South African dual citizenship: Where you can and can’t apply for it

Living abroad as a South African, the concept of dual citizenship is likely to have crossed your mind or been a topic of conversation. Making the right decision for your circumstances involves understanding the intricacies of South African citizenship and the process of applying for dual citizenship. In this comprehensive guide, we will delve into the details of South African dual citizenship, exploring eligibility, processes, advantages, and potential drawbacks.

Important update: As of early May 2025, a ConCourt ruling has effectively nullified the need for a Retention Letter, please read more here. Apostil.co.za does not currently offer a Determination of Citizenship service. Please stay updated on our current service offerings by visiting our pricing page.

Understanding dual citizenship

Dual citizenship, simply put, refers to an individual holding two nationalities simultaneously. It entails possessing passports and enjoying both countries’ rights and responsibilities. The distinct nationality laws of each country shape the dynamics of dual citizenship. Residing in two countries concurrently renders individuals double citizens, with the acquisition of dual citizenship necessitating adherence to the laws and regulations of each nation.

Processes of obtaining dual citizenship

Obtaining dual citizenship involves various processes, contingent on the specific regulations of the countries involved. Birthright, naturalization, marriage, and investment are common pathways to dual citizenship. Some countries grant citizenship based on birth within their borders, irrespective of residence status. Naturalization requires individuals to fulfil residency requirements, with permanent residency often serving as a prerequisite. Marriage to a citizen can expedite the citizenship process in certain nations, while investment programs offer citizenship or residency in return for economic contributions.

South African dual citizenship: protocols and procedures

For South Africans contemplating dual citizenship, it is crucial to understand the protocols outlined by the South African Nationality Act of 2006. South Africa does allow dual citizenship, provided individuals adhere to specific procedures outlined by the Department of Home Affairs. Those over 18 seeking dual citizenship must first apply to retain their South African nationality.

Maintaining South African citizenship while acquiring a foreign one involves obtaining prior permission. Failure to secure permission could result in the automatic loss of South African nationality upon acquiring foreign citizenship. Reinstating South African citizenship, once lost, is a protracted and cumbersome process.

Weighing the pros and cons of South African dual citizenship

Despite the appeal of holding two passports, dual citizenship comes with potential downsides. Double taxation is a concern, and the application process can be time-consuming and expensive. Retaining South African citizenship alone can take up to 12 months, coupled with the foreign country’s residency requirements.

The decision to pursue dual citizenship should be weighed carefully, considering the benefits against the disadvantages. Being subject to the laws of two countries requires thorough research and consideration before embarking on the process.

Countries allowing dual citizenship

Over the last couple of years, more and more countries have become favorable toward allowing dual citizenship for their citizens. This can be through amending the requirements for naturalization or recognizing multiple/dual citizenship. While many countries allow outright dual citizenship, some only allow in in specific circumstances.

The table below indicates the list of countries that do allow dual citizenship as well as those that do not:

Countries that DO allow Dual Citizenship	Countries that DON’T allow Dual Citizenship
Albania	Afghanistan
Algeria	Andorra
American Samoa	Austria
Angola	Azerbaijan
Antigua & Barbuda	Bahrain
Argentina	China
Armenia	Djibouti
Australia	Eritrea
Barbados	Estonia
Belgium	Ethiopia
Belize	Georgia
Benin	Guinea
Bolivia	Guyana
Bosnia & Herzegovina	India
Brazil	Indonesia
British Virgin Islands	Iran
Bulgaria	Japan
Burkina Faso	Kazakhstan
Burundi	Kiribati
Cambodia	Kuwait
Canada	Laos
Cape Verde	Lesotho
Central African Republic	Liberia
Chile	Libia
Colombia	Liechtenstein
Comoros	Madagascar
Costa Rica	Malawi
Croatia	Malaysia
Cyprus	Maldives
Czech Republic	Marshall Islands
Denmark	Mauritania
Djibouti	Micronesia
Dominica	Monaco
Dominican Republic	Mongolia
East Timor	Montenegro
Ecuador	Mozambique
Egypt	Myanmar, Burma
El Salvador	Nepal
Equatorial Guinea	Netherlands
Fiji	North Korea
Finland	Norway
France	Oman
Germany	Palau
Ghana	Qatar
Ghana	Rwanda
Greece	San Marino
Grenada	Sao Tome and Principe
Guatemala	Saudi Arabia
Guinea-Bissau	Singapore
Haiti	Slovakia
Honduras	Suriname
Hong Kong	Swaziland
Hungary	Tanzania
Iceland	Togo
Iraq	Ukraine
Ireland	United Arab Emirates
Israel	Uzbekistan
Italy	Vanuatu
Ivory Coast
Jamaica
Jordan
Kenya
Kosovo
Kyrgyzstan
Latvia
Lebanon
Lithuania
Luxembourg
Macau
Macedonia
Mali
Malta
Mauritius
Mexico
Moldova
Morocco
Namibia
Nauru
New Zealand
Nicaragua
Niger
Nigeria
Pakistan
Panama
Papua New Guinea
Paraguay
Peru
Philippines
Poland
Portugal
Republic of Congo (Brazzaville)
Romania
Russian Federation
Saint Kitts & Nevis
Saint Lucia
Saint Vincent and the Grenadines
Samoa
Scotland
Serbia
Seychelles
Sierra Leone
Slovenia
Somalia
South Africa
South Korea
South Sudan
Spain
Sri Lanka
Sudan
Sweden
Switzerland
Syria
Taiwan
Tajikistan
Thailand
The Gambia
Tibet
Trinidad & Tobago
Tunisia
Turkey
Uganda
United Kingdom
United States
Uruguay
Vatican City
Venezuela
Vietnam
Yemen
Zambia
Zimbabwe

Countries restricting dual citizenship

Certain countries do not allow dual citizenship. Notable examples include Andorra, Azerbaijan, Bahamas, Bahrain, Belarus, Botswana, Bhutan, China, Oman, Japan, Malaysia, and Singapore. For more information, please refer to the detailed table on countries that allow dual citizenship and those that don’t.

The application process for South African dual citizenship

If you’re contemplating dual citizenship in South Africa, the application process involves several steps. Firstly, you must apply to retain your South African citizenship after completing a determination of citizenship. This includes completing forms, providing supporting documentation, and submitting a letter from the foreign country’s Consulate or Embassy confirming that you haven’t acquired citizenship there.

The necessary documents include the DHA-175 and DHA-529 forms, proof of uninterrupted residence one year before application, South African Police clearance certificate, foreign police clearance, a letter confirming acceptance of dual nationality, and proof of payment.

Conclusion

In conclusion, navigating the realm of dual citizenship requires a thorough understanding of the legal processes, potential pitfalls, and benefits. As a South African seeking dual citizenship, meticulous consideration and compliance with the applicable laws will guide you toward making informed decisions for your unique circumstances.