A person may have multiple citizenships. A person who does not have citizenship of any state is said to be stateless, while one who lives on state borders whose territorial status is uncertain is a border-lander.
Nationality is often used as a synonym for citizenship in English – notably in international law – although the term is sometimes understood as denoting a person's membership of a nation (a large ethnic group). In some countries, e.g. the United States, the United Kingdom, nationality and citizenship can have different meanings (for more information, see Nationality versus citizenship).
Each country has its own policies, regulations and criteria as to who is entitled to its citizenship.
- Citizenship by birth (jus sanguinis). If one or both of a person's parents are citizens of a given state, then the person may have the right to be a citizen of that state as well. Formerly this might only have applied through the paternal line, but sex equality became common since the late twentieth century. Citizenship is granted based on ancestry or ethnicity and is related to the concept of a nation state common in Europe. Where jus sanguinis holds, a person born outside a country, one or both of whose parents are citizens of the country, is also a citizen. Some states (United Kingdom, Canada) limit the right to citizenship by descent to a certain number of generations born outside the state; others (Germany, Ireland) grant citizenship only if each new generation is registered with the relevant foreign mission within a specified deadline; while others (France, Switzerland, Italy) have no limitation on the number of generations born abroad who can claim citizenship of their ancestors' country. This form of citizenship is common in civil law countries.
- Born within a country (jus soli). Some people are automatically citizens of the state in which they are born. This form of citizenship originated in England, where those who were born within the realm were subjects of the monarch (a concept pre-dating citizenship) and is common in common law countries. Most countries in the Americas grant unconditional jus soli citizenship, while it has been limited or abolished in almost all other countries. In many cases, both jus soli and jus sanguinis hold citizenship either by place or parentage (or both).
- Citizenship by marriage (jus matrimonii). Many countries fast-track naturalization based on the marriage of a person to a citizen. Countries which are destinations for such immigration often have regulations to try to detect sham marriages, where a citizen marries a non-citizen typically for payment, without them having the intention of living together. Many countries (United Kingdom, Germany, United States, Canada) allow citizenship by marriage only if the foreign spouse is a permanent resident of the country in which citizenship is sought; others (Switzerland, Luxembourg) allow foreign spouses of expatriate citizens to obtain citizenship after a certain period of marriage, and sometimes also subject to language skills and proof of cultural integration (e.g. regular visits to the spouse's country of citizenship).
- Naturalization. States normally grant citizenship to people who have entered the country legally and been granted permit to stay, or been granted political asylum, and also lived there for a specified period. In some countries, naturalization is subject to conditions which may include passing a test demonstrating reasonable knowledge of the language or way of life of the host country, good conduct (no serious criminal record) and moral character (such as drunkenness, or gambling), vowing allegiance to their new state or its ruler and renouncing their prior citizenship. Some states allow dual citizenship and do not require naturalized citizens to formally renounce any other citizenship.
- Citizenship by investment or Economic Citizenship. Wealthy people invest money in property or businesses, buy government bonds or simply donate cash directly, in exchange for citizenship and a passport. Whilst legitimate and usually limited in quota, the schemes are controversial. Costs for citizenship by investment range from as little as $100,000 (£74,900) to as much as €2.5m (£2.19m)
- Excluded categories.
Many thinkers point to the concept of citizenship beginning in the early city-states of ancient Greece, although others see it as primarily a modern phenomenon dating back only a few hundred years and, for humanity, that the concept of citizenship arose with the first laws. Polis meant both the political assembly of the city-state as well as the entire society. Citizenship concept has generally been identified as a western phenomenon. There is a general view that citizenship in ancient times was a simpler relation than modern forms of citizenship, although this view has come under scrutiny. The relation of citizenship has not been a fixed or static relation, but constantly changed within each society, and that according to one view, citizenship might "really have worked" only at select periods during certain times, such as when the Athenian politician Solon made reforms in the early Athenian state.
Slavery permitted slaveowners to have substantial free time, and enabled participation in public life.Epochs%20of%20European%20Civi]]Polis citizenship was marked by exclusivity. Inequality of status was widespread; citizens (πολίτης igher status than non-citizens, such as women, slaves, and resident foreigners (metics). The first form of citizenship was based on the way people lived in the ancient Greek times, in small-scale organic communities of the polis. Citizenship was not seen as a separate activity from the private life of the individual person, in the sense that there was not a distinction between public and private life. The obligations of citizenship were deeply connected into one's everyday life in the polis. These small-scale organic communities were generally seen as a new development in world history, in contrast to the established ancient civilizations of Egypt or Persia, or the hunter-gatherer bands elsewhere. From the viewpoint of the ancient Greeks, a person's public life was not separated from their private life, and Greeks did not distinguish between the two worlds according to the modern western conception. The obligations of citizenship were deeply connected with everyday life. To be truly human, one had to be an active citizen to the community, which Aristotle famously expressed: "To take no part in the running of the community's affairs is to be either a beast or a god!" This form of citizenship was based on obligations of citizens towards the community, rather than rights given to the citizens of the community. This was not a problem because they all had a strong affinity with the polis; their own destiny and the destiny of the community were strongly linked. Also, citizens of the polis saw obligations to the community as an opportunity to be virtuous, it was a source of honour and respect. In Athens, citizens were both ruler and ruled, important political and judicial offices were rotated and all citizens had the right to speak and vote in the political assembly.
In the Roman Empire, citizenship expanded from small-scale communities to the entirety of the empire. Romans realized that granting citizenship to people from all over the empire legitimized Roman rule over conquered areas. Roman citizenship was no longer a status of political agency, as it had been reduced to a judicial safeguard and the expression of rule and law. Rome carried forth Greek ideas of citizenship such as the principles of equality under the law, civic participation in government, and notions that "no one citizen should have too much power for too long",Epochs%20of%20European%20Civi]]but Rome offered relatively generous terms to its captives, including chances for lesser forms of citizenship. the Roman sense increasingly reflected the fact that citizens could act upon material things as well as other citizens, in the sense of buying or selling property, possessions, titles, goods. One historian explained:
Roman citizenship reflected a struggle between the upper-class patrician interests against the lower-order working groups known as the plebeian class. A citizen came to be understood as a person "free to act by law, free to ask and expect the law's protection, a citizen of such and such a legal community, of such and such a legal standing in that community". Citizenship meant having rights to have possessions, immunities, expectations, which were "available in many kinds and degrees, available or unavailable to many kinds of person for many kinds of reason". The law itself was a kind of bond uniting people. Roman citizenship was more impersonal, universal, multiform, having different degrees and applications.
During the European Middle Ages, citizenship was usually associated with cities and towns, and applied mainly to middle class folk. Titles such as burgher, grand burgher (German Großbürger) and bourgeoisie denoted political affiliation and identity in relation to a particular locality, as well as membership in a mercantile or trading class; thus, individuals of respectable means and socioeconomic status were interchangeable with citizens.
During this era, members of the nobility had a range of privileges above commoners (see aristocracy), though political upheavals and reforms, beginning most prominently with the French Revolution, abolished privileges and created an egalitarian concept of citizenship.
During the Renaissance, people transitioned from being subjects of a king or queen to being citizens of a city and later to a nation. Each city had its own law, courts, and independent administration. And being a citizen often meant being subject to the city's law in addition to having power in some instances to help choose officials. City dwellers who had fought alongside nobles in battles to defend their cities were no longer content with having a subordinate social status, but demanded a greater role in the form of citizenship. Membership in guilds was an indirect form of citizenship in that it helped their members succeed financially. The rise of citizenship was linked to the rise of republicanism, according to one account, since independent citizens meant that kings had less power. Citizenship became an idealized, almost abstract, concept, and did not signify a submissive relation with a lord or count, but rather indicated the bond between a person and the state in the rather abstract sense of having rights and duties.
The modern idea of citizenship still respects the idea of political participation, but it is usually done through "elaborate systems of political representation at a distance" such as representative democracy. Modern citizenship is much more passive; action is delegated to others; citizenship is often a constraint on acting, not an impetus to act. Nevertheless, citizens are usually aware of their obligations to authorities, and are aware that these bonds often limit what they can do.
From 1790 until the mid-twentieth century, United States law used racial criteria to establish citizenship rights and regulate who was eligible to become a naturalized citizen. The Naturalization Act of 1790, the first law in U.S. history to establish rules for citizenship and naturalization, barred citizenship to all people who were not of European descent, stating that "any alien being a free white person, who shall have resided within the limits and under the jurisdiction of the United States for the term of two years, may be admitted to become a citizen thereof."
Under early U.S. laws, African Americans were not eligible for citizenship.
It was not until the abolition of slavery following the American Civil War that African Americans were granted citizenship rights. The 14th Amendment to the U.S. Constitution, ratified on July 9, 1868, stated that "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." Two years later, the Naturalization Act of 1870 would extend the right to become a naturalized citizen to include "aliens of African nativity and to persons of African descent".
Despite the gains made by African Americans after the Civil War, Native Americans, Asians, and others not considered "free white persons" were still denied the ability to become citizens.
Native Americans were not granted full US citizenship until the passage of the Indian Citizenship Act in 1924. However, even well into the 1960s some state laws prevented Native Americans from exercising their full rights as citizens, such as the right to vote. In 1962, New Mexico became the last state to enfranchise Native Americans.
It was not until the passage of the Immigration and Nationality Act of 1952 that the racial and gender restrictions for naturalization were explicitly abolished. However, the act still contained restrictions regarding who was eligible for US citizenship, and retained a national quota system which limited the number of visas given to immigrants based on their national origin, to be fixed "at a rate of one-sixth of one percent of each nationality's population in the United States in 1920". It was not until the passage of the Immigration and Nationality Act of 1965 that these immigration quota systems were drastically altered in favor of a less discriminatory system.
The 1918 constitution of revolutionary Russia granted citizenship to any foreigners who were living within Russia, so long as they were "engaged in work and [belonged] to the working class." It recognized "the equal rights of all citizens, irrespective of their racial or national connections" and declared oppression of any minority group or race "to be contrary to the fundamental laws of the Republic." The 1918 constitution also established the right to vote and be elected to soviets for both men and women "irrespective of religion, nationality, domicile, etc. [...] who shall have completed their eighteenth year by the day of election." The later constitutions of the USSR would grant universal Soviet citizenship to the citizens of all member republics in concord with the principles of non-discrimination laid out in the original 1918 constitution of Russia.
National Socialism or "Nazism", the German variant of twentieth century fascism whose precepts were laid out in Adolf Hitler's Mein Kampf, classified inhabitants of the nation into three main hierarchical categories, each of which would have different rights and duties in relation to the state: citizens, subjects, and aliens. The first category, citizens, were to possess full civic rights and responsibilities. Citizenship would be conferred only on males of German (or so-called "Aryan") heritage who had completed military service, and could be revoked at any time by the state. The Reich Citizenship Law of 1935 established racial criteria for citizenship in the German Reich, and because of this law Jews and others who could not prove "German" racial heritage were stripped of their citizenship.
The second category, subjects, referred to all others who were born within the nation's boundaries who did not fit the racial criteria for citizenship.
The final category, aliens, referred to those who were citizens of another state, who also had no rights.
Citizenship status, under social contract theory, carries with it both rights and duties. In this sense, citizenship was described as "a bundle of rights -- primarily, political participation in the life of the community, the right to vote, and the right to receive certain protection from the community, as well as obligations." Citizenship is seen by most scholars as culture-specific, in the sense that the meaning of the term varies considerably from culture to culture, and over time. In China, for example, there is a cultural politics of citizenship which could be called "peopleship".
How citizenship is understood depends on the person making the determination.
Citizenship is a status in society.
Modern citizenship has often been looked at as two competing underlying ideas:
- The liberal-individualist or sometimes liberal conception of citizenship suggests that citizens should have entitlements necessary for human dignity. It assumes people act for the purpose of enlightened self-interest. According to this viewpoint, citizens are sovereign, morally autonomous beings with duties to pay taxes, obey the law, engage in business transactions, and defend the nation if it comes under attack, but are essentially passive politically, and their primary focus is on economic betterment. This idea began to appear around the seventeenth and eighteenth centuries, and became stronger over time, according to one view. According to this formulation, the state exists for the benefit of citizens and has an obligation to respect and protect the rights of citizens, including civil rights and political rights. It was later that so-called social rights became part of the obligation for the state.
- The civic-republican or sometimes classical or civic humanist conception of citizenship emphasizes man's political nature, and sees citizenship as an active process, not a passive state or legal marker. It is relatively more concerned that government will interfere with popular places to practice citizenship in the public sphere. Citizenship means being active in government affairs. According to one view, most people today live as citizens according to the liberal-individualist conception but wished they lived more according to the civic-republican ideal. An ideal citizen is one who exhibits "good civic behavior". Free citizens and a republic government are "mutually interrelated." Citizenship suggested a commitment to "duty and civic virtue".
Scholars suggest that the concept of citizenship contains many unresolved issues, sometimes called tensions, existing within the relation, that continue to reflect uncertainty about what citizenship is supposed to mean. Some unresolved issues regarding citizenship include questions about what is the proper balance between duties and rights. Another is a question about what is the proper balance between political citizenship versus social citizenship. Some thinkers see benefits with people being absent from public affairs, since too much participation such as revolution can be destructive, yet too little participation such as total apathy can be problematic as well. Citizenship can be seen as a special elite status, and it can also be seen as a democratizing force and something that everybody has; the concept can include both senses. According to sociologist Arthur Stinchcombe, citizenship is based on the extent that a person can control one's own destiny within the group in the sense of being able to influence the government of the group. One last distinction within citizenship is the so-called consent descent distinction, and this issue addresses whether citizenship is a fundamental matter determined by a person choosing to belong to a particular nation––by their consent––or is citizenship a matter of where a person was born––that is, by their descent.
Some intergovernmental organizations have extended the concept and terminology associated with citizenship to the international level, where it is applied to the totality of the citizens of their constituent countries combined. Citizenship at this level is a secondary concept, with rights deriving from national citizenship.
An agreement known as the amended EC Treaty established certain minimal rights for European Union citizens. Article 12 of the amended EC Treaty guaranteed a general right of non-discrimination within the scope of the Treaty. Article 18 provided a limited right to free movement and residence in Member States other than that of which the European Union citizen is a national. Articles 18-21 and 225 provide certain political rights.
Union citizens have also extensive rights to move in order to exercise economic activity in any of the Member States which predate the introduction of Union citizenship.
The concept of "Commonwealth Citizenship" has been in place ever since the establishment of the Commonwealth of Nations. As with the EU, one holds Commonwealth citizenship only by being a citizen of a Commonwealth member state. This form of citizenship offers certain privileges within some Commonwealth countries:
- Some such countries do not require tourist visas of citizens of other Commonwealth countries, or allow some Commonwealth citizens to stay in the country for tourism purposes without a visa for longer than citizens of other countries.
- In some Commonwealth countries, resident citizens of other Commonwealth countries are entitled to political rights, e.g., the right to vote in local and national elections and in some cases even the right to stand for election.
- In some instances the right to work in any position (including the civil service) is granted, except for certain specific positions, such as in the defense departments, Governor-General or President or Prime Minister.
- In the United Kingdom, all Commonwealth citizens legally residing in the country can vote and stand for office at all elections.
Although Ireland was excluded from the Commonwealth in 1949 because it declared itself a republic, Ireland is generally treated as if it were still a member. Legislation often specifically provides for equal treatment between Commonwealth countries and Ireland and refers to "Commonwealth countries and Ireland". Ireland's citizens are not classified as foreign nationals in the United Kingdom.
Canada departed from the principle of nationality being defined in terms of allegiance in 1921.
Citizenship most usually relates to membership of the nation state, but the term can also apply at the subnational level.
The United States has a federal system in which a person is a citizen of their specific state of residence, such as New Jersey or California, as well as a citizen of the United States. State constitutions may grant certain rights above and beyond what are granted under the United States Constitution and may impose their own obligations including the sovereign right of taxation and military service; each state maintains at least one military force subject to national militia transfer service, the state's national guard, and some states maintain a second military force not subject to nationalization.
"Active citizenship]" is the philosophy that citizens should work towards the betterment of their community through economic participation, public, volunteer work, and other such efforts to improve life for all citizens. In this vein, citizenship education is taught in schools, as an academic subject in some countries. By the time children reach secondary education there is an emphasis on such unconventional subjects to be included in academic curriculum. While the diagram on citizenship to the right is rather facile and depth-less, it is simplified to explain the general model of citizenship that is taught to many secondary school pupils. The idea behind this model within education is to instill in young pupils that their actions (i.e. their vote) affect collective citizenship and thus in turn them.
It is taught in the Republic of Ireland as an exam subject for the Junior Certificate. It is known as Civic, Social and Political Education (CSPE). A new Leaving Certificate exam subject with the working title 'Politics & Society' is being developed by the National Council for Curriculum and Assessment (NCCA) and is expected to be introduced to the curriculum sometime after 2012.
Citizenship is offered as a General Certificate of Secondary Education (GCSE) course in many schools in the United Kingdom. As well as teaching knowledge about democracy, parliament, government, the justice system, human rights and the UK's relations with the wider world, students participate in active citizenship, often involving a social action or social enterprise in their local community.
- Citizenship is a compulsory subject of the National Curriculum in state schools in England for all pupils aged 11–16. Some schools offer a qualification in this subject at GCSE and A level. All state schools have a statutory requirement to teach the subject, assess pupil attainment and report student's progress in citizenship to parents.
- In Wales the model used is Personal and Social Education.
- Citizenship is not taught as a discrete subject in Scottish schools, but is a cross-curricular strand of the Curriculum for Excellence. However they do teach a subject called "Modern Studies" which covers the social, political and economic study of local, national and international issues.
- Citizenship is taught as a standalone subject in all state schools in Northern Ireland and most other schools in some forms from year 8 to 10 prior to GCSEs. Components of Citizenship are then also incorporated into GCSE courses such as 'Learning for Life and Work'.
Criticism of citizenship education in schools
There are two kinds of criticism of citizenship education in schools.
- Citizenship in Canada
- Citizenship in Germany
- Citizenship in the United States
- Citizen in uniform
- Global citizenship
- History of citizenship
- Honorary citizenship Honorary Canadian citizenship Honorary citizen of the United States
- Non-citizens (Latvia)
- Spatial citizenship
- Transnational citizenship