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Passports: What are the post-Brexit rules for dual-nationals travelling in Europe?

People who have more than one citizenship often hold multiple passports, so what does this mean for crossing borders? Here's what you should know.

A person holds a German and British passport.
A person holds a German and British passport. Photo: picture alliance / Britta Pedersen/dpa-Zentralbild/dpa | Britta Pedersen

For many readers of The Local, gaining citizenship of the country where they live helps them to feel more settled – but there are also travel benefits, including avoiding the long ‘non EU’ queue when coming back into the Schengen zone.

But this week the problems associated with travelling while holding dual citizenship came to light, leaving many people wondering what they should know when they are entering different countries.

Put simply – which passport should you use? And do you have to carry both with you?

Financial Times journalist Chris Giles tweeted that the UK Border Force “detained” his dual-national daughter while she was travelling from France into the UK with her German passport – and not her British one. 

He went on to say that UK border guards released his daughter. According to Giles, the border staff said she should have had both passports with her “and asked why she was travelling on her German one”.

The rules on dual-nationality have not changed, but now that the UK is not in the EU, there are strict rules on non-Brits who enter the country (and vice-versa) which has made it trickier for travel.

For instance, UK nationals receive a stamp in their passport when entering Schengen member states because they are only allowed to stay up to 90 days within an 180 period (unless they have a visa or residency card).

READ ALSO: Brexit: EU asks border police not to stamp passports of British residents 

People coming from the EU to the UK can generally visit as a tourist for up to six months without a visa – but are not allowed to carry out any work while there.

So which passport should you show?

The first thing to be aware of is there are no specific rules on travelling with more than one passport. 

Travellers can choose to use whichever passport they prefer when going to a country. 

But one thing to note is that it’s worth using the passport that is best suited to your destination when travelling there. Each country has its own set of immigration and visa rules that you’ll need to research closely.

It could be that one passport is better suited for your trip – and you may be able to avoid visa requirements.  

READ ALSO: How powerful is the German passport?

In the case of the UK, many people are still getting to grips with the different rules that apply because it’s not in the EU anymore.

A question submitted to the Secretary of State for the Home Department in September 2021 provided some insight into this issue. 

The question from Labour’s Paul Blomfield asked what steps the UK government “is taking to enable dual UK and EU citizens to travel to the UK on an EU member state passport without having to further prove their UK citizenship?”

The Conservatives Kevin Foster said: “Border Force Officers examine all arriving passengers to establish whether they are British citizens, whether they require leave to enter or if they are exempt from immigration control.

“Where the passenger claims to be British, but does not hold any evidence of British citizenship, the officer will conduct all relevant checks to satisfy themselves the passenger is British.

Border control at Hamburg airport.

Border control at Hamburg airport. Photo: picture alliance/dpa | Christian Charisius

“When dual nationals who are eligible to use e-gates travel to the UK, they will enter via the e-gates without being examined by an immigration officer.

“We recommend all dual nationals, including EU citizens, travel on their British passport or with evidence or their British citizenship to minimise any potential delay at the border or when commencing their journey.”

The Local contacted the UK Home Office to ask if there was any official advice. 

A spokesman said: “An individual can present whichever passport they desire to enter the UK, however they will be subject to the entry requirements associated with the nationality of the passport they present.”

They said anyone who is looking for more information should check out guidance on entering the UK and on dual nationality.

In short, if you present a German passport on entry to the UK you will be treated the same as any other German citizen – which can include being quizzed about your reasons for visiting the UK – as border guards have no way of knowing that you are a dual-national. 

Do I have to carry both passports?

There’s no rule requiring you to have both passports, but you won’t get the benefits of a British passport (entry into the UK without questions) if you don’t show it.

Likewise if you are a French-British dual national and you enter France on your UK passport, you will need to use the non-EU queue and may have your passport stamped.

Should I think about anything else?

An important thing to remember is that if you apply for a visa and register your passport details, the same passport has to be used to enter the country. 

It could also make sense to travel with both passports, just in case. 

However, note that some countries – like the US – require that US nationals use a US passport to enter and leave the States even if they are dual nationals. 

In general, it’s best to use the same passport you entered a country with to depart.

The rules and systems are different depending on the country. But many countries require people to show their passport when leaving – and they will either stamp or scan the passport – this is how authorities know that a foreign visitor hasn’t overstayed their time in the country. 

So if your passport is checked as you leave the UK, you should show the one you arrived with, just to ensure there is a record of you arriving and leaving.

However as you enter France/Germany/other EU destination, you can show your EU passport in order to maximise the travel benefits of freedom of movement.

Member comments

  1. You mentioned above that “The first thing to be aware of is there are no specific rules on travelling with more than one passport. Travellers can choose to use whichever passport they prefer when going to a country.”

    However, many countries require you to enter with the passport of that country if you are a citizen of that country.

    E.g. from this official US government site: https://travel.state.gov/content/travel/en/legal/travel-legal-considerations/Advice-about-Possible-Loss-of-US-Nationality-Dual-Nationality/Dual-Nationality.html

    “U.S. nationals, including dual nationals, must use a U.S. passport to enter and leave the United States.”

    1. Hi Steven, yeah we mention the US rule further down in the article – but this is focusing on travel between the UK and EU for dual UK/EU nationals

  2. If you have a Swedish and UK passport, leave Sweden with your Swedish passport and enter Britain with your UK one. On return, leave Britain with your UK passport and enter Sweden with your Swedish. Simple. And if you travel to elsewhere in Europe, use your Swedish passport, unless you love queuing!

  3. As a dual EU/UK national I’d understood best practice is now to use the EU passport when entering and leaving the EU and the Uk passport when entering and leaving the Uk. A pain to carry both but allows a quicker passage, ensures the systems in each country register who’s coming and going and avoids issues with visas etc. Usually no problems doing this, but recently at Eurostar terminal where the UK and French controls are next to each other a member of staff tried to stop me doing this. Said I had to leave the Uk and enter EU with the same passport. Another then stepped in and said it was fine… so it seems clarification would indeed be helpful!

  4. It’s a no brainier really and the journalist from the FT should simmer down.

    It’s obvious that they must go by the passport presented. I think reasonable to ask why you didn’t use your UK passport.

    My partner is dual German/British.

    By ferry from Caen to Portsmouth.

    UK at checkin (booking on UK)
    German at French control.
    UK at Portsmouth

    Dual nationals are so lucky, take all your passports 🙂

  5. Those with an Irish passport just need to carry that one: the benefits of an EU citizen entering France and unrestricted UK access due to the Common Travel Area.

  6. I agree with Steven above – many countries require that you enter the country of your nationality on that passport. For example Canadians CANNOT enter Canada on anything other than a Canadian passport. But when travelling back to Ireland, I need to use my Irish passport meaning that, as far as Canada know, I am still there, drifting around without a job or home.

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FACT CHECK: Do residents still need Covid documents to travel back to Spain?

Spain has dropped most Covid-19 restrictions, but do foreign residents in Spain travelling back to the Spanish territory from an EU or non-EU country still need to show proof of vaccination, testing or recovery in September and October 2022?

FACT CHECK: Do residents still need Covid documents to travel back to Spain?

The Covid-19 pandemic no longer dominates daily life or travel in Spain.

In recent days, the Spanish government has scrapped the Spth health control form for all travellers and soon it will stop carrying out temperature and visual checks on non-EU arrivals

That’s not to say that all of Spain’s Covid-19 travel restrictions have been lifted. Non-EU tourists still need to show Covid-19 documents to be allowed into Spain, and on planes that are bound for Spain passengers must wear face masks

But how about for foreign residents in Spain who are travelling back to the Spanish territory after a holiday abroad or a visit to their country of origin? 

For example, would a UK or US national who legally resides in Spain and who has just spent a couple of weeks back in their country of origin need to show proof of vaccination, testing or recovery when they arrived back in Spain?

The question is not so much whether you’re a resident in Spain, but rather which country you’re travelling to Spain from. 

If it’s a non-EU/Schengen country, then you technically have to show Covid documents. If you’re completely unvaccinated or more than 270 days have passed since your last Covid-19 vaccine, you’ll need to present proof of a negative PCR or antigen test. That’s irregardless of whether you’re a Spanish national or foreign resident in Spain. 

Do residents still need Covid documents to travel back to Spain
Screenshot from travelsafe.spain.info showing how an unvaccinated UK national who is resident in Spain needs to get a Covid test before arrival in Spain if travelling from a non-EU country such as the United Kingdom.

If on the other hand you’re returning to Spain from another EU/Schengen country, then you will not have to show a Covid-19 certificate or equivalent document. Again, that’s irregardless of whether you’re a Spanish national, a resident of Spain (EU or non-EU national) or even a non-EU tourist who was already in the EU/Schengen Area before visiting Spain.

do residents need covid documents to travel back to spain
Screenshot from travelsafe.spain.info showing how an unvaccinated US national who is resident in Spain doesn’t need to show Covid documents or get tested before arrival in Spain if travelling from another EU country.
 

This is according to Spain’s travelsafe.spain.info website, where on its homepage section there is a section which allows you to choose “origin” (city/country you’re travelling from), your nationality and your vaccination status. 

When you fill in the categories and click through, it tells you whether or not you need to get a Covid-19 test. 

It also states your country of residence, even though you’re not given the option of filling this in (although, we reiterate, residence isn’t what counts). 

Are Spanish airport officials still rigorously checking the Covid documents of arrivals from outside of the EU/Schengen Area? No. 

Whether or not you get asked is up to chance. Some travellers have said they have been asked to show proof, whereas others have not.

“I went to the United Kingdom, vaccinated with the third dose more than 290 days ago (20 days over), so I needed a negative diagnostic test to return to Spain. I got a PCR in London, it cost me €80, and in Barcelona I didn’t even get asked for it”, one Spanish national wrote on Twitter.

Keep in mind as well that if you’re travelling back to Spain from a non-EU country, but you have a layover in another EU/Schengen country first before reaching Spain, it will be that country’s rules that apply in terms having to show Covid-19 documents. You will already have entered the EU/Schengen Area before reaching your final destination (Spain), so you will not be asked to provide proof of Covid certificates when you land in Spain.

Is there a risk of being refused entry as a resident if you don’t have any Covid-19 documents upon arrival in Spain and you get asked to provide them? 

The worst-case scenario is that you will be required to take a Covid test there and then at the airport. Spain has allowed legal Spanish residents (whether they’re EU or non-EU nationals) to return home to Spain even at the worst stages of the pandemic when travel was heavily restricted.

So, if you’re travelling back to Spain as a resident from a non-EU country, what Covid proof do you technically have to be able to show? Only one of the following:

  • A Covid-19 vaccination certificate – Your vaccination status must meet the Spanish authorities’ validity period requirements. If more than 270 days have passed since your initial vaccination, you need to show proof of a booster shot.
  • A negative Covid-19 test – This should be either a PCR taken within 72 hours prior to departure, or an antigen test, taken within 24 hours prior to departure. 
  • A recovery certificate – This must be dated within the last six months. You can use a medical certificate or recovery record to prove your Covid-19 status. 

You can prove the above by showing a digital or paper certificate issued by the relevant authorities of the country in which you were vaccinated. If you were vaccinated in Spain, this can be Spain’s EU Digital COVID Certificate.

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