Citizenship and membership

Citizenship is membership of a political community. It has at least three dimensions:

• Legal status: nationality recognised in law, giving a right to enter and reside, diplomatic protection and, usually, a passport.
• Rights and duties: the bundle of civil, political and social rights that members enjoy, and obligations such as obeying laws, paying taxes or serving on juries.
• Participation and identity: taking part in self-government and seeing oneself as belonging to a community.

Every polity, including every governance experiment, must answer who belongs, how membership is acquired and lost, and what it entitles members to. In experimental settings the question appears as membership rules of co-operatives and communes, e-residency schemes, DAO token-holding and network-state "citizenship".

Republican and liberal models

The republican tradition, from Aristotle's definition of the citizen as one who shares in ruling and being ruled, stresses active participation and civic virtue. The liberal tradition stresses citizenship as a legal status protecting individual rights, with participation optional. Dominique Leydet's survey adds a third dimension of identity and belonging, and notes the tensions between them.

Marshall's three elements

T. H. Marshall's Citizenship and Social Class (1950) described the development of citizenship in England as the successive extension of civil rights (liberty of the person, property, justice) in the eighteenth century, political rights (to vote and stand for office) in the nineteenth, and social rights (to welfare and education) in the twentieth. Social citizenship, he argued, moderated the inequalities of class. Critics note that the sequence fits English male workers better than women, colonised peoples or other countries.

Nationhood and acquisition rules

Rogers Brubaker contrasted the French tradition, which combined territorial birthright (jus soli) with an assimilationist, state-centred idea of the nation, and the German tradition, which long relied on descent (jus sanguinis) and an ethnocultural idea of the nation. Both countries have since converged: Germany introduced conditional birthright citizenship in 2000 and broadened it in 2024.

Denizenship and stakeholding

Tomas Hammar coined denizen for long-term foreign residents who enjoy most civil and social rights but lack political rights and full security of residence. Theorists such as Rainer Bauböck argue that membership should follow a stakeholder principle: those whose life prospects are tied to a polity have a claim to citizenship there.

Birthright and inequality

Ayelet Shachar's The Birthright Lottery (2009) argues that birthright citizenship in a rich state functions like inherited property, transmitting large advantages, and proposes a "birthright privilege levy" and stronger rights based on genuine connection (jus nexi).

• Germany: since the 2024 reform of the Nationality Act, foreigners can usually be naturalised after five years of lawful residence, multiple nationality is accepted, and children born in Germany acquire citizenship if a parent has lived there lawfully for five years with permanent residence rights.
• The United States grants birthright citizenship under the Fourteenth Amendment (1868); its scope has been the subject of renewed political and legal conflict.
• Nottebohm: in 1955 the International Court of Justice held that Guatemala need not recognise the Liechtenstein nationality of Friedrich Nottebohm for purposes of diplomatic protection, because it lacked a genuine connection with Liechtenstein.
• Investor citizenship: on 29 April 2025 the Court of Justice of the EU held that Malta's scheme granting nationality essentially in exchange for predetermined payments or investments breached Article 20 TFEU and the duty of sincere cooperation, treating it as a commercialisation of member-state nationality.
• EU citizenship, created by the Maastricht Treaty (1992), is additional to national citizenship and gives free movement and local and European electoral rights in other member states.
• Statelessness: millions of people lack any nationality, often through discriminatory laws, state succession or gaps between jus soli and jus sanguinis rules.
• E-residency (Estonia) offers a digital identity for business purposes, explicitly without citizenship or residence rights, showing how membership can be unbundled.

• Exclusion: citizenship is by definition exclusive; cosmopolitans argue that tying fundamental life chances to an accident of birth is unjust.
• Second-class membership: denizens, guest workers and irregular migrants can live for decades in a society without political rights.
• Commodification: investor schemes sell membership and are criticised for enabling corruption and money laundering; defenders see them as legitimate economic policy.
• Assimilation pressure: integration and language tests can be used to exclude rather than include.
• Denationalisation: some states have expanded powers to strip citizenship from dual nationals for security reasons, raising concerns about unequal citizenship.
• Digital and token-based membership: DAO membership and network-state citizenship often lack the rights, duties and legal protections that make citizenship meaningful.

Citizenship rules across democracies have converged towards mixed regimes combining descent, conditional birthright and naturalisation after a period of residence, and towards tolerance of dual nationality. The gap between residents and citizens nonetheless remains large in many states, and the global distribution of valuable citizenships is highly unequal. For new polities, the practical lesson is that membership needs clear criteria for entry and exit, a defined bundle of rights and duties, protection against arbitrary loss, and recognition by others if it is to carry real weight.

• Dominique Leydet, "Citizenship", Stanford Encyclopedia of Philosophy
• ICJ, Nottebohm Case (1955)
• CJEU, Commission v Malta, Case C-181/23 (2025)
• German Nationality Act (StAG)
• T. H. Marshall, Citizenship and Social Class (Cambridge University Press, 1950)
• Rogers Brubaker, Citizenship and Nationhood in France and Germany (Harvard University Press, 1992)
• Ayelet Shachar, The Birthright Lottery (Harvard University Press, 2009)