Dual citizenship in Spain for Russians in 2026

Spain does not recognise dual citizenship with Russia. When acquiring Spanish citizenship, a Russian must make a renuncia — a formal renunciation of their previous citizenship. The exception applies only to natives of Ibero-American countries, Andorra, Portugal, the Philippines, Equatorial Guinea and France, and to Sephardic Jews: they do not have to sign this declaration.

At the same time, the renuncia is a requirement of the procedure itself, and it does not end the previous citizenship. Leaving that citizenship is only possible through a separate procedure, which you have to go through yourself. Below is the full list of countries, the exact provisions of the Spanish Civil Code, how to obtain the documents and practical rules for those who have already naturalised.

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Contents

1. Which countries Spain allows dual citizenship with
2. Exemption from the renuncia and a convention — what is the difference
3. France: the only exception outside Latin America
4. Sephardic Jews
5. Spanish citizenship through marriage: one year instead of ten
6. Russia and Spain: why there is no dual citizenship
7. Belarus, Kazakhstan, Ukraine: why you cannot go by the Russian case
8. Four alternatives where no renuncia is needed
9. What happens at the oath: three legal acts
10. Documents and certificates for the application
11. The risk of losing Spanish citizenship: article 25.1 of the Civil Code
12. Notifying Russia of a second citizenship
13. How to live with two passports: practice
14. Frequently asked questions

Which countries Spain allows dual citizenship with

These are the states of Latin America and a few others with which Spain has concluded the relevant agreements. Their citizens do not have to give up their previous nationality — they remain nationals of both states. The full list:

• Ibero-American countries: Argentina, Bolivia, Brazil, Venezuela, Guatemala, Honduras, Dominican Republic, Colombia, Costa Rica, Cuba, Mexico, Nicaragua, Panama, Paraguay, Peru, El Salvador, Uruguay, Chile, Ecuador
• Portugal
• Andorra
• The Philippines
• Equatorial Guinea
• France — under the 2021 convention
• Sephardic Jews of Spanish origin — under Ley 12/2015

The legal basis is article 23.b of the Civil Code: it exempts from the declaration “natives of the countries listed in paragraph 1 of article 24”. Article 24.1 names the Ibero-American states, Andorra, the Philippines, Equatorial Guinea and Portugal.

Who is not on the list. The criterion is not geography but historical and linguistic ties with Spain. Guyana, Haiti, Jamaica and Trinidad and Tobago are in the same region, but their official languages are English or French, so they do not count as Ibero-American countries and their citizens do sign the renunciation. Puerto Rico is a special case: the territory is considered Ibero-American, but its inhabitants are also US citizens, and Spain has no agreements with the USA.

Exemption from the renuncia and a dual citizenship convention — what is the difference

These two concepts are constantly confused, although they work differently.

The exemption operates under the Spanish Civil Code and covers the whole list above. It means one thing: at the oath you do not have to make the renuncia. Spain simply does not require this act.

A dual nationality convention is a bilateral international treaty. Spain has concluded such treaties with 13 states. A convention gives more than a simple exemption: it establishes mutual recognition of both citizenships and determines which of them is considered “active” depending on the place of permanent residence. Military service obligations, tax and civil rights depend on this.

Country	Year the convention was signed
Chile	1958
Peru	1959
Paraguay	1959
Nicaragua	1961
Guatemala	1961
Bolivia	1961
Ecuador	1964
Costa Rica	1964
Honduras	1966
Dominican Republic	1968
Argentina	1969
Colombia	1979
France	2021

The practical conclusion: a Brazilian, Mexican or Cuban does not sign the declaration when naturalising — this follows from the code. However, there is no separate convention with these states, so the mechanism of “active nationality” based on place of residence does not apply to them.

The residence period for all these categories is two years of legal residence instead of the standard ten, under article 22.1 of the Civil Code. The procedure is covered in detail in our article on fast-track Spanish citizenship for citizens of Ibero-American countries.

	Dual citizenship	Two citizenships
Basis	a bilateral agreement between the countries	no agreement, the passports exist independently
How the person is seen	each country recognises them as a citizen of both states	each recognises them only as its own citizen
Taxes, military service	allocated under the agreement	imposed by each country separately
Diplomatic protection in a third country	agreed between the countries	conflicts of jurisdiction are possible
A Russian with a Spanish passport	—	this is their case

A person with two nationalities is called a bipatride. Legally, their status is dual only when both states have agreed to recognise it.

Why there are few such agreements

Such treaties are concluded by states bound by a shared history: the United Kingdom and the Commonwealth countries, France and Canada, Italy and Argentina, Portugal and Brazil. It is not a privilege but a standard mechanism for countries with a common past, and Russia does not fall into it: the linguistic and historical link on which such treaties are built does not exist between the two countries.

Dual citizenship agreements were concluded selectively — with countries linked by a common language and colonial history. For all other countries the general rule of article 23.b applies, and the list of exception countries has barely changed since the nineties: only a new bilateral treaty can extend it, as happened with a country such as France. So the question “could there be an agreement with my country?” depends not on the applicant’s wishes but on the intergovernmental agenda.

France: the only exception outside Latin America

The nationality convention between Spain and France was signed on 15 March 2021 in Montauban, published in the BOE on 29 March 2022 and came into force on 1 April. Citizens of both countries can acquire the other’s citizenship without giving up their own.

It is the only treaty of its kind outside the Ibero-American area. The legal basis is article 11.3 of the Spanish Constitution: the state may conclude such treaties with Ibero-American countries “or with those that have had or have a special link with Spain”. The political context is the descendants of some 500,000 Spanish Republicans who emigrated to France after the Civil War: the treaty spared them from choosing between two citizenships.

For Russians this matters indirectly: French citizenship is compatible both with the previous passport and with a Spanish one. The scheme “first French citizenship, then move to Spain” lets you live in Spain with the rights of an EU citizen and hold both passports without giving anything up. How entry to France works for a founder or specialist is covered in our article on getting France’s talent passport.

Already a French citizen and moving to Spain? You need neither a visa nor a residence permit: a French citizen, like a citizen of any other EU country, registers in the Central Register of Foreigners and receives a green certificate. What to do step by step is in the article NIE verde: the EU citizen registration certificate.

Sephardic Jews

Ley 12/2015 gave descendants of the Sephardic Jews expelled from Spain in 1492 the right to citizenship through a shortened procedure and without a renuncia.

Applications closed on 1 October 2019; some cases are still being processed. The exemption itself for Sephardic Jews of Spanish origin remains in force in article 23.b.

We covered the history of the community and how origin was proved for a passport in our article on Jewish life in Spain.

Spanish citizenship through marriage: one year instead of ten

Marriage to a Spaniard shortens the residence period to one year under article 22.2 — the fastest route after origin. But the benefit concerns only the period: marriage does not exempt you from the renuncia. A Russian married to a Spanish citizen signs the renunciation on general terms and shortens the wait by almost a decade — exactly that.

The conditions, the interview to check for a sham marriage, the list of documents and what happens on divorce are covered in a separate analysis: Spanish citizenship through marriage.

Russia and Spain: why there is no dual citizenship

There is no dual citizenship agreement between the two states, and Russia is not on the list of those exempted from the renuncia by the Civil Code. So a Russian obtaining a second passport must declare the renunciation of their previous citizenship.

This is where what is rarely written about begins.

The declaration does not end your previous citizenship

The statement a person makes before a Spanish authority is a declaration within the citizenship procedure itself. Spain does not check whether citizenship has actually been lost under the law of the other state, and does not arrange your exit from the previous one for you.

Leaving it is a separate procedure under the citizenship law, with its own application, set of documents and a decision by the competent authority. If you have not gone through it, you are still a Russian citizen.

De facto multiple citizenship arises

This creates a situation that is legally more accurately called not dual but multiple citizenship: a person may hold two valid passports, but neither state recognises the second citizenship. Other legal systems can work differently; here the two states simply ignore each other.

• For Spain you are its citizen.
• At home you are a Russian with a foreign nationality that must be notified.

This is neither a loophole nor a grey scheme: it is how two legal systems collide. But the situation has consequences you need to understand in advance.

Belarus, Kazakhstan, Ukraine: why you cannot go by the Russian case

The Spanish part of the procedure is the same for everyone: without an agreement with Spain, the applicant signs the renunciation. But the consequences at home differ fundamentally — Belarus does not officially recognise a second nationality, Kazakhstan applies the principle of single citizenship, and Ukraine has revised its rule.

A country-by-country analysis and what to find out from a local lawyer before the oath is in the article dual citizenship in Spain for citizens of Belarus, Kazakhstan and Ukraine.

Four alternatives where no renuncia is needed

Let us say plainly what articles on this topic usually keep quiet about: nobody is obliged to naturalise. Renunciation is the price of a specific status, not an entry ticket to the country. There are four scenarios in which you live in Spain and lose nothing: stop at permanent residence after five years, acquire the nationality of another EU state, choose Andorra, or simply not decide now — a decade passes between arrival and the right to apply. The grounds for a first residence are collected in our overview Spanish residence permits: all the grounds for a residence permit, and the conditions of long-term status in permanent residence in Spain: the right to live there permanently and how to get the status.

The residence route is broader than it seems. Besides the basic grounds there is residence through settlement (arraigo) for those who have already lived in the country for three years without status, residence through arraigo socioformativo with training in an in-demand profession, residence through property after the golden visa was abolished, the digital nomad residence permit for remote employees, residence through the startup visa, student residence and the non-lucrative residence permit for those living on passive income. The conditions and processing times for each ground are set by the new immigration regulation in force since May 2025 — immigration practice under it still varies between provinces.

Changing grounds within resident status — a modification of the residence permit to cuenta propia — does not reset the time accumulated: years under any residence permit count towards the same ten-year total that later gives the right to citizenship. A separate scenario is the Andorran residence permit: the country is in neither the EU nor Schengen, but lives by its own tax rules right next to the Spanish border.

Everything below is for those who do go on to citizenship.

What happens at the oath: three legal acts

The moment called the oath (jura o promesa) consists, under article 23 of the Civil Code, of three mandatory acts:

1. An oath or promise of allegiance to the King, the Constitution and the laws of Spain. It must be taken by all applicants over 14 who are able to make such a declaration themselves.
2. Renuncia — a declaration renouncing the previous citizenship, except for natives of the countries in article 24.1 and Sephardic Jews of Spanish origin.
3. Registration of the acquisition of citizenship in the Registro Civil.

The third point is critical and is often forgotten. The Ministry of Justice’s decision does not in itself make you a Spanish citizen: citizenship is acquired only from the moment it is recorded in the Registro Civil. Until then you cannot get a DNI or a passport, and the decision can “lapse” — there is a limited time to appear.

The practical conclusion: once you receive a positive decision, book the oath straight away and watch the deadline. In large cities the queue at the Registro Civil can take months; in some cases the oath can be taken before a notary, which is noticeably faster. The general procedure is covered in our article on getting Spanish citizenship.

Documents and certificates for the application

The exact list depends on the grounds and the region where you apply, but the basic set to obtain in advance is the same:

• criminal record certificate from your previous place of residence and from Spain — the former needs an apostille and a sworn translation, and its validity is limited;
• birth certificate with an apostille and a sworn translation;
• marriage certificate, if marriage is the ground;
• certificado de empadronamiento — local registration confirming that you actually live in Spain;
• DELE A2 and CCSE certificates, if you are not a citizen of a Spanish-speaking country;
• proof of legal residence — a resident card covering the whole required period without gaps;
• diploma or proof of education, if you will need it for employment after obtaining citizenship;
• bank statement and income details — not for the application itself, but for renewing residence on the way to it.

The apostille on your home-country documents is added at home, and this is the only part of the pack that cannot be arranged from Spain. It is best to gather it in advance: the criminal record certificate has a limited shelf life, and an expired document means starting the cycle again.

The risk of losing Spanish citizenship: article 25.1 of the Civil Code

Almost every article on this topic makes a mistake here by citing article 24 of the Civil Code. Article 24 governs loss of citizenship by Spaniards by origin. Naturalised citizens are covered by article 25.1:

Spaniards who are not Spaniards by origin lose their citizenship if for three years they use exclusively the nationality they declared they renounced when acquiring Spanish citizenship.

The key word is “exclusively” (exclusivamente). The risk is created not by the mere fact of holding your previous passport but by a pattern of behaviour: a person has obtained Spanish citizenship but in every respect continues to live as a Russian, without using their Spanish status.

What follows from this in practice:

• The danger is not keeping your previous passport but systematically presenting it instead of local documents where you already act as a Spanish citizen.
• The three-year period runs from the acquisition of Spanish citizenship, that is, from the date of registration in the Registro Civil.
• If you live in Spain, pay taxes here and use a DNI and a Spanish passport, the “exclusive use” test cannot be met in principle.

When Spain can revoke citizenship

Ground	Condition
Exclusive use of the previous nationality	for 3 years after acquiring Spanish citizenship
Service in the armed forces of another state	without the Spanish government’s permission
Holding public office abroad	without the Spanish government’s permission
False or inaccurate information in the application	established by a court

The risk is provided for by law, and how often it materialises does not change the legal construction: if holding both passports is critical for you, the situation should be reviewed with a lawyer before applying, not after the oath.

Notifying Russia of a second citizenship

The main point that is most often stated wrongly: the obligation does not apply to Russians who live permanently abroad. It arises when you enter Russia — from that date you have 60 days. A notification is filed separately for each residence permit and separately for an acquired nationality.

Deadlines, ways to file, the list of documents and liability under article 19.8.3 of the Russian Code of Administrative Offences and article 330.2 of the Russian Criminal Code are in a separate article: notifying Russia of a second citizenship and residence permit.

How to live with two passports: practice

The oath does not close the question: the two statuses have to be kept carefully apart. The essentials: you enter and leave Russia on your Russian international passport, Spain and the EU on your Spanish one, and in all local procedures you present your DNI. Your previous passport should not be your main document in Spain: this creates confusion in your records and works towards the “exclusive use” test of article 25.1.

The practical difference between the statuses shows at the border. With a resident card you enter Spain as a foreigner with a residence permit, while a Spanish passport gives visa-free access to about 186 countries and the right to live and work in any EU country without permits and without being tied to an employer. Third-country nationals have no such freedom. Visa-free travel and freedom of movement within the EU are the only things resident status does not replace: work, business, healthcare and school are available equally with Spanish citizenship and with a residence permit.

The bottom line: Spanish citizenship does not automatically cancel your previous citizenship, and your previous citizenship does not stop you living in Spain. Spain sees you as its citizen, your home country sees you as its own, and each side is right within its jurisdiction — that is dual citizenship in practice.

Related guides: citizenship for a child by birth, Kazakh citizenship and a Spanish passport, Belarusian citizenship abroad, 183 days a year and tax residence and the Spanish FNMT digital certificate for filing documents online.

How the choice of passport is made in practice: a family case where different members applied on different passports.

Frequently asked questions

Does Spain recognise Russian citizenship as a second citizenship?

No. Spain records the declaration of renunciation and from then on sees only Spanish citizenship, while Russia sees only Russian citizenship. Each state considers you exclusively its own citizen, and this is not a conflict but normal practice: Spain’s relations with most countries outside the list in article 24.1 of the Civil Code work the same way.

Can you have dual Russian and Spanish citizenship?

No. No such agreement has been concluded between the two states, and Russia is not on the list in article 23.b of the Civil Code. When naturalising, a Russian signs the renuncia. More details in the section “Russia and Spain”.

Is Russian citizenship cancelled when you get Spanish citizenship?

No, it is not cancelled automatically. The declaration before a Spanish authority does not end your previous citizenship: leaving it requires a separate procedure.

Which countries does Spain have a dual citizenship agreement with?

Conventions have been concluded with 13 states: Chile, Peru, Paraguay, Nicaragua, Guatemala, Bolivia, Ecuador, Costa Rica, Honduras, Dominican Republic, Argentina, Colombia and France. In addition, natives of all Ibero-American states, Portugal, Andorra, the Philippines and Equatorial Guinea, as well as Sephardic Jews, are exempt from renunciation.

Can you be stripped of Spanish citizenship for using your previous passport?

Only for exclusive use of the previous nationality for three years (article 25.1). Having a second citizenship is not in itself a ground — see the section on risks.

How long do you have to live in Spain before getting Spanish nationality?

The standard period is 10 years of legal residence. For natives of Ibero-American states, Portugal, Andorra, the Philippines, Equatorial Guinea and Sephardic Jews — 2 years. For spouses of Spanish citizens and for children and grandchildren of Spaniards born in Spain — 12 months. For refugees — 5 years.

Can you get Spanish citizenship through investment?

No. The “golden visa” programmes for buying property have been abolished, and Spanish nationality cannot be bought. Investment in property or companies helps you get a residence permit, but property in itself gives no right to nationality and does not shorten the residence period.

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Every case is individual: timescales, documents and legal consequences depend on the grounds of residence, the family and the region where you apply. If you need a specific situation reviewed, write to us: we will go through it by message and tell you plainly if we cannot help.

Author: Irina Firsova, lawyer, member of the Barcelona Bar Association No. 46.385. This material is for reference only: every case needs to be reviewed individually.

Legal sources: article 11.3 of the Spanish Constitution; articles 22, 23, 24 and 25 of the Spanish Civil Code; the nationality convention between Spain and France (BOE of 29.03.2022); Ley 12/2015 on granting citizenship to Sephardic Jews; Russian Federal Law No. 138-FZ “On Citizenship of the Russian Federation”.