Europe wrote the rules of citizenship by descent, and Europe is now rewriting them. Italy’s 2025 decree cut the line at the grandparent, and the market that had grown up around unlimited Italian ancestry started looking for alternatives.
Most of what it found runs on a different logic. European descent laws tend to treat citizenship as a bloodline that passes indefinitely unless someone breaks it. Outside Europe, the common model is registration: a citizen’s child born abroad is a citizen too, provided somebody files the paperwork, and the chain usually ends there.
Daniel Atz of LuxCitizenship reads the difference as historical. “Europe’s unusually extensive descent rules partly reflect generations of mass emigration and long-established legal relationships with diasporas,” he says.
“Elsewhere, modern states may have different histories, newer diasporas, or stronger traditions of singular nationality.”
The exceptions are the interesting part. Armenia grants citizenship on proof of Armenian origin, with no residence requirement, though a draft law would add one from 2028. Chile and Israel reach the grandchild. Vietnam reopened the door for descendants in 2025, and the Philippines lets its former citizens come back with their minor children.
Each route below is in force, and each description comes from the statute or consular sources that apply it.
Latin America, One Generation Deep
Four of the region’s largest countries give citizenship at birth to the children of citizens born abroad, and all four deliver it through consular birth registration rather than an application.
🇲🇽 Mexico’s consulates register children born abroad to at least one Mexican parent as Mexicans by birth. The Los Angeles consulate’s checklist asks for the child’s original foreign birth certificate, the Mexican parent’s birth certificate, and photo identification for both. Adults may register themselves, and the process takes two appointments: one to review documents and one to sign and fingerprint.
The chain runs one link at a time. A Mexican by birth born abroad is a Mexican parent for the next generation, so his children qualify in turn, but a grandchild cannot skip the step if the parent never registered.
That chain rests on a 2021 constitutional reform. Since then, Atz notes, “a Mexican parent no longer needs to have been born in Mexico to transmit nationality, allowing nationality to continue through generations where the intermediate generation is recognized as Mexican.”
He calls it “the program we saw most operationalized outside Europe until Canada’s changes took effect at the end of 2025.”
🇧🇷 Brazil writes the rule into Article 12 of its constitution. A person born abroad to a Brazilian father or mother is Brazilian by birth if registered at a competent Brazilian office, or if he comes to live in Brazil and opts for Brazilian nationality at any time after reaching majority. The two routes mean an unregistered child does not lose the right; he exercises it from inside Brazil instead.
🇨🇴 Colombia’s Article 96 treats children of a Colombian father or mother born abroad as nationals by birth once they either take up domicile in Colombia or register at a consulate. Late registration by adults is allowed, with witness statements in place of a timely declaration.
🇵🇪 Peru used to cut the right off at 18. A 2018 constitutional reform to Article 52 removed the rule that children of Peruvians born abroad could only be registered as minors, and they may now register at any age.
Argentina’s Option and Chile’s Grandchild Rule
🇦🇷 Argentina does not register children of citizens as Argentine; it lets them choose. Under the nationality-by-option procedure on the foreign ministry’s site, the child of a native-born Argentine who was born abroad may opt for Argentine citizenship at a consulate, with a legalized foreign birth certificate, a valid foreign identity document, and the Argentine parent’s birth certificate.
The consulate is not the only door. “The option doesn’t have to go through a consulate,” says Martín Hecht of MH Legal Hub. “It can be filed in Argentina; it’s sometimes faster than going through a consulate.”
Hecht sees growing demand from first- and second-generation Americans, as “a lot of Argentine grandparents are starting to emerge from family records.”
Minors opt through the parents who hold parental responsibility; adults appear in person, and each family member needs a separate appointment.
Two limits follow from the wording: the parent must be Argentine by birth, not by naturalization, and the page offers nothing for grandchildren. At consulates, a grandchild qualifies only if the parent opted first.
Hecht says “most consulates are unwilling to take grandchildren cases at all,” but “in Buenos Aires, it’s a different story.”
More applicants trip over the process itself: they “apply in the wrong place, like the Immigration Department,” rely on incomplete information online, or struggle to obtain old birth certificates.
The misconceptions he hears most are that an Argentine-born child passes citizenship up to the parents, that marriage confers it, and that any Argentine ancestor counts. “None of them is true,” he says. “The chain stops at the grandparent, and marriage or an Argentine-born child opens the door to residency, not to the option.”
🇨🇱 Chile reaches one generation further. Since a 2005 amendment, Article 10 of the constitution makes a person born abroad Chilean if one of his parents or grandparents acquired Chilean nationality by birth in Chile, by naturalization, or by special grant. The earlier requirement that the parent had lived in Chile for a year was dropped at the same time.
The grandchild of a Chilean therefore registers directly at a consulate, with the documents that prove the grandparent’s nationality, even if the parent never did. That makes Chile the only Latin American route in this piece that reaches the grandchild by law.
🇦🇲 Armenia: Origin, No Residence (for Now)
Armenia’s route is the broadest in this piece, and the shortest to describe. Article 13 of the Law on Citizenship lets a person “of Armenian origin, i.e. has Armenian predecessors” acquire citizenship without the three years of residence and the Armenian-language requirement that apply to everyone else. The statute counts no generations and sets no cut-off date.
The same article covers two narrower groups: people whose parent was an Armenian citizen or was born in Armenia, who must apply within three years of turning 18, and spouses and parents of Armenian citizens. Dual citizenship is permitted, and the law treats a dual national as Armenian only, for its own purposes.
What the statute does not say is how origin is proven. That is left to government regulation, and in practice the document Yerevan accepts most readily is a baptismal certificate from an Armenian church, legalized by an Armenian embassy. Birth or family records recording Armenian ethnicity can serve where no baptism was recorded.
In practice, the proof sets a limit the statute does not. “The recognized proof reaches a parent, grandparent, or sibling, so a claim resting on a great-grandparent alone has no listed route,” says Nerses Isajanyan of Vardanyan & Partners.
The President grants citizenship by decree, with review of up to 90 working days and longer where security checks are raised. Government fees are nominal. The law’s most recent amendment dates from December 11, 2023.
The route may not stay this open. On September 8, the Ministry of Internal Affairs published draft laws that would require two calendar years of lawful residence and at least 366 days of physical presence in Armenia, from a proposed start date of January 1, 2028. Isajanyan had expected a residence permit requirement, but “the drafts go further,” and nothing has been tabled in parliament yet.
The drafts would also have a dedicated commission check Armenian origin, require that the oath be taken in Armenia, and raise the state duty five-fold to AMD 250,000.
For applicants, Isajanyan says, the detail that matters is the transitional rule: applications filed before the start date “would be examined under the current rules. Since the wait for a filing appointment already runs to several months, anyone who starts in late 2027 risks missing the cut-off.”
Russian Armenians file the most applications, Isajanyan says, followed by applicants from Lebanon, Syria, Iran, and other former Soviet republics, then the Western diaspora. “Most want the passport.” The minority who settle come mainly from the Middle East and the former Soviet space, while “applicants from Western countries rarely move here.”
The Asian Routes: Reacquisition More Than Descent
East and Southeast Asia’s nationality laws descend from a tradition that distrusts dual nationality, and the routes that exist are mostly for people who once held the citizenship, or whose parents did, rather than for distant descendants.
🇵🇭 The Philippines has the clearest. Republic Act 9225 lets a natural-born Filipino who lost citizenship by naturalizing abroad take it back by oath at an embassy. The Madrid embassy’s checklist asks for the Philippine birth certificate, the old Philippine passport if it survives, the foreign naturalization certificate, and the current foreign passport. Unmarried children under 18 are deemed Filipino with the parent.
For a child born abroad to a Filipino parent, the equivalent step is a Report of Birth at the consulate, which then serves as the Philippine birth certificate for any later application. The route stops with that generation unless the child in turn registers his own.
🇯🇵 Japan transmits nationality to a child born abroad to a Japanese parent, but the Nationality Act requires that the nationality be reserved within three months of birth when the child also acquires a foreign one, or it is lost. The Ministry of Justice page on the choice of nationality then sets the second clock: a person who holds two nationalities from before 18 must choose one before turning 20, and one who acquires the second later has two years. A Japanese grandparent confers nothing on his own.
🇰🇷 South Korea offers residence rather than citizenship. The F-4 Overseas Korean visa, as the Los Angeles consulate describes it, is open to former Korean nationals and their lineal descendants, proven through the ancestor’s family register and the applicant’s birth certificate. It is a five-year multiple-entry visa with two-year stays and near-full work rights, and it is the usual first step toward restoration of nationality for those who want it.
🇻🇳 Vietnam moved in 2025. The National Assembly passed an amended Law on Vietnamese Nationality on June 24, in force from July 1, that eases restoration for people who lost the nationality and acquisition for those with Vietnamese parents or grandparents. Qualifying applicants may keep a foreign nationality with the President’s approval, and applications can now be filed at Vietnamese missions abroad.
🇹🇼 Taiwan transmits nationality to a child born abroad to a Republic of China national, but nationality and residence are separate. Such a child is a “national without household registration,” with a passport but no right to live in Taiwan until he obtains household registration under the National Immigration Agency’s guidelines, which run through a permanent resident certificate and entry within six months.
Beyond These Regions: Canada, Jamaica, and Africa
🇨🇦 “The standout in 2026, particularly from a US perspective, is Canada,” Atz says. Bill C-3, in force since December 15, 2025, extends citizenship to second and later generations born abroad before that date.
Children born abroad since then qualify only if their Canadian parent, if also born abroad, had spent at least 1,095 days in Canada first.
🇯🇲 Jamaica “expressly permits citizenship by descent where the parent is himself or herself Jamaican by descent, so the law can reach beyond the first generation abroad,” he notes, though he has not handled the procedure himself.
🇧🇯 Africa is where Atz expects more openings. Benin’s Afro-descendant nationality law lets qualifying descendants of people deported from sub-Saharan Africa through the transatlantic slave trade seek Beninese nationality, and Ghana runs a separate Right of Abode framework for the diaspora.
“More countries may follow suit as governments look for ways to reconnect with increasingly established second- and third-generation diasporas,” he says.
