Citizenship by exception is a grant of nationality that skips some or all of the normal naturalization rules because a government decides it serves the national interest. A minister, cabinet, president or parliament makes the decision, usually for a person with exceptional achievements, rare skills, a major economic contribution or a humanitarian need.
Unlike a citizenship by investment program, there is normally no published price, no checklist that guarantees approval and no right to appeal a refusal. The power exists in the law of many countries, but it is used sparingly. For most people, it is a legal curiosity rather than a realistic route to a second passport.
This guide explains how discretionary naturalization works, where the legal basis sits in several countries, and what to watch for when someone offers to arrange it for a fee.
Key takeaways
- Citizenship by exception is a discretionary grant that waives normal conditions such as years of residence, language tests or renouncing your old nationality.
- The legal power exists in countries as different as Austria, Canada, France, Spain, Poland, Uruguay and Turkey.
- Grants usually go to athletes, artists, scientists, major investors, people who served the state, and stateless people.
- There is rarely a fixed fee, a fixed timeline or an appeal, and refusal is common.
- The EU's top court ruled in April 2025 that a member state may not grant citizenship in a purely transactional way, which shapes how exception routes in Europe are judged.
What citizenship by exception means
Every naturalization law sets conditions: a residence period, proof of income, a language test, good character and, in some countries, renunciation of other nationalities. An exception clause allows the state to waive some of those conditions for a specific person.
The key word is discretion. Ordinary naturalization in many countries works like an entitlement: if you meet the rules, approval is expected. An exception grant works the other way. Meeting every informal expectation does not oblige the state to say yes.
Different countries use different labels for the same idea, including naturalization in the national interest, extraordinary naturalization, special grant, citizenship by merit and grace naturalization. The label matters less than three questions: who decides, what conditions they can waive, and whether the decision can be challenged.
Exception, investment and honorary citizenship compared
These three terms are often mixed up. The table shows how they differ in general.
| Feature | Citizenship by exception | Citizenship by investment | Honorary citizenship |
|---|---|---|---|
| Legal basis | Discretionary clause in a nationality law or constitution | Dedicated program with published rules | Symbolic act, often a resolution or proclamation |
| Who decides | Minister, cabinet, president or parliament | Program unit, then a minister | Parliament or head of state |
| Published price | No | Yes | No |
| Passport and full rights | Yes | Yes | Often no |
| Approval rate | Low and unpublished in most countries | Published or estimable in some programs | Not applicable |
| Appeal | Rare | Limited | Not applicable |
Honorary citizenship deserves a note. The United States, for example, has conferred honorary citizenship on only a handful of people, such as Winston Churchill in 1963. It is a symbolic honor and does not create the rights of a US citizen.
Where the legal power exists
The table below lists examples of countries with a discretionary grant power in their law. It describes the legal basis, not how often each power is used.
| Country | Legal basis | Who decides | What it can waive |
|---|---|---|---|
| Austria | Citizenship Act, section 10(6) | Federal Government confirms the special interest of the Republic | Residence period, income test and renunciation |
| Canada | Citizenship Act, subsection 5(4) | Minister | Any other requirement of the Act |
| Ireland | Irish Nationality and Citizenship Act 1956, section 16 | Minister for Justice | Some or all naturalization conditions in listed cases |
| France | Civil Code, article 21-21 | Government decree, on the foreign minister's proposal | Residence requirement |
| Spain | Civil Code, article 21 (carta de naturaleza) | Council of Ministers by royal decree | Residence and standard procedure |
| Poland | Constitution, article 137 | President | Statutory naturalization conditions |
| Uruguay | Constitution, article 75 | General Assembly | Residence rules, for notable services or merit |
| Turkey | Citizenship Law No. 5901, article 12 | President | Standard residence rules |
| Serbia | Law on Citizenship, article 19 | Government authorities, in the interest of the Republic | Residence and release from prior citizenship |
Austria
Section 10(6) of the Austrian Citizenship Act is a constitutional provision. It lets the Federal Government confirm that granting citizenship is in the special interest of the Republic because of the applicant's extraordinary past and expected achievements. Once confirmed, the usual 10-year residence period, the self-sufficiency test and the duty to give up a foreign nationality no longer apply. Austria has used the clause for athletes, artists, scientists and, in some cases, major investors with large projects in the country.
Canada
Subsection 5(4) of the Citizenship Act lets the minister grant citizenship, despite any other provision of the Act, to reduce statelessness, to address special and unusual hardship, or to reward services of exceptional value to Canada. The provision is used rarely and for individual cases.
France and Spain
France's Civil Code lets the government naturalize a French-speaking foreigner whose outstanding work contributes to France's international influence and economic relations, without the usual residence period. A separate rule allows foreign soldiers wounded on operations, including Foreign Legion members, to acquire French nationality. Spain's carta de naturaleza is granted by royal decree when exceptional circumstances apply. Spain has used it for elite athletes and, historically, for veterans of the International Brigades.
Uruguay, Poland and Turkey
Article 75 of Uruguay's Constitution lets the General Assembly grant legal citizenship for notable services or relevant merit. In Poland, the constitution gives the president the power to grant citizenship, a power separate from the statutory routes run by regional governors. Turkey's citizenship law groups several routes under 'exceptional' acquisition, including people who bring industrial facilities or outstanding contributions in science, technology, economics, sports, culture or art. Turkey's well-known investment route is set out under the same article through implementing regulations.
The UAE
Since 2021, the UAE has allowed some foreigners to receive citizenship by nomination. Investors, doctors, scientists, inventors, artists and other specialists can be nominated by official bodies, and they may keep their existing nationality. There is no application route: a person cannot apply on their own initiative.
Who actually receives it
Public examples cluster in a few groups:
- Athletes who can represent the country at international competitions.
- Artists, scientists and academics with international recognition.
- Investors and business founders whose projects create significant jobs or exports, usually far beyond the sums required by investment programs.
- People who served the state, such as soldiers, doctors in a crisis or diplomats' local staff.
- Stateless people and humanitarian cases, as provided in Canada's and Ireland's laws.
Passive investments such as buying property are rarely enough on their own. Governments that use the power tend to expect a contribution they can point to publicly.
How the process usually works
Because the decision is discretionary, the process is less formal than standard naturalization. It often looks like this:
- Sponsorship. A ministry, sports federation, university or business body supports the case, or the applicant files a petition with supporting evidence.
- Evidence. The file documents achievements, the expected benefit to the country and the applicant's links to it.
- Background checks. Police, intelligence and source-of-funds checks still apply. Our guide to source of funds checks for investment migration explains what reviewers usually ask for.
- Decision. A minister, cabinet or president decides, often without published reasons.
- Oath and documents. If approved, the applicant takes an oath where required and then applies for an identity card and passport.
Timelines are rarely published, and a refusal usually cannot be appealed on the merits.
Risks, red flags and the EU dimension
Citizenship by exception attracts intermediaries who sell it as a product. Treat these signs with caution:
- A fixed price for a discretionary decision. No legal fee schedule can promise a discretionary outcome.
- Large payments before any official decision. If the government refuses, the money may not come back.
- No identifiable legal basis. A credible route can be traced to a specific article of law.
- Promises of speed. Discretionary routes rarely have binding timelines.
In Europe, the legal ground shifted on April 29, 2025, when the Court of Justice of the European Union ruled in Commission v Malta (C-181/23) that Malta's investor citizenship program breached EU law. The court held that granting nationality in exchange for predetermined payments or investments amounts to a transactional process that is incompatible with the bond of solidarity and good faith between a state and its citizens. Malta stopped the investor route after the ruling and amended its Citizenship Act in July 2025 (Act XXI of 2025), while keeping a discretionary route for citizenship by merit. Any European exception route that looks like a sale of citizenship now faces the same test. See our article on the EU crackdown on golden passports.
The FATF and the OECD also published a joint report in November 2023 on the misuse of citizenship and residency by investment programs, which highlighted weak due diligence and poorly supervised intermediaries as risk areas. Citizenship obtained by misrepresentation can also be revoked later, a risk covered in our analysis of whether citizenship by investment can be revoked.
Is it a realistic route?
For a small number of people with exceptional profiles, yes. For most people looking for a second passport, structured routes are more predictable: naturalization after residence, citizenship by descent, or a codified investment program with published rules. Our guides to how to get a second passport and the best citizenship by investment programs compare those options.
Frequently asked questions
What is citizenship by exception?
It is a discretionary grant of nationality that waives some or all of the normal naturalization conditions because the government considers it to be in the national interest. A minister, cabinet, president or parliament usually decides.
Can you buy citizenship by exception?
Not in a lawful, transactional sense. Some countries consider economic contributions, but the decision remains discretionary, and the EU's top court has ruled that member states may not grant nationality in exchange for predetermined payments.
How long does citizenship by exception take?
There is no standard timeline. Some cases move quickly when a government wants the person, for example an athlete before a tournament, while others take years or never receive a decision.
Is honorary citizenship the same thing?
No. Honorary citizenship is usually symbolic and may not include a passport or legal rights. Citizenship by exception is full citizenship granted through a discretionary procedure.
Can a discretionary grant be revoked?
Yes, in many countries. Citizenship obtained through fraud or misrepresentation can usually be withdrawn, and some countries also allow deprivation of naturalized citizens on public-interest grounds.
Important: This article is general information, not tax, legal or financial advice. Rules change often and depend on your personal circumstances. Speak with a qualified professional in each relevant country before you act.