Citizenship in Latin America

Today FCI continues its series on the (historical) development of citizenship in different regions, having previously discussed Europe and China. As Diego Acosta has noted in his seminal work The National versus the Foreigner in South America, citizenship and migration practices need to be studied on all continents in order to “break away from the stale dichotomy focusing solely on the USA and Europe as models of global migration management”. As South America presents an ideological approach that is both innovative and exceptional, “recognising the importance of South America as a global alternative to American and European approaches to immigration and citizenship is both an intellectual necessity and an opportunity to produce original answers to contemporary challenges of migration regulation”.




Acosta notes that from the very beginning, one exceptional feature in South American laws was the idea of open borders. At the same time, however, South American countries continue to apply to this day a legally sanctioned division between “naturals” (natives) and those who are “naturalised”. The latter are a different legal category of residents with fewer rights, and birth in the territory has always been considered an essential condition to be a “true” citizen. Another characteristic is short residence periods before naturalisation. Despite the lenient conditions, naturalisation rates have generally been (extremely) low, particularly in comparison to the numbers in Europe, as analysed by FCI in a previous post.


Acosta lists a few oft-mentioned reasons for this in a separate contribution, namely tradition; citizenship renunciation requirements in the naturalisation practices of some South American countries; relatively low immigration rates in recent decades, especially when compared to the massive immigration of the early 20th century; and Latin American immigration being mostly of regional origin. Thus, naturalisations run from several hundreds per year in Colombia to on average 4,000 per year in Mexico. These numbers are indeed surprisingly low when contrasted with the number of South Americans who naturalise elsewhere. As Acosta observes, “between 2008-2017, more than 775 thousand South and Central Americans, and Mexicans, naturalised in Spain through residence in the country”.

With South Americans thus not being averse to the concept of naturalisation itself, the reasons for the low numbers in Latin America itself are probably found in lack of information or government campaigns, burdensome administrative procedures regarding the necessary paperwork, and discriminatory practices. Acosta notes that research on this aspect is particularly urgent, for instance in light of the Venezuelan refugee crisis that is affecting other countries in the region and the migration from the Northern Triangle (Guatemala, Honduras and El Salvador) to the US via Mexico where, if they stay long enough in transit, might become eligible for naturalisation after obtaining a residence permit.


The abovementioned “open borders vision” presently finds its expression mainly in the wish to secure more rights for the many South American emigrants. In order to grant reciprocal rights to immigrants, however, many of the American states have also come to accept “dual citizenship, extend the franchise to foreigners, and sign agreements with reciprocal settlement rights throughout the region”. While FCI previously investigated whether there is something as a right to migrate, this right is already present in several South American laws, thus demonstrating a strong human rights focus. In Acosta’s words, “with all its contradictions, drawbacks and implementation challenges, it is stimulating [for South America] to be the first one to verbalise a new vocabulary of non-criminalisation, migration as a right and universal citizenship, even if not always proven effective”.


Author: Dr Olivier Vonk

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