By Parviz Malakouti-Fitzgerald, Esq.
Which mobility benefits of a citizenship are cast in iron...and which are made of wood or plastic?
This article is part of our series on mobility concept & strategy explainers.
Critically missing from all "passport" or citizenship rankings that I've ever seen is a consideration of the robustness of the mobility benefits discussed.
Here, I define robustness as resistance to involuntary loss or degradation.
Mobility benefits of a citizenship refers to where the citizenship allows you to enter or stay.
The concept of robustness is barely discussed in the global mobility industry. Here's why it matters so much for any aspiring multiple citizen.
Article Outline:
The most robust mobility benefit that a citizenship gives its holder is the highest right of entry and indefinite right of residence ("core residency" rights) in the country's territory.
That's because all other mobility benefits (like visa-free travel, right of residence in other countries and other beneficial treaties) of said citizenship are dependent upon agreement with other countries or unions. This is especially true of "satellite residency" rights, as I call them.
Unfortunately "dependence on" means "vulnerability to."
The Case of the UK and the European Union
Brits relying on their citizenship for EU residency had a rude awakening in 2020. This will inevitably happen again in the EU.
Imagine if you were a British citizen in 2015 marveling at the right of residence all over the UK and mainland Europe that your British citizenship afforded you. If you had considered that your right of residence in all that territory was all equally robust, you found out quickly in January 2020 that it was not.
That's because the relationship between the UK and the European Union (“EU”) changed and with that change came loss of right of residency in EU countries.
The British citizen in 2015 had core residency rights in the United Kingdom and satellite residency rights in the rest of the European Union. The latter vanished five short years later.
“Core” vs. “Satellite” Residency Rights
Now apply that same lesson to rights of residency in the greater EU provided by any EU country. They may be equal in practice now, but they may not (actually over a long enough timeline WILL not) be in the future. Therefore, if robustness and time is considered in the analysis, those rights of residence are not equal in strength and value, even now.
Your right of residence in the EU country you are a citizen of sits at one level of higher robustness (the "core" residency right").
Your core residency rights sits at the top of the hierarchy of robustness of mobility benefits
And your right of residence in other EU countries sits at a lower level of robustness (the "satellite" residency right). That's because the satellite residency rights are vulnerable to more changes than core residency rights. Four of those possible changes are:
dissolution of the EU
exit of your country from the EU
exit of the country you want to be resident in from the EU
unlawful restriction of one country in the EU on citizens of another EU country than the core residency right.
Obviously any rational person pursuing a mobility asset like citizenship or residency would want to factor robustness into their decision-making. For this, there’s no substitute for having a real citizenship advocate or advisor.
If core residency rights are made of iron, satellite residency rights are made of wood
Robustness of Mobility Benefits in Other Contexts
Of course, I believe the same robustness principle applies to mobility benefits afforded by agreement with a foreign country or membership in any travel union, including the Common Travel Area (“CTA”), or MERCOSUR.
Map of MERCOSUR countries
This principle also applies to any country springboard benefits, including satellite residency rights and especially visa-free travel. Again, all three of these mobility benefits are dependent on third country agreement, which is what makes them less robust than core residency rights.
Furthermore, a country that has a minuscule landmass cannot, despite any other perceived mobility benefits of its citizenship, sit atop any credible ranking of citizenships or "passports" (which is actually a misnomer).
This observation is no slight against those small countries - many of them are marvelous. But if the citizenship's core residency rights consists of nothing more than a city-state or tiny island, it simply cannot be the most powerful mobility asset in the world.
Therefore, when evaluating citizenships and residencies to add to your mobility portfolio over the years, you should always give special consideration to both the robustness of a given citizenship’s mobility benefits, and the extent of its core residency rights.