POLAND-Türkiye DUAL CITIZENSHIP

 Is Polish-Turkish dual citizenship possible? Does a Turkish citizen lose their Turkish citizenship upon acquiring Polish citizenship? Does a Polish citizen have to renounce their Polish citizenship before acquiring Turkish citizenship? How does dual citizenship arise in children? Which passport should be used and when? This comprehensive guide examines the Polish-Turkish dual citizenship regime in detail, based on current official sources.

The issue of Polish-Turkish dual citizenship has become much more visible in recent years, in terms of migration, investment, family reunification, and the status of children. Turkish citizens who have lived in Poland for a long time, in particular, wonder whether their Turkish citizenship will automatically be revoked if they acquire Polish citizenship. Similarly, Polish citizens living in Türkiye or with family ties to Turkey want to know how Polish law views this when they acquire Turkish citizenship. The most common mistake in practice is treating the dual citizenship regimes of the two countries as a single legal system. However, in Polish-Turkish dual citizenship cases, two separate legal systems always operate simultaneously: one is Polish citizenship law, and the other is Turkish citizenship law. A sound legal analysis is only possible when these two regimes are considered together.

Is dual Polish-Turkish citizenship possible?

Yes, it is generally possible. According to Article 44 of the Turkish Citizenship Law No. 5901, if a person who has acquired the citizenship of a foreign state submits the necessary documents and it is confirmed that they are the same person, a note indicating "multiple citizenship" is entered in the population registry. This system shows that in Turkish law, multiple citizenship is not prohibited but treated as a registered status. On the Polish side, official legislation and statements from border authorities reveal that a Polish citizen who also holds the citizenship of another state has the same rights and obligations as a person who is solely a Polish citizen in relation to the Republic of Poland. Considering this structure together, Polish-Turkish dual citizenship is a legally possible status; however, how each citizenship will be handled before the authorities of each country must be evaluated separately.

How does dual citizenship work under Polish law?

Polish law recognizes dual citizenship; however, Polish citizenship takes precedence before Polish authorities. According to the official statement of the Polish Border Guard and the citizenship regime on which it is based, a Polish citizen, even if simultaneously holding citizenship of another state, is considered to have the same rights and obligations before the Republic of Poland; furthermore, they cannot invoke different legal consequences before Polish authorities based on their other citizenship. This means that Poland does not prohibit second citizenship; however, it does not allow for a freedom of choice such as "I actually want to be treated as a Turkish citizen" in the relationship between the Polish state and the individual. This is the essence of the Polish side of the Polish-Turkish dual citizenship regime.

The most practical consequence of this principle is seen at border crossings. According to the current statement of the Polish Border Guard, Polish citizens with dual citizenship are required to present either a Polish passport or a Polish identity card at border control, depending on their direction of travel. The explanation of border procedures on the Human Rights Commissioner's website is also along the same lines: although Poland allows multiple citizenship, border authorities consider the person as only a Polish citizen from Poland's perspective. Therefore, a person with Polish-Turkish dual citizenship should not think, "I'll just use my Turkish passport and not show my Polish passport"; this approach may create problems on the Polish side.

How to lose Polish citizenship?

In Polish law, the loss of citizenship is not automatic but subject to constitutional guarantees. According to the official gov.pl website, Polish citizenship can only be lost through renunciation and with the approval of the President of Poland. The same statement indicates that the loss takes effect 30 days after the President's decision, or within a shorter period as determined by the President. For individuals residing in Türkiye, the Polish website for Turkey shows the same procedure: applications are made through the competent Polish consulate addressed to the President of Poland; applications sent directly to the Presidency are returned. Therefore, a Turkish citizen having acquired Polish citizenship does not, in itself, mean that they have subsequently lost it; a renunciation procedure is also required for loss.

Polish law also has special rules regarding children. When permission to renounce Polish citizenship applies to parents, it can, under certain conditions, also extend to minor children; however, children aged 16-18 must give their personal consent. The current information note from the Polish representation in Türkiye clearly states that for a minor to be included in the renunciation, the consent of the other parent and the personal declaration of the child over 16 at the consulate are required. Therefore, in Polish-Turkish dual citizenship cases, the status of children is not a secondary detail added to the parents' decision, but a fundamental element that needs to be planned separately.

How does multiple citizenship work in Turkish law?

In Turkish law, the explicit administrative equivalent of multiple citizenship is the "multiple citizenship notification" mechanism. According to the official statement of the General Directorate of Population and Citizenship Affairs, if a person who has acquired the citizenship of a foreign state for any reason submits documents regarding this situation and it is determined that they are the same person in the records, a statement indicating that they possess multiple citizenship is entered into their family registry. The same page states that if the other citizenship is subsequently lost, a separate notification will be made to invalidate this statement. This structure demonstrates that Turkish law does not treat the acquisition of foreign citizenship as an event outside the system, but rather as a status recorded in the population registration system.

The procedure for declaring multiple citizenship is also officially defined. According to the official PDF linked to the NVI (National Institute of Viability), the application requires a VAT-12 form, a biometric photograph, a national identity card or a copy thereof, and a certified document with a Turkish translation showing the date on which other national citizenship was acquired. Applications are made in person or through a special power of attorney to the district population registry office within the country, and to diplomatic missions abroad; applications by post are not accepted. Therefore, one of the most important practical steps for a Turkish citizen who has acquired Polish citizenship is to properly register the declaration of multiple citizenship in the Turkish records after obtaining Polish citizenship.

Does Turkish citizenship automatically become invalid upon acquiring foreign citizenship?

In Turkish law, the most reliable interpretation of this issue is that instead of automatic loss, a separate "permission to renounce citizenship" regime exists. According to the official website of the NVI (National Citizenship Authority), permission can be granted by the Ministry to a person who wishes to renounce Turkish citizenship in order to acquire the citizenship of another state, provided that they meet certain conditions, including being of legal age, having the capacity to discern, having acquired foreign citizenship or having credible indications of acquiring it, not being wanted for crime or military service, and not having any financial or criminal restrictions. When considering that in Turkish law, the acquisition of foreign citizenship is also subject to registration under the heading of "multiple citizenship," and that renunciation of citizenship is also regulated as a separate authorized process, it becomes clear that in the case of Polish-Turkish dual citizenship, the logic of registration and permission is more fundamental than the logic of automatic loss on the Turkish side. This conclusion is a legal assessment derived from a combined reading of the official regulations.

The Blue Card regime is also of particular importance for those who have renounced their Turkish citizenship with permission. The official NVI website states that those who were born Turkish citizens but lost their citizenship by obtaining permission, and their descendants up to the third degree, will continue to enjoy the same rights as Turkish citizens, except for the exceptions specified in the law; and that a Blue Card will be issued to these individuals. Therefore, if some individuals choose to renounce their Turkish citizenship with permission while acquiring Polish citizenship, the case should be evaluated not only on the basis of "I have lost my citizenship," but also in conjunction with the question of "What rights are protected under the Blue Card status?".

What happens when a Turkish citizen obtains Polish citizenship?

On the Polish side, the main ways for a Turkish citizen to acquire Polish citizenship are separate procedures such as granting citizenship by the President, "recognition as a Polish citizen," and confirmation or restoration of previous citizenship. According to the official gov.pl website, applications for citizenship by the President are made through the Voivode for those residing in Poland and through the consulate for those residing abroad; the President is not bound by a specific timeframe for the decision, and the decisions are final. Within the same system, the "recognition" process requires criteria such as at least 3 years of permanent/long-term residency and income/housing requirements, or at least 2 years of permanent residency plus at least 3 years of marriage to a Polish citizen, as well as a B1 level Polish language proficiency. Within this official framework, prior renunciation of existing citizenship is not considered a general application requirement.

Therefore, in practice, Turkish citizens who have lived in Poland for a long time often prefer to register their multiple citizenships with the Turkish authorities after acquiring Polish citizenship. However, the critical difference here is that acquiring Polish citizenship and proving that citizenship with the Polish authorities are not the same thing. According to the official gov.pl website, a valid Polish passport or Polish identity card directly proves citizenship; if these are not available, an application can be made to the voivode, or in the case of those living in Türkiye, through the consulate, to confirm the existence or loss of citizenship. This is especially important for Turkish citizens who hold Polish citizenship through ancestry but lack the necessary documentation.

What happens when a Polish citizen acquires Turkish citizenship?

In Turkish law, there are various ways to acquire citizenship later in life. The official NVI (National Citizenship Institution) website states that Turkish citizenship can be acquired by birth, by decision of the competent authority, by adoption, or by right of choice; furthermore, it clarifies that marriage alone does not directly confer citizenship, but an application can be made after at least three years of marriage and under certain conditions. Since the same official system also regulates the declaration of multiple citizenships, a Polish citizen acquiring Turkish citizenship may have consequences under the principle of multiple citizenship depending on their specific case. The key here is to plan the process of acquiring Turkish citizenship and the subsequent population registration procedures together.

Turkish law also has clear rules regarding the place of application. The NVI's frequently asked questions page states that applications for acquiring Turkish citizenship must be submitted in person or through a special power of attorney to the governor's office of the applicant's place of residence within Turkey, or to diplomatic missions abroad. Applications submitted by mail will not be accepted. Therefore, the application strategy may differ for Polish citizens residing in Türkiye and those residing abroad; the competent authority should be clearly identified from the outset when preparing the application.

The status of children in Polish-Turkish dual citizenship

In the Polish-Turkish dual citizenship regime, the strongest and most frequently encountered area is children. Turkish law explicitly states on the official NVI website that citizenship is acquired by birth based on lineage, and that it is sufficient for only one parent (mother or father) to be a Turkish citizen at the time of the child's birth. On the Polish side, official state sources indicate that for a child to acquire Polish citizenship by birth, it is sufficient for at least one parent to be a Polish citizen. Considering these two legal systems together, a child born to parents who are Turkish and Polish citizens can, in most cases, be both Turkish and Polish citizens by birth; however, registration, notification, and, if necessary, citizenship confirmation procedures must be completed separately in both countries.

The most common mistake in handling child cases is the belief that "since the child is a citizen of both countries, there's no need for further action." However, official Polish records indicate that if a valid Polish passport or identity card is not available, the citizenship confirmation procedure can be initiated; while on the Turkish side, birth and citizenship information must be separately reported within the population registration system. In other words, Polish-Turkish dual citizenship may exist for a child at birth; however, problems may arise in daily practice without taking steps such as Turkish population registration, Polish birth registration, passport, PESEL (Polish-Turkish National Identity Registry System) or citizenship confirmation to make the rights usable.

Dual citizenship in marriage, settlement and naturalization files

Polish-Turkish dual citizenship is not limited solely to birth or ancestry. Turkish citizens can obtain Polish citizenship through long-term residency, marriage, Polish origin, or presidential decree; Polish citizens can obtain Turkish citizenship through general, exceptional, or marriage acquisition methods. However, the approaches of the two countries differ. In Poland, the "recognition" procedure is primarily based on residency duration, type of residence, and language proficiency; citizenship by presidential decree operates with broader discretionary power. In Türkiye, in addition to the general system, there are separate avenues such as marriage, exceptional acquisition, and reacquisition. Therefore, "Polish-Turkish dual citizenship" should not be evaluated based on a single application model, but rather on which acquisition method the specific case falls under.

It's important to correct a common misconception, particularly regarding marriage-related cases: neither Turkish nor Polish law grants citizenship directly through marriage alone. The official Turkish law states that marrying a Turkish citizen does not automatically confer citizenship; however, applications can be made only after at least three years of marriage and under specific conditions. In Poland, the official recognition procedure requires at least two years of residency of a specific type and at least three years of marriage to a Polish citizen. Therefore, in Polish-Turkish dual citizenship planning, marriage is not automatic citizenship; rather, it is a strong link in some of the pathways to citizenship.

The three most critical points in practice

The first critical point in Polish-Turkish dual citizenship is to avoid confusing registration with citizenship itself. Having a statement of multiple citizenship recorded in Turkish population registers does not negate the need for a separate passport or confirmation process on the Polish side. The second critical point is to plan in advance which documents each country will request at border crossings; especially on the Polish side, a Polish citizen is expected to process transactions with Polish documents. The third critical point is to treat the status of children not as an additional detail in the parental file, but as a separate legal matter; because both Polish and Turkish law have specific rules regarding the acquisition, loss, confirmation, and registration of citizenship for children.

Conclusion

Dual Polish-Turkish citizenship is legally possible; however, this status requires more than simply possessing two passports, necessitating the proper management of two separate legal systems simultaneously. Polish law recognizes multiple citizenship, but maintains the priority of Polish citizenship before Polish authorities. Turkish law, on the other hand, registers the acquisition of foreign citizenship in the population registry through a "declaration of multiple citizenship"; it also provides for separate mechanisms such as authorized renunciation of citizenship and the Blue Card. Therefore, the path followed by a Turkish citizen who acquires Polish citizenship and a Polish citizen who acquires Turkish citizenship are not technically the same; both cases must be established within their own logic of acquisition, registration, and proof.

In conclusion, it is important to emphasize that the main issue regarding Polish-Turkish dual citizenship is not simply whether "dual citizenship is permitted." The crucial point is determining which documents will be used to prove this status, which citizenship will be considered primary before which authority, how it will affect children, and which rights will be protected in case of renunciation or termination ofcitizenship. A successful citizenship application is not just about obtaining a second passport; it is about managing the registration, consular, border, child, and population aspects together.