Just like his parents, Paul Zaba was born in the UK and given British citizenship at birth. But this only reflected part of the picture. Culturally, Paul’s family has always been part Polish – they all speak the language, and Paul attended Polish Saturday school and scout camps. “I describe myself as Polish-British,” says Paul, who feels like he belongs to both countries. “I’m very involved with the Polish diaspora.” But even though Paul has four Polish grandparents, he never held a Polish passport. It never seemed necessary – until now.
“On the day we got the result of the Brexit vote, [my Polish friends and I] texted each other that, obviously, we’re going to get Polish citizenship now,” says Paul. “It was that immediate; the plan was hatched. We wanted to retain all the benefits of being EU citizens, of being able to travel in Europe unimpeded and have the option to settle there.”
Many UK-born people who, like Paul, always had the right to dual citizenship with a European country, simply never bothered to do the paperwork. It costs money and is a lot of hassle, so unless there’s a specific reason, why bother? But all that changed with Brexit, when Brits lost their freedom of movement to not just seamlessly travel in Europe, but also to live and work in 27 EU countries with almost the same rights as locals. The desire to retain these rights has led hundreds of thousands of Brits to grab bureaucracy by the horns and read the fine print – the rules vary widely depending on the country – and work out if they can claim citizenship on the basis that mum, grandpa or maybe even great-grandpa came from an EU country.
According to the Office for National Statistics, 1.26 million people who live in Britain, or 2.1 per cent of the population, now have passports to both the UK and one other country. More specifically, the 2021 Census found a fivefold increase in people born in the UK now holding both British and EU passports. The Global Citizenship Observatory estimates that Brexit has prompted 90,000 Brits to acquire a second passport from Europe. This number does not include those securing their first Irish passports, a number estimated between 120,000 and up to half a million people.
Paul became officially Polish in 2018 after his mother, Christina Malkowska, finished filing for citizenship as the child of a Polish person – only then could Paul and his sister do the same. Christina explains that her mum had kept her old Polish passport after naturalising in Britain, but didn’t have her birth certificate: “My mum was born in 1927, and a lot of documents were destroyed in the war. But her christening certificate still existed in the parish records in Poland,” she explains. She was able to get a copy from the parish priest. As part of the 12-page application, Christina had to explain her connection to the country. “I had to write this in Polish. I had to tell the story of my parents, my grandparents, my great-grandparents, as far back as I could.” The file was finally reviewed by the courts, which determined that she’s indeed a Polish citizen.
Paul, who also goes by Paweł, is happy to finally be Polish – as we spoke he was eager to get to vote for the first time in a Polish election. “I feel proud of my citizenship. I feel like I’ve earned it.” Paul now uses his Polish passport to travel in Europe, skipping the long immigration queues that have become a sore point for many Brits who, since Brexit, now have to start their holidays in the slow lane. While we’ll likely be able to start using e-gates in Europe again next year, the new electronic visa system is currently scheduled to go live in late 2026, providing a fresh reminder to Brits that we’re not officially a member of the European family anymore. The European Travel Information and Authorisation System (ETIAS) will require Brits to provide their personal information before entering Europe, in exchange for a passport-linked travel permit that will require renewal every three years, at the cost of €7.
With just a UK passport, I would have been very limited in my travel. If I wanted to move to Spain or Italy, it would have been very difficult. Whereas with an Irish passport, I’m European
Sarah Wellband
The most common European ancestry for a UK-born person is Irish, head and shoulders ahead of French and then German, Polish and Italian. Sarah Wellband grew up English and only realised she had Irish heritage when she found her birth mother in 2000. By coincidence, Sarah was living in Dublin at the time, but didn’t pursue Irish citizenship: “It’s long-winded. You’ve got everything going on in your life. If you don’t see the value in something, you don’t think about pursuing it. It just wasn’t a priority.”
But then Brexit happened. Sarah was living in Portugal by this point – she wasn’t worried about her rights to stay there, as she had permanent residency. “But with just a UK passport, I would have been very limited in my travel. If I wanted to move to Spain or Italy, it would have been very difficult. Whereas with an Irish passport, I’m European.” Sarah got the documents she needed from her birth mum: “I had certificates coming out of my ears,” she laughs. “I didn’t even know if it was possible for me, as I was adopted [by British parents]. But it didn’t matter as long as I had my original birth certificate.”
While Sarah started the process for practical reasons, the experience has led to profound changes in how she sees herself. “I have my Irish heritage, and also, I love the country. This is far more valuable to me than just a travel document,” she says. “If anybody asks me now, I tell them I’m Irish because officially, I am. I identify as Irish.”
Technically speaking, most people who become citizens through ancestry aren’t actually applying for citizenship, which is a process for immigration. Instead, people like Sarah are simply providing extensive documentation to prove that, actually, they are already citizens, and they’d like to make it official, please. But even though it’s a birthright, claiming a national identity can lead to conflicting feelings.
Tom Harrison’s grandmother on his father’s side was Irish, but he also happens to be born in Northern Ireland, meaning he’s also entitled to Irish citizenship as per the Good Friday Agreement. “I lived in Portstewart until I was six, when my family moved back to England,” says Tom. He’s always been aware he could get a second passport: “But it just never seemed important. From a practical perspective, a British passport was stronger,” says Tom, whose British-identifying father actively discouraged him from pursuing it. “Dad would say, why would you want to be associated with Ireland?”
Tom made the decision to go ahead only after Brexit changed the score, and his British passport no longer provided entry to Europe. “I’m worried about the political route this country is taking. Access to Europe is important to me … Ireland is a lot more progressive now than it used to be. It’s become far more attractive [as a place to live].” His dad has come around on the passport thing too now, as “he’s very pro-EU”, Tom laughs. But even though he has fond memories of his early years in Northern Ireland, Tom has found himself wondering whether he has any right to call himself Irish: “I have a legal entitlement, but I don’t have any real connection with the culture. So when I speak to Irish people, I don’t feel like I can claim that identity.”
Most countries will only extend citizenship rights for one, maybe two generations, and only if specific and sometimes narrow conditions are met. But as a gesture of restitution, Germany, along with Austria, Spain and Portugal, has dedicated routes for people who lost their citizenships due to political, racial or religious persecution. In Germany, the rules apply to people who were deprived of their nationality due to persecution during the 1933-1945 Nazi regime, and to their descendants.
This is why Peter Flemming, who was born in the UK, has spent several years researching the early life of their grandfather Moritz, who was born in Germany in 1910 before his family emigrated to the US. “Moritz wanted to go to medical school, but at the time the US had a limit to how many Jewish students would be admitted to study medicine,” Peter says. “So Moritz decided to move to Germany for education in 1932, and completed a medical degree in [German] Königsberg, which is now [Russian] Kaliningrad. Moritz graduated in 1938 and returned to the US, showing impeccable timing.”
Peter has plenty of copies of documents proving all of this, but the Germans need originals. “I need to establish that Moritz had ordinary residence in Germany before January 1933, when Hitler became chancellor,” says Peter, who’s currently trying to get shipping records to prove Moritz arriving in Hamburg in late 1932. Then it will be time to apply, and cross fingers that the evidence will be sufficient.
Peter’s motivation for doing this is simple: “I want freedom of movement back. I want that liberty … I don’t have deep German roots – Moritz only lived in Germany for about 10 years. I feel an affinity with Europe more than to Germany specifically.” But the process has proven rewarding, especially as it’s turned into a family research project. Moritz didn’t speak much about this time in his life – Peter has copies of letters from the university, on swastika letterhead, warning Moritz that he wouldn’t be able to practice medicine because he was Jewish. While it’s not clear what Moritz was thinking when he left Germany, no doubt he understood things wouldn’t go well for him if he stayed. “All of this has made me think a lot about family,” says Peter. “Even if I don’t get German citizenship in the end, what I’ve learned will have been worth it.”