Irina Firsova Author Irina Firsova Immigration lawyer in Spain, member of the Barcelona Bar Association no. 46.385 19 min read Message the author

Dual nationality in Spain for citizens of Belarus, Kazakhstan and Ukraine

Spain has no dual nationality agreement with Belarus, Kazakhstan or Ukraine: citizens of all three sign a renuncia on naturalisation, a declaration renouncing their previous nationality (Art. 23 b) of the Spanish Civil Code, Código Civil, BOE-A-1889-4763). The consequences back home differ, however. Kazakhstan terminates citizenship by operation of law, Belarus keeps it but does not recognise the second one, and Ukraine has allowed multiple citizenship since 16 January 2026 and has included Spain in its list of states.

Key points

  • Article 23 b) of the Código Civil requires a declaration renouncing previous nationality from everyone except nationals of the countries listed in Art. 24.1 and Sephardic Jews; Belarus, Kazakhstan and Ukraine are not on that list.
  • The naturalisation period for citizens of these three states is the general ten years of legal residence under Art. 22.1 of the Código Civil, unless there is a separate ground such as marriage to a Spanish citizen (one year, Art. 22.2.d).
  • Spain records the renunciation declaration itself in the oath ceremony and does not check whether the previous citizenship has actually been lost under the other country’s law.
  • Kazakhstan: citizenship is lost upon acquiring a foreign one (Art. 21(5) of the Law of the Republic of Kazakhstan “On Citizenship” No. 1017-XII of 20.12.1991); you must notify the authorities and hand in your documents within 30 calendar days.
  • Belarus: acquiring foreign citizenship is not among the grounds for loss (Art. 19 of Law No. 136-Z of 01.08.2002), so Belarusian citizenship is retained; the state simply does not recognise the second one.
  • Ukraine: Law No. 4502-IX of 18.06.2025 has applied since 16.01.2026; Cabinet of Ministers Resolution No. 589 of 08.05.2026 extended the list of states to 33, including Spain. Multiple citizenship with Russia and Belarus is expressly prohibited.
  • Article 25.1 a) of the Código Civil threatens loss of Spanish nationality not for holding a second passport but for exclusively using the previous nationality for three years after naturalisation.

What Spain requires from citizens of Belarus, Kazakhstan and Ukraine

The same from all three: ten years of legal residence, exams and, at the end, three steps under Art. 23 of the Código Civil, one of which is a declaration renouncing previous nationality. Spanish law provides no country-specific concessions for Belarus, Kazakhstan or Ukraine, and Spain has no bilateral nationality conventions with these states.

Article 23 lists three conditions without which naturalisation is not considered complete:

  • an oath or promise of allegiance to the King and obedience to the Constitution and the laws, from the age of 14;
  • a declaration renouncing previous nationality;
  • registration of the new nationality in the Registro Civil (civil registry).

The wording of paragraph b) is worth quoting in full, because it defines who is exempt:

«Que la misma persona declare que renuncia a su anterior nacionalidad. Quedan a salvo de este requisito los naturales de países mencionados en el apartado 1 del artículo 24 y los sefardíes originarios de España».

“That the same person declares that they renounce their previous nationality. Exempt from this requirement are nationals of the countries mentioned in paragraph 1 of Article 24 and Sephardic Jews originating from Spain.”

A separate note on timelines: the accelerated two years do not apply to our three states. The general calculation and the full list of documents are covered in our article on how to get Spanish citizenship.

Residence period Who Legal provision
10 years General rule: citizens of Belarus, Kazakhstan, Ukraine, Russia Art. 22.1 Código Civil
5 years People granted asylum Art. 22.1 Código Civil
2 years Ibero-American countries, Andorra, the Philippines, Equatorial Guinea, Portugal, Sephardic Jews Art. 22.1 Código Civil
1 year Spouse of a Spanish citizen, people born in Spain, descendants of Spaniards and other categories on a closed list Art. 22.2 Código Civil

The only realistic way for a Belarusian, Kazakh or Ukrainian to cut ten years to one is to fall within the closed list of Art. 22.2. Most often this means marriage: the conditions and pitfalls are covered in our article on Spanish citizenship through marriage.

Why everyone confuses Article 23 b) and Article 24.1

These are two different provisions addressed to two different people, and mixing them up is the most common mistake in Russian-language articles. Article 23 b) is addressed to a foreigner acquiring Spanish nationality. Article 24.1 is addressed to a Spaniard acquiring a foreign one.

Article 24.1 says the following: a Spaniard habitually resident abroad who voluntarily acquires another nationality loses Spanish nationality after three years unless they declare before the Registro Civil that they wish to keep it. It then adds a proviso: acquiring the nationality of Ibero-American countries, Andorra, the Philippines, Equatorial Guinea or Portugal does not lead to loss.

That list on its own has nothing to do with foreigners. It applies to them only through the cross-reference in Art. 23 b): “nationals of the countries mentioned in paragraph 1 of Article 24”. In other words, the same list is used twice: as an exception from loss of nationality for Spaniards and as an exception from the renuncia for foreigners.

The practical consequence: phrases such as “Spain allows dual nationality with the countries under Art. 24.1” are inaccurate. Spain does not “allow” anything: in one case it does not take away its own nationality, in the other it does not require a formal renunciation of the foreign one. The general logic of the Spanish approach to holding two passports is explained in our main guide to dual nationality in Spain.

France: proof that the list can be extended

The list in Art. 24.1 is not set in stone; it can be extended by an international treaty. The Convenio de nacionalidad España–Francia was signed on 15.03.2021 in Montauban (BOE-A-2022-4916) and has been in force since 1 April 2022; the Instrucción of the DGSJFP of 31.03.2022 (BOE-A-2022-5573) clarified that French nationals are exempt from the Art. 23 b) requirement.

An important detail: the convention does not shorten the residence period; it only removes the renuncia. For our three states this means only one thing: in theory such a convention is possible with them too, but as of August 2026 Spain has no such treaty with Belarus, Kazakhstan or Ukraine.

What renuncia means in practice

It is an oral and written declaration before a Spanish official during the oath ceremony, not an application to your own country’s consulate. Spain records that you pronounced the renunciation, and there its interest ends. The Spanish declaration does not and cannot trigger any procedure for giving up citizenship in your country of origin.

From that point on, the other country’s law takes over, and this is where the three states diverge. Kazakhstan considers citizenship terminated upon acquiring a foreign one. Belarus does not consider it terminated at all. Ukraine has expressly allowed a second citizenship since 2026 and replaced renunciation with a declaration of loyalty.

The deferred Spanish risk is set out in Art. 25.1 a) of the Código Civil: a naturalised Spaniard loses Spanish nationality if for three years they use exclusively (exclusivamente) the nationality they declared they were renouncing. The key word is “exclusively”. The rule is aimed not at holding a second passport but at completely ignoring Spanish status.

Separately, Art. 25.2: in cases of forgery, concealment or fraud, the acquisition of nationality is annulled by a court, and the public prosecutor can bring an action within fifteen years. Fifteen, not ten: the “10 years” figure circulating on Russian-language websites is a mistake.

Summary table: Spain and your country

The Spanish column is the same for all four states: renunciation is required. The differences begin in the columns describing the law of the country of origin, and these are what determine how the oath ceremony will play out for you personally.

Country Does Spain require renuncia Is citizenship lost under that country’s law Deadline for notifying at home Penalty Legal provision
Russia Yes No, multiple citizenship is permitted; at home the person is treated only as a Russian citizen 60 calendar days; for those abroad, from the date of entry into Russia RUB 500–1,000 under Art. 19.8.3 of the Code of Administrative Offences; for failure to notify, Art. 330.2 of the Criminal Code (a fine of up to RUB 200,000 or up to 1 year’s income, or up to 400 hours of compulsory work) Art. 11 of Federal Law No. 138-FZ of 28.04.2023
Ukraine Yes No, multiple citizenship has been permitted since 16.01.2026; Spain was included in the list by Cabinet of Ministers Resolution No. 589 of 08.05.2026 The mechanism is a declaration of loyalty instead of renunciation; practice is still developing Multiple citizenship with Russia and Belarus is expressly prohibited Law No. 4502-IX of 18.06.2025
Belarus Yes No. Acquiring foreign citizenship is not among the grounds for loss; the second citizenship is simply not recognised The citizenship law sets no obligation to notify Rights are not restricted, and the obligations of a Belarusian citizen remain in full Art. 11 and Art. 19 of Law No. 136-Z of 01.08.2002
Kazakhstan Yes Yes, loss occurs by operation of law upon acquiring foreign citizenship 30 calendar days from acquisition: notify the internal affairs authorities or a Kazakh mission abroad and hand in your passport and identity card Art. 496(2) of the Code of Administrative Offences of Kazakhstan; an example from practice: a fine of 516,880 tenge, Taskala District Court, September 2024 Art. 10 of the Constitution of Kazakhstan; Art. 21(5) of Law No. 1017-XII of 20.12.1991

Ukraine: multiple citizenship since 16 January 2026

This is the only one of the three states where the situation has changed radically and recently. Ukraine’s Law No. 4502-IX on multiple citizenship was adopted on 18.06.2025 and came into force on 16.01.2026. It abandoned the old principle of single citizenship in favour of a closed list of states with which multiple citizenship is permitted.

The original list included five states: Poland, the Czech Republic, Germany, the USA and Canada. Spain was not on it. Resolution No. 589 of the Cabinet of Ministers of Ukraine of 08.05.2026 extended the list to 33 states, and Spain was included.

The full extended list: Austria, Belgium, Bulgaria, the United Kingdom, Germany, Greece, Denmark, Estonia, Ireland, Iceland, Spain, Italy, Canada, Cyprus, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, the USA, Hungary, Finland, France, Croatia, the Czech Republic, Switzerland, Sweden.

Multiple citizenship with Russia and Belarus is expressly prohibited by law. For those acquiring Ukrainian citizenship, the mechanism is a declaration of loyalty instead of renouncing their previous citizenship.

An essential caveat about how the list is worded

Precision is needed here, and it is usually missing from popular summaries. The official title of the list is “states whose citizens acquire Ukrainian citizenship under a simplified procedure”. In other words, the document literally describes movement towards Ukraine.

The two-way effect, meaning that a Ukrainian can obtain Spanish nationality while keeping Ukrainian citizenship, is confirmed by secondary sources, but we have not been able to verify it against a direct quotation from the law. So we put it cautiously: Spain is on the list, enforcement practice is still developing, and before the oath you need to check the current version of the law and consult a Ukrainian lawyer.

The practical significance is still great. Before 2026, a Ukrainian taking the oath in Spain was in a position where renunciation was mandatory under Spanish law and Ukrainian law did not provide for a second citizenship. Now there appears to be no such direct conflict, but it is too early to present this as a guarantee.

What the law did not change: the border and military registration

The rules for crossing the Ukrainian border remain the same. A Ukrainian citizen crosses the Ukrainian border on a Ukrainian passport; a Spanish document does not exempt them from this.

For men aged 18–60, exit restrictions apply under martial law. A second passport does not exempt anyone from checks and does not create grounds for leaving. This is the most common misconception about Law No. 4502-IX, and it is dangerous because it is tested at the border, not in a lawyer’s office.

A separate note on status before naturalisation: for most Ukrainians in Spain, the road to ten years of residence runs through temporary protection followed by a change of legal basis. What this route looks like in practice is covered in our article on Ukrainians in Spain.

Kazakhstan: single citizenship and loss by operation of law

The strictest of the three legal systems. The principle of single citizenship is enshrined at constitutional level: Article 10 of the Constitution of the Republic of Kazakhstan states that a citizen of the Republic is not recognised as a citizen of another state.

The termination mechanism is set out in Art. 21(5) of the Law of the Republic of Kazakhstan “On Citizenship of the Republic of Kazakhstan” No. 1017-XII of 20.12.1991: citizenship is lost as a result of a person acquiring the citizenship of another state.

The crux here is the phrase “as a result of”. Loss occurs by operation of law, upon acquiring Spanish nationality, not upon your notification and not upon a decision by any authority. Notification is a separate obligation, not a condition of loss.

Thirty days and what follows

Within 30 calendar days of acquiring another citizenship, you must report it to the internal affairs authorities or a Kazakh mission abroad and hand in your Kazakh passport and identity card.

Liability for breach is provided for in Art. 496(2) of the Code of Administrative Offences of Kazakhstan. We give one example from practice without presenting it as a set rate: in September 2024 the Taskala District Court imposed a fine of 516,880 tenge. The amount depends on how the offence is classified and the circumstances of the case, so do not rely on a specific figure.

The practical conclusion for a Kazakh citizen is straightforward: Spanish and Kazakh citizenship are a choice, not a combination. You cannot legally keep both, and no Spanish procedure changes that. What you lose together with the passport (access to certain land transactions, public service, simplified inheritance) is worth assessing in advance; the general context of life in the diaspora is covered in our article on Kazakhs in Spain.

Belarus: citizenship is not recognised, but not lost either

The conclusion here is counter-intuitive and is almost never stated correctly. A Belarusian who obtains a Spanish passport legally remains a citizen of Belarus. The state simply does not recognise their second citizenship.

The basis is Art. 11 of the Law of the Republic of Belarus “On Citizenship of the Republic of Belarus” No. 136-Z of 01.08.2002:

“A person who is a citizen of the Republic of Belarus shall not be recognised as holding the citizenship of a foreign state, unless otherwise provided by international treaties of the Republic of Belarus.”

A practical case is covered separately: moving from Poland to Spain for Belarusians, covering what to do with your Polish status and how it affects your Spanish one.

The second part of the same article adds something important: people with two citizenships are not restricted in their rights and are not released from the obligations arising from Belarusian citizenship. In other words, the obligations remain in full.

Why a Spanish passport is not a ground for loss

Because Article 19 of Law No. 136-Z, which lists the grounds for loss of citizenship, does not include acquiring foreign citizenship. The list covers service in the army, police or security bodies of a foreign state, an application by parents on behalf of their children, international treaties, and extremist activity for those who acquired citizenship through admission or restoration.

Belarusian citizenship can be ended only by renouncing it. This is a permission-based procedure: you submit an application and the President makes the decision. Nothing happens automatically in either direction.

What this means in practice: after the Spanish oath, a Belarusian is in a position where Spain considers them to have renounced their citizenship, while Belarus still considers them its citizen with all the obligations. This is not a violation; it is a consequence of the two states deciding the matter independently of each other. Everyday consequences and diaspora experience are covered in our article on Belarusians in Spain.

Russia for comparison

In this group Russia looks the most liberal: multiple citizenship is permitted, a second passport does not lead to loss of Russian citizenship, and inside the country the person is treated only as a Russian citizen. In return there is an obligation to notify.

The deadline is 60 calendar days; for those abroad, the count starts from the date of entry into Russia. The basis is Art. 11 of Federal Law No. 138-FZ of 28.04.2023. For breaching the filing procedure, Art. 19.8.3 of the Code of Administrative Offences provides for a fine of RUB 500–1,000 for individuals; for failing to notify at all, Art. 330.2 of the Criminal Code provides for a fine of up to RUB 200,000 or the amount of income for a period of up to one year, or up to 400 hours of compulsory work.

Forms, recipients and nuances for those who do not travel to Russia are covered separately in our article on notification of a second citizenship.

What to do before the oath

The decision on renuncia is made not at the start of the journey but at its very end. A decade passes between arriving in Spain and becoming eligible to apply for citizenship, and in that time the legislation of all four states has time to change, as the Ukrainian example of 2025–2026 clearly showed.

So the sensible order is: do not decide in advance, but gather information before applying and check it again immediately before the oath.

Step What to find out Why it matters
1 Your state’s position on a second citizenship, from a lawyer in your country of citizenship rather than from articles online The three legal systems work differently and change independently of each other
2 Whether the consequences arise upon acquisition or upon notification In Kazakhstan loss is automatic, and notification does not affect it
3 The deadline and the recipient of the notification Missing the deadline is an offence in its own right, regardless of anything else
4 What exactly you lose at home: property and land transactions, bank accounts, inheritance, public service, military registration The main cost of the decision is usually not the passport but these rights
5 The current version of the rule on the date of the oath A year or more passes between the application and the oath

It is also worth asking yourself whether you need citizenship at all. For many purposes permanent residence in Spain is enough: larga duración (long-term residence) status gives stable residence and the right to work without any oath or renuncia.

Myths

“Spain has a dual nationality agreement with Kazakhstan or Belarus”

No. Spain has concluded few nationality conventions, and the only recent example is the 2021 Convenio de nacionalidad with France. As of August 2026 there are no such treaties with Belarus, Kazakhstan or Ukraine.

“Renouncing at the oath automatically strips you of your previous citizenship”

No. It is a declaration before a Spanish official. Whether citizenship actually ends is decided by the other country’s law: in Kazakhstan, yes; in Belarus, no; in Ukraine since 2026, no.

“Belarus takes away citizenship for a Spanish passport”

No. Art. 19 of Law No. 136-Z contains no such ground for loss. The second citizenship is not recognised, but Belarusian citizenship itself is retained until renounced through the permission-based procedure.

“Ukraine still has single citizenship”

Out of date. This was correct until 16.01.2026, when Law No. 4502-IX came into force. Since May 2026 the list of states has been extended to 33, including Spain.

“Holding a second passport is grounds for losing Spanish nationality”

No. Article 25.1 a) of the Código Civil refers to exclusive use of the previous nationality for three years, not to merely holding it. The difference is fundamental.

“Citizens of these countries have a shorter naturalisation period”

No. It is ten years under Art. 22.1. The shorter periods are two years for Ibero-American countries and Sephardic Jews, and one year under the closed list of Art. 22.2. Belarus, Kazakhstan and Ukraine are not on any of these lists.

Frequently asked questions

Does Spain have a dual nationality agreement with Kazakhstan?

No. Spain has concluded a nationality convention with France (BOE-A-2022-4916, in force since 01.04.2022) and has historical agreements with Ibero-American countries. There is no such treaty with Kazakhstan, so the requirement of Art. 23 b) of the Código Civil to renounce previous nationality applies in full.

Dual nationality in Spain for Ukrainians: how does it work?

Spain still requires a declaration of renunciation at the oath. Since 16.01.2026, under Law No. 4502-IX, Ukraine allows multiple citizenship, and Cabinet of Ministers Resolution No. 589 of 08.05.2026 added Spain to the list of states. Enforcement practice is still developing, so before the oath check the current version of the law and consult a Ukrainian lawyer.

Can you keep your Kazakh passport after getting a Spanish one?

No. Article 10 of the Constitution of Kazakhstan does not recognise a citizen of the Republic as a citizen of another state, and Art. 21(5) of Law No. 1017-XII of 20.12.1991 provides for loss of citizenship as a result of acquiring a foreign one. Loss occurs by operation of law, upon acquisition, whether or not you have notified the authorities.

Will your Belarusian passport be taken away after you get a Spanish one?

Under Belarusian law there are no grounds for this. Article 19 of Law No. 136-Z of 01.08.2002 does not list acquiring foreign citizenship among the grounds for loss. Citizenship is retained, but Belarus does not recognise the second one, and the citizen’s obligations remain in full under Art. 11.

Is the naturalisation period different for citizens of Belarus, Kazakhstan and Ukraine?

No, it is the general one: ten years of legal and continuous residence under Art. 22.1 of the Código Civil. The reduction to two years applies to Ibero-American countries, Andorra, the Philippines, Equatorial Guinea, Portugal and Sephardic Jews. The period drops to one year only under the closed list of Art. 22.2, for example for the spouse of a Spanish citizen.

Does renouncing at the oath automatically end your previous citizenship?

No. Spain records the declaration itself in the oath ceremony and does not check whether loss has actually occurred under the other country’s law. The further consequences are determined by the law of the country of origin: in Kazakhstan citizenship ends, in Belarus it does not, and in Ukraine since 2026 a second citizenship with Spain is permitted.

What happens if you do not hand in your Kazakh passport within 30 days?

The obligation to notify the internal affairs authorities or a mission abroad and to hand in your passport and identity card applies for 30 calendar days from acquiring another citizenship. Liability is under Art. 496(2) of the Code of Administrative Offences of Kazakhstan. As an example from practice, in September 2024 the Taskala District Court imposed a fine of 516,880 tenge; this is not a fixed rate.

Does a Ukrainian citizen have to give up Ukrainian citizenship to become Spanish?

The Spanish procedure requires a declaration of renunciation under Art. 23 b) of the Código Civil, and Ukrainians are not exempt from it. The question is whether that declaration leads to loss of Ukrainian citizenship. After 16.01.2026 and Spain’s inclusion in the list by Resolution No. 589, there appears to be no direct conflict according to secondary sources, but practice is only just developing.

Can Spain take away nationality for holding a second passport?

Holding a second passport is not in itself a ground. Article 25.1 a) of the Código Civil provides for loss if a naturalised Spaniard uses exclusively, for three years, the nationality they declared they were renouncing. Separately, Art. 25.2 allows a court to annul nationality in cases of forgery, concealment or fraud, with the public prosecutor able to bring an action within fifteen years.

How do you renounce Belarusian citizenship?

Only through the permission-based renunciation procedure: you submit an application and the President of the Republic of Belarus makes the decision. Law No. 136-Z does not provide for automatic termination upon acquiring foreign citizenship. The law guarantees neither the timeframe nor the likelihood of a decision, so do not plan renunciation as a quick step.

Has the new Ukrainian law changed the exit rules for men aged 18–60?

No. Law No. 4502-IX did not change the rules for crossing Ukraine’s border. A Ukrainian citizen crosses the Ukrainian border on a Ukrainian passport, and the exit restrictions for men aged 18–60 under martial law remain in force. Holding a Spanish passport does not exempt anyone from checks.

Does a Russian citizen have to report acquiring Spanish nationality?

Yes. The deadline is 60 calendar days under Art. 11 of Federal Law No. 138-FZ of 28.04.2023; for those abroad, the count starts from the date of entry into Russia. Breaching the filing procedure carries a fine of RUB 500–1,000 under Art. 19.8.3 of the Code of Administrative Offences, and failing to notify at all falls under Art. 330.2 of the Criminal Code, with a fine of up to RUB 200,000.

Sources

This article is not a substitute for advice from a lawyer in your country of citizenship: the legislation of Belarus, Kazakhstan and Ukraine changes independently of Spanish law, and the decision on renuncia should be made on the basis of the current rules of both sides.

If you would like someone to look at your specific situation (citizenship, status in Spain, timelines and what you lose at home), write to us and we will go through it date by date and rule by rule; we will tell you plainly if we cannot help.

This article is for reference only and is not a substitute for professional advice.

Contents
  1. Key points
  2. What Spain requires from citizens of Belarus, Kazakhstan and Ukraine
  3. What renuncia means in practice
  4. Summary table: Spain and your country
  5. Ukraine: multiple citizenship since 16 January 2026
  6. Kazakhstan: single citizenship and loss by operation of law
  7. Belarus: citizenship is not recognised, but not lost either
  8. Russia for comparison
  9. What to do before the oath
  10. Myths
  11. Frequently asked questions
  12. Sources
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