Citizenship by Descent: Turning a Grandparent Into an EU Passport, and What It Changes When You Buy Property

Published on: July 22, 2026

Last reviewed: 22 July 2026. Nationality laws changed materially in 2024–2026 and continue to evolve; verify current rules before relying on any route.

Golden visas make headlines, but the cheapest second passport most people will ever encounter is usually hanging in the family tree. Citizenship by descent, jus sanguinis, the right of blood, lets millions of people claim citizenship of an EU country because a parent, grandparent or (in some countries) more distant ancestor was a citizen. No investment, no residence requirement in most cases, and typically total costs in the hundreds to low thousands of euros if you do the document work yourself.

For property buyers, the payoff goes well beyond a nicer passport queue. An EU passport changes what you're allowed to buy, where you're allowed to live in your own home, and how you plan your estate. It also happens to be the one route where the rules have been tightening fast (Italy rewrote its law in 2025), so timing matters.

How descent differs from every other route

Naturalization asks you to live somewhere for years. Investment programs ask for capital. Descent asks only one question: were you already a citizen at birth without knowing it? In countries like Italy, Ireland and Poland, qualifying applicants aren't "granted" citizenship; the state recognizes a citizenship they legally held all along. That distinction is why there's usually no language test, no residence requirement and no investment.

Country-by-country snapshot (mid-2026)

Italy: the rules changed in 2025. Here's where they stand

For three decades Italy recognized citizenship through an unbroken bloodline with no generational limit; great-great-grandchildren qualified. That era ended abruptly. Decree-Law 36/2025 (the "Tajani decree", 28 March 2025) was converted into Law 74/2025, in force since 24 May 2025, and in 2026 Italy's Constitutional Court upheld the reform (Judgment 63/2026), so authorities are applying it as the governing framework.

The practical shape of the new regime:

• Two-generation limit. Broadly, a person born abroad now qualifies automatically only where a parent or grandparent was born in Italy (or holds or held exclusively Italian citizenship), or where a citizen parent legally resided in Italy for at least two continuous years before the applicant's birth.
• Grandfathering. Applications submitted complete to a consulate, comune or court by 27 March 2025 are assessed under the old rules.
• Court routes survive for specific cases, notably "1948 cases": lines running through an Italian woman before 1948, when women couldn't transmit citizenship. These were always judicial rather than consular.
• A residence pathway remains: people of Italian descent who don't meet the new automatic criteria can still pursue citizenship after two years of legal residence in Italy, with no generational limit on that route.
• Transitional protections may apply to some minors recognized under the old rules.

The lesson generalizes: descent windows close. Spain's did in 2025, Luxembourg's in 2018, Italy's just narrowed dramatically. If you have a plausible claim anywhere, establishing it early is cheap insurance.

What an EU passport actually changes for a property buyer

1. Purchase restrictions disappear across much of Europe. Several countries restrict non-EU buyers specifically: Austria's provinces require approvals that EU citizens are largely exempt from; Poland requires a ministry permit for non-EEA buyers of houses and land; Hungary requires an authorization; Croatia applies reciprocity rules to non-EU nationals; Malta's AIP permit regime treats EU citizens far more generously; Finland requires a defence-ministry permit for non-EU/EEA buyers. An EU passport takes you out of scope of most of these. (Nuances remain even for EU citizens: Denmark's holiday-home rules and Switzerland's Lex Koller turn on residence, not passport alone. And citizenship-based bans in third countries, like Canada's foreign-buyer ban, aren't affected by an EU passport at all.)

2. Spain's proposed non-EU surcharge wouldn't touch you. Spain's much-publicized proposal for a tax of up to 100% on resale purchases by non-EU non-residents was submitted to parliament in May 2025 and, as of mid-2026, has still not been voted on; it is not law, and reporting through spring 2026 describes it as stalled. But its design says everything: EU citizens and residents are exempt. Whatever version of buyer-restriction politics arrives next in Europe, an EU passport is the durable exemption.

3. The 90/180 clock stops mattering. Non-EU owners of European homes live by the Schengen 90/180 rule. EU citizens can occupy their own property year-round, in any member state, indefinitely: no visa, no counting days.

4. Residence unlocks resident-grade financing. Mortgage terms in many European markets differ sharply between residents and non-residents. Citizenship gives you the right to become a resident anywhere in the EU, which in turn can open loan-to-value ratios and rates reserved for locals.

5. Estate planning gets a powerful tool. Under the EU Succession Regulation, you can generally elect the inheritance law of your nationality to govern your estate: a significant lever for owners of property in forced-heirship countries like France or Spain.

Process, cost and the classic pitfalls

The work is genealogical before it is legal: birth, marriage, death and, critically, naturalization records for every link in the chain, apostilled and translated. The chain-breaker in most systems is an ancestor who naturalized elsewhere before the next person in line was born; in that moment, citizenship often stopped transmitting. Name-spelling discrepancies across old records are the second great time-sink.

Doing it yourself, expect government and document fees in the hundreds of euros plus translation and apostille costs; full-service providers commonly charge a few thousand to five figures depending on complexity. Timelines range from months (Ireland's register) to years (court cases and backlogged consulates).

Before you spend anything, check three things

• The chain: did any ancestor naturalize elsewhere before the next generation was born?
• The window: is the route you qualify for still open, and is a reform pending?
• Both passports: does your current country, and the new one, allow dual citizenship?

Frequently asked questions

Is citizenship by descent the same as a golden visa?
No. Descent recognizes a citizenship you arguably already hold: no investment, and usually no residence requirement. Golden visas are residence permits purchased through qualifying investment, with citizenship (if ever) years away.

My great-grandparent was Italian. Am I out of luck now?
Under the automatic rules, generally yes since 2025, but check the exceptions: a grandparent born in Italy, a parent's two-year residence in Italy before your birth, a pre-1948 female-line court case, or the two-year residence route can each revive a claim.

Does an EU passport help with Canada's or other non-EU countries' buyer bans?
No. Restrictions tied to a specific country's own citizenship or residency (Canada is the prominent example) are unaffected. The EU passport solves European restrictions.

Can I hold dual citizenship?
Italy, Ireland, Portugal, Hungary and Poland generally allow it; some countries (and your current country) may not, or only conditionally. Check both ends; see our dual citizenship matrix.

The bottom line

If any branch of your family tree runs through Europe, price the paperwork before you price a golden visa. A recognized ancestral citizenship costs hundreds to low thousands of euros if you do the work yourself, removes purchase restrictions, retires the 90/180 count and hands you an estate-planning lever. And the recent lesson from Italy, Spain and Luxembourg is that the windows do not stay open: verify the chain, gather the records, and file while the route you qualify for still exists.

Sources & further reading

• Italy, Law 74/2025 converting Decree-Law 36/2025 on citizenship by descent (normattiva.it); Constitutional Court Judgment 63/2026 (cortecostituzionale.it)
• Ireland, Department of Foreign Affairs, Foreign Births Register (ireland.ie)
• Germany, Federal Office of Administration, citizenship by declaration under StAG §5 (bva.bund.de)
• Spain, Democratic Memory Law (Law 20/2022) nationality provisions (boe.es)
• EU Succession Regulation No 650/2012 (eur-lex.europa.eu)

Rules cited are as of July 2026; nationality law is politically active territory and changes with little warning.

This article is general information, not legal advice. Nationality laws changed materially in 2024–2026 and continue to evolve; verify current rules with the relevant consulate or a qualified nationality lawyer before relying on any route.

JanusHermes is the cross-border real estate intelligence platform built for international buyers operating across 50+ countries. Explore markets, costs, and country-level intelligence at janushermes.com.

Related reading on JanusHermes

• Dual Citizenship Matrix (2026): Which Countries Allow It, Which Require Renunciation
• From Residency to Passport: How Long After Buying Property Until Citizenship? A Country-by-Country Timeline
• The 90/180 Schengen Rule for Second-Home Owners in 2026: How Brits and Non-EU Owners Can Legally Spend More Than 90 Days in Their Own EU Property
• Does Buying Property Abroad Actually Get You Residency or Citizenship? The Myth vs Reality, Country by Country (2026)