An IMGW News Feature Article by Chidinma Okebalama
In recent decades, there has been a growing acceptance of dual citizenship worldwide. Although a few Asian states — notably India, China, and Japan — continue to oppose dual citizenship to varying degrees, most of the developed world has acknowledged it, and the same applies to Africa. As more African countries are realising the advantages of being more open to welcoming other foreign nationals and permitting their citizens to hold dual or multiple nationalities, many are taking advantage of the benefits that accrue.
In an essay in the Henley Global Citizenship Programme Index, Prof. Dr. Yossi Harpaz, a sociologist whose research examines the impact of globalization on national identity and citizenship, notes that by 2016 more than 80% of European and American countries had recognized and allowed dual citizenship. As for Africa, Dr. Bronwen Manby, a leading authority on nationality law and statelessness on the continent, highlights in Citizenship Law in Africa: A Comparative Study that at independence, most African countries decided not to allow dual nationality. But over time, for various reasons that include the substantial African diaspora of almost 350 million people (making it the ‘“’third country’”’ in the world after India and China), with roots in multiple countries, as well as millions of Africans on the continent who have connections to two or more African countries, things have changed.
Many African countries are following the global trend and changing their rules. Now, most African countries allow dual citizenship, a handful permit it in certain cases only, and there are just six that don’t: Cameroon, the Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, and Tanzania. The latest African country to approve dual citizenship was Liberia, in 2021[IL1] [IL2] , while Lesotho amended its constitution in 2018, and Zambia in 2017.
8 of Africa’s wealthiest countries that permit dual citizenship:
- South Africa: Allows dual citizenship with prior permission.
- Egypt: Permits dual citizenship with approval; however, the president, prime minister, their spouses, and parents cannot hold dual nationality.
- Nigeria: Allows dual citizenship, excluding the president, state governors, and members of national and state assemblies.
- Kenya: Permits dual citizenship, provided it is disclosed within three months; the president and deputy president are excluded.
- Morocco: Allows dual citizenship with permission.
- Mauritius: Recognizes dual citizenship for native-born Mauritians aged 21 or older.
- Algeria: Permits dual citizenship, excluding the president.
- Ghana: Allows dual citizenship, excluding the president and members of parliament.
These countries have adopted policies that enable their citizens to hold multiple nationalities, reflecting a broader acceptance of dual citizenship across the continent.
Essential Data
Dual citizenship a win-win for nation states and their citizens
Zanzibar-born political analyst Ahmed Rajab of the Pan-African Institute for Strategic Studies points out that the pros of dual citizenship outweigh any perceived cons, and the main benefits are to the economies of countries that permit dual or multiple citizenship. It increases their talent pools and diversity, and can position them for success in the 21st century. And there are benefits for individuals too.
There are many drawcards to having more than one citizenship, but ongoing global turmoil has seen security, personal access rights, and opportunity rise to the top of everyone’s priority lists. Certain countries have far less crime, or suffer fewer natural disasters, or are better prepared for climate change, or offer more advanced healthcare systems which can be access with greater ease, or premium education opportunities.
Sometimes there are personal reasons that single out certain countries as being safer options. For example, certain individuals will likely feel far freer in countries that do not criminalize their sexuality, while asthmatics would face fewer health risks in less polluted environments. For many, the security benefit of dual citizenship is simply the peace of mind of knowing that if their country of residence had to face an unexpected catastrophe, they would have the option to relocate elsewhere.
Eight of Africa’s 10 wealthiest countries permit dual nationality
The Africa Wealth Report 2023 published by Henley & Partners lists Africa’s wealthiest countries in terms their millionaire populations – namely, high-net-worth individuals with investable wealth of USD 1 million or more. Of the Top 10 wealthiest countries on the continent, eight allow dual citizenship.
At the top of the list is South Africa, with 37,800 resident millionaires. South Africa’s Citizenship Act allows dual citizenship, but if you’re 18 or over, before you acquire another citizenship, you must apply and be granted permission to retain your South African citizenship.
Egypt is Africa’s second wealthiest country, with 16,100 millionaires, and has a similar stance to South Africa. Egyptian citizens can gain a foreign nationality and retain their Egyptian citizenship after obtaining permission from the Minister of the Interior but this does not extend to wives or non-minor children. Gaining foreign citizenship also exempts Egyptians from military service[IL3] [IL4] . Egypt’s president and prime minister, and their spouses and parents, cannot be dual nationals.
Africa’s third wealthiest country, Nigeria, has 9,800 millionaires and permits dual citizenship for most of its citizens, but not for the president, state governors, or members of national and state assemblies.
Kenya, which is number four on Africa’s wealthiest countries list, with 7,700 resident high-net-worth individuals, also allows dual citizenship as long as you disclose your new additional citizenship within three months, but not if you’re the president or deputy president.
Morocco is the fifth wealthiest country in Africa, with 5,800 millionaires, and has allowed dual citizenship since 1958, while Mauritius, in sixth place with 4,900 high-net-worth residents, allows dual nationality for its nationals from birth but not for those who naturalize in the island nation. The continent’s seventh wealthiest country, Algeria, permits dual nationality for all but its president.
Ninth-placed on Africa’s wealthiest countries list is Ghana, with 2,600 millionaires, which permits dual nationality to all citizens apart from the president and members of parliament.
Angola, ranking 11th in Africa’s wealthiest countries list with 2,400 millionaires, and Namibia, ranking 13th with 2,100, also permit dual citizenship, although similarly to Mauritius, Namibia only permits this to its citizens by birth.
The two outliers permit special treatment for diaspora members
Ethiopia is one of two countries on Africa’s top 10 wealthiest list (in eighth spot with 2,700 millionaires) that do not permit dual citizenship, but in 2019 its parliament passed a bill to allow members of the country’s diaspora who have taken up other nationalities to invest, buy shares, and set up lending businesses in its financial sector.
Tanzania, which ranks 10th with 2,400 high-net-worth residents also denies dual citizenship, but in May, Foreign Affairs Minister Stergomena Tax announced that the government would give special status to Tanzania’s diaspora. The arrangement was designed in consultation with the diaspora, specifically for those who have acquired other countries’ citizenships, and is expected to come into force in the coming financial year, allowing them to enjoy various services and opportunities available in the country.
Dual citizenship enhances global mobility
Having multiple citizenships also opens up the possibility of traveling to a wider range of destinations more easily. But perhaps the most significant and expansive advantage is that it widens the range of options for investors and their families and enables them to access the life they choose depending on their needs and requirements.
Over and above being able to choose somewhere safer or more lucrative to live, people might simply prefer one state over another based on any number of reasons, ranging from aesthetic preferences to ideological commitments. The ability to choose where to set up your life offers extraordinary power to define your reality and your future.
Gaining Another Citizenship
For individuals keen on expanding their citizenship portfolios, options include naturalization, marriage, and investment. Naturalization conditions vary by country and are often rigorous, and finding a life partner who is a citizen of the desired country isn’t always feasible. However, for those with financial resources, residence and citizenship by investment offers the most straightforward path to an additional citizenship.
With rising wealth in Africa, many African investors are choosing this route. According to Henley & Partners, their top choice in 2023 is the Portugal Golden Residence Permit Programme, requiring a minimum real estate investment of EUR 280,000. After five years of legal residency in Portugal, applicants may qualify for citizenship in this EU member state. The Caribbean also offers several popular citizenship programmes favored by African families, including the St. Kitts and Nevis Citizenship by Investment Programme with a minimum investment of USD 250,000, and options in Antigua and Barbuda, Dominica, and St. Lucia, each requiring a minimum of USD 100,000.
Country Requirements for Dual Citizenship in Africa
- South Africa: Permitted with prior permission.
- Egypt: Permitted with permission; president, prime minister, spouses, and parents excluded.
- Nigeria: Permitted; excludes the president, state governors, and members of national/state assemblies.
- Kenya: Permitted with disclosure within three months; excludes the president and deputy president.
- Morocco: Permitted with permission.
- Mauritius: Recognized for native-born Mauritians aged 21 or older.
- Algeria: Permitted, excluding the president.
- Ethiopia: Not permitted.
- Ghana: Permitted; excludes the president and members of parliament.
- Tanzania: Not permitted.
- Angola: Permitted.
- Namibia: Permitted only for citizens by birth.
- Botswana: Permitted under specific conditions.
[IL2]https://constitutionnet.org/news/lesotho-amends-constitution-allow-dual-citizenship
[IL3]https://www.egyptindependent.com/conditions-set-for-egyptians-to-obtain-foreign-nationality/
[IL4]https://www.egyptembassy.org/citizenship/dual-approval/
About the Author
Chidinma Okebalama is a Senior Consultant at Henley & Partners. She advises clients from across the globe and focuses mainly on the African market. With over four years of experience as a client advisor at the firm, she helps high-net-worth families navigate their options in legacy planning as they seek tailor-made solutions to their residence and citizenship by investment needs.
Chidinma has a degree in electrical engineering from Northeastern University in Boston, USA. A six-sigma certified specialist, she previously worked with a US defense contractor spanning roles as a system integration, test, and process engineer.
Chidinma is also an internationally renowned recording and performing artist and has performed at several stately events across Nigeria, including the recent inauguration ceremony of the 16th president of Nigeria. She recently released her debut album ‘Goodness & Mercy’ on all media platforms.
For more IMGW.New reports about Africa please see:
- Investment Migration: Unlocking Global Access for Africa’s Wealthiest
- Egypt: A Nexus of Socio-Political, Economic, and Cultural Significance
- Could Africa be the Next Frontier for Investment Migration?
- Global Wealth Dynamics: The World’s Wealthiest Cities in 2024, and Emerging Destinations
