Citizenship by Investment, Merit, or Hypocrisy? Germany’s Citizenship Data Tell an Interesting Story

Lars Hoffmann
Co-Author

CBI is “dangerous,” says the EU. Meanwhile, Germany quietly naturalizes nationals from the same countries it flags as security risks.

Boasting a population of approximately 84 million and a GDP of around €4.3 trillion, Germany is by far the most populous and economically significant country among the member states of the European Union (EU). As such, it plays a key role in shaping and executing EU policy.

Regarding investment migration, the last few years have seen a relentless attack from EU organs on sovereign countries, both within and outside the EU, which have offered CBI and Golden Visa programs.

The EU Commission has been pivotal in pushing the Caribbean Citizenship by Investment (CBI) programs towards the “6 CBI Principles” and the Memorandum of Understanding in 2023.

The European Court of Justice (ECJ) ruled against Malta’s CBI program in early 2025, despite support from its own Advocate General. The ruling sided with the European Commission, which had brought the case to challenge Malta’s program.

Shortly after, the European Parliament and the Council of the European Union reached a provisional agreement to tighten the EU’s visa suspension mechanism, appearing to explicitly target CBI countries with Schengen visa access.

For now, it seems that CBI is dead; long live Citizenship by Merit.

Amid all this, observers often overlook a key question: What practices do major EU countries follow themselves? While pushing new rules and regulations on other sovereign states, how do they handle their own naturalization policies?

Naturalizations in Germany

From 2000 to 2024, Germany naturalized 3,347,745 people. Especially since 2020, the number of naturalizations has increased nearly exponentially. Having naturalized 109,880 people in 2020, the number has nearly tripled to 292,020 in 2024.

Domestic critics have noticed this acceleration, with Berlin recently drawing criticism for its digitalized ‘turbo naturalizations’ that have processed tens of thousands of applications through streamlined online procedures.

Despite federal CDU/CSU politicians raising concerns about the security and thoroughness of these rapid digital processes, Berlin’s mayor has defended the approach as both efficient and secure.

The composition of those naturalizing is also highly relevant, especially since the EU frequently tries to influence who can apply to CBI programs through “suggested” blacklists.

The chart below shows the total aggregate of the ten most original citizenships of applicants who successfully naturalized in Germany between 2000 and 2024.

Given the extensive history of migrant workers between Germany and Turkey, the first place hardly surprises. However, looking further, some highly interesting data surface.

Having averaged yearly naturalization numbers of 1,315 between 2000 and 2014, Syrian nationals have jumped to second place. They averaged yearly naturalization numbers of 3,368 between 2015 and 2020. Since 2020, they have averaged yearly naturalization numbers of 56,538. A case study on how a supposedly temporary humanitarian shelter has turned into permanent economic migration.

Other notable inclusions in the top ten include Iran, Iraq, and Afghanistan. All countries whose nationals are heavily scrutinized in the CBI industry.

As for the United Kingdom, 46,048 of the 51,140 (90%) naturalized in Germany between 2016 and 2024, and thus post-Brexit.

Naturalizations by Exception or Merit in Germany

Similar to most countries, Germany’s nationality law also provides for the acquisition of citizenship by exception or merit. The respective provisions are codified in the German nationality law under article 8.2 and relate to “reasons of public interest” as well as “the avoidance of particular hardship”.

Up until this month, however, the data have not been public. A recent Freedom of Information Act (FOIA) request has shed some light on an aspect of Germany’s naturalization practice that is rarely acknowledged or talked about. Yet, for the investment migration industry, it is of high relevance as it highlights the often hypocritical treatment of CBI programs.

The FOIA data provide the top five nationalities that naturalized by exception or merit between 2000 and 2023 (2024 data not available).

While certainly low by total population comparisons, Germany still granted citizenship by exception or merit to a total of 77,745 people between 2000 and 2023.

While mostly a small portion of overall naturalizations, the percentage of naturalizations by exception or merit of the total has spiked considerably.

In aggregate, the top five recipient nationalities of German citizenship by exception or merit between 2000 and 2023 were Turkey, Syria, Ukraine, Russia, and Iraq. All of these are also included in the top ten of total naturalizations. 

Similar to total naturalizations, the spike in naturalizations by exception or merit of Syrian nationals since 2020 is noteworthy. Especially since many did not migrate to Germany via legal migration pathways.

The total yearly top five nationalities split contains some other surprising nationalities, even if of marginal relevance compared to the aggregate top five.

Quo Vadis Germany?

The data highlight that Germany, the EU’s most populous and economically influential member state, has granted citizenship through both standard procedures and merit-based exceptions to nationals from countries the EU is actively trying to block from accessing CBI and Golden Visa programs. This is highly hypocritical.

While CBI due diligence is very often much more stringent than naturalization background checks of EU countries, the investment migration industry should encourage more pushback from sovereign countries offering CBI and Golden Visa programs.