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BREXIT

Should British-Danish dual citizenship applicants also apply for post-Brexit residency?

British nationals who are applying for, or have been approved for, Danish citizenship in 2021 likely also need to apply for post-Brexit residency in Denmark.

Should British-Danish dual citizenship applicants also apply for post-Brexit residency?
British nationals with active Danish citizenship applications are likely to need to apply for post-Brexit residency status. Photo: Nils Meilvang/Ritzau Scanpix

British nationals who moved to Denmark under EU free movement rules before December 31st 2020 must submit an application for new residence status and a new residence document in 2021.

But what about those who are applying or have already been approved for Danish citizenship?

Citizenship entitles you to a Danish passport and gives you the right to vote in parliamentary elections, as well as providing a permanent basis for residency in the country. It also means you retain the right to live and work in Denmark (and other EU countries) even if you leave Denmark.

You must, of course, meet a number of closely-defined criteria and requirements in order to be eligible for citizenship by naturalisation.

Permanent residency means that a person is allowed to stay in Denmark and does not need to apply for residence again, though is important to note that if you leave Denmark for more than two years, you will have to revoke your permanent residency. 

It also means you no longer need to meet the conditions for your original grounds for residence, so you won’t lose your right to reside in Denmark if you stop working or studying, for example.

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But if you are a British national who is eligible for Danish citizenship, and even if you have already applied for Danish citizenship, you probably need to apply for the post-Brexit residence status as well.

If you have applied for Danish citizenship but not yet received a decision, you need to apply for the post-Brexit status. That is because you would not be expected to become a full Danish citizen by the end of 2021.

Under Danish law, citizenship can only be granted to foreign nationals via legal nationalisation: applications must be voted through by parliament. Successful applicants for citizenship receive notification that they will be accepted on the next naturalisation bill. These are normally put forward twice a year, in April and October, and voted through around June and December respectively.

But once the bill with your successful citizenship claim has passed parliament, you are still not a full citizen until you have attended a so-called ‘citizenship ceremony’ at your local municipality and shaken hands with a local official.

Dependent on how far you have come through this process in 2021, you will likely still need to apply for the post-Brexit permanent residency.

“Citizenship is initially effective from the moment the applicant has participated in a citizenship ceremony, if this is a condition [exemption is granted in specific cases, ed.],” the Ministry of Immigration and Integration told The Local via email.

“The law which is expected to be tabled in October 2021 is expected to be passed in December 2021, taking effect around the turn of the year. Since municipalities must conduct citizenship ceremonies one to four months after the law granting the right to citizenship takes effect, the applicant would not be able to take part in a citizenship ceremony before the end of 2021,” the ministry explained.

For applicants not required to take part in the ceremonies, it is currently unclear whether the law will take effect in 2021 or 2022, it added, meaning people in this situation should also apply for post-Brexit status.

As such, British applicants who currently reside in Denmark under the pre-Brexit EU rules for permanent residency must apply for the new document before December 31st.

“If the applicant does not apply for a new residency document according to the (Brexit) withdrawal agreement by the end of 2021, that person risks losing their right to reside in Denmark,” the ministry wrote.

But one group of 2021 citizenship applicants may not need to apply for post-Brexit permanent residency, according to the immigration ministry: those whose applications were already ratified by parliament in June this year.

This group will have already taken part in citizenship ceremonies or have one coming up soon, since these must be held between July and October 2021.

If you have taken part in a citizenship ceremony during this time you will have become a Danish citizen before the deadline for application for post-Brexit permanent residency, namely December 31st.

“However, the ministry generally recommends everyone encompassed by the withdrawal agreement to send their application for residency status to SIRI,” the ministry wrote.

It should be noted that while EU free movement allowed British nationals to live anywhere in the EU, the withdrawal agreement “only gives right in the country in which that person has taken residence and not in other EU member states,” the ministry told The Local.

Additionally, British citizens who moved to Denmark under EU free movement before switching to the new withdrawal agreement residency status will still be eligible for family reunification under EU rules, the ministry also confirmed to The Local. This is provided by the withdrawal agreement and remains valid if that person later becomes a Danish citizen.

“This applies even though the family member does not yet reside in Denmark. However, it is a requirement that the family relation existed before the expiry of the transition period on December 31st, 2020,” the ministry stated.

According to figures provided to The Local by the immigration ministry, the end of the transition period does not appear to have prompted a spike in Brits applying for dual citizenship.

Ministry figures show 527 Brits applied for Danish citizen ship in 2019, followed by 507 in 2020. The data carry a degree of uncertainty because they are based on a registration system, rather than a statistical count.

So far this year (up to September 15th), 290 people with British citizenship have applied for Danish naturalisation, the ministry said.

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DANISH CITIZENSHIP

How do Denmark’s citizenship rules compare to Sweden and Norway?

We take a look at how Denmark’s citizenship requirements compare to other Scandinavian countries.

How do Denmark’s citizenship rules compare to Sweden and Norway?

Gaining citizenship of one Nordic country grants you rights in the others, such as making it easier to move there, work there, and even become a citizen. So, where is it easiest to become a citizen, and where will you be waiting the longest?

Photo by Nick Karvounis on Unsplash

Denmark

Length of stay: 9 years

Normally, you must have lived in Denmark for nine consecutive years (without living elsewhere for more than three months) in order to qualify for Danish citizenship.

This period is reduced in some cases: for refugees it becomes eight years, citizens of Nordic countries need a two-year stay and people married to Danes qualify after 6-8 years, depending on the length of the marriage.

Other exceptions are made for those who have taken a significant portion of their education in Denmark, who may qualify after five years. If you moved to Denmark before your 15th birthday, you can become nationalised after you turn 18.

EU and non EU citizens must have a permit for permanent residency in Denmark for a minimum of two years before applying for citizenship.

Language test

Applicants must have passed the national Prøve i Dansk 3 language test, the final exam in the national Danish language school system. This involves a reading, writing, speaking and listening test which equates to B2 Danish.

There are certain exemptions from the language requirements. Residents of Greenland and the Faroe Islands, as well as Swedish and Norwegian speakers, do not need to document Danish proficiency. Dispensation can be given for applicants with certain types of illnesses and disabilities, and different rules apply to children.

Citizenship test

A condition of getting Danish citizenship is to demonstrate knowledge of Danish society, culture and history, by having passed a citizenship test (indfødsretsprøve).

In April 2021, the existing citizenship test, consisting of 40 multiple choice questions, was supplemented with five extra questions about “Danish values” such as equality, freedom of speech and the relation between legislation and religion. 

The pass mark is 36/45 and at least four of the five Danish values questions must be answered correctly. 

Children under 12, Swedish and Norwegian citizens, and people from the Danish minority in German region Schleswig-Holstein do not need to take the citizenship test.

Other requirements

  • Sign a declaration pledging allegiance and loyalty to Denmark and Danish society and promising to abide by its laws.
  • Be free of debt to the public sector and be financially self-sufficient.
  • Have no criminal convictions.
  • Hold a full-time job or been self-employed for three and a half of the last four years. 
  • Attend a ceremony, declare you will uphold Denmark’s laws, values and principles and shake hands with an official.

You also need to submit paperwork to prove your identity, current nationality, residency and economic activity in Denmark.

Processing time and fees

At the end of 2021, the processing time for applications was approximately 14 months, according to the immigration ministry. The fee is 4,000 Danish kroner (~€537).

After this time, you receive a letter notifying you that you can expect to be accepted for citizenship at the next round of parliamentary procedure (which happens twice yearly), provided you still fulfil the requirements at that time.

Once the new law making you a citizen comes into force, you will be sent a declaration that you have been accepted for citizenship with one final condition: you attend a ceremony, declare that you will uphold Denmark’s laws, values and principles, shake hands with an official and become a citizen.

Photo by lilzidesigns on Unsplash

Sweden

Length of stay: 2-5 years

EU and non EU citizens can apply for Swedish citizenship after living in Sweden for five continuous years with right of residence. 

In some cases, this period can be even shorter.

Nordic citizens who have lived in Sweden for at least five years can become Swedish citizens through notification. This involves filling out a form and sending it to the local country administrative board, with a fee of 475 kronor.

The alternative is to submit an application for citizenship to the Migration Agency, which Nordic citizens can do after living in Sweden for two years. No other requirements below are needed for Nordic citizens.

EU and non-EU citizens who have lived with a Swedish citizen for at least two years can apply for citizenship earlier, after three continuous years in Sweden. However applicants will be asked to show that they have adapted well to Swedish life. This could be shown through learning the language, proving you can support yourself, or through the length of your marriage.

The requirement for continuous residency in Sweden means that if you spend more than six weeks abroad in any given year, it will extend the period of time until you can apply for citizenship.

For non-EU citizens, the process for getting citizenship is just the same as for EU citizens, except there is an additional requirement for a permanent residence permit. Permanent residency for non EU citizens is usually granted after four years of living in Sweden.

Other requirements: No outstanding debts or recent crimes

In addition to length of stay, EU and non EU citizens must have “conducted themselves well in Sweden”, and the Migration Agency will request information on whether you have debts or have committed crimes in the country.

An application can be rejected if a person has unpaid taxes, fines, or other charges. Debts to private companies passed on to the Swedish Enforcement Authority could also impact the application, even if they are paid, as two years must pass after payment to prove you’re debt-free. If you’ve committed a crime, there’s also a qualifying period before citizenship can be granted which depends on the sentence. 

An automated test (in Swedish) can be filled in here to see if you meet those requirements. 

Language and citizenship test: May soon be required

While Swedish language skills and knowledge of Swedish society are not currently a requirement for citizenship, this could change in the future. In January 2021, the Swedish Ministry of Justice and Migration put forward proposals to introduce an A2 language exam for would-be Swedes, with exceptions for vulnerable individuals who have made a reasonable effort to learn the language. There are also proposals for a knowledge test about Swedish society.

These proposals will be subject to a long political process before they can be put into law, so at present the requirements are proof of identity, duration of residency in Sweden, and no record of serious criminal offences or debts.

Processing time and fees

The Migration Agency says applicants should expect an average of 39 months between submitting their application and becoming Swedish. Readers of The Local have reported the process taking anywhere between a couple of weeks to over three years. The application costs 1,500 SEK (~€150).

Photo by Mikita Karasiou on Unsplash

Norway

Length of stay: 6-8 years

EU and non EU citizens can apply for Norwegian citizenship after living in Norway for eight years out of the past eleven years and if they have held residence permits that were each valid for at least one year during that time.

A new rule, which came into effect in January 2022, means that if you have sufficient income, you can apply after six years rather than eight. Currently sufficient income is 319,997 kroner (~€30,520), but this can change annually.

Those with Norwegian spouses, registered partners, or cohabitants can apply after living in Norway for three of the last ten years. 

Nordic citizens over the age of 12 can apply for Norwegian citizenship after two years living in Norway and do not need to fulfil any further requirements below.

Language test

EU and non EU citizens have to pass an oral Norwegian language test at either A2 or B1 level. A2 refers to an elementary level of Norwegian, and B1 is considered semi-fluent. 

The change to the language requirement from A2 to B1 will apply from autumn 2022 at the earliest, according to the UDI

Citizenship test

Applicants must pass a citizenship test (statsborgerprøve), or a social studies test if aged between 18 and 67. The tests must be taken in Norwegian, either Bokmål or Nynorsk.

For the citizenship test, applicants need to answer at least 24 of 36 multiple choice questions correctly to pass. Topics included in the test are history, geography, democracy, welfare, education, health and working life in Norway.

Other requirements

After filling in an online application, applicants have to deliver a series of documents in person, including birth certificates, marriage certificates (if applicable), a full list of entries into and departures from Norway, at least seven years of tax returns, and a police report certifying “good conduct”.

Processing time and fees

It costs 6,500 kroner to apply if you are over 18. However, the fee is cheaper or completely waived if you are a Nordic citizen, previously held Norwegian citizenship, or are under 18 years of age. 

Applications take around 16 months to process but this can vary.

READ MORE: EXPLAINED: How to apply for Norwegian citizenship

Roundup

Even if Sweden decides to include a language and citizenship test in their application process, the country will remain the easiest and cheapest in Scandinavia in which to become a citizen, although there’s a downside – it also has the longest processing time for citizenship applications.

Here’s the roundup.

Swedish citizenship

Application Fee: ~€150 (1,500 Swedish kronor) 

Length of time living in country: 3-5 years 

Language level needed: None, but this may change

Citizenship test: None, but this may change

Other requirements: No record of serious criminal offences or debts

Dual nationality allowed: Yes

Processing time: Around 39 months

Norwegian Citizenship 

Application Fee: ~€250 (2,500 Norwegian kroner)

Length of time living in country: 6-8 of the past 11 years

Language level needed: A2 Norwegian, soon to change to the more difficult B1 Norwegian

Citizenship test: Yes

Other requirements: A full list of entries into and departures from Norway, at least seven years of tax returns, and a police report certifying “good conduct”.

Dual nationality allowed: Yes thanks to a law change in 2020 

Processing time: Around 16 months

Danish citizenship

Application Fee: ~€537 (4,000 Danish kroner)

Length of time living in country: 9 years

Language level needed: B2 Danish

Citizenship test: Yes

Other requirements: No record of serious criminal offences or debts and be financially self-sufficient; sign a declaration pledging allegiance and loyalty to Denmark and its laws; hold a full-time job or been self-employed for three and a half of the last four years; attend a ceremony.

Dual nationality allowed: Yes 

Processing time: 14 months – 2 years

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