The laws of China, United States (U.S.), and Poland have many similarities and differences when it comes to acquiring citizenship. The citizenship system of each country reflects the history and culture of each place. In all these cases, citizenship may be acquired through birth or naturalization, and there are various benefits that come with citizenship in each country.

Section I: Ways to Acquire Citizenship

1. Birth

Countries may grant citizenship based on ancestry or where a person was born. China and Poland follow the principle of citizenship through bloodline, meaning that citizenship is based on ancestry, while the U.S. follows the principle of “right of soil,” meaning that citizenship is based on where you were born.

A person born in China automatically has Chinese nationality at birth if one or both parents is a Chinese national. Every person born in the U.S. or in a U.S. territory is automatically a U.S. citizen at birth. A person born in Poland automatically has Polish citizenship if one of their parents is a Polish citizen. Additionally, a person may acquire citizenship by descent if they have an ancestor (parent, grandparent, or great-grandparent) who had citizenship and lived in Poland after 1920.

2. Naturalization

Most countries allow you to become a naturalized citizen after you have lived in the country for a while and you meet certain standards for citizenship.

You can acquire citizenship in China if you are a near relative of a Chinese national, you have settled in China, or you have another legitimate reason. You must be willing to abide by China’s constitution and laws.

You can become a naturalized U.S. citizen if you are at least 18 years old and you have lived in the U.S. as a lawful permanent resident for the required amount of time. You must be willing to take an oath of allegiance to the U.S.

To acquire Polish citizenship, you must have lived in Poland for the required amount of time, have legal title to occupy residential premises, and have stable and regular income in Poland.

3. Application Process

Generally, in China, the U.S., and Poland, a person applying for citizenship will submit their documentation and a country official will either grant or deny the application. Officials may deny you citizenship if there is reason to believe that there your application is a threat to the national interest or public security and order.

Section II:       Questions about Citizenship

1. Can I be a citizen of two different countries at the same time?

Some countries allow you to hold dual citizenship, meaning that you can be a citizen of two or more countries simultaneously. However, other countries reject this possibility.

China strictly rejects the possibility of dual citizenship for its citizens. When a Chinese citizen willingly becomes a citizen of another country, they automatically lose Chinese citizenship. The United States and Poland recognize dual citizenship.

2. Do I need to know the language to be a citizen?

A command of the country’s language of which you are a citizen means more than just speaking with people, it is also a way to connect with the culture and people who surround you. China, the U.S., and Poland all require naturalized citizens to have a command of the Chinese, English, or Polish language, respectively.

3. Does being a citizen mean I can vote?

Voting is an important part of being a citizen. In China, the U.S., and Poland, being a citizen means that you can run for office and vote in elections. Since being a citizen of Poland means being a citizen of the European Union, Polish citizens can also vote for European Parliament. It should be noted that in both the U.S. and Poland, non-citizens may be able to vote in local elections.

4. Can my family member also become a citizen?

Naturalization as a citizen of a country may bring benefits for your family members regarding their own citizenship or rights to residency. In China, spouses and children of citizens are eligible for a residence permit. Children of naturalized citizens in the U.S. can also become citizens. As a U.S. citizen, you can also petition for your family members to join you. As a Polish citizen, your foreign close family members may be eligible for residency.

5. Where can I travel?

Being a citizen of a country means passport eligibility. The “power” of a passport may depend on the wealth, stability and foreign relations of a country. At the time this post was written, you can travel without a visa to 95 countries with a Chinese passport, 170 countries with a U.S. passport, and 174 countries with a Polish passport. Being a citizen of Poland means freedom to live or work in any Member State of the European Union.

6. Are there any social benefits to being a citizen?

Citizenship status brings social benefits from the systems within each country. Social benefits include state-sponsored programs and other benefits available just to citizens or lawful residents.

Chinese citizens are assigned a hukou, either rural or urban, which determines the type of social welfare they receive from the state. If you have a rural hukou, you are allocated a housing plot with land for farming. If you have an urban hukou, you are provided with a variety of government services, including healthcare, education, unemployment benefits, and subsidized housing. Chinese citizens enjoy healthcare either through their employer or through their residency.

In the U.S., various social programs are available to citizens, including public education and social security benefits, and additional programs are available to those with financial need, such as food assistance, subsidized healthcare and housing assistance.

Polish citizens have access to public healthcare, education, and other social services available in the territory. Another benefit of Polish citizenship is that it grants you citizenship to the European Union. As an EU citizen, a person may live and move within the EU without discrimination based on nationality. Citizens may also access healthcare anywhere in the EU if they meet certain requirements.

7. Are there any employment benefits to being a citizen?

An important part of being a citizen of a country is working and contributing to your community. Each country provides different benefits to workers.

Employers and employees in China contribute to mandatory social insurance for citizens, which covers pension, work injury, unemployment, maternity insurance, and more.

Some financial opportunities and work benefits in the U.S. are only available to citizens and select government jobs are only available to citizens. Being a citizen of the U.S. is often linked to higher earning capacity.

Citizens of Poland, as citizens of the EU, have the freedom to work in any Member State without obtaining a work permit. They benefit from the protections and rights that citizens of those states enjoy, including career advancement, competitive pay, and access to social security benefits. The European Union also has a favorable business market for entrepreneurs, and there are several programs and resources to support EU business ventures.

Conclusion

Each country’s citizenship system gives a look into the culture and laws of the country. What might be an interesting factor, is also how often people are actually granted a citizenship. In Poland (population 36.5 million), about 10,000 people obtain Polish citizenship every year. In the U.S. (population 340 milion), the number of citizenships issued annually, through naturalization, varies but generally averages around 700,000 to 800,000. China (population exceeds 1.4 billion) issues very few citizenships annually. While the data is not public, it is estimated that each year not more than 1000 people are granted citizenship. Without a doubt, China is the country whose citizenship is the most difficult to obtain, among the countries discussed here.

Understanding how different countries regulate and treat citizenship is key to understanding your own rights as a citizen in your country.

 

Note: In China, the terms “nationality” and “citizenship” are used interchangeably, but this is not the case in Poland or the United States. For this reason, the word “citizen” is used throughout this article.