There is no worldwide rule limiting a person to one, two or even three citizenships. You can legally hold several nationalities if the laws of every country involved allow them to coexist in your particular case.
That qualification is crucial. A country may permit you to acquire its citizenship without renouncing another, while one of your current countries may automatically withdraw its citizenship when you naturalise elsewhere. The result may also change depending on whether citizenship is acquired automatically at birth, confirmed by descent, restored, or obtained through voluntary naturalisation.
This guide focuses on Hungary, Greece, Bulgaria and Portugal, with additional examples from across the EU. It provides a decision framework rather than a substitute for country-specific legal advice.
Is there a global limit on the number of citizenships?
No. Nationality is a legal relationship between a person and a state, and each state determines who its nationals are. The European Convention on Nationality defines multiple nationality as the simultaneous possession of two or more nationalities by the same person. It does not impose a numerical ceiling.
“Dual citizenship” is often used as a general expression, even when a person holds three or more citizenships. The number itself is rarely the decisive issue. The real questions are:
- Will the new country grant citizenship without requiring renunciation?
- Will every current country allow its citizenship to be retained?
- Does the method of acquisition change the result?
- Are permission, notification, registration or timing requirements involved?
A person may therefore hold three citizenships lawfully, while another person with the same three countries in mind may not. Their acquisition history, residence, family connection and the sequence of applications can produce different outcomes.
Citizenship, passports, residence and tax residence are different
These concepts should not be used interchangeably:
- Citizenship or nationality is the legal status connecting a person to a state.
- A passport is a travel and identity document evidencing a nationality. An expired passport normally does not mean the citizenship has expired.
- A residence permit authorises residence under immigration law; it is not citizenship.
- Tax residence is determined under tax legislation and treaties. Holding several passports does not automatically make someone tax resident in all those countries.
An EU Member State’s nationality also creates EU citizenship. EU citizenship is additional to national citizenship and does not replace it. Holding Hungarian and Portuguese nationality, for example, means holding two national citizenships, but not two separate categories of EU citizenship.
Why the method of acquisition changes the answer
Birth, descent and restoration
Children may acquire several citizenships automatically through parents with different nationalities or through interaction between descent and birthplace rules. These cases are often treated more permissively than a voluntary adult application, but registration, generational or later retention requirements may still apply.
A descent procedure may confirm citizenship held since birth rather than create a new status on the approval date. Restoration can also have different consequences from ordinary naturalisation. The exact statutory basis and effective date must be identified.
Naturalisation and marriage
Voluntary naturalisation is the highest-risk category. The destination state may demand release from previous citizenship, while a current state may treat the application, oath or grant as triggering loss. Any required retention permission must be secured before the legally decisive event.
Marriage rarely grants nationality automatically. It may open a facilitated route or an exception to renunciation, but country-specific conditions still apply.
The four-part test before adding another citizenship
Assume a person already holds citizenships A and B and wants to naturalise in country C.
1. Check country C’s acquisition law
Can the applicant retain A and B? Does the answer change for descent, marriage or naturalisation? Is a renunciation declaration required?
2. Check countries A and B’s retention laws
Could voluntary acquisition of C terminate either citizenship? Is advance permission available, and do birth, residence, marriage or EU-related exceptions apply?
3. Check procedure and timing
Identify the decisive event—application, approval, oath or registration—and complete every permission, notice or renewal step beforehand.
4. Check the consequences
Review passport-use rules, consular protection, public duties, political restrictions, family and inheritance issues, compliance disclosures and tax residence.
All four checks should be completed before an application or oath. A passport issued afterward cannot repair a citizenship that was already lost automatically.
Country-by-country comparison
| Country | Starting position | The point that can change the result |
|---|---|---|
| Hungary | Hungarian law accommodates simultaneous Hungarian and foreign citizenship. | The other country’s law may still require renunciation or cause loss. In Hungary, the person is generally treated as Hungarian for Hungarian-law purposes. |
| Greece | Greece generally permits multiple citizenship, and its current ordinary-naturalisation procedure does not list renunciation of prior citizenship as a condition. | The applicant must still check whether an existing country permits retention and whether special loss rules apply. |
| Bulgaria | Bulgarian law recognises that Bulgarian citizens may also hold another citizenship. | Ordinary naturalisation generally requires release from prior citizenship, subject to important exceptions, including specified family, EU/EEA/Swiss, reciprocity and Bulgarian-origin cases. |
| Portugal | Portuguese nationality generally continues when another nationality is acquired. | Portuguese nationality can be lost by a qualifying person’s declaration that they do not wish to remain Portuguese; the other state’s law remains decisive. |
| Germany | Multiple nationality has been broadly accepted under the reform effective since 27 June 2024. | A current non-German nationality may still be lost under its own law. |
| Austria | Austria generally restricts dual and multiple citizenship. | An Austrian voluntarily acquiring another citizenship normally needs written retention approval in advance; automatic acquisition at birth and other exceptions are treated differently. |
| Netherlands | Dutch rules remain restrictive, although several exceptions exist. | Naturalising applicants generally must renounce other citizenships, and a Dutch adult may automatically lose Dutch nationality when voluntarily acquiring another, subject to statutory exceptions. |
| Spain | Spain has recognised dual-nationality categories, but its general acquisition procedure includes a declaration renouncing the previous nationality. | The exception depends on the applicant’s existing nationality and the relevant Spanish rule or agreement. The practical effect abroad must be checked separately. |
This table is a screening tool, not a complete statement of each nationality code. The official procedure and legislation current on the filing date must control.
Hungary: a multiple-citizenship-friendly framework, but only on the Hungarian side
Hungary’s Citizenship Act expressly addresses a Hungarian citizen who is simultaneously a citizen of another state. Unless legislation provides otherwise, Hungarian law treats that person as Hungarian for Hungarian-law purposes.
This means Hungarian law can accommodate two or more nationalities and does not impose a general numerical limit. It does not mean every applicant can safely keep every citizenship they already hold. An Austrian, Dutch or other citizen considering Hungarian naturalisation must first analyse the retention rules of their current country.
A Hungarian dual national in Hungary should expect the authorities to deal with them primarily as Hungarian; another state’s consular assistance may be limited.
Hungarian residence is not Hungarian citizenship
The Hungary Guest Investor Program is a residence-by-investment framework, not citizenship by investment. The current official route includes a qualifying investment fund share of at least EUR 250,000, subject to statutory conditions and a minimum holding period. It provides a residence status, not automatic naturalisation, accelerated citizenship or a guaranteed passport.
The investment carries financial and regulatory risk; capital value, liquidity, repayment and returns are not guaranteed. Citizenship eligibility is assessed separately.
For verified information about Hungarian investor residence, visit investmentvisa.eu.
Greece: generally compatible with multiple nationality
Greece’s current official naturalisation procedure sets residence, good-character, language, economic and social-integration requirements but does not list renunciation of the applicant’s previous citizenship as a standard condition. Greek law also provides separate procedures for a Greek citizen who wishes to lose or renounce Greek nationality.
The starting point is therefore that Greece generally accepts multiple nationality, but the combination succeeds only if every current country allows retention. Descent and voluntary naturalisation can produce different results. Greek residence permits remain immigration statuses, not citizenship.
Bulgaria: recognition of multiple citizenship does not remove the renunciation rule
Bulgaria illustrates why a one-word “yes” or “no” is misleading.
Article 3 of the current Bulgarian Citizenship Act recognises that a Bulgarian citizen may also be a citizen of another state and provides that Bulgarian law generally treats that person only as Bulgarian. However, Article 12 requires an applicant for ordinary naturalisation to have been released—or to be released upon acquisition—from their previous citizenship.
The Act contains important exceptions. Release is not required under Article 12 for:
- spouses of Bulgarian citizens;
- citizens of an EU Member State, an EEA state or Switzerland; and
- citizens of states covered by a treaty establishing reciprocity.
Separate facilitated provisions also remove the ordinary renunciation condition for certain applicants of Bulgarian origin, adoptees and people with a Bulgarian parent.
The correct conclusion is not simply “Bulgaria allows dual citizenship.” Bulgaria recognises multiple nationality, but whether an applicant can retain existing citizenship depends heavily on the naturalisation route and the applicant’s present nationality.
Portugal: nationality generally survives acquisition of another
Portugal is comparatively clear on retention. Under the Portuguese nationality framework, loss requires a person who already holds another nationality to declare that they do not wish to remain Portuguese. The official nationality regulation also states that Portuguese nationality continues when another nationality is acquired unless the person declares otherwise.
Portuguese law is therefore generally compatible with multiple nationality, but that answers only the Portuguese side. A restrictive destination state may still demand renunciation. Portugal changed nationality eligibility rules in 2026, so applicants should verify the current route and effective dates.
Other EU models worth comparing
The EU does not have one citizenship code. The European Commission’s naturalisation guidance expressly notes that some EU countries require applicants to give up existing citizenship.
Three contrasting models show why pre-application checking matters:
- Germany broadly enabled multiple nationality in its reform effective from 27 June 2024. This removed the former German-side renunciation barrier for ordinary cases.
- Austria generally requires a foreign national acquiring Austrian citizenship to give up the prior nationality. An Austrian who voluntarily seeks another citizenship generally needs written permission to retain Austrian citizenship before taking steps to acquire the new one.
- The Netherlands generally requires renunciation during naturalisation and can automatically withdraw Dutch citizenship when an adult voluntarily acquires another nationality, although birth, childhood-residence and spousal exceptions may apply. Long residence outside the Netherlands and the EU can create a separate loss risk for dual nationals.
- Spain generally requires a renunciation declaration after acquisition, except for recognised dual-nationality cases. The Spanish declaration and the actual effect under the other country’s law are separate questions.
Older internet lists become unreliable quickly: Germany changed its position in 2024, and other countries continue to adjust loss rules.
Practical consequences of holding several citizenships
A legally valid combination can still create operational issues:
- A country may require its citizens to enter and leave using that country’s passport.
- Consular protection can be limited while a person is in another country of their nationality.
- Military service, civil service or national-security restrictions may apply in one jurisdiction.
- Voting, political office and security clearance can involve disclosure or eligibility rules.
- Different names or transliterations across civil registers can delay passport, inheritance and family procedures.
- Banks and regulated advisers may require disclosure of every citizenship for KYC, sanctions and source-of-funds checks.
- Tax residence must be analysed under domestic law and treaties, not inferred from passport count.
- Some citizenships can be lost through voluntary acquisition, prolonged residence abroad, missed document-renewal steps or failure to obtain advance permission.
None of these consequences is universal. They are prompts for jurisdiction-specific review.
Documents to collect before applying
Prepare a citizenship file before seeking a third or subsequent nationality:
- current and expired passports and citizenship certificates;
- birth, marriage, adoption and name-change records;
- proof of how, when and on what legal basis each citizenship was acquired;
- prior retention permissions, renunciation records or nationality determinations;
- residence, tax-residence and foreign-registration history;
- the laws in force on each relevant date; and
- written advice wherever retention is uncertain.
Ask advisers to confirm the result in writing and to state the legally decisive date. A general embassy email saying that “dual citizenship is allowed” may not address the applicant’s route, exceptions or current citizenship combination.
The decision is about compatibility, not a number
You can potentially hold two, three or more citizenships. The lawful maximum is the number that can coexist under every relevant country’s rules.
Hungary, Greece and Portugal generally provide a workable starting point for multiple-nationality planning. Bulgaria requires closer attention to the route and statutory exceptions. Austria, the Netherlands and Spain demonstrate how renunciation, automatic loss and prior-permission rules can change the outcome, while Germany shows that national policy can change substantially.
Before filing for another nationality, complete a coordinated citizenship, immigration and tax review. Westbridge Consulting can help map the jurisdictions involved, distinguish residence from citizenship and coordinate the appropriate local advisers.
Considering Hungarian residence as part of a wider mobility strategy? Review the Hungary Guest Investor Program at investmentvisa.eu or contact Westbridge Consulting for a case-specific assessment. Citizenship and tax questions require separate legal advice.
This article provides general information as at 20 August 2026. It is not nationality, immigration, tax, military-service or consular advice. Citizenship laws, administrative practice and international agreements can change, and every proposed combination should be checked with qualified counsel before an application, oath, renunciation or investment.