, travel flexibility, and the right to live and work in two countries. With two passports, you can enter more countries visa-free, pass through immigration lines faster, and enjoy benefits not available to single-passport holders.
