Membership Security – World Citizen Theory

Why Living Somewhere Must Eventually Open a Path to Political Equality

Imagine a woman who has lived in a country for ten years.

She has worked, raised a family, and built a life there. She believes that after so many years, she should finally be able to apply for citizenship.

But the rules are not so simple.

Some of her years of residence may not count. Her immigration status may not qualify. Even if she becomes eligible to apply, approval may not be assured.

She has spent a decade becoming part of the community. Yet she cannot tell when, or whether, she will become one of its full political members.

How long must she wait?

And who decides whether the years she has already lived there are enough?

When should durable residence open a meaningful path to full political membership?

When Does Living Somewhere Begin to Matter?

A visitor and a long-term resident do not have the same relationship with a political community.

Someone may arrive intending to work for a year, then remain for decades. A career develops, a family forms, and the place that once seemed foreign becomes home.

Yet the law must decide which years of residence count toward citizenship, which legal statuses qualify, and what additional conditions apply.

Such rules are necessary. But they can also fail to recognize the relationship a person has developed with the community.

The question is not simply whether residence matters. It is how political institutions should recognize that residence when deciding who may become a full member.

Different Countries, Different Answers

Many countries already recognize residence as an important basis for acquiring citizenship.

Germany reduced its ordinary residence requirement for naturalization—the process of acquiring citizenship after birth—from eight years to five in 2024. A special three-year route was abolished in October 2025.

Five years is now the ordinary minimum, but it does not guarantee citizenship. Applicants must meet other legal conditions.

Canada takes a different approach.

Adult applicants generally need permanent resident status and at least 1,095 days of physical presence during the preceding five years. At least 730 of those days must have been spent as permanent residents, although some earlier lawful residence can count toward the total.

New Zealand generally requires five years of qualifying resident status. Its rules include at least 1,350 days of physical presence during that period and at least 240 days in each twelve-month period.

Other requirements apply in both countries.

Why do these differences matter?

Two people may have lived in a country for the same number of years, yet only one may qualify to apply because of their legal status or the way their days of residence are counted.

There is no single residence period that democratic countries universally recognize as sufficient.

And choosing a number is only part of the problem.

Even after someone has lived somewhere long enough to apply, what makes the route to membership fair and meaningful?

A Path Must Be More Than a Promise

The European Convention on Nationality, adopted in 1997, offers one starting point.

It requires countries bound by the Convention to provide a possibility of naturalization for people who lawfully and habitually reside in their territory. Under Article 6(3), the required period of residence before applying must not exceed ten years.

This does not mean everyone becomes a citizen after ten years. Countries may impose other lawful conditions, and not every European country is bound by the Convention.

Still, it recognizes that established residence matters when access to citizenship is considered.

The Convention also addresses how applications are handled.

It requires nationality applications to be processed within a reasonable time. It generally requires written reasons for decisions and provides for administrative or judicial review. It also addresses application and review fees.

These protections do not guarantee approval.

They help prevent the opportunity to apply from becoming an empty promise.

Imagine satisfying the stated residence requirement, only to receive a refusal without an explanation. How could the applicant know whether the law had been applied fairly?

Requirements concerning language, knowledge of institutions, financial circumstances, and conduct may serve legitimate purposes.

But those purposes must justify the burdens they impose.

Someone who has worked and raised a family in a community for many years should not face arbitrary obstacles merely because the law still classifies that person as foreign.

Nor does a better naturalization procedure solve everything. A meaningful route to membership also requires opportunities to enter, establish lawful residence, and remain securely enough to build a lasting political relationship.

When the Voters Decide Who May Join

The difficulty becomes especially clear when existing citizens decide whether particular residents may become citizens.

Consider the Swiss municipality of Emmen.

On March 12, 2000, voters decided naturalization applications involving 56 people.

Eight applicants from Italy were approved. The remaining applicants, mostly from the former Yugoslavia, were rejected.

The decisions were made through a popular vote.

At first glance, this might seem like a direct exercise of democratic self-government. Existing members were deciding who could join their political community.

But the results raised a deeper question.

Could a majority reject individual applicants without explaining its reasons? Could a vote justify discrimination based on origin?

In 2003, the Swiss Federal Supreme Court ruled that the challenged decisions violated constitutional protections against discrimination and the obligation to provide reasons.

The Court did not establish an unconditional right to citizenship.

It held that naturalization decisions must respect constitutional rights, even when voters make those decisions directly.

That distinction matters.

Democracy gives a political community authority to govern itself. But not every decision approved by a majority is necessarily legitimate.

The Emmen case reveals a problem at the boundary of political membership.

Existing citizens have legitimate authority to establish membership rules. Yet those seeking to join also have rights.

Who determines the boundary—and what limits must govern that decision?

Who Decides When Residence Is Enough?

The question extends beyond Switzerland.

Existing citizens generally choose the representatives who establish citizenship laws. Long-term residents may live under those laws for years without participating in the elections that shape them.

The World Citizen framework distinguishes Hand Democracy, concerning collective democratic self-government, from Foot Democracy, concerning meaningful political-community choice.

Neither gives one side unlimited authority over the other.

A community may establish legitimate conditions for membership. But those conditions must respect the rights and legitimate claims of people seeking to join.

The Emmen case illustrates a minimum requirement: democratic decisions about membership must remain subject to equality and fair procedure.

The Same Five Years, Different Choices

The number of years required for naturalization can conceal important differences.

Germany and Japan illustrate this.

Germany’s ordinary residence requirement is five years. Under its 2024 reform, German law generally permits people to retain another nationality when becoming German.

Japan also generally requires five years of continuous domicile.

But naturalization requires permission from the Minister of Justice. Meeting the statutory conditions does not guarantee approval.

Japan also generally requires applicants to lose their previous nationality when acquiring Japanese citizenship, subject to limited exceptions.

The same residence period can therefore lead to very different choices.

In one country, a person may join a new political community while retaining citizenship in the old one, where both countries’ laws permit it.

In another, acquiring new citizenship may require giving up an existing nationality.

That decision may affect family relationships, political rights, and the possibility of returning to the country of origin.

Countries may have reasons for adopting different rules. Those reasons deserve examination.

But a five-year residence requirement alone tells us little about what prospective members must actually give up or prove.

A meaningful route to membership depends on what people must do to complete it, not merely on how long they must wait.

Membership Must Be Secure

Even long-term, lawful residence does not necessarily create full political membership.

A permanent resident may have the right to live and work in a country without being able to vote in national elections. Some countries permit noncitizens to vote without granting them all the protections associated with citizenship.

Secure residence, electoral participation, and full membership are not identical.

The World Citizen framework therefore connects Resident Sovereignty with Resident Equality and Membership Security.

Resident Sovereignty holds that durable residence, rather than inherited nationality, is the primary basis of ordinary political membership.

Resident Equality concerns the equal standing of full political members.

Membership Security requires that a full member not be removable under ordinary immigration law merely because that person also holds another nationality.

This is distinct from exceptional questions about nationality obtained through fraud.

The principle is that someone who has become a full political member should no longer remain an ordinary immigration-law outsider.

Without that security, political equality remains incomplete.

Must Everyone Become a Citizen?

A meaningful opportunity to become a member does not mean everyone must take it.

Some residents may wish to retain their original citizenship. Others may want both nationalities. Some may have reasons to postpone naturalization.

Political freedom includes the ability to make those choices.

But there is a difference between choosing not to become a citizen and being unable to do so under unnecessarily burdensome rules.

A person should not have to abandon an existing political relationship without sufficient justification merely to acquire another.

Nor should someone remain indefinitely excluded from full membership because a supposed pathway exists only on paper.

The aim is not compulsory citizenship.

It is meaningful access to secure and equal political membership.

No Universal Number

Return to the woman who has lived in another country for ten years.

Perhaps she has satisfied a residence requirement. Perhaps the law counts only some of those years. Perhaps she must still meet other conditions.

What should matter is not simply whether a particular number has passed.

It is whether the institutions governing her life recognize the enduring relationship she has established with the community.

The World Citizen framework does not prescribe one universal period of residence for every political community.

But it rejects indefinite exclusion merely because someone was born elsewhere.

Existing members may establish legitimate conditions for joining. Those conditions must remain open to justification, and the opportunity to acquire membership must be real.

A resident should be able to understand what is required, pursue the process under fair conditions, and challenge an unjust decision.

After becoming a full member, that person’s political standing should be secure.

The question is not simply how long someone must wait.

It is who decides, by what rules, and with what protection against arbitrary exclusion.

Residence should be able to become belonging—not merely in principle, but through institutions that make political equality attainable.

References

Council of Europe, European Convention on Nationality, ETS No. 166 (1997), especially Articles 6 and 10–13. https://www.coe.int/en/web/conventions/full-list?module=treaty-detail&treatynum=166.
German Federal Government, “Staatsangehörigkeit frühestens nach fünf Jahren,” October 30, 2025. https://www.bundesregierung.de/breg-de/suche/kabinett-einbuergerung-2350620.
Immigration, Refugees and Citizenship Canada, “Physical Presence Calculator and Requirements.” https://eservices.cic.gc.ca/rescalc/resCalcStartNew.do?lang=eng.
New Zealand Government, “Presence in NZ Requirements.” https://www.govt.nz/browse/passports-citizenship-and-identity/nz-citizenship/requirements-for-nz-citizenship/presence-requirements/.
Swiss Federal Supreme Court, BGE 129 I 217, judgment of July 9, 2003, concerning naturalization decisions in Emmen. https://relevancy.bger.ch/php/clir/http/index.php?highlight_docid=atf%3A%2F%2F129-I-217%3Ade&lang=de&type=show_document.
Japan, Nationality Act (Act No. 147 of 1950), especially Articles 4 and 5. https://laws.e-gov.go.jp/law/325AC0000000147.
Ministry of Justice of Japan, “Nationality Q&A,” particularly the conditions for naturalization. https://www.moj.go.jp/MINJI/minji78.html.