The matter of dual citizenship in Montenegro should be approached with an emphasis on preserving sovereignty, ensuring political stability, and establishing clear residency regulations, according to the Center for Democratic Transition (CDT).

“In the present circumstances, where hundreds of thousands of Montenegrin emigrants retain formal residency in the country—thus having the right to vote—any moves to broaden or redefine citizenship, like the proposed ‘blue card’, could result in significant political and social repercussions. Montenegro shapes its citizenship policy in light of national interests and demographic factors. Consequently, the dual citizenship discussion is framed within existing legal and administrative structures,” the CDT stated.

This NGO has published a document examining how smaller European nations have navigated voting rights for their citizens.

“Examples from other countries can offer valuable insights, but they must be contextualized to fit the unique needs and circumstances of Montenegrin society,” they noted.

With the emergence of the former Democratic Front, the CDT highlights that the topic of dual citizenship is being revisited in Montenegro.

“While the current legislation is firmly restrictive on dual citizenship, initiatives like the ‘blue card’, recently suggested by Milan Knežević, leader of the Democratic People’s Party, have revived public discourse on this issue. The ‘blue card’, which Turkey introduced in 1995 through amendments to its citizenship law, is granted to individuals who once were Turkish citizens but lost their citizenship upon acquiring another nationality. Holders of the ‘blue card’ enjoy rights similar to those of Turkish citizens, except for voting and holding certain public offices. Knežević’s proposal to adapt this ‘blue card’ concept for Montenegrin emigrants and their descendants aims to provide them special status, permitting them access to rights such as employment, education, and property, while excluding voting rights,” they elaborated.

However, the Society of Statisticians and Demographers estimates that over 200,000 Montenegrin emigrants live abroad, and Montenegrin law permits them, “without penalty, to maintain their residency even after leaving Montenegro.”

“According to the Law on the Election of Councilors and Representatives, all citizens with permanent residency in Montenegro have voting rights. Therefore, Montenegrin citizens who are temporarily abroad but maintain their permanent residency can vote if they return to Montenegro on election day, as they remain on the electoral register. This applies to emigrants who, despite living abroad, vote in a manner that contradicts the Constitution and the law — which stipulates that voting rights are granted to Montenegrins who have resided in the country for a minimum of two years,” the CDT added.

While Knežević’s proposal is framed as a means of reconnecting with the diaspora and rectifying a “historical injustice,” critics argue it serves as a backdoor approach to enacting dual citizenship, possibly driven by political motivations.

“Moreover, drawing comparisons between Turkey with its approximately 85 million citizens and Montenegro’s population of around 630,000 regarding dual citizenship is inappropriate. Additionally, Turkey’s state and political structure should not be seen as a role model for Montenegro, which, as a candidate for EU membership, should primarily adhere to European standards, a message reinforced from Brussels,” noted the CDT.

They remind us that European Commissioner for Enlargement Marta Kos indicated that Montenegro must provide prior notification to the EU about any intentions regarding dual citizenship to maintain stability and transparency in the European integration process.

Under the framework of the European Convention on Nationality, ratified by Montenegro in 2010, states are free to manage the matter of multiple citizenships independently, although it is advised that regulations align with the principles of preventing statelessness and safeguarding fundamental human rights, according to the CDT.

“In an effort to safeguard its interests, Montenegro follows a ‘more restrictive’ citizenship policy. The Citizenship Law currently in effect was enacted in 2008, two years after Montenegro regained independence. The law states that citizenship is based on birth, descent, admission, or bilateral agreements regarding dual citizenship with another country. Dual citizenship is only allowed if it was obtained prior to Montenegro’s declaration of independence (June 2006) or if a bilateral treaty exists with another nation. Individuals acquiring another citizenship after June 2006 forfeit their Montenegrin citizenship automatically. Although this is the legal text, in practice, several Montenegrin nationals also hold citizenship in various countries, especially in the region,” writes the CDT.

They highlight that Article 45 of the Montenegrin Constitution asserts that individuals must reside in Montenegro for two years before acquiring the right to vote, and modifying this article necessitates the backing of three-fifths of the electorate in a national referendum.

The Venice Commission and the ODIHR have long recommended abolishing the residency requirement for national elections to comply with established standards. However, the CDT observes that achieving citizen support for such changes poses a significant challenge.

“The two-year waiting period for voting in national elections is viewed as an undue limitation and contravenes the Code of Good Practice in Electoral Matters. It is advised that this provision should be rescinded,” states the opinion.

Furthermore, the CDT emphasizes that the discussion on dual citizenship in Montenegro is complicated by a nuanced social and political landscape, touching upon identity, relationships with emigrants, and maintaining ethnic and political equilibrium within the country.

While some advocate for dual citizenship as a fitting response to the diaspora’s needs, others perceive it as a potential threat to the state’s sovereignty and political stability.

“In a developing society like Montenegro, which is striving to find a balance between internal interests and international responsibilities, it is crucial that such matters are addressed with caution, openness, and in alignment with European benchmarks, rather than being swayed by narrow political ambitions,” asserted the CDT.

CDT analyzed legal frameworks in smaller European nations regarding the voting rights of passport holders.

Baltic countries

Lithuania:

Lithuania permits dual citizenship only under rare conditions, primarily for individuals who are children or young people born abroad or within mixed families. A referendum was conducted in 2024 to amend the Constitution for broader dual citizenship recognition, but it failed to gather sufficient votes.

Under current law, a Lithuanian citizen may only hold dual nationality if specific conditions are met.

“All Lithuanian citizens retain the right to vote in parliamentary elections, regardless of holding another citizenship. Given that dual citizenship is largely restricted, only a small number of voters possess two passports. However, if a voter maintains dual citizenship, it does not affect their voting rights in Lithuania,” explains the CDT.

Latvia

Latvia allows dual citizenship in certain cases, according to the Law on Citizenship effective from October 1, 2013. Latvian citizens can retain or acquire second citizenship from another EU, EFTA, or NATO member state, Australia, Brazil, or New Zealand, or from nations that have a dual citizenship agreement with Latvia (none currently exist). Special approval from the Latvian government can also permit dual citizenship due to significant national interests.

Children of Latvian citizens may hold dual citizenship from any nation; however, if the second citizenship is from a non-permitted country, they must choose between them by age 25.

Only Latvian citizens can vote in parliamentary elections. Notably, Latvia has a large population of non-residents who are restricted from voting at the national level, but can partake in local elections.

Estonia

Estonia maintains a stringent stance against dual citizenship, according to CDT’s observations.

“Estonian law prohibits adults from holding two citizenships simultaneously; children may temporarily have dual nationality, but they must choose one upon turning eighteen. Estonia perceives dual citizenship as a potential threat to its sovereignty, especially considering the significant number of ethnic Russians in its population post-Soviet Union,” they noted.

Only Estonian citizens are entitled to vote in national elections.

“Recent constitutional amendments have also eliminated the right to vote for non-EU citizens in local elections, with 93 out of 101 members of parliament supporting this change,” they added.

Other European countries

Croatia

Croatia allows for dual citizenship without requiring the renunciation of foreign citizenship in specific instances, as per the Croatian Citizenship Act. This includes individuals married to Croatian citizens, emigrants and their descendants, those whose admission benefits the Republic of Croatia, minors following their parents, former Croatian citizens seeking readmission, and members of the Croatian diaspora.

All Croatian citizens over eighteen are entitled to vote in elections, as stated by the CDT.

Slovenia

In Slovenia, dual citizenship is predominantly restricted, though exceptions exist—such as for children of mixed marriages (where one parent is Slovenian and the other is from another country), individuals who gain Slovenian citizenship through exceptional naturalization (e.g., notable contributions in various fields), and those whose home nations do not permit renunciation of citizenship.

If there is mutual agreement between Slovenia and another country regarding dual citizenship, retaining both nationalities is also feasible.

Typically, renouncing previous citizenship is necessary for naturalization, unless one of the aforementioned exceptions applies. Slovenian citizens who later acquire other citizenships do not automatically lose their Slovenian nationality, while those born abroad may renounce their Slovenian citizenship by age 25 under specific conditions.

Voting rights depend on residency for Slovenian citizens; expatriates are entitled to vote under certain conditions in local and European elections, either by mail or in person.

Malta

When Malta gained independence on September 21, 1964, its citizenship laws did not authorize dual nationality, except for minors. They had to relinquish foreign citizenship upon reaching their 18th birthday to retain Maltese nationality. If not, they would lose it once they turned 19, according to the CDT.

However, amendments made in 2000 to the Maltese Citizenship Act now allow individuals to be citizens of both Malta and another nation.

“Thus, following the changes on February 10, 2000, Maltese citizens can retain Maltese nationality even if they acquire a foreign citizenship, just as foreigners can maintain both nationalities when obtaining Maltese citizenship through naturalization, provided their home country permits it,” the CDT clarified.

Regarding voting rights, Malta requires certified documentation of dual citizenship for voter registration, though registration is not automatic and requires an application. EU citizens residing in Malta also have the right to vote in local elections, contingent on holding a residence permit.

Luxembourg

In Luxembourg, where the population is around 653,000, individuals seeking dual citizenship must have lived in Luxembourg for a minimum of five years. Those with dual citizenship who satisfy all requirements possess voting rights in elections held in Luxembourg.

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