Table of contents
- Introduction
- Basic principles of citizenship
- The most common country combinations and their special features
- Digital birth certificates
- Documents and formalities
- International naming law
- Legal consequences of dual citizenship
- Special advice for unmarried couples
- Practical checklist
- Frequently Asked Questions (FAQ)
Children whose parents have different nationalities are referred to as binational. Almost one in three children in Germany was born into an international family in 2023. While this gives children the opportunity to hold two citizenships, the bureaucratic process of applying for them can present challenges.
Registering a birth is not just a formal act – it is the legal recognition of a child's existence and identity, forming the basis for many other documents and rights in life. For children of binational origin, this process is more complex, as two different legal systems must be considered.
The advantages of dual citizenship:
- Greater freedom of travel and residence rights in both countries
- Access to two education and health systems
- Expanded adult labor market
- The possibility of being rooted in two cultures
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Have your marriage certificate translatedBasic principles of citizenship: How does it work?
Worldwide, there are two basic principles according to which nationalities are granted:
The principle of birthright citizenship (jus soli): Citizenship is acquired based on the place of birth. This principle is particularly widespread in immigration countries such as the USA, Canada, and many Latin American countries.
The principle of citizenship by descent (jus sanguinis): Citizenship is acquired through descent from nationals of the respective country. This principle is prevalent in most European countries, including Germany, as well as in many Asian countries.
The most common country combinations and their special features
Germany-USA:
Child's nationality:
- Birth in Germany: The child acquires German citizenship by descent . US citizenship can be acquired by descent if certain requirements regarding the length of residence of the US parent in the USA are met.
- Birth in the USA: The child automatically acquires US citizenship by birthright . Additionally, it receives German citizenship by descent if one parent is German.
Special feature: The USA levies taxes on its citizens for life, regardless of where they live.
More information about obtaining US citizenship retroactively can be found here.
Germany-France:
Child's nationality: The child acquires both German and French nationality by descent, regardless of place of birth.
Special feature: There is a special regulation between France and Germany according to EU Regulation 2016/1191. , which does not require an apostille or legalization.
Read more about the German-French alliance.
Germany-Türkiye:
Child's nationality: The child receives German and Turkish nationality by descent.
Cultural aspects:
- In Turkey, the family name is traditionally important and patrilineally oriented.
- Cultural and religious aspects can play a role in the naming process.
- Special attention should be paid to the correct spelling of Turkish names with special characters.
Germany-Russia:
Child's nationality: The child acquires both nationalities by descent.
Special features:
- The correct transliteration of names between Cyrillic and Latin scripts is important.
- Russian naming law traditionally provides for a patronymic, which is derived from the father's given name.
Germany-Latin America (using Brazil as an example):
Child's nationality:
- A child born in Brazil automatically receives Brazilian citizenship (jus soli).
- German citizenship is acquired through descent.
Special features in the naming process:
- In Brazil and many Latin American countries, it is traditional to have two surnames: the mother's first surname and the father's first surname.
- The order of surnames differs from Spanish tradition (in Brazil, the father's surname comes last).
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Have the birth certificate translatedDigital birth certificates: The future of documentation
More and more countries are issuing digital birth certificates – this can significantly simplify the process for binational families. These electronic documents are secured with digital signatures and can be applied for and submitted more quickly.
Advantages of digital birth certificates :
- Faster processing times
- Easy communication between authorities
- Reduced risk of document loss
- Available in many languages
Important: Not all countries yet accept digital documents for official purposes. You can find more information about digital birth certificates in our blog post – Digital Birth Certificates on the Rise – A Practical Guide
Documents and formalities: What you need to know
Required basic documents for both nationalities
The following documents are required for dual citizenship:
- Child's birth certificate (depending on the country, also with apostille)
- Passports of both parents
- Proof of habitual residence
- Birth certificates of both parents
- Marriage certificate (if available)
Country-specific document requirements
In addition to the standard documents, you will need these additional documents depending on the country:
USA:
- Proof of the physical presence of the US parent in the USA (for at least 5 years, of which 2 must be after the child's 14th birthday)
- US tax returns from recent years
- Employment contracts or certificates of enrollment as proof of attendance
- DS-2029 form for the Consular Report of Birth Abroad (CRBA)
Türkiye:
- Turkish Family Register (Nüfus)
- Form for registration in the Turkish civil registry
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Certified translations and apostille
The following documents generally require a certified translation:
- Child's birth certificate (for the foreign authority)
- Marriage certificate (for both authorities)
- Foreign birth certificates of the parents (for German authorities)
- Acknowledgement of paternity (if applicable)
In some cases, a certified translation is not sufficient. An apostille or legalization is also required.
Apostille: A simplified form of authentication for countries that are party to the 1961 Hague Convention. The apostille is issued by a designated authority in the issuing state and confirms the authenticity of the document.
Legalization : For countries that are not party to the Hague Convention, legalization is required. In this process, the German diplomatic mission in the issuing country confirms the authenticity of the document. Prior authentication by local authorities is often necessary.
EU Regulation 2016/1191 : Simplification within Europe
Within the European Union, the procedures were significantly simplified by Regulation (EU) 2016/1191:
- Certain public documents, including birth certificates, are exempt from the requirement of legalization or apostille.
- Multilingual standard forms can be attached as a translation aid, which in many cases eliminates the need for certified translations.
- This simplification applies to all EU member states and significantly facilitates the free movement of public documents.
International name law: Which name in which passport?
Naming laws are an important aspect for children of binational origin. Different countries have different regulations, and the order of a surname, as in Brazil, for example, can have long-term consequences for official naming and documentation.
Different naming systems worldwide
Single name system (e.g. Germany)
- A child is usually given a family name, which can either be the name of one parent or a double name.
- When getting married, spouses can choose a shared family name.
Dual-name system (e.g., Spain)
- A person has two surnames: the first surname of the father and the first surname of the mother.
Asian naming conventions
- In many Asian countries (e.g., China, Korea, Japan), the family name comes before the given name.
- In Japan, married couples must have a shared surname, usually the husband's surname.
Naming at birth and name changes
- In many countries (e.g., Germany, France), naming is subject to legal regulations, e.g., regarding the permissibility of first names.
- In countries like the USA or Great Britain, there is more freedom as long as the name is not offensive or misleading.
- Name changes are only permitted under certain conditions in some countries (e.g., Germany, Austria), while they are relatively easy to do in others (e.g., the USA).
Legal consequences of dual citizenship
Dual citizenship offers many advantages, but also entails legal obligations that binational families should be aware of.
Conscription and military service
In countries with compulsory military service, dual citizenship can lead to conflicts:
In Germany, compulsory military service was suspended in 2011. Therefore, there is no longer an obligation to serve in the Bundeswehr (German Armed Forces). However, if you have dual citizenship, that other country may still have compulsory military service.
Some countries, such as Greece and Turkey, have compulsory military service and can require their citizens (even those with dual citizenship) to perform military service. Further information can be found here .
Tax obligations
The tax consequences of dual citizenship vary depending on the countries involved:
- A peculiarity of the USA: The USA taxes its citizens worldwide, regardless of their place of residence. According to the IRS ( Internal Revenue Service, 2023 ), US citizens must file a US tax return annually, even if they live abroad and pay taxes there.
- Double taxation agreements: Germany has concluded double taxation agreements with over 90 countries, which are intended to prevent income from being taxed twice ( Federal Ministry of Finance, 2023 ).
Special advice for unmarried couples
Additional requirements apply to unmarried couples with binational children:
- Paternity acknowledgment: In Germany, legal recognition of paternity requires a declaration of paternity, which can be made before or after the birth.
- Custody: In Germany, if the parents are unmarried, the mother initially receives sole custody. A joint custody agreement is possible and often advisable.
- Naming conventions: The regulations regarding naming are more complex for unmarried couples and can vary greatly depending on the country.
Practical checklist: How to master the paperwork
Checklist for binational births
□ Find out about the citizenship laws of both countries
□ Clarify the naming conventions according to the laws of both countries
□ Check the validity period of your passports/ID cards
□ Find out about the deadlines for registering a birth in both countries.
□ Identify the responsible authorities in both countries
□ Find out about apostille or legalization, if required.
□ Find a qualified translator for any necessary translations
□ Inform the hospital staff about your binational situation
□ Pay attention to the correct spelling of all names
□ Have several original copies of the birth certificate issued to you.
□ Ask for multilingual forms, if available
□ Note down the contact details of the maternity ward for later inquiries.
□ Register the child at the relevant consulate/embassy
□ Apply for the foreign birth certificate or consular certificate
□ Apply for citizenship if it was not acquired automatically
On the website of the Federal Ministry for Family Affairs, Senior Citizens, Women and Youth you will find further checklists for the birth of binational children .
Frequently Asked Questions (FAQ)
Can my child keep both citizenships?
This depends on the citizenship laws of the countries in question. Many countries, including Germany, the USA, and most EU member states, allow dual citizenship at birth. However, some countries, such as Japan, require a choice of citizenship by the time one reaches adulthood (in Japan, by age 22).
You can find more information at the Federal Foreign Office .
What should be considered when giving birth abroad?
If you are planning to give birth abroad, you should consider the following points:
- Register the birth at the local registry office.
- Apply for the local birth certificate with several originals.
- Have the birth certificate apostilled/legalized (if required).
- Register the birth at the German embassy or consulate.
- Apply for the subsequent registration at Registry Office I in Berlin.
- Apply for travel documents for the child in both countries.
How can I retroactively apply for a second citizenship for my child?
If the second nationality was not acquired automatically, there are different procedures depending on the country:
- For German citizenship: Subsequent registration at Registry Office I in Berlin , provided that one parent was German at the time of birth.
- For foreign nationality: Registration at the consulate of the respective country, usually with proof of ancestry.
- Note possible deadlines: Some countries set age limits for retroactive registration.
What does subsequent registration at Registry Office I in Berlin mean?
Subsequent registration is the entry of a birth that took place abroad into the German birth register. It:
- Provides the legal basis for German documents
- Enables the issuance of a German birth certificate
- It is often easier to use in dealings with German authorities than foreign documents.
- Can be carried out by Registry Office I in Berlin or by the registry office of the German place of residence.
What do I do if my child, born abroad, has been adopted?
For adoptions abroad, you will need a translated adoption certificate for German authorities – often with an apostille or legalization. Only then can the adoption be recognized here. If you have more questions about adoption documents, please take a look at our guide to adoption documents .
What does a medical license have to do with my child's birth certificate?
If a parent works in a medical profession abroad and wishes to apply for a medical license in Germany, many authorities also require the child's birth certificate. This is especially true for binational families – for example, to clarify marital status, nationality, or residency status. The birth certificate usually needs to be submitted with a certified translation.
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The bureaucratic processes surrounding binational children can be complex, but the effort is worthwhile for the many benefits your child will enjoy. Seek expert help if needed and allow plenty of time for all the formalities.
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