Dual citizenship and franchise (1/2): active suffrage

With the European Parliament elections of 23 May 2019, fast approaching, today we discuss the sometimes-controversial relation between (dual) citizenship and suffrage. A distinction can be made between the right to vote (active suffrage) and the right to stand for election (passive suffrage). The latter will be the subject of a separate episode.


The traditional argument against the right to vote for dual citizens in their host country is that their voting behaviour will be less responsible since they have an “exit clause”: there is always another country to which they can return. Those having several citizenships can also be accused of acting as puppets for other governments, representing those governments’ interests in the country of residence. There is some truth in this argument, as Michael Jones-Correa has shown that Mexico has sought to mobilize expatriates with dual nationality in the United States to further Mexican interests. The Mexican goal was to “have a potentially significant swinging group with ties and influence with both the United States and Mexico, serving as an important linchpin in relations between the two countries”. Similarly, the Turkish government has expected to gain political benefits from Turkish nationals living in Europe. Zeynep Kadirbeyoglu has noted that “the lobbying potential of migrants living in European countries has been seen as an asset by Governments in Turkey”.



It is difficult to say whether dual nationality makes it easier for home country governments to use their dual nationals as puppets to serve their interests, or whether this accusation makes an unfounded caricature of multiple citizens. In any case, it is questionable to what extent the phenomenon of multiple nationality can be blamed for this, as also naturalized nationals who abandoned their previous nationality can be accused of voting and acting according to the preferences of their former country. The absence of legal ties with the country of origin does not necessarily say anything about one’s emotional attachment to it.


Another point is whether multiple nationals should be allowed to vote in the country where they are not resident, although there is often a residence requirement for the exercise of this right. It can indeed be argued that their having more nationalities gives them more political rights than mono-nationals. Ruth Rubio-Marín takes the view that absentee voting should not be allowed. This view is not based, however, on the argument of some authors that nationals who reside abroad are not sufficiently informed or do not have a sufficient stake in the home country. Rather, she thinks they can be informed and affected, but this in itself is not strong enough a reason to justify a claim to absentee voting. The right to vote should be a prerogative of residents in a country for they are affected most strongly by the exercise of public authority. She also disagrees with the argument that “‘economic’ citizenship and ‘political citizenship’ should go hand in hand”, meaning that the expatriates’ contribution to the home country economy through remittances should be rewarded with political rights. These remittances may indeed be a great asset to the economy, but this does not justify establishing a connection between economic contribution and political rights. According to Rubio-Marín, “the construct of democratic citizenship ... has as one of its fundamental virtues the setting of some limits on the way in which economic power ... translates into political power”. Other authors disagree with this view and claim that voting in two countries does not violate the principle of “one person one vote” because votes cast by the same person in two different countries are counted only once in each election.


Just like citizenship, access to the franchise has been affected by the more porous nature of state boundaries in our age of globalization. The extension of voting rights beyond citizenship (that is, to non-national immigrants) and residence (that is, to expatriates) is referred to as “transnational voting rights”. While it has been speculated that this may undermine democracy, current state practice (according to Daniele Caramani and Florian Grotz) appears to go in the direction of offering migrants franchise in their place of residence at local level and in their home country at national level.


The issue of voting rights may also play in the context of CBI programmes. Countries that have such programmes will often require factual residence to be able to exercise national voting rights – not just in Europe but also in the Caribbean. Jelena Dzankic, quoting Section 8 of the Citizenship Act of St. Kitts and Nevis, shows that “naturalisation by investment does not confer all of the citizenship rights [such as the franchise] to those who have acquired the citizenship of St. Kitts and Nevis but have opted not to reside there”. Similarly, countries such as Cyprus or Malta do not allow non-resident citizens to vote in national elections. Thus, Article 57 of the Maltese Constitution stipulates that a citizen is only entitled to vote in the national elections if (s)he “is resident in Malta and has during the eighteen months immediately preceding his registration been a resident for a continuous period of six months or for periods amounting in the aggregate to six months”.


Author: Dr. Olivier Vonk

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