The question of whether China allows dual citizenship has a clear and strict answer: no. Unlike many Western countries that accept the concept of multiple citizenship, the People’s Republic of China (PRC) adheres to the principle of single loyalty. This policy is enshrined in legislation and actively applied in practice.
Millions of Chinese people live, study, and work abroad. Global investors are looking for ways to do business in China, while Chinese entrepreneurs strive for international mobility. In this context, China’s strict policy on dual citizenship is not just a legal formality but a fundamental factor influencing personal, family, and economic strategies.
Dual citizenship is a status in which a person is legally recognized as a citizen of two (or more) countries simultaneously. This grants them rights and imposes obligations in each of the jurisdictions. For citizens of China, such a scenario is legally impossible.
Fundamentals of the PRC Citizenship Law
The legal foundation regulating this issue is the Law on Nationality of the PRC, adopted in 1980. It is concise and extremely clear in its wording.
The main postulate is contained in Article 3:
“The People’s Republic of China does not recognize dual citizenship for any Chinese citizen.”
This article is the cornerstone of the entire migration policy of the country. The logic is simple: a person cannot be loyal to two sovereigns. The Ministry of Public Security (MPS), responsible for immigration and internal registration, strictly adheres to this norm. Any citizen of the PRC who acquires a foreign passport, from Beijing’s point of view, commits an act incompatible with their Chinese status.
What happens when obtaining a second passport
Many mistakenly believe that to renounce PRC citizenship, one must submit an application or go through a procedure. The Citizenship Law works differently — it operates automatically.
The key provision is contained in Article 9:
“Any citizen of China who has permanently settled abroad and has been naturalized as a foreign citizen or acquired foreign citizenship voluntarily automatically loses Chinese citizenship.”
What does this mean in practice? Let’s consider the most common scenario: does China allow dual citizenship with the USA?
A citizen of China moves to the USA on a work visa, obtains a Green Card (permanent resident status), resides for the required period, and submits documents for American naturalization. At the moment when they take the oath of allegiance to the United States and receive the naturalization certificate, they automatically (according to the meaning of Article 9) cease to be a citizen of China.
His Chinese citizenship is not “suspended.” It is annulled. He cannot “choose” which one to keep. Chinese law makes the choice for him. The same applies to naturalization in Canada, Australia, Germany, or any other country granting its citizenship.
How Beijing Fights Against “Secret” Second Passports
Some try to bypass the system. They naturalize abroad but do not report this to the Chinese authorities, keeping their Chinese passport and, more importantly, “хукоу” (hukou) — the internal registration system that provides access to social services, property, and education in China.
However, the Chinese authorities are actively identifying such individuals. Facial recognition technologies at borders, analysis of travel data, and requirements during passport renewals make concealing second citizenship increasingly difficult.
If the fact of having a second passport (for example, an American one) is revealed, consequences follow immediately. China does not recognize this status. The authorities do not consider the person a “dual citizen”; they consider them a former citizen of China who has violated the law.
The consequences for those caught hiding a second citizenship are quite serious. Here is just the main list of what awaits the violator:
- Forced cancellation of hukou: This is the main blow. Without hukou, a person loses resident status in their native city, which entails the loss of access to local schools, medical insurance, and pension savings;
- Annulment of a Chinese passport: The document is confiscated or declared invalid. Departure from China or entry into it with this passport becomes impossible;
- Visa requirement: To visit China (even for a family visit), a former citizen will have to apply to the Chinese consulate in the country of their new citizenship (for example, in the USA) and request a Chinese visa as a foreigner;
- Restrictions on ownership: Owning real estate or conducting business in China for foreigners is regulated much more strictly than for citizens.
Special cases: Hong Kong, Macau, and children born abroad
The situation with dual citizenship China becomes less straightforward when it comes to special administrative regions and children born in mixed families.
Hong Kong and Macau
Due to their colonial past (Britain and Portugal), the residents of Hong Kong and Macau are in a unique legal position. Many of them have foreign passports (for example, the British BNO or a Portuguese passport granting the right to EU citizenship). Does China recognize this? Both yes and no.
China considers all ethnic Chinese residing in Hong Kong and Macau exclusively as citizens of the PRC. Foreign passports (British, Portuguese, Canadian) are regarded by Beijing only as “travel documents.”
This has an important practical consequence: while on the territory of China (including Hong Kong and Macau), such a person cannot count on consular protection from the United Kingdom or Portugal. For Beijing, they are Chinese. However, they are allowed to have these documents and use them for international travel.
Children born abroad
Difficulties also arise with children. Article 5 of the Citizenship Law states:
“A child born abroad, whose parents (or one of the parents) are citizens of China and have not permanently settled in this country [do not have permanent residency/Green Card], has Chinese citizenship.”
Let’s consider an example: can you have dual citizenship of the USA and China at birth?
- Scenario 1: Parents (citizens of the PRC) are temporarily studying in the USA (for example, on an F-1 visa) and have a child. According to US laws, the child is a US citizen (jus soli). According to Article 5 of the PRC Law, the child is also a citizen of China (since the parents have not “settled” there).
- Result: A “conflict of citizenships” arises. China does not recognize the American citizenship of this child. They will not be given a Chinese visa (it is not placed in the passport of “their own” citizen). Instead, they will be issued a special Chinese “Travel Document” for entry into the PRC.
- Scenario 2: Parents (citizens of the PRC) live in the USA and already have a Green Card (permanently settled). If they have a child, the child will be a citizen of the USA, but, according to Article 5, will not obtain PRC citizenship.
Why does Vanuatu attract investors from the PRC
So, China dual citizenship is a dead end. Naturalization in the USA, Canada, or Europe inevitably leads to the loss of Chinese status. But the need for global mobility, asset diversification, and a “plan B” among wealthy Chinese has not disappeared.
The Chinese passport, despite progress, still requires visas for entry into many key regions. This creates barriers for business and personal travel. Here, citizenship by investment (CBI) programs come into play, and Vanuatu is one of the most sought-after options.
It is important to understand: this is not the legalization of dual citizenship in the eyes of Beijing. This is the acquisition of a second passport as a mobility tool, which is legally structured differently from naturalization. Chinese law (Article 9) refers to “naturalization” and “permanent settlement.” The Vanuatu CBI (Development Support Program) does not require either.
For a Chinese investor, this is a fundamentally different path. Instead of 5-10 years of living in the USA, they obtain Vanuatu citizenship in 2-3 months in exchange for a non-refundable contribution (donation) to the country’s economy.
The process offers several strategic advantages for PRC citizens seeking to bypass strict restrictions:
- Speed and confidentiality: The process is completely remote and takes only a few months. Vanuatu does not notify China about granting citizenship.
- The absence of residency requirements: The investor does not need to “permanently settle” abroad, which allows them (albeit with legal risks) not to fall under the direct wording of Article 9.
- Global mobility: The Vanuatu passport provides visa-free access to more than 100 countries.
- Tax optimization: Vanuatu does not tax global income, inheritance, or capital gains.
An investor from China continues to live in the PRC. He uses his Chinese passport for all domestic operations and for returning home. When traveling to Europe, he leaves China with his Chinese passport (for example, to Dubai or Istanbul), and from there flies to the EU using a Vanuatu passport.
This is associated with risk. If Chinese border guards discover a second passport, the Chinese document will most likely be annulled. But for many investors, the advantages (freedom of movement, financial security) outweigh these risks.
Get a second passport with us
China’s dual citizenship policy remains one of the strictest in the world. Beijing makes no exceptions and actively combats the concealment of second passports. An attempt to naturalize in the USA or any other country will guaranteedly result in the automatic loss of Chinese citizenship.
Under these conditions, programs like Vanuatu citizenship do not offer “dual citizenship” in its classical sense. They offer a tool — a second passport obtained through investment, not naturalization. This is a strategy for enhancing global mobility, which requires thorough legal planning and full awareness of the associated risks.
If you are considering ways to diversify your assets and gain global mobility, contact us for a confidential assessment of your situation and discussion of legal ways to obtain second citizenship.