Most people never choose their citizenship. It was chosen for them, centuries before they were born, by rules shaped by feudal obligation, colonial settlement, or ethnic nationalism. Three Latin phrases capture the main doctrines.
Ius soli, right of the soil, ties citizenship to where you are born. Ius sanguinis, right of blood, passes it through parentage. And ius pecuniae, right of money, skips both and grants it for an economic contribution instead.
Other paths exist (marriage, naturalization through long residence, discretionary exception), but these three form the structural bedrock.
The unusual thing about this moment is that the first two are contracting simultaneously. The third keeps expanding. That combination has no precedent.
Soil
Edward Coke’s 1608 ruling in Calvin’s Case established that anyone born under the king’s dominion was a natural subject. Colonial powers carried the principle across the Atlantic for a blunt reason: settler states needed bodies, and birthright citizenship was the fastest way to build a population.
The American version, written into the 14th Amendment in 1868 to protect the citizenship of formerly enslaved people, is the world’s most prominent example. At least 33 countries still apply unconditional ius soli, according to the CIA World Factbook, and all but six sit in the Western Hemisphere per a Library of Congress survey.
That number has been shrinking for decades. Britain ended unconditional birthright citizenship in 1981. Australia followed in 1986.
India restricted it in 1987, then again in 2004.
Ireland held out longest in Europe. A 2005 referendum, triggered by the Chen birth-tourism case, saw 79% of voters approve a constitutional amendment eliminating it.
No European country now offers unconditional ius soli; France, Germany, and Portugal maintain conditional variants requiring parental residence, but the trajectory tells one story only.
President Trump’s Executive Order No. 14160, signed January 20, 2025, would strip automatic citizenship from children born to undocumented or temporary-visa parents. Every federal court to review it issued an injunction.
The Supreme Court, in Trump v. CASA (June 2025), dismantled the universal injunctions without reaching the merits. It accepted Barbara v. Trump for full review in December 2025, and oral arguments are expected by summer 2026.
If the order survives, the United States would become the first developed nation to curtail ius soli by executive fiat rather than legislation or referendum. That alone would make 2026 a watershed year in citizenship law.
Blood
Ius sanguinis is the global default. The Napoleonic Code popularized it in the 19th century as a principle of ethnic nationhood, and nearly every country in Europe, Asia, and Africa treats parental citizenship as the primary basis for nationality at birth. Nobody seriously contests first-generation transmission.
Generational depth is where it gets political. Italy, until March 2025, allowed descent-based citizenship to pass indefinitely.
Think about what that meant in practice. A Brazilian whose great-great-grandparents left Calabria in 1890 could claim an Italian passport without ever visiting the country.
An estimated 80 million people worldwide are theoretically qualified, roughly the population of Germany.
That ended with Decree-Law No. 36, adopted March 28, 2025, and converted into Law No. 74/2025 on May 24. Applicants now need at least one parent or grandparent who held Italian citizenship. Administrative backlogs, security concerns about issuing EU passports to strangers, and the sheer absurdity of 80 million potential claimants with zero connection to the Republic all played a role.
Italy was an outlier, but the direction is not. Ireland conditions descent citizenship on parental connection, and Germany increasingly demands “genuine link” criteria.
As Patrick McFawn observed, the derivative citizenship rules tripping up most descent applicants come down to distinctions that barely existed a generation ago: whether a parent naturalized versus acquired citizenship through ius soli, for example.
Every restriction on descent reclassifies people who assumed they had a free path into potential customers for a paid one. The pipeline feeds itself.
Money
Ius pecuniae is by far the youngest doctrine. Dr. Hussain Farooq traced its intellectual roots to ancient Rome, where civic rights were granted for economic contribution. Julius Caesar, famously, never demanded “genuine links.”
The modern incarnation dates to 1984, when St. Kitts and Nevis opened the world’s first CBI program one year after independence. For two decades, almost nobody used it.
Globalization and geopolitical instability changed that in the mid-2000s, and the growth since has reshaped entire national economies. Between 2011 and 2017, capital deployed through just 11 major residence and citizenship programs jumped from $2.86 billion to $12.4 billion, a compound annual growth rate of 23.4%, according to a market analysis. The global investment migration market is now conservatively valued at over $20 billion a year.
These are not supplementary revenue streams for the countries that run them. Dominica’s CBI program generated $232 million in fiscal year 2022/23, equal to 37% of the country’s GDP.
Jordan brought in $1.38 billion from just 531 investors through December 2024, and Grenada processed 1,314 applications that same year for $186 million in revenue.
More than a dozen CBI programs are active today. The EU has spent a decade trying to eliminate the model within its own borders: Cyprus closed its program in 2020, and Malta fell to a European Court of Justice ruling in 2025.
Neither closure reduced demand. It redirected it. Henley & Partners reported that applications from UK nationals surged 183% in Q1 2025 alone, driven partly by the abolition of the non-domiciled tax regime.
Meanwhile, at least 14 countries are proposing or legislating new programs, including Argentina, which would become the first in South America. St. Vincent and the Grenadines has confirmed a 2026 launch.
The European Commission may not like any of this. The market does not appear to care.
Displaced Demand Flows Toward Money
Soil and blood used to move independently; a country might restrict one while the other held firm. What makes this period different is that both are contracting across the developed world at the same time.
Portugal’s citizenship law is under revision, with proposals to double naturalization periods. Italy has curtailed one of the most generous descent regimes in history.
And the United States may be months away from a Supreme Court ruling that reshapes the oldest constitutional birthright citizenship guarantee on earth.
Every restriction on soil or blood creates displaced demand. Displaced demand, in the citizenship market, flows toward money.
Ius pecuniae will keep growing because the forces behind it are not cyclical. They are baked into the politics of every developed nation that wants fewer immigrants but still needs their capital.
