By Georgina Elustondo
The citizenship by birth—known as jus soli— It is not the rule in the world. Although in the United States it is a consolidated constitutional right, most countries do not automatically grant nationality to those born in their territory.
A recent analysis by the Pew Research Center confirms that this model is actually rare globally.
You can see: Could your children lose citizenship in 2026?
Jus soli implies that any person born in the territory of a country acquires its citizenship, regardless of the immigration status of their parents. In contrast, many countries apply the jus sanguinis (right of blood)where nationality is transmitted by parents, not by place of birth.
In which countries does “jus soli” exist?
Full jus soli is mainly concentrated in America:
- United States (by the 14th Amendment of the Constitution).
- Canada.
- Most Latin American countries, such as Argentina, Mexico, Brazil and Chile.
In these nations, being born in the territory is usually sufficient to obtain citizenship, with very limited exceptions (for example, children of diplomats).
Where it does not apply
In much of Europe, Asia, Africa and Oceania, the automatic citizenship by birth does not exist or is restricted. Some examples:
- Europe: countries like Germany, France or Spain combine criteria, but do not apply full jus soli; They usually require appropriate residence of the parents or additional conditions.
- Asia: Japan, China and India prioritize jus sanguinis.
- Oceania: Australia and New Zealand limited jus soli in recent decades.
Why the US is an exception
The United States stands out for maintaining a broad model of citizenship by birth, even in contexts of strong immigration debate. According to Pew, the global trend in recent decades has been to restrict this right, not expand it.
The 14th Amendment, ratified in 1868 after the Civil War, establishes that anyone born in the United States is a citizen. This principle has been reaffirmed by the Supreme Court and remains a pillar of the country’s legal system.
A debate with immigration impact
For millions of immigrant families, andThis topic is not theoretical. Outline key rights such as access to education, health and appropriate protection. Therefore, every time the debate is reopened in the US, interest in understanding how it works in the rest of the world also grows.
In short, although many assume it to be universal, birthright citizenship is a global exception. The United States does not follow the dominant trend: it defies it.
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