Citizenship rules are shifting on three axes: land, blood, and money

Most people do not actively “pick” citizenship. Instead, legal systems decide it through established rules. Those rules were shaped over centuries by feudal duties, colonial administration, and ideas of ethnic nationhood. If we reduce the main models to three Latin labels, the current landscape can be summarized as follows.

Ius soli—“the right of land”: citizenship depends on where a person is born. Ius sanguinis—“the right of blood”: citizenship follows ancestry, typically through a parent’s legal status. And finally ius pecuniae—“the right of money”: citizenship can be obtained by providing an economic contribution, without tying the decision to birthplace or origin.

Other routes exist as well—such as citizenship through marriage, naturalization after years of residence, or discretionary exceptions—yet these three principles remain the backbone of modern frameworks.

The striking feature of today’s moment is that ius soli and ius sanguinis are being tightened at the same time, while ius pecuniae is expanding. This synchronized shift is unusual.

Land (ius soli)

In 1608, Edward Coke’s decision in Calvin’s Case helped formalize the notion that a person born in a monarch’s domains becomes a subject automatically. European colonial administrations then carried this logic abroad. The reason was practical: settler societies needed population growth, and birth-based status helped increase it quickly.

The United States is the most widely referenced example. Its approach is reflected in the 14th Amendment (adopted in 1868), originally designed to secure citizenship status for people formerly enslaved. On a global scale, the CIA World Factbook indicates that at least 33 countries still apply unconditional ius soli. Still, a review by the Library of Congress points out that nearly all of them are located in the Western Hemisphere—aside from a few exceptions.

Even so, the number of states offering fully unconditional citizenship solely on birthplace has been declining for years. The UK ended unconditional birth-based citizenship in 1981, and Australia followed in 1986.

India narrowed the rule in 1987 and tightened it again in 2004. In Europe, Ireland held out the longest. A 2005 referendum—sparked by concerns about “birth tourism,” meaning births intended to obtain status—resulted in 79% of voters backing a constitutional change that eliminated unconditional ius soli.

Today, no European country provides completely unconditional citizenship by birth. France, Germany, and Portugal still allow conditional variants, where the decisive factor is often the parents’ relationship to the country and/or their residence. But the direction of travel is clear.

One particularly tense case is the United States. Executive Order No. 14160, signed on January 20, 2025, proposes removing automatic citizenship for children born to parents who lack documentation or are present on temporary visas. Multiple federal courts that addressed the issue issued preliminary injunctions.

In June 2025, the U.S. Supreme Court in Trump v. CASA effectively narrowed the scope of universal bans without deciding the underlying question. Then, in December 2025, the Court agreed to hear Barbara v. Trump as a full matter, with oral arguments expected in summer 2026.

If the executive order is upheld, the U.S. could become the first developed country to restrict ius soli through executive action rather than through legislation or a referendum. That is why 2026 is being discussed as a possible turning point in citizenship policy.

Blood (ius sanguinis)

Ius sanguinis is often treated as the “default” worldwide. In the 19th century, the Napoleonic Code helped popularize it within the logic of an ethnic state: citizenship at birth was tied mainly to belonging to a particular group through family lines. In many European, Asian, and African countries, passing citizenship from parents remains the baseline assumption.

However, political debate typically begins when the conversation shifts from “whether” ancestry matters to “how far back” the state recognizes a claim based on lineage—meaning how many generations are covered.

Italy illustrates this clearly. Until March 2025, it allowed citizenship by descent with no time limit. In practice, this meant that descendants—such as people whose Italian ancestors left the country in the late 1800s—could pursue an Italian passport even without living there.

Analysts estimated that, in theory, up to 80 million people could have qualified—roughly comparable to Germany’s population.

That changed after Decree-Law No. 36 (March 28, 2025), later converted into Law No. 74/2025 (May 24). Now applicants must have at least one parent or grandparent who was an Italian citizen. Officials also cited administrative complexity, security concerns about issuing European passports to individuals with no clear connection to the state, and the sheer scale of claims—many of which lacked any meaningful link to Italy.

Italy was an outlier, but the trend is broader. Ireland ties citizenship by descent to whether parents have a genuine connection to the country, and Germany has increasingly introduced “real connection” requirements.

Importantly, measures that disappoint applicants’ expectations often target distinctions that were barely relevant a generation ago. For instance, whether a parent became a citizen through naturalization or acquired citizenship via ius soli can now influence eligibility.

Each tightening of how citizenship is transmitted by ancestry converts some people who once relied on a “free” route into customers for paid alternatives. Market dynamics follow the same rule every time: when one path closes, demand moves to the next available option.

Money (ius pecuniae)

Ius pecuniae is the newest of the three principles. Its roots are sometimes traced back to ancient Rome, where certain civic rights could be granted for contributing to public life. Popular historical accounts often mention Julius Caesar as an example of a leader who did not require what we would now call “real connections.”

The modern version began to take shape in the 1980s. In 1984, Saint Kitts and Nevis launched one of the earliest CBI (citizenship by investment) frameworks—effectively “citizenship for investment”—not long after independence. For the first two decades, interest stayed relatively limited.

Then globalization and geopolitical instability in the mid-2000s dramatically changed the picture. Residence- and citizenship-by-capital schemes reshaped the economic strategies of entire states. According to market assessments, between 2011 and 2017 the capital flowing through 11 key residence-and-citizenship programs rose from $2.86 billion to $12.4 billion, with an average annual growth rate of 23.4%. Conservatively, the global investment migration industry is now valued at more than $20 billion per year.

Crucially, this is not “extra money” in the sense of being symbolic. For some governments, these revenues become a material share of the national budget. Dominica’s program, for example, produced $232 million in fiscal year 2022/23—about 37% of GDP.

Jordan reportedly received $1.38 billion from only 531 investors as of December 2024. Over the same period, Grenada processed 1,314 applications, generating $186 million.

Today, more than a dozen CBI programs operate worldwide. The European Union has tried for roughly a decade to restrict these models within its territory. Cyprus ended its program in 2020, and Malta did so after an EU Court of Justice decision in 2025.

Yet shutdowns did not remove demand—they simply redirected it. For example, Henley & Partners reported a 183% rise in applications from UK citizens in Q1 2025, partly linked to the end of the non-domiciled taxation regime.

Meanwhile, at least 14 countries are either considering new programs or have already passed enabling legislation. Argentina may become the first South American state to adopt such a model, and Saint Vincent and the Grenadines has indicated a start date of 2026.

The EU Commission may object, but the market does not appear to be responding in the way regulators hoped.

How demand moves from land and blood toward money

In the past, soil and blood could be adjusted separately: a state might restrict one route while keeping the other. What distinguishes the current period is that developed countries are narrowing both models at once.

Portugal is revising its citizenship rules by proposing longer naturalization timelines. Italy has already limited one of the most generous descent-based regimes in its history. And in the U.S., a Supreme Court ruling could reshape, in constitutional terms, the oldest citizenship guarantee in the world—birth-based citizenship.

Any restriction to soil or blood produces “forced” demand. In a citizenship market, that demand naturally redirects toward ius pecuniae.

Ius pecuniae is likely to keep expanding because the drivers are not temporary. They are embedded in the politics of developed states: governments often want reduced immigration, but they still require capital.

If you want to follow how citizenship logic is shifting—from jus soli and jus sanguinis toward ius pecuniae—it’s important to focus on practical, investable paths where funding plays a real role. At Digital Nomad, we explain investment-based residence/citizenship options, help you select the route that fits your objectives, and guide you through document preparation with clear next steps. Start here: https://digital-nomad.gr/en/goldenvisa.

Our Telegram channel about various types of Greek residence permits, digital nomad programs, and the Greek Golden Visa: @digitalnomadgr