Countries
We work where families were built.
Heritage citizenship exists because migration built the modern world, and the countries that sent or received those migrations have chosen — each in its own legal idiom — to keep a door open for the descendants. The frameworks differ dramatically. Some recognize descent without generational limit; others stop at grandchildren; some require a formal opt-in each generation; a few condition recognition on actually settling in the country. Several have redrawn their rules within recent memory, in both directions.
What follows is a general reading of the nine jurisdictions we know best, in the order we are most often asked about them. Each opens into a longer page.
Ley 346 · opción de nacionalidad
Argentina
Argentina received one of the largest migrations in modern history, and its nationality law has long reflected a certain generosity toward the families that resulted. The framework of Ley 346 — a statute of remarkable age — recognizes the children of native Argentines born abroad, who may take up Argentine nationality through a procedure known as the opción de nacionalidad.
In practice this makes Argentina one of the more open descent jurisdictions we work in. The option right belongs to each generation in turn: the child of a native Argentine may opt, and once recognized, their own children acquire the same right. Longer family chains are therefore built patiently, one generation at a time, rather than claimed in a single filing.
Typical overall timeline: roughly 6 to 18 months from complete documentation to recognition, plus DNI and passport issuance — varying considerably by consulate.
Article 146 · Ley 7052/2023
Paraguay
Paraguay’s constitution has long promised natural nationality to the children of Paraguayans born abroad — and Article 146 states the condition just as plainly: the promise is perfected when the descendant settles in the Republic permanently. That settlement requirement, radicación, is written into the constitutional text itself; no statute could waive it, and none has.
Law No. 7052, adopted in 2023, gave the framework its modern administrative shape. Its real headline is security: no natural Paraguayan now loses that nationality except by express renunciation, so the emigrant generations — and the claims that stand on them — no longer dissolve with a foreign naturalization. For the descendants themselves, the law defined the procedure: recognition by declaration before the civil courts in Paraguay, on proof of permanent settlement. What it did not create, despite persistent reports to the contrary, is a general consular route for the diaspora.
Typical overall timeline: research and documentation aside, the judicial declaration has moved in months once a family is genuinely settled and documented — but the settlement that must precede it runs on the family’s own calendar, with cédula and passport issuance to follow.
Ley 16.021 · Ley 19.362
Uruguay
Uruguay recognizes the children of Uruguayan citizens born abroad as natural citizens under Ley 16.021, and — since Ley 19.362 of 2015 — extends registration to the grandchildren of Uruguayan-born grandparents. On paper this places Uruguay among the more generous descent jurisdictions in the region.
The distinctive feature is avecinamiento: the requirement that the descendant demonstrably settle in Uruguay before citizenship is perfected. Unlike Argentina or Italy, Uruguay cannot generally be claimed entirely from abroad. For families genuinely drawn to Montevideo or the interior, that requirement is an invitation; for those seeking a document without a connection, it is a firm and rather characteristic Uruguayan answer.
Typical overall timeline: document assembly aside, expect several months of presence-building in Uruguay before registration, and additional months for the cédula and passport that follow.
Article 30 · nationality by descent
Mexico
Mexican nationality rests on Article 30 of the Constitution, which combines two generous principles: birth on Mexican soil confers nationality regardless of the parents’ status, and birth abroad to a Mexican parent transmits nationality by descent. A constitutional reform in 2021 broadened the descent rule further, reaching children born abroad to Mexican parents who were themselves born outside Mexico.
For families this means a Mexico-born ancestor can anchor claims across several living generations — provided each link in the chain can be documented and registered. The work is procedural rather than adversarial: births registered at a consulate or before the civil registry, records reconciled with RENAPO, and identity documents issued in course.
Typical overall timeline: once the ancestral record is in hand, consular registration commonly runs weeks to a few months per generation, with CURP and passport issuance to follow.
Jure sanguinis · reshaped in 2025
Italy
For over a century, Italian citizenship by descent — jure sanguinis — recognized no generational limit: a great-great-grandchild of an emigrant from Liguria could, with a complete file, be recognized as Italian. That long era ended abruptly in 2025, when a decree-law, later converted with amendments, restricted recognition for new applications: in broad terms, an applicant now needs a parent or grandparent who held exclusively Italian citizenship, or a parent who resided in Italy for two continuous years before their birth, subject to defined exceptions and transitional rules.
The reform reshaped rather than closed the practice. Families who meet the new ancestor test still have a path; cases filed before the cut-off proceed under the older rules; maternal-line cases affected by the pre-1948 rule continue to run through the courts; and the reform has now been tested — Italy’s Constitutional Court upheld its core in April 2026, while referring the question of its retroactive effect to the EU Court of Justice that July, where it remained pending at the time of writing. Few jurisdictions better illustrate why descent rights should be examined while they exist.
Typical overall timeline: 12 to 36 months depending on route — consular queues remain long, and judicial cases run on court calendars. Document assembly alone is often a six-month undertaking.
Foreign Births Register
Ireland
Irish descent citizenship is orderly, well-documented, and administered with a certain quiet rigour. A person born abroad to a parent who was born in Ireland is an Irish citizen automatically. A person with an Irish-born grandparent may become one by entry in the Foreign Births Register, maintained by the Department of Foreign Affairs.
The register carries one rule that families overlook at real cost: registration takes effect from the date of entry, not from birth. A registered person’s children born after registration can themselves be registered; children born before cannot. For families thinking a generation ahead, the order of events matters more in Ireland than almost anywhere else we work.
Typical overall timeline: Foreign Births Register processing has in recent years run from several months to over a year, before passport issuance. Record retrieval from Irish registries adds weeks, not months, when the facts are known.
Memoria Democrática · option rights
Spain
Spanish descent law is best understood as a set of doors that open and close by statute. The Democratic Memory Law of 2022 opened a broad, time-limited window for the children and grandchildren of Spaniards — including descendants of those exiled for political reasons — and that window, after one extension, closed to new filings in late 2025. Applications lodged in time continue through the consulates. An earlier window for descendants of Sephardic Jews, under the 2015 law, closed in 2019 on similar terms.
Between windows, Spain still offers durable routes: children of Spanish nationals may opt for nationality, and nationals of Ibero-American countries — a status many of our families reach through Argentine, Mexican, or Uruguayan descent work — qualify for Spanish naturalization after only two years’ legal residence. Spanish strategy, more than most, is about sequencing.
Typical overall timeline: pending Memory Law files have been processing over months to a few years, consulate by consulate. The two-year residency route runs on its own calendar: residence first, then an application measured in months.
Nationality Law · reformed 2026
Portugal
Portuguese nationality law still offers one of Europe’s more workable grandparent routes: the grandchild of a Portuguese national who has not lost that nationality may acquire Portuguese nationality by attribution, on demonstrating effective ties to the Portuguese community. Children of Portuguese nationals born abroad may be registered more directly. But the framework was substantially rewritten by Lei Orgânica 1/2026, in force since 19 May 2026, and every Portuguese assessment now divides at that date.
The 2026 reform pulled in three directions at once. It tightened the grandchild route, giving the effective-ties requirement more demanding content — including demonstrated knowledge of the Portuguese language and of Portuguese culture. It closed the Sephardic naturalization route to new applications, ending a chapter opened in 2015; files lodged before the reform continue under the prior rules. And it created, for the first time, an express route for great-grandchildren — conditioned on a period of legal residence in Portugal. Portuguese assessments, like Italian ones, should be dated.
Typical overall timeline: children’s registrations move fastest; grandchildren’s attribution files have commonly run 12 to 30 months through the central registry, and processing rhythms under the reformed framework — with its new language and integration showings — are still settling.
Art. 116(2) GG · StAG §5 and §15
Germany
German descent law divides into two very different bodies of work. The first is restorative: Article 116(2) of the Basic Law restores citizenship to those deprived of it between 1933 and 1945 on political, racial, or religious grounds — and to their descendants. Legislation in 2021 added parallel routes, notably §15 of the Nationality Act, for descendants of persecuted people who fled and lost their citizenship in ways the constitutional text did not quite reach.
The second body is corrective and ordinary: a declaration route under §5 of the Nationality Act, open for a ten-year window ending in 2031, for children — and their descendants — who were excluded from German citizenship by the gender-discriminatory rules of the past, such as birth before 1975 to a German mother and foreign father. Alongside both, the standard rule endures: children of German citizens are German by descent, subject to a registration requirement for some born abroad to parents themselves born abroad after 1999.
Typical overall timeline: restoration and declaration files run through the Federal Office of Administration and have commonly taken one to three years, archival research aside. Passport issuance follows confirmation.