Handover of Hong Kong and the complexity of British citizenship: BNO, right of residence, and the BNO visa

The British Nationality Act 1981 sets out six different categories of British citizenship. However, only one of them provides a right of residence in the UK and Northern Ireland. Because of this branching system, the country effectively uses several “three-letter” passport codes in documents issued under ICAO rules.

If you’ve ever looked at a British passport, you may have noticed that the cover says “British Passport”. This is because the UK has multiple types of standard passports (issued under different eligibility grounds), but the cover keeps a single wording. Inside, the nationality line reveals the specific citizenship category.

A standard passport is issued to a citizen in the “ordinary” way—meaning it is not a diplomatic, service, temporary, or non-citizen document.

These passports differ depending on the type of citizenship shown on the nationality page, and that, in turn, is linked to different levels of right of residence. Under UK law, this right is treated as a separate category—functioning, in effect, like an “additional” layer of statuses tied to historical autonomy of certain territories.

Origins and acquisition of British National (Overseas)

One of the most unusual statuses is British National (Overseas), shortened to BNO. This status was created by The Hong Kong (British Nationality) Order 1986, which took effect on 1 July 1987—exactly ten years before Hong Kong was handed over from the UK to China.

The arrangement allowed residents of Hong Kong who held the then citizenship of British Dependent Territories (BDT) to retain a certain connection to British citizenship after the BDT status was scheduled to end.

Important: BNO status was granted only through active registration during a designated ten-year window. It was not transferable by inheritance: if a child was born in a country where only not jus soli applies (i.e., citizenship is not granted based on birthplace), they could end up stateless at birth unless the country provided rules granting citizenship to people who would otherwise become stateless.

According to the UK Home Office, today there are roughly 2.9 million BNO citizens, but in 2020 valid passports were held by about 400,000 people.

BNO citizens can apply for a BNO passport—essentially a British passport where the nationality field states BNO. They can also seek consular protection from UK diplomatic missions.

At the same time, the BNO status itself does not grant a right of residence in any country. This is a rare situation globally—among the few comparable cases, other British citizenship types can be mentioned.

The BNO visa for the UK: who can apply and what it provides

Since 2021, the UK has been issuing a BNO visa to BNO citizens, as well as their children (including adult children if they live in the same household) and spouses—including same-sex marriages.

Applications can be submitted fully online while you are in the UK as a visitor. Home Office estimates suggest that, as of 2020, BNO citizens and their dependants together total about 5.4 million people.

A BNO visa allows you to live and work in the UK (Great Britain and Northern Ireland), and to access a range of social and public services. After 5 years of holding the visa, you can apply for settlement—what the UK calls Indefinite Leave to Remain (ILR).

One year later, you may apply for British citizenship. UK law also allows dual/multiple citizenship: a person may hold different categories of British citizenship at the same time and, as a result, obtain multiple British passports with different nationality markings.

BNO passport as a travel document

Even though BNO status by itself does not grant a right of residence, a BNO passport is still a fairly strong travel document.

It provides unconditional visa-free travel to 139 countries and territories, plus access to ETA or e-Visa for another 38 destinations.

For Taiwan, visa-free travel is conditional: it depends on where the holder was born (birthplace must be Hong Kong).

Unconditional visa-free access includes Schengen Area countries, as well as the UK (no ETA is required when visiting). In addition, visa-free travel is available for Japan, South Korea, and most countries in Latin America.

A BNO passport can also be used as a basis to obtain ETA for countries such as Canada, Australia, New Zealand, and Israel. This information is based on independent checks using data from Timatic by the International Air Transport Association (IATA).

Who has BNO citizenship today

BNO status has no “automatic” burden: a person may hold a BNO passport, use consular support, and still keep the ability to obtain further residency status by meeting the relevant conditions.

Out of roughly 2.9 million BNO citizens, available data suggests that more than 2 million do not currently hold a valid passport.

Some of them are people who are now 30–40 years old. Many were born and raised outside Hong Kong, with one parent from Hong Kong and the other from Europe or North America. They may have been registered as BNO as children, sometimes without their active involvement.

The fact that a large share has not obtained a valid passport indirectly suggests that many may not know they effectively hold BNO citizenship.

If you’re planning a long-term relocation and legal stay strategy in the UK, it’s crucial to understand what rights a BNO (British National (Overseas)) status actually provides and how it differs from full citizenship. At Digital Nomad, we help you navigate the rules, timelines, and realistic pathways for residence so you can make an informed decision with fewer uncertainties. Learn more and book a consultation 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