Ask anyone in the citizenship by descent trade what question they hear most. The answer is always the same one: “How far back can I go?”
That is often the wrong question. Countries do publish generational limits, and Italy stops at a grandparent, Lithuania at a great-grandparent, Hungary at no one in particular.
The generation count is a weak guide to whether a claim for citizenship by descent ever succeeds. What decides most cases is what one particular ancestor did with his or her nationality, and on precisely which day.
In March 2025, eight Venezuelans filed a claim at a court in Turin. Their ancestor was born in that same city in 1837, became Italian when the peninsula unified in 1861, and sailed for Venezuela without ever giving up Italian citizenship.
Under the rules in effect the day before they filed, the claim was airtight, because Italy set no generational limit at all. Distance from the ancestor counted for nothing.
Then, on March 28, 2025, a decree slid a new Article 3-bis into the nationality law, and on May 23 parliament converted it into Law 74/2025.
The Venezuelans’ ancestor had not changed, and nor had the paperwork. What changed was the law.
Two types of citizenship by descent frameworks
Audra DeFalco, Director of Citizenship by Descent at Latitude, opens every case with one of two questions.
“The first thing I ask a client, depending on where their ancestry is from, is either how many generations back their ancestor is or what citizenship that ancestor was holding the day their child was born.”
This is because every citizenship by descent law in Europe is built on one of two frameworks. Either they test every single generation, or they test the ancestor alone.
That framework determines what the case officer wants to know about your family.
Each single generation’s citizenship is tested
The first type of framework hands citizenship down automatically at birth, which means a test of each single generation for eligibility.
In these systems, a child is a citizen because a parent was a citizen on the day that child was born. The same test then applies to the next child, and the next.
On paper nothing caps the chain. In practice the chain breaks where an ancestor was no longer a citizen when the following generation was born, most often after a foreign naturalization.
Only the ancestor is tested, once
The second framework tests a single ancestor, once.
Slovakia asks whether a parent, grandparent, great-grandparent (and in some cases a great-great-grandparent) was a Czechoslovak citizen born on what is now Slovak soil, along with a few other disqualifiers. Prove it, and you can naturalize in your own right.
Whatever the intervening generations did with their loyalties falls outside the test, because nothing was ever passed down. There is no chain to break.
Italy stops at an exclusively Italian parent or grandparent
Article 3-bis treats anyone born abroad with another citizenship as never having acquired Italian citizenship in the first place. That is a startling change from the previous law.
For more than a century, Italian law had said the child of an Italian was Italian at birth, full stop. The new rule reaches back and declares that entire cohorts of those children were never Italian at all, however eligible they had been the day they were born.
Claims already lodged survived under the old rules. Anything filed with a consulate, a municipality, or a court by 23:59 Rome time on March 27, 2025 falls under the older, more permissive framework.
Everyone else now has two doors, and both are narrow.
An applicant may claim through a parent or grandparent who has Italian citizenship and nothing else, or who had nothing else at the moment of death. The second door opens where a parent lived in Italy for at least two continuous years after acquiring Italian citizenship and before the applicant was born.
Italy’s Constitutional Court examined the retroactive language of Law 74/2025 in Judgment 63/2026. The court accepted that the law reaches backward, and described it as an exemplary case of retroactivity in the strict sense.
It found that no right had been stripped. Decades of unlimited transmission had produced what the judgment calls a “virtual” Italian citizenship, never ascertained and open to activation at any time.
The court classified Article 3-bis as an “original preclusion” of acquisition rather than a revocation, and declared the challenge unfounded.
Three months later the same court moved in the opposite direction. In Order 147/2026 it referred Article 3-bis to the Court of Justice of the European Union and suspended its own proceedings.
The question now before the court in Luxembourg is whether a member state may retroactively withdraw European Union citizenship from people born abroad before March 28, 2025.
Italy’s limit applies today. Whether it survives is for European judges to decide.
One more ruling is in play. On July 26, 2026 Italy’s Court of Cassation revived descent cases that consulates had rejected over a parent’s naturalization while the child was a minor.
Ireland poses no generational limits, with a caveat
Section 7 of the Irish Nationality and Citizenship Act 1956 sets no generational limit, and there is a caveat. The first recognition can only come through an Irish parent or grandparent.
A person with Irish great-grandparents cannot seek recognition of Irish citizenship, unless their parent, who has an Irish grandparent, obtained recognition before their birth.
The reverse also applies. Once an applicant obtains recognition of Irish citizenship, it can pass on forever, as long as each generation registers with the Foreign Births Register before the next generation is born.
Citizenship begins on the date of entry, not the date of birth.
In some jurisdictions, one historical date decides it
A cluster of countries tests one ancestor against a single date in history.
Lithuania restores citizenship to the child, grandchild, or great-grandchild of anyone who was a Lithuanian citizen before June 15, 1940.
Latvia uses a 1940 cutoff of its own, June 17, and its migration office presumes that citizenship on that date flowed down to every generation since.
Slovakia, as noted, wants a Czechoslovak-citizen ancestor born in Slovak territory. The route imposes no residence requirement and no language test, and since July 15, 2026 no residence-permit step either.
That permit was never a condition of citizenship, and everyone had to obtain one anyway.
Croatia erased its generational limit on January 1, 2020. Descend, at any remove, from someone who emigrated before October 8, 1991, and you can naturalize without a language test.
Romania reaches the second or third degree depending on how the ancestor lost Romanian citizenship. Article 10 reaches a second-degree descendant, and Article 11 reaches the third degree where the ancestor lost citizenship for reasons outside their control.
Law 14/2025 added a Romanian language examination.
Hungary sets no generational limit and no residence requirement. Any Hungarian ancestor will do, however distant, and the applicant must demonstrate knowledge of Hungarian.
Poland and Germany test every single generation
Applicants who receive Polish citizenship by descent get recognized retroactively from the date of their birth. A child of a Polish citizen is a Polish citizen from birth.
The chain breaks in one main way. Under the 1920 Citizenship Act, acquiring a foreign citizenship meant loss of Polish citizenship, and so did taking public office or military service abroad without the Polish government’s consent.
Polish law only abandoned that rule when the current Act took effect in 2012.
So if a potential applicant’s Polish ancestor naturalized, that naturalization may cut off the claim, though not always. Anyone seeking Polish citizenship by descent must find out if and precisely when their Polish ancestor became a citizen of another country besides Poland.
Germany passes citizenship to the child of a German parent with no cap on generations, as long as German citizenship was not lost, for example through foreign naturalization, before the birth of the next generation.
There were also historical restrictions on the ability of women to pass citizenship on. Depending on when a person’s German ancestor came to the United States or elsewhere, that ancestor may have inadvertently lost German citizenship unless they met certain conditions.
One alternative pathway to German citizenship has no generational limit. People persecuted by the Nazi regime between 1933 and 1945, and their descendants, have a right to naturalization.
Some doors closed while others opened
Spain’s Democratic Memory Law let the child or grandchild of an exile opt for Spanish nationality. The window was extended once and expired in 2025.
Portugal shut its Sephardic descent route in 2026, after controversy over wealthy applicants using it to obtain European Union citizenship. Applications lodged before the change proceed under the old wording.
Portugal’s ordinary route reaches a grandchild, who must show ties to the national community. The law measures those ties by the same parameters as naturalization, covering the Portuguese language and culture, the country’s history and its national symbols.
Further generations may qualify, provided each intermediate generation is recognized first.
Canada removed its first-generation limit through Bill C-3, which received royal assent on November 20, 2025. A Canadian ancestor, however many generations removed, now potentially qualifies you.
The condition applies going forward. According to CIC News, children born on or after December 15, 2025 are eligible only if the Canadian parent spent at least 1,095 days in Canada before the birth.
Armenia sets no generational limit and no residence requirement for ethnic Armenians, and drew a record 32,000 applications in 2025. Officials have promised amendments but no bill has appeared.
How to find out whether you qualify
Work backward to the ancestor who left. That is the one who emigrated, not the earliest name in the family tree.
Establish what nationality that person had on the day the next generation was born.
In the United States, that means the National Archives and Records Administration and United States Citizenship and Immigration Services. In Canada, it means Immigration, Refugees and Citizenship Canada.
Follow the rules, gather the documents, and book the consular appointment, or hire someone who does this for a living.
File, and wait.
