Many countries have legislative provisions that allow citizenship to be granted to foreign nationals when this is deemed to be in the national interest. In legal texts, this mechanism is commonly referred to as discretionary naturalization, naturalization by exception, or citizenship for special merit in a specific field. According to analysis by Elma Capital, approximately 70% of citizenship laws worldwide contain some form of such provision.
Citizenship legislation varies significantly in how national interest and special merit are defined. In some jurisdictions, the law explicitly refers to “outstanding achievements” in areas such as sports, culture, science, or economics. In these cases, a recommendation to grant citizenship is typically issued by the relevant ministry. In other countries, the legal language is deliberately broad and leaves substantial room for interpretation and discretion.
The main difference between these legal provisions lies not in their wording, but in how actively they are applied in practice. Large and economically strong countries such as France, the United Kingdom, or Canada tend to invoke discretionary naturalization only in exceptional and highly visible cases. A well-known example is President Macron’s decision to grant French citizenship to Mamadou Gassama, a Malian national who rescued a child from a balcony in Paris. Despite being in France illegally at the time, his act of heroism led to citizenship being granted under a special procedure.
Smaller countries, particularly those with a strong interest in attracting foreign direct investment, have often adopted a more pragmatic approach. In parts of the Balkans and similar regions, discretionary citizenship has at times been granted to large investors. This practice, however, has frequently attracted criticism for its lack of transparency and its reliance on subjective decision-making.
In countries that do not operate formal citizenship-by-investment programs, private advisors may sometimes attempt to structure investments in a way that increases the likelihood of obtaining citizenship through discretionary provisions. Jurisdictions where such practices have historically existed include Austria, Bulgaria, Slovakia, Cape Verde, Cambodia, and several others.
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It is important to understand that citizenship based on special merit cannot be standardized or offered as a scalable commercial product. For this reason, we advise clients to treat such offers found online with extreme caution. In many cases, they involve either outright corruption or arrangements with a very low level of predictability, where substantial funds are paid without any reliable guarantee of a successful outcome.
Elma Capital assists international clients in obtaining second citizenship through structured and lawful accelerated pathways that do not rely on discretionary merit. These typically include official citizenship-by-investment programs or citizenship by descent.