Birthright and citizenship by descent
There are two principles of citizenship. Jus sanguinis (’right of blood’) — the child receives the parents’ citizenship regardless of the country of birth; most European countries, as well as Russia, follow this principle. Jus soli (’right of the soil’) — citizenship is granted by the territory of birth, regardless of the parents’ citizenship.
Birth tourism is possible precisely because of jus soli: by travelling to give birth in a country with birthright citizenship, you legally secure a second citizenship for your child from day one.
Countries with unconditional birthright citizenship
In these countries, the simple fact of birth on the territory is enough — parental status is irrelevant:
- 🇺🇸 USA — citizenship under the 14th Amendment — one of the strongest passports in the world.
- 🇧🇷 Brazil — citizenship straight away, plus permanent residence for parents and a path to their passport within 1 year.
- 🇦🇷 Argentina — citizenship for the child immediately (Decree 366/2025 did not change this).
- 🇲🇽 Mexico — citizenship by birth; permanent residence for parents through the child.
- 🇺🇾 Uruguay, 🇵🇦 Panama — citizenship for the child immediately, with different conditions for parents.
- As well as Canada and most countries in Latin America.
Countries with conditional birthright citizenship
🇨🇱 Chile — citizenship for the child, provided that the parents held legal resident status at the time of birth (a tourist ’on holiday’ does not qualify). That is why Chile requires a residence permit to be arranged in advance.
Where birthright citizenship doesn’t apply
Pure jus soli does not apply in Europe: Germany, France, Spain and others grant citizenship to children of foreigners only under additional conditions (years of parental residency, second-generation birth). Turkey follows jus sanguinis — being born there does not confer citizenship, even though comfort births are popular there. That is why families travel to the Americas for a birthright passport.
What a second citizenship gives the child
Freedom of movement (visa-free access to 150–180 countries depending on the country), the right to live, study and work in the country of citizenship, access to its education and healthcare — and in adulthood, the ability to help family members obtain legal status. This is a lifelong asset, secured once — at birth.