Dual Citizenship for Germans: What Applies to a Second Passport Since 2024

What changed on 27 June 2024

The Act to Modernise Nationality Law came into force on 27 June 2024. For Germans who want to acquire another nationality, three points matter:

• No more automatic loss. The old § 25 of the Nationality Act (StAG) said that a German who acquired a foreign nationality on their own application lost German citizenship by operation of law. That rule is gone. The German Foreign Office states that acquiring a foreign nationality on application no longer leads to the loss of German citizenship since 27 June 2024.
• No more retention permit. The Beibehaltungsgenehmigung, the permit from the Federal Office of Administration that used to prevent the loss in advance, has been abolished. You do not need to apply for anything in Germany before taking the second passport.
• No more option duty. The obligation for children born in Germany to foreign parents to choose between two nationalities has also been dropped.

The reform is not retroactive. Anyone who applied for and accepted a foreign passport before 27 June 2024 without a retention permit lost German citizenship at that time and does not get it back automatically. For these cases the Foreign Office points to naturalisation of former Germans under § 13 StAG, which runs through the Federal Office of Administration and has its own conditions. Anyone who received a retention certificate back then should keep it together with the foreign naturalisation certificate: it proves that the acquisition did not trigger a loss under the old law.

Politically, dual nationality has not been rolled back since. In October 2025 the Bundestag did abolish the so-called fast-track naturalisation after three years, so naturalisation in Germany now requires a uniform minimum of five years' residence. The right to hold another nationality alongside German citizenship was left untouched. As of October 2026 the rule still applies.

What can still lead to loss

The law is not entirely without grounds for loss. The main remaining one is § 28 StAG: an adult who voluntarily joins the armed forces of another state whose nationality they also hold loses German citizenship, unless they have approval from the Federal Ministry of Defence or an intergovernmental treaty permits it. This rarely affects the typical Caribbean investor passports, but it can matter for countries with conscription. There is also renunciation: if you want to give up German citizenship, you can declare it explicitly. It is then lost through the declaration, not through the second passport.

The other side: does the other country allow dual citizenship?

Germany accepting dual nationality says nothing about how the other country sees it. There are two questions here.

• The country of the new passport. The well-known citizenship by investment programmes, meaning St. Kitts and Nevis, Dominica, Grenada, Antigua and Barbuda, St. Lucia and Vanuatu, do not require you to give up your existing nationality. Turkey also permits dual nationality. Naturalisation through long-term residence is a different matter: some countries generally require you to give up your previous nationality. Check this country by country before you apply.
• A third passport you already hold. If you already have another passport besides the German one, check that country's law too. Some states withdraw their own nationality when their citizens voluntarily acquire a foreign one. The German reform does not help there.

The investment programmes themselves have their own articles on St. Kitts and Nevis, Grenada and the US E-2 visa and Vanuatu.

What still applies to you as a German with two passports

The second passport does not change your relationship with Germany. You remain German with all rights and duties, and inside Germany you are treated as German only. In practice:

• Enter and leave Germany on a German document. Under § 1 of the Passport Act, Germans leaving or entering Germany must carry a valid passport and identify themselves with it. That means a German document. Arriving in Frankfurt on your Caribbean passport as if you were a foreigner is not how it works. Keep your German passport or ID card valid, even if you mostly travel on the other one.
• The ID duty stays. The German duty to hold an identity document follows your nationality, not the passport you prefer to use.
• Population register. The Foreign Office does not mention any separate duty to notify a federal authority that you acquired another nationality. The population register does, however, store your current nationalities under § 3(1) no. 10 of the Federal Registration Act. If you are registered in Germany, you state them at your next registration, and giving false information is not a good idea.
• Voting and military service. You keep your right to vote in Germany. Conversely, you may be subject to duties in the other country, such as military service if that country has it.

Consular protection: where the Foreign Office cannot help

Many people buy a second passport as a crisis backup. Consular protection deserves a sober look here, because with two passports it does not get twice as good. In one place it gets weaker.

• Little protection against the other state. Most states treat dual nationals on their territory solely as their own citizens. If you are in Grenada as a Grenadian and run into trouble there, the German embassy can only do so much towards Grenada. Under international law there is practically no diplomatic protection against your own other home state.
• The exception in the Consular Act is narrower than often claimed. § 5 of the Consular Act only excludes Germans from emergency help when three things coincide: habitual residence in the other state, holding its nationality, and a father or mother who holds or held it as well. Someone who buys an investor passport usually does not meet the third condition. The practical limit is therefore less in German law than in the fact that the other state treats you as its own citizen and does not have to accept German officials as responsible.
• In third countries the German passport is the stronger one. Travel to a third country on your German passport and you are a German and EU citizen there, with the full network of German missions and consular protection from other EU states. A small Caribbean state has no embassy of its own in many countries.

For the backup question this means: the second passport is an option for entry and residence, not a second safety net.

Tax: the passport decides nothing

The most common mistake with a second passport is a tax one. Germany does not tax by nationality but by residence. Under § 1 of the Income Tax Act, anyone with a home or habitual abode in Germany has unlimited tax liability there. Whether you also hold a passport from St. Kitts or Vanuatu plays no role. The consequences run both ways:

• If you live in Germany, you pay in Germany. A passport from a country without income tax does not cut your tax by a single euro while your home, family or centre of life stays in Germany. What counts as a home and habitual abode is explained in more detail in the article on Plan B residency options.
• If you genuinely move away, you do not need a second passport. With a German passport you can live anywhere you have a residence right. For tax purposes the move counts, not the travel document.

On a genuine move abroad, two rules of the Foreign Tax Act (AStG) apply, and they do not depend on your passport either:

• Exit tax under § 6 AStG. If you had unlimited German tax liability for at least seven of the last twelve years and hold shares in a corporation within the meaning of § 17 of the Income Tax Act (generally a stake of 1 percent or more), moving away is treated as if you had sold the shares. On application the tax can be paid in seven annual instalments, usually against security. If you return within seven years it lapses under certain conditions, and that period can be extended by up to five years.
• Extended limited tax liability under § 2 AStG. A German who had unlimited tax liability for at least five of the last ten years, moves to a low-tax country and keeps substantial economic interests in Germany stays liable to German tax on a much wider range of income until the end of the tenth year after leaving. Low-tax means, in simplified terms, more than a third less income tax than in Germany, or a preferential tax regime. The rule only applies in years where that income exceeds 16,500 euros in total. The very countries that advertise second passports are often exactly such low-tax countries.

How these rules play out in your own case depends on the details, and before a move it belongs with a tax adviser who knows both sides.

The second passport at the bank: tax residence, not nationality

One point rarely found in the brochures: banks worldwide report account data under the OECD Common Reporting Standard to the tax authorities of the country where the account holder is tax resident. What decides this is not the passport but the tax residence you declare in the self-certification.

• The self-certification asks for tax residence. Every account opening comes with a form on which you list every country where you are tax resident, with a tax number. If you live in Germany, you enter Germany, even if you open the account with the Caribbean passport. The bank then reports to the German Federal Central Tax Office.
• Banks know the investor passports. The OECD has identified citizenship and residence by investment schemes that carry a high risk of being used to get around the reporting system. Under the CRS rules, banks may not rely on a self-certification if they have reason to believe it is wrong. In practice they ask follow-up questions on such passports: was the status obtained through investment, where else do you have residences, how many days did you spend in other countries last year, where did you file tax returns. The Australian tax office ATO describes this approach on its page on CRS circumvention schemes.
• False statements are the real risk. Opening an account on a second passport and leaving out Germany as your tax residence while you live there is a false declaration. That is not a grey area.

A second passport can still help when opening an account, for example when a bank outside the EU only accepts certain nationalities. What access to accounts outside the EU looks like in 2026 is covered in the article on the non-EU bank account.

Step by step: the German checklist

If you apply for a second passport, you can work through the German side in this order:

• Check beforehand that the other country allows dual nationality and that a third passport you already hold is not put at risk by the acquisition.
• Keep your German passport or ID card valid. It remains your document for entering and leaving Germany.
• File the naturalisation certificate and passport copies safely, and for acquisitions before 27 June 2024 any retention certificate as well.
• State the additional nationality at your next registration if you are registered in Germany.
• Expect nothing on tax while you live in Germany. Only a genuine move changes anything, and then with § 6 and § 2 AStG in view.
• Declare your tax residence correctly at banks, regardless of which passport you show.