Naturalisation by Association in Ireland: Exploring the New Citizenship Guidelines

Applications for Irish nationality and citizenship are governed by the Irish Nationality and Citizenship Act 1956, as amended. The Act outlines who qualifies as an Irish citizen by birth or descent and sets out the criteria for individuals seeking to naturalise.

Applications for naturalisation must meet several different criteria, including the requirement that an applicant must be legally resident in the state for a minimum of five of the last nine years. They must also be of good character, not have spent too much time outside of the state and provide specific documentation to prove their residency. If, however, an individual has a connection to the Irish state through descent, blood or affinity, the Minister may waive some of the aforementioned criteria.

As stated under sections 16(1)(a) and 16(1)(b) of the Act, the Minister may, in their absolute discretion, grant an application for a certificate of naturalisation, although the conditions for naturalisation (or any of them) are not met, where the applicant is of Irish descent or Irish associations. Until recently, there was very little guidance for those wishing to apply for naturalisation via association on what would be considered sufficient evidence to prove an Irish association.

Updated guidelines

At the beginning of April 2025, the Department of Justice published guidance for those applying for naturalisation and seeking to rely on associations to waive one or more of the naturalisation criteria. The department will now process these applications in the following five steps.

1. 1. 1. Determine whether an applicant is a person of Irish descent or Irish associations
      2. Determine the statutory naturalisation condition(s) that may be considered for waiving
      3. Assessing the relative strength of the case
      4. Make a decision
      5. Communicate the decision

The department will first determine whether an individual is of Irish descent or Irish associations. Irish descent refers to anyone who is a direct lineal descendant of a person who is, or was at the time of their death, an Irish citizen. Irish associations refer to anyone who may be related by blood to an Irish citizen, such as the parent of an Irish citizen child.  They may also be related through marriage, civil partnership or adoption. 

The second step will determine which of the statutory conditions the applicant is asking the Minister to waive. For many applicants looking to pursue an application via associations, this will relate to the requirement to have legal residency in Ireland for five of the last nine years.

After ascertaining which conditions the applicant is seeking the Minister to waive, the department will assess the relative strength of the application. The guidelines now provide four categories of information/ documentation that will be assessed:

1. 1. 1. Experiential connection to the State
      2. Family connection to the State
      3. Cultural connection to the Sate
      4. Establishment in the State

Much like the recent adoption of a points system for supporting documentation for applications based on residency, there is now a points system which applicants must satisfy before their applications will be considered by the Minister. They have provided a table for each category stated above with the accepted documentation or evidence. They have also indicated the points that each piece of evidence has been awarded. Applicants must meet at least 50% or more of total available points in at least two or more of the aforementioned categories. 

After assessing all available information, the Minister will make a decision as to whether the applicant will be granted Irish citizenship. It is important for applicants to understand that even if they meet the above criteria and have the requisite points, there is still no guarantee the application will be granted.

The Immigration Service Delivery has stated “While being of Irish descent or Irish associations is a necessary prerequisite for consideration under these guidelines, it is in itself not sufficient to ensure the waiving of any statutory naturalisation conditions. The Minister will exercise their absolute discretion in determining applications under section 16(1)(a) and 16(1)(b) of the Act (as amended).”

How can Fragomen help with the Irish naturalisation process?

While the new guidelines clarify what information and documentation may be required for an applicant, there is still a significant weight afforded to residency in Ireland. Those who have not lived in Ireland for several years may find it difficult to satisfy 50% of the points required in a number of categories.

While there is some optimism and possible opportunity here, for those with great-grandparents who do not meet the foreign birth registration requirements, and do not currently reside or previously have resided in Ireland, an application for naturalisation based on associations may still be outside of their reach.

Fragomen’s Ireland team is available to assess individual circumstances and determine whether the new guidelines may offer a viable pathway to Irish citizenship through naturalisation. This includes individuals who narrowly missed eligibility for citizenship through Foreign Birth Registration because their parent(s) did not register their birth with the Department of Foreign Affairs prior to their birth, as required under the relevant legislation.

Need to know more?

For further information on naturalisation requirements, please contact the Irish Personal Immigration Services team at [email protected] or the Dublin team at [email protected].

This blog was published on 17 April 2025, and due to the circumstances, there are frequent changes. To keep up to date with all the latest updates on global immigration, please subscribe to our alerts and follow us on LinkedIn, Twitter, Facebook and Instagram.