From February 25, dual citizens of the UK and Ireland will have to follow new passport regulations, implemented by each country separately.
The changes have caused panic among many Australians with dual citizenship who plan to travel to the UK or Ireland in the next few months.
Here's how to make sure you won't get caught out.
What are the changes?
From February 25, British/Irish dual citizens will be prevented from entering the UK using a passport from a different country, such as an Australian passport.
They will need to use their valid British or Irish passport, or another valid passport containing a certificate of entitlement (COE).
This means dual citizens will have to choose whether to pay for a British passport, the COE or renounce their British citizenship.
This has created many complications because British nationals and Irish nationals who have Australian passports or Australian citizenship are usually counted as dual citizens unless they renounce their Irish/UK citizenship.
If they have just decided to keep an Australian passport, they will now need a COE or to renew a British or Irish passport.
What is a certificate of entitlement?
A certificate of entitlement (COE) is a document placed in a foreign passport to prove the passport holder has the right to stay in the UK.
It allows you to live and work in the country without immigration restrictions or a time limit.
Every time your passport is renewed, your COE will need to be as well.
How much is a certificate of entitlement?
The COE is an expensive option, costing 589 pounds ($1,180) when applied for outside of the UK or Ireland.
You can apply for a certificate of entitlement online here.
If you do not have a British passport or a COE you will not be able to board a plane or ship to the UK on or after February 25.
Commercial airlines will likely be fined if they allow someone with incorrect documents to enter the country.
Is a COE different to an ETA?
From February 25, most travellers to the UK from visa-exempt countries for tourism or short stays, such as Australia and the US, will be required to have an electronic travel authorisation.
The digital permit is required for those entering England, Scotland, Wales and Northern Ireland.
It will cost about $32 and applies to babies and children as well.
An approved permit is valid for two years or until the holder's passport expires, and you can travel to the UK as much as you like during that time.
The UK's Home Office advises the quickest way to apply for an ETA is via the UK ETA app, available on both the Apple App Store and Google Play.
If you are a British passport holder, have permission to live, work or study in the UK or have a COE you do not need an ETA.
You do not need it if you are transitioning through a UK airport and you will not pass through border control.
Check with your airline if you are not sure.
You can find more information about ETA applications and requirements here.
Applications are usually approved within 24 hours.
How do I check my citizenship status?
Associate professor Dannielle Ireland-Piper is a citizenship expert at the Australian National University and says the concept of dual citizenship can be very complex.
"Basically the issue is that international law is actually neutral to a grant of citizenship and what that means is there is no internationally agreed rule as to when a person can be designated a citizen, granted a citizenship or naturalised as a citizen," she said.
"So the effect of that is it is unpredictable to work out when you are a citizen and you aren't because there are not internationally agreed upon rules.
She says it is up to each nation to determine who is its citizen and historically we've seen that play out in Australia, where MPs had to work out whether they were a citizen or may have had the status or not been aware of it.
"So to figure out if you are a British citizen, you have to follow the British system to work it out," she said.
"That can create complications in a world where we're hyper-connected, which means we often have a relationship or connection to more than one country through ancestry, marriage or residency."
Dr Ireland-Piper says it is vital that passengers follow official channels such as UK government websites with a government URL to avoid getting scammed.
How do I know if I am a dual UK citizen?
Many countries do not allow dual citizenship but the UK does.
This means you can apply for a foreign citizenship and keep your British citizenship.
This means that existing British citizens can apply for a foreign citizenship without forfeiting their rights in the UK.
Additionally, you may be considered a UK citizen, even if you hold foreign citizenship elsewhere, if you:
- Have a parent who is considered a national of the UK
- Apply for citizenship of Australia or another county and do not renounce your UK citizenship
- Were born in the UK
British citizenship is normally automatically passed down one generation to children born outside the UK if one of the parents is a citizen at the time of birth.
As a result, you can be a British citizen but not hold a UK passport or even know you're considered a citizen.
You can check if you're a dual citizen here.
If you're not automatically a dual citizen, you may be eligible to register as one.
If that is the case then you will need to travel to and from the UK on your foreign passport with a COE.
Keep in mind that if you marry a UK citizen, you'll need to proactively apply for citizenship.
How do I know if I am a dual citizen of Ireland?
If you or your parent were born on the island of Ireland before 2005, you are an Irish citizen.
You can apply for an Irish passport without making an application for citizenship.
If you, or your parent, were born on the island of Ireland on or after January 1, 2005, your right to dual Irish citizenship depends on:
- the parents' citizenship at the time of the birth
- the residency history of one of the parents before the birth
Your entitlement to an Irish passport through ancestry does not mean you are automatically a citizen.
If you are unsure, it is best to check with Irish authorities like the Embassy.
What happens if my UK passport is expired and I'm a dual citizen?
You will need to apply for a new one before you plan to travel or get a COE for your Australian or other foreign passport.
Do I need to renounce citizenship? How?
You do not have to renounce your citizenship unless you do not want your UK passport or to pay for a COE.
You can apply to give up your British citizenship to the UK government.
If accepted, you'll get a "declaration of renunciation" that you can use to show that you're no longer British.
If you give up your British citizenship it could affect the status of children you have in the future.
You can only give it up if you already have citizenship elsewhere or you will get another citizenship after giving it up.
Do you know more, or are you affected?
