Citizenship is the legal bond between an individual and a state that carries a bundle of rights, duties, and protections. At its most basic, it answers the question of who belongs to a political community and on what terms. But the definition has never been purely legal. Sociologists describe citizenship as a fluid status produced through everyday practices and struggles, not just a line on a passport. That tension between the formal and the lived experience of belonging runs through nearly every debate about what citizenship really means.
The Legal Core
In legal terms, citizenship is the formal membership status that a sovereign state grants to a person, entitling them to a passport, the right to vote, eligibility for public office, consular protection abroad, and the right to reside in the country without restriction. In return, citizens typically owe duties such as paying taxes, obeying laws, and in some countries, performing military service or jury duty. This exchange of rights and obligations distinguishes citizenship from other immigration statuses like permanent residency or a work visa, which grant some but not all of these entitlements.
Most countries recognize at least two automatic pathways to citizenship at birth. Jus soli, or “right of the soil,” grants citizenship to anyone born on a country’s territory regardless of parentage. Jus sanguinis, or “right of blood,” passes citizenship from parent to child regardless of where the birth takes place. The United States, Canada, and most of Latin America lean heavily on jus soli. Much of Europe and Asia rely primarily on jus sanguinis. Many countries blend both principles, so a child born abroad to a citizen parent may acquire citizenship automatically but might need to register or meet residency conditions to keep it past a certain age.
A third pathway, naturalization, allows non-citizens to acquire citizenship later in life. This usually involves meeting a residency requirement, demonstrating language ability, passing a civics test, and renouncing or retaining a prior citizenship depending on the host country’s rules. The specifics vary enormously. Some countries require five years of residence; others require ten or more. Some demand proof of financial self-sufficiency; others do not.
How Naturalization Rules Shape Outcomes
The fine print of naturalization law matters more than people tend to assume. Across multiple countries and policy reforms, research shows that faster access to citizenship increases take-up and improves immigrants’ economic, educational, political, and social integration.1Labour Economics. Citizenship and integration In other words, when you shorten the waiting period or simplify the paperwork, more immigrants naturalize, and those who do tend to fare better on measures like employment, earnings, and civic participation.
The flip side is also well documented. When Denmark and the Netherlands introduced stricter language requirements and civic integration tests, researchers observed lower naturalization rates and significantly delayed timelines, especially among immigrants with less formal education.2European Sociological Review. Long-Term Heterogeneity in Immigrant Naturalization: The Conditional Relevance of Civic Integration and Dual Citizenship That finding complicates the popular narrative that integration tests simply ensure immigrants are “ready” for citizenship. The tests may filter out people who would have integrated well but lack the resources to clear administrative hurdles. Application fees have a similar gatekeeping effect; eligibility rules of all kinds influence not just who naturalizes, but who benefits from the rights that come with it.3Labour Economics. Citizenship and integration
Citizenship as Belonging, Not Just Paperwork
If you stop at the legal definition, you miss most of what citizenship means in daily life. A sociological concept of citizenship, especially what scholars call substantive citizenship, treats it as fundamentally a matter of belonging, including recognition by other members of the community.4American Sociological Review. Constructing Citizenship Someone can hold a passport and still be treated as an outsider because of their accent, skin color, religion, or neighborhood. Conversely, people without formal citizenship sometimes participate fully in a community’s economic and social life for decades. The gap between legal status and lived reality is one of the central puzzles in citizenship studies.
This distinction shows up vividly in research on young people from immigrant backgrounds. A study of Moroccan- and Turkish-origin youth in Belgium found that those who perceived a culturally different peer as fitting the national identity were more likely to identify strongly as Belgian themselves, both at the time and a year later.5PubMed Central. National Identity Development Among Minority Youth: Longitudinal Relations with National Fit Perceptions and School Belonging In plain terms, when minority youth felt the national story was broad enough to include people like them, they claimed it. When it was not, many did not, regardless of what their identity documents said. Citizenship in the psychological sense tracks how inclusive a society feels, not just what the law permits.
How Civic Identity Forms
The psychological side of citizenship goes beyond whether someone feels they belong to a nation. Researchers describe a broader phenomenon called civic identity: the way people come to see themselves as members of a political community with responsibilities toward it. Adolescents develop civic identity through a layered process that involves making personal connections between civic engagement and the self, and deepening those connections through interactions with others. At the most developed levels, young people connect their civic activities to larger social issues and ideas about social change.6Journal of Adolescent Research. Understanding Adolescents’ Civic Identity From a Narrative Perspective
Across different cultural settings, researchers have identified several psychological mechanisms that shape this process. The most common include absorbing civic content from the surrounding culture, imitating the civic behavior of role models, and personalizing what being a citizen means to you as an individual.7Collection of Research Papers “Problems of Modern Psychology”. Psychological Mechanisms of the Emergence, Development, and Establishment of Civic Identity Less common but still relevant mechanisms involve reflecting on direct experiences with the state and fellow citizens, and consciously thinking about what your own citizenship means. The point is that citizenship is partly something a government grants and partly something a person constructs internally over years through experience, conversation, and observation.
Dual and Multiple Citizenship
For a growing share of the world’s population, citizenship is not a single status. Dual citizenship provides access to secure legal status and rights in more than one country for an unprecedented number of migrants and their descendants worldwide.8International Migration Review. A Global Panel Dataset of Dyadic Dual Citizenship Acceptance The trend has accelerated over the past few decades as more countries have relaxed or eliminated rules that once required people to give up one citizenship before acquiring another.
Dual citizenship is valued for practical reasons: it can mean visa-free travel to more countries, the ability to work or retire in either place, access to two healthcare or education systems, and a safety net if political conditions deteriorate in one country. But it also raises thorny questions about allegiance, taxation, and military obligations. Some countries still do not allow it. Others tolerate it in practice while discouraging it in law. And a few actively market a second citizenship to wealthy individuals through investment programs, a phenomenon sometimes called “citizenship by investment” or “golden passports.” These programs have drawn academic scrutiny for how they reveal the limits of state sovereignty and the ways migration regimes are shaped by global inequalities.9PubMed Central. Global Fields and Migration Regimes: Citizenship by Investment
When Citizenship Is Taken Away
If citizenship can be granted, it can also be revoked, and the conditions under which governments strip people of their status are among the most contested areas of citizenship law. In recent years, hundreds of individuals have had their citizenship revoked, most commonly under national security justifications tied to counterterrorism efforts. Western governments in particular have increasingly turned to denaturalization as a tool against people accused of links to terrorist organizations.10The Boğaziçi Law Review. THE BOUNDARIES OF DISCRIMINATION IN CITIZENSHIP REVOCATION: LEGAL AND ETHICAL DILEMMAS FOR NATURALISED IMMIGRANTS
The practice raises serious legal and ethical concerns. Revocation almost always targets naturalized citizens, not those who acquired citizenship at birth, creating what critics describe as a two-tier system of membership. There is significant uncertainty about whether revoking someone’s citizenship complies with international legal standards, including a state’s obligations toward all people under its jurisdiction. When revocation renders a person stateless, meaning they hold no citizenship anywhere, it can cut them off from the right to work, travel, access healthcare, or even exist legally in any country. International law discourages statelessness, and several treaties require states to prevent it, but enforcement mechanisms remain weak.
Gender and Unequal Citizenship Laws
Citizenship law is not gender-neutral in every country. In some states, nationality laws discriminate against women in ways that affect not only the women themselves but also their children and spouses. Research on Pakistan’s nationality law, for instance, documents how gender-discriminatory citizenship rules undermine women’s access to healthcare, education, employment, family unity, inheritance, mobility, and property rights.11Central Asia. Gender Discrimination and its Impact on Pakistani Women Married to Afghan Refugees (1980-2018) Pakistani women married to Afghan refugees faced particular hardship because the law did not allow them to pass citizenship to their spouses or, in some circumstances, their children on equal terms with men.
As of the mid-2020s, roughly two dozen countries still have nationality laws that treat mothers and fathers differently when it comes to passing citizenship to children or spouses. The effects ripple outward: children born to a citizen mother and a non-citizen father may be stateless if the father’s country also does not grant citizenship automatically. These gaps in the law tend to be invisible to people living in countries where gender equality in citizenship has long been settled, but they remain a significant human rights issue globally.
Supranational Citizenship and the EU Model
Citizenship does not always map neatly onto a single nation-state. The most developed example of supranational citizenship is European Union citizenship, which every national of an EU member state holds automatically. EU citizenship is a nested membership in a multilevel polity: it operates at both the member-state level and the union level.12Theoretical Inquiries in Law. Why European Citizenship? Normative Approaches to Supranational Union In practice, this means EU citizens can live, work, and vote in local elections in any member state, not just their own. They also enjoy consular protection from any EU country’s embassy when abroad in a non-EU state where their home country has no representation.
The EU model sits on three pillars: democratic representation at the supranational level through the European Parliament, internal freedom of movement among member states, and defined geographic limits on expansion.13Theoretical Inquiries in Law. Why European Citizenship? Normative Approaches to Supranational Union It is not a replacement for national citizenship but an additional layer on top of it. You cannot be an EU citizen without being a citizen of a member state first, and if a country leaves the EU, as the United Kingdom did in 2020, its nationals lose EU citizenship rights. The arrangement is unique in scope, though smaller regional blocs around the world have experimented with similar free-movement agreements.
Municipal Citizenship and City-Level Belonging
At the opposite end of the scale from supranational citizenship, some cities have created their own forms of local membership. Municipal ID programs in places like New Haven, Connecticut, and San Francisco provide identification cards to all residents, including undocumented immigrants, that allow them to access basic city services and identify themselves to police and other officials.14Politics & Society. Municipal ID Cards for Undocumented Immigrants
These programs do not confer legal citizenship or override federal immigration law. City officials who designed them were careful to frame the cards as administrative tools for improving city operations, not as expansions of immigrant rights. But the practical effect is a form of local belonging: a person carrying a municipal ID can open a library account, interact with city agencies without fear of being asked about immigration status, and report crimes to police. Research on these programs found that officials navigated the tension between pro-immigrant advocates and opponents by emphasizing the health, safety, and welfare benefits for all residents, which let them promote the integration of undocumented immigrants without directly challenging federal authority.15Politics & Society. Municipal ID Cards for Undocumented Immigrants The result is a de facto, if limited, municipal citizenship that exists in the gap between federal law and local reality.
Digital Residency and the Platform State
Estonia’s e-residency program, launched in 2014, pushes the definition of state-individual relationships into even more unfamiliar territory. E-residency allows anyone in the world to apply for a government-issued digital ID that provides remote access to Estonian public and private online services, including the ability to register a business, sign documents digitally, and conduct banking. It is not citizenship or even physical residency; e-residents have no right to enter or live in Estonia. But research on how e-residents perceive the arrangement reveals something interesting: beyond the transactional, service-based relationship, some e-residents report a sense of membership in the Estonian state and describe the digital ID as a basis for transnational belonging.16TRAMES. ESTONIAN E-RESIDENCY AND CONCEPTIONS OF PLATFORM BASED STATE-INDIVIDUAL RELATIONSHIP
The digital state, in this framing, is not just a service provider but also a membership organization that enacts its own rules of inclusion through digital ID schemes.17TRAMES. ESTONIAN E-RESIDENCY AND CONCEPTIONS OF PLATFORM BASED STATE-INDIVIDUAL RELATIONSHIP Estonia has issued over 100,000 e-residency cards to people from more than 170 countries, mostly entrepreneurs looking for access to the EU single market’s digital infrastructure. The program does not challenge the traditional definition of citizenship, but it chips away at the assumption that a meaningful relationship between a person and a state requires physical presence or territorial ties. Whether other countries adopt similar models, and whether those models eventually shade into something closer to actual citizenship, remains an open question. For now, e-residency occupies a genuinely new category: not citizenship, not tourism, not immigration, but a digitally mediated tie to a state that its holders sometimes describe in terms that sound a lot like belonging.