Frequently Asked Questions

There are quite a lot of words that are ambiguous. Nationality and citizenship are cases in point. Though used in different ways I have always seen nationality as linked to the geopolitical entity in which you are born but citizenship as the political affiliation to a geopolitical entity. 

The UK as a sort of ‘supra-national entity’ also allocates citizenship to that ‘supra-national entity’ to all citizens of the member countries. In a sense there is no difference between the UK doing that and the EU doing it. That the UK as a ‘supra-national entity’ is also a country is an anomaly. It causes problems at the UN because of that in that it creates recursive loops within data structures! 

So many words become loaded… ‘The only thing I can think of is the Roman Empire, but then the Romans ruled the Empire in a way that the EU does not.’ When the UK had an empire some non-nationals (I use the word national to be etymologically linked to natus – a place of birth) were given citizenship. 

The problem in a sense is that some people are trying to understand EU citizenship in a way that the authors of the founding treaty did not intend. It is individual and personal affiliation with the EU in terms of rights, obligations and privileges in much the same way as citizenship of a country is individual and personal affiliation with that country in terms of rights, obligations and privileges.

Think of it in terms of dual-citizenship (dual-nationality seems to be an oxymoron to me in that you cannot be born in more than one place). Is a Scot more Scottish or more British? Some would say one and some the other. 

I would agree that the founding authors of the TEU were less than clear on how it worked. I am also saddened that nothing was written into A50 to say what happens when a member state leaves the EU to those citizens. When countries split – for instance the partition of Yugoslavia I believe you could claim citizenship based upon where you were living regardless of ethnicity. That would have and helped in the secession of the UK from the EU.

Richard Fairhead


It’s not an unreasonable question, so I’ll give it what I hope is a professional answer.

The Treaty of Maastricht included the following declaration: “Citizenship of the Union is hereby established. Every person holding the nationality of a Member State shall be a citizen of the Union. Citizenship of the Union shall be additional to and not replace national citizenship.” It and the Treaty of Lisbon associated a number of rights with such ‘citizenship’.

In a sense the use of the term ‘citizenship’ was unfortunate, precisely because it leads to people asking this and similar questions. Think of it like this: The EU gives you a certain ‘package’ of rights; you need to call that package something; and although it’s not citizenship in the same sense as national citizenship (obviously) nevertheless the term ‘citizenship’ is probably as good an approximation to what this package of rights actually gives you as you’re going to find that is translatable into all of the EU’s official languages.

To put this into the kind of language that we use in the world of policy development and implementation planning: the Treaty of Maastricht envisaged a policy package  that accorded certain incremental rights to every person holding the nationality of a Member State; it used the expression ‘Citizenship of the Union’ as a convenient title for that policy package.

If you go to Cuba, for example, and find yourself in consular difficulties, you – as a citizen of an EU Member State – could appeal to any of the Member States’ embassies for help in the same way as one of their own citizens. In a sense, therefore, it may be regarded as a kind of citizenship.

The point I’d really like to make is this: what you call it isn’t important, and if you get hung up on that, you’re missing the point entirely. The important thing is that you have some very useful rights that are worth valuing and protecting.

Stuart Brown


Previous legal cases have demonstrated that one can only lose EU citizenship if you make fraudulent claims or undertake criminal activity. These cases are extremely rare.

There is currently a considered ambiguity, in part due to variant language versions of the various treaties involved, as to whether or not you can lose EU citizenship if a Member State leaves the European Union.