British Citizenship for Germans in the UK: the Impact of Brexit

The UK’s decision to leave the European Union will bring big changes for many. For Germans citizens in the UK, options for acquiring British citizenship or re-settling in the UK at a later date are likely to be impacted significantly.

Although the post-Brexit situation is not yet clear, for Germans in the UK holding German-British dual citizenship is likely to get a lot more difficult, or perhaps impossible for some.

What’s the issue?

Historically, a German citizen who naturalised in another country would automatically lose German citizenship. However, since 28th August 2007, German citizens can acquire the citizenship of another EU country or Switzerland without automatically losing their German citizenship.

Since that time German citizens could become British citizens through naturalisation or registration without any impact on their German citizenship.

However, since the triggering of Article 50, the United Kingdom is set to leave the EU on 29 March 2019. With the UK no longer in the EU, the exception to the loss of German citizenship will no longer apply unless specific arrangements are made by the German government.

The German Foreign Office recently presented a draft law on the acquisition of German citizenship for British nationals in Germany during the transition period — but to date there have been no similar proposals for Germans living in the UK.

Therefore, as it stands, German citizens who wish to naturalise in the UK would subsequently lose their German citizenship if they acquire British citizenship on or after Brexit-day, which is now fewer than 240 days away.

What can be done?

If you are a German citizen in the UK and meet the requirements for naturalisation as a British citizen, there’s still time to gain British citizenship before the UK leaves the EU. This would guarantee your right to UK-German dual citizenship.

However, this process takes several months — and the clock is ticking. Those who do not start the process soon may miss the deadline and the opportunity to secure UK-German dual citizenship.

Applying for British citizenship after Brexit

It will still be possible for German citizens to naturalise in the UK after Brexit. However, German citizens who wish to acquire another citizenship from a non-EU country can only avoidlosing German citizenship through receipt ofan official government permission to retain their German citizenship (Beibehaltungsgenehmigung). Applying for a Beibehaltungsgenehmigung requires a well-presented argument and relevant evidence to convince the German authorities togrant you such permission.

Moreover, the Beibehaltungsgenehmgung is only valid for two years. It would be essential to obtain British citizenship within this time frame to prevent the automatic loss of German citizenship.

Currently, the average processing time for such applications is between four or five months if all required documents are complete. However, waiting timesare expected to increase significantly after Brexit due to greater demand.

As the UK is still in the EU, it is not yet possible to apply for a Beibehaltungsgenehmigung when applying for British citizenship. Therefore it is impossible to “pre-emptively” apply for a Beibehaltungsgenehmigung before Brexit for an application made after Brexit.

What does Passportia recommend?

The decision to naturalise is a personal one and your own specific circumstances must be carefully considered.

Advantages include a totally indefinite and unrestricted right to live in the UK, as well as a second passport if dual UK-German citizenship is acquired.

Unlike settled status or Indefinite Leave to Remain, British citizenship does not lapse after a period of absence. (Two years for Indefinite Leave to Remain, and a proposed five years for those with settled status.) In other words, a British citizen is free to return to the UK after any period time, allowing greater freedom for study, work or retirement abroad while leaving the option of re-settling in the UK open — forever.

Potential complications must also be taken into account. Before naturalising in the UK a German citizen would need to consider how this will affect derivative residency rights for family members and relatives. This is a complicated area of law. We recommend seeking the advice of an OISC-regulated advisor or other qualified immigration practitioner.

If you do wish to naturalise in the UK, and want to ensure that you do not lose your German citizenship in the process, we advise consulting a qualified immigration and nationality advisor as soon as possible to find out if you qualify and to ensure your application will be successful on the first attempt.

In any case, it is important to take full advantage of the time remaining before Brexit.

13 replies
  1. Heike
    Heike says:

    Very interesting article, just one question. Where do I find a qualified immigration and nationality advisor? The embassies don’t seem to be able to give good advice, I get told something different every time I speak to them.

  2. Heike Griffiths
    Heike Griffiths says:

    Very informative.
    Also just one question: is it correct that currently you need to have one year’s residency?
    I never applied for residency. I have lived here for 27 years and would like to apply for citizenship. But will it be too late? Do I have to wait for one year?
    Alternatively, once the new settled status comes in, will I be able to apply for British citizenship straight away?
    Heike (a different one)

    • Stanley Johnson
      Stanley Johnson says:

      Hi Heike,

      You need to have been resident in the UK for one year without an immigration time restriction, and you must get a European Union permanent residence document before naturalising *but* it is important to understand that the permanent right to reside is not given by the permanent residence document and if you have been living in the UK for 27 you almost certainly obtained the permanent right to reside over 1 year ago.

      If you would like to discuss this further and talk about how it applies to your specific circumstances please get in touch!


  3. Michael Riaz
    Michael Riaz says:

    Hi I’ve been here since 2002 still holding my German citizenship, would it mean that I would have to change mine?

    • Stanley Johnson
      Stanley Johnson says:

      Hi Michael – only if you want to and if this suits your personal circumstances and plans for the future. The important point is that, for Germans in the UK, the opportunity to naturalise as a British citizen while maintaining German citizenship will be gone soon.

      If you do not want to naturalise and wish to apply for settled status or indefinite leave to remain instead you can do that. Alternatively you can naturalise as a British citizen after Brexit if you want, although you may lose German citizenship in doing so.

      To discuss this further you can speak to our advisors on 02079938975 or get in touch via our contact us page.

  4. Gabriele
    Gabriele says:

    Would you know if I need to take action ? While having kept my German passport , I have lived and worked in the Uk for 37 years with a permanent residency : was married to an English National but recently divorced and got two daughters with English passports, a house, a national insurance number plus state pension … is that sufficient ?
    There must be so many in the same situation.

    • Stanley Johnson
      Stanley Johnson says:

      Hi Gabriele. It sounds likely that you would be eligible to naturalise as a British citizen. Whether you would need to take actions depends on whether you want to hold dual UK-German citizenship. If you’d like to remain a German citizen only you can apply for leave to remain or settled status, or you can apply for British citizenship at a later date if you don’t mind losing your German citizenship. If in doubt, contact our advisors on 02079938975 or or via our contact us page.

    • Stanley Johnson
      Stanley Johnson says:

      Thanks for your comment. You would need to demonstrate sufficient knowledge of life in the UK and the English language. Depending on your own education history you may or may not need to take a test. For example, if you studied a degree in English that may suffice. If in doubt, get in touch with our advisors on 02079938975 or via our contact us page.

  5. Bea Petersen
    Bea Petersen says:

    Hii, what would be the first step to take in the process of applying for naturalisation, please? I have lived, studied and worked in Scotland since 1997 and would like to become a British citizen whilst maintaining my German Nationality. I’d be grateful for your advice.

  6. Birgit
    Birgit says:

    I have had a stamp in my old German passport giving me leave to remain indefinitely but this isn’t mentioned in my current passport I have lived in the UK for 30+ years do I have to do anything? I work have a mortgage and I am just a bit worried as there doesn’t seem to be a lot of information available. Also what is the cost of Naturalising now please it was over £1000 when I last enquired but this was before it was possible to keep dual citizenship which I oddly only found out about through an add on Facebook.
    thanks for any advice Birgit


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