Does the EU mandate certain requirements for citizenship of member states?

For example, criminal background checks, multiple nationalities.

The origin of my question is that EU Citizenship, introduced with Maastricht Treaty might mean that the member state with the lowest barrier to entry becomes a target.

  • 2
    Why would that make them a target? EU citizenship does give some rights in the entire EU, but citizenship in one country does not mean they enjoy all the citizen rights of another country. In particular, freedom of movement has certain restrictions, as explained here.
    – JJJ
    Commented Oct 6, 2018 at 17:01
  • I mean it might make a country a target for people to gain EU citizens.
    – 52d6c6af
    Commented Oct 6, 2018 at 17:13
  • It remains unclear to me what you mean by target. Do you mean that the country with the lowest barrier would be impacted negatively by people who merely want EU citizenship? Or do you mean that the EU would suffer because that one country might be a 'weak point'?
    – JJJ
    Commented Oct 6, 2018 at 17:21
  • But "EU citizens" is not much of a thing, beyond travel. If let's say, Hungarian citizenship were "open to everybody", all that you would get would be a lot of citizens of Hungary. But none of them could affect the government of France even if they were to live there. And of course, even if not for the sake of the EU, every country keeps control of their citizenship candidates for its own sake. And if you are thinking of some kind of conspiracy, it takes a lot of conspiracy to make a dent in a population of nearby 400 million people.
    – SJuan76
    Commented Oct 6, 2018 at 17:25
  • @SJuan76 it would also entitle them to get consular assistance from the other EU countries. See this page by the EC.
    – JJJ
    Commented Oct 6, 2018 at 17:52

3 Answers 3


The origin of my question is that EU Citizenship, introduced with Maastricht Treaty might mean that the member state with the lowest barrier to entry becomes a target.

This is indeed a situation which has caused some concern in the past few years. For example, see this news story from 2014:

Malta has bowed to EU pressure over its controversial new passport scheme for non-EU nationals, saying applicants will now be required to spend at least a year in Malta in order to qualify.

The new condition was announced by Malta in a joint statement with the European Commission.


It followed talks between EU Commission officials and the Maltese government. EU Justice Commissioner Viviane Reding has said applicants should have "a genuine link to the country" - not just the ability to pay.

Or this story from a couple of months ago:

The [Financial Times] quoted EU Commissioner for Justice, Vera Jurova (sic), as saying that such schemes in eight member states will come under tougher scrutiny from Brussels as part of a broader drive against money laundering and corruption.

"In cases of any doubt, a person should not have the privilege of citizenship," Jourova told the Financial Times. "We have no power to ban such a practice but we have an obligation to put high requirements on the member states to be careful."

Does the EU mandate certain requirements for citizenship of member states?

It seems (e.g. from Jourová's comments above) that there are some requirements around criminal background / money-laundering checks, although I haven't managed to track them down. Notably there is no specific mention of them in Transparency International's report of March this year about the selling of citizenship by EU countries.


The rules are quite different from country to country. Most have some reason or another to enact special cases, from the Brits with their Commonwealth to the Germans with the aftermath of WWII.

  • Some citizenships are easier to get than others.
  • Some citizenships are easier to get for investors. This does not mean they're for sale, but money helps greatly.

In the end, any EU citizenship gives some rights in Europe, but not all the rights of a local citizen. The effect you worry about does happen, but it is not high on the list of migration problems facing the EU.

  • When the amount the investor is required to contribute to the "National Development and Social Fund" is greater than the amount that the investor is required to invest and where there is no requirement to actually live in the country (though there is requirement to maintain residential property) it sounds very much like "citizenship for sale" to me. Commented Oct 21, 2018 at 2:29

With respect to the OP's question, it is worth noting that the EU does not impose any particular requirement on Member States for national citizenship. Since EU citizenship is derived from national citizenship (cf. Article 20 (1) of the Treaty on the Functioning of the European Union), it might be surprising, but the EU law is quite clear on that matter:

[...] in the absence of relevant Community rules, each Member State freely determines and defines the procedures for the acquisition and loss of nationality and also adopts the rules applicable to cases of dual nationality. (Case C-369/90, https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:61990CJ0369)

In short, the EU respects national decisions regarding citizenship. It is not an abuse of process for instance to be granted a particular nationality only to enjoy free movement within the EU.

In 2014, Malta introduced its Malta Individual Investor Programme (MIIP, cf. http://www.maltaimmigration.com/), recognized by the EU, that allows someone to buy his Malta citizenship (€650,000 for the main applicant), hence his European citizenship as a consequence. MIIP still accepts applications. However, with the link provided one can see that among the requirements there is the following one:

Applicants must have a clean criminal record.

The Malta government is assumed to conduct criminal checks, and

applicants must also provide a police certificate before they will be approved for European citizenship.

The wording of this last quote is a bit strange, since in compliance with the EU law, UE citizenship is not subject to a different process than the national one. So, I guess one should understand this certificate as being mandatory for the Malta citizenship itself in the framework of MIIP.

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