Does Brazil Allow Dual Citizenship? Country-by-Country Guide (2026)

The moment usually arrives in a government office abroad. A Brazilian engineer in Lisbon, papers approved, is minutes from taking the Portuguese oath — and freezes on a question the internet answers in five contradictory ways: am I about to lose my Brazilian citizenship? Somewhere else, an American who has built a life in Curitiba hesitates over the Brazilian naturalization application for the mirror-image reason: will Brazil make me give up my US passport?

Both fears are reasonable, because both used to have teeth. For decades, Brazil’s Constitution said that a Brazilian who voluntarily naturalized elsewhere lost Brazilian nationality, subject to exceptions that generated endless litigation — including one famous extradition case that turned entirely on an American naturalization. People structured their lives around that risk. Much of what is written online still describes it as current law. It is not.

The thing this guide turns on is that “does Brazil allow dual citizenship?” is really two questions wearing one coat. Brazil’s side of the answer changed decisively in October 2023 and is now one of the most permissive in the world: you lose Brazilian nationality essentially only if you ask to lose it. The side that still bites is the other country’s law — each state decides for itself whether its nationals may hold a second passport, and those answers range from complete indifference to automatic loss. Once you separate the two questions, the confusion dissolves.

This is educational content prepared by the ZS Advogados Associados team for Brazilians naturalizing abroad, foreigners naturalizing in Brazil, and families holding — or about to hold — more than one passport. It explains the 2023 constitutional change, who decides what, whether Brazilian naturalization demands renunciation, and how seventeen other countries currently treat dual nationality with Brazil. It complements our guides on dual citizenship in Brazil, the loss and reacquisition of Brazilian citizenship, and Brazilian citizenship by descent.

One framing note before anything else: ZS Advogados advises on Brazilian law only. Every statement in this guide about another country’s nationality rules is factual context assembled from official sources, offered so you know which questions to ask — it is not advice on that country’s law, and it must be verified with counsel licensed there before you act on it.

Does Brazil allow dual citizenship? The direct answer

Yes. Brazilian law fully tolerates dual and multiple nationality. Since Emenda Constitucional nº 131, of October 3, 2023, article 12, §4º of the Federal Constitution recognizes only two ways a Brazilian loses nationality:

1. Judicial cancellation of naturalization — applicable only to naturalized Brazilians whose naturalization is cancelled by court judgment for fraud in the naturalization process or for attacking the constitutional order and the Democratic State; and
2. Express request — the person files a formal, voluntary request for loss of Brazilian nationality with the competent Brazilian authority, and even this is barred where it would result in statelessness (apatridia).

The old rule — loss upon voluntary acquisition of another nationality, with its two carve-outs for foreign birthright citizenship and for naturalizations imposed as a condition of residence or work — was revoked outright. The amendment also added a new §5º: a person who renounces Brazilian nationality by express request retains the right to reacquire their original Brazilian nationality under the law.

Three practical consequences flow from the new text:

• Naturalizing abroad is now legally safe from the Brazilian side. A Brazilian who takes German, American, or Portuguese citizenship keeps Brazilian nationality automatically — no petition, no exception to invoke, no declaration to file in Brazil.
• Loss became essentially unilateral and voluntary. Nobody “accidentally” loses Brazilian nationality anymore. Outside the fraud/attack scenario (which touches only naturalized Brazilians), loss happens only on your own initiative.
• Born-Brazilian status is untouchable except by your own request. Native-born Brazilians (brasileiros natos) cannot have nationality cancelled at all; their only exit is the express request.

Legal basis: Constituição Federal, art. 12, §4º, I and II, and §5º, as amended by Emenda Constitucional nº 131/2023, which expressly revoked the former loss-by-naturalization rule (old art. 12, §4º, II, “a” and “b”).

For anyone who lost Brazilian nationality before the amendment under the old rule, EC 131/2023 did not automatically restore it — but a reacquisition path exists and has become considerably more straightforward in policy terms. Our guide on loss and reacquisition of Brazilian citizenship covers that route; the current procedure should be confirmed before filing, as forms and processing have been updated repeatedly since 2023.

Whose law decides — Brazil’s or the other country’s?

Nationality is the one field of law where every country is sovereign over exactly one thing: its own citizenship, and nobody else’s. Brazil decides who is Brazilian; Japan decides who is Japanese; neither can decide the other’s question. There is no global treaty harmonizing this, so every dual-citizenship situation is the intersection of two independent legal systems.

That yields a simple two-step method that resolves nearly every real case:

1. The Brazilian side — governed by art. 12 of the Constitution. After EC 131/2023: acquiring another citizenship never causes loss; only an express request (or judicial cancellation of a fraudulent naturalization) does.
2. The other country’s side — governed entirely by that country’s law: whether its citizens lose nationality upon becoming Brazilian, and whether it demands renunciation from Brazilians naturalizing there.

Brazil cannot protect you from the second question. A Japanese national who naturalizes in Brazil keeps nothing of Japan’s nationality to keep — Japanese law itself extinguishes it. Conversely, Germany’s 2024 reform means a Brazilian naturalizing there today keeps both, where two years earlier the German side would have demanded renunciation. Same Brazil, different outcomes — because the deciding law was never Brazil’s.

Speak to counsel — in the right country. Questions about keeping US, German, or Japanese citizenship are questions of US, German, or Japanese law. ZS Advogados is licensed in Brazil and advises on the Brazilian side; for the other side, the table below tells you what to verify, and counsel in that jurisdiction tells you whether it holds in your case.

Does naturalizing as a Brazilian require renouncing your citizenship?

No. The naturalization conditions of the Migration Law (Lei nº 13.445/2017) — minimum residence, civil capacity, ability to communicate in Portuguese, absence of relevant criminal convictions, among others — include no renunciation requirement. Brazil does not ask applicants to abandon, or prove abandonment of, their original nationality at any stage, and the naturalization certificate issues regardless of how many other passports the applicant holds.

This makes the Brazilian application one-directional: the only citizenship question it raises is on the origin-country side. An American, Briton, Canadian, Argentine, or Portuguese applicant emerges a dual citizen. A Japanese, Chinese, or Indian applicant emerges Brazilian only — their own country’s law, not Brazil’s, closes the door behind them. Our Brazilian naturalization guide covers the application itself.

Legal basis: naturalization requirements are set out in Lei nº 13.445/2017 (Lei de Migração) and its regulations; none of the statutory conditions requires renunciation of the applicant’s current nationality.

Country-by-country: who tolerates dual nationality with Brazil?

The table below summarizes how seventeen countries currently treat dual nationality in combination with Brazil, in both directions: their citizen naturalizing in Brazil, and a Brazilian naturalizing there. Read it with three warnings. First, these are rules of foreign law — factual context to verify with counsel in that country, not advice. Second, nationality laws move: Germany’s rule flipped in 2024, South Africa’s in 2025. Third, nearly every “yes” and “no” below carries exceptions (military service, public office, minors, prior-permission channels) that a summary cannot hold. Where a rule is genuinely nuanced, the row says so.

Country	Tolerates dual nationality with Brazil?	The rule, in one line	Watch for
United States	Yes	US law does not require choosing; loss of US citizenship requires a voluntary act performed with intent to relinquish	Naturalization oath’s renunciation wording has no effect on the Brazilian side; use the US passport at US borders; citizenship-based taxation
United Kingdom	Yes	Dual citizenship is expressly permitted; no action needed when a Briton naturalizes elsewhere	None specific; check status implications only in edge cases (e.g., diplomatic roles)
Canada	Yes	Canadian law has recognized dual citizenship since 1977; naturalizing abroad causes no loss	Travel document rules; verify particulars for naturalized (vs born) Canadians in rare scenarios
Argentina	Yes	Argentina tolerates multiple nationality; native Argentine nationality is treated as effectively irrenounceable	Verify treatment of naturalized Argentines and any treaty specifics with Argentine counsel
Portugal	Yes	Portuguese law permits dual nationality; acquiring another citizenship does not cause loss	Loss occurs essentially only by voluntary declaration — mirror of Brazil’s rule
Spain	Yes, for Brazilians (Ibero-American exception)	Naturalizing in Spain normally requires declaring renunciation — but nationals of Ibero-American countries, including Brazil, are exempt (Civil Code arts. 23–24); Spaniards acquiring an Ibero-American nationality do not lose Spanish nationality	The exemption is category-specific; non-Ibero-American third citizenships in the stack follow the stricter general rule — verify with Spanish counsel
France	Yes	France permits dual nationality; no loss upon voluntary acquisition of another citizenship	Voluntary release procedures exist but are elective
Italy	Yes	Italian law permits dual nationality; Italians acquiring another citizenship retain Italian nationality	2025 reforms tightened descent-based acquisition rules — a separate issue from dual-nationality tolerance; verify current descent rules with Italian counsel
Germany	Yes — since June 2024	The citizenship-law modernization (amending the StAG) abolished both the renunciation requirement for naturalization and the automatic loss for Germans naturalizing abroad	Acquisitions completed before the reform followed the old loss rule; pre-2024 cases need individual German-law review
Netherlands	Restrictive — exceptions only	Dutch nationality is lost automatically on voluntary acquisition of another, unless an exception applies: born in the other country and living there, five years’ residence there before age 18, or acquiring a spouse/registered partner’s nationality	A Dutch national married to a Brazilian who naturalizes in Brazil typically keeps Dutch nationality; outside the exceptions, loss is automatic — verify with Dutch counsel before applying
Japan	No	The Nationality Act (art. 11) strips Japanese nationality automatically upon voluntary acquisition of a foreign nationality	Applies the moment Brazilian naturalization completes; dual nationals by birth face a separate choice regime
China	No	The Nationality Law does not recognize dual nationality; a Chinese national settled abroad who voluntarily acquires a foreign nationality automatically loses Chinese nationality	Enforcement details vary; treatment of persons residing in China differs — verify with counsel
India	No	Indian citizenship terminates upon voluntary acquisition of a foreign citizenship; the OCI (Overseas Citizen of India) card offers lifelong visa-like status but is not citizenship	OCI carries no voting rights or public office; Indian passport must be surrendered
South Africa	Yes — automatic-loss rule struck down	The Constitutional Court held in 2025 that the Citizenship Act provision causing automatic loss on foreign naturalization is unconstitutional, with retroactive effect — those who lost citizenship under it are deemed never to have lost it	Administrative implementation is recent; affected individuals should confirm documentation steps with South African counsel
Nigeria	Yes, for citizens by birth	The constitutional framework permits Nigerians by birth to hold another citizenship; naturalized/registered Nigerians face forfeiture rules for additional nationalities	Direction matters: a Brazilian-born person naturalizing in Nigeria sits in the nuanced category — verify with Nigerian counsel
Israel	Yes, with an asymmetry	Israeli citizens do not lose citizenship by naturalizing abroad; immigrants under the Law of Return acquire Israeli citizenship without renouncing — but ordinary naturalization in Israel traditionally involves renunciation	Which acquisition track applies changes the answer — verify with Israeli counsel
Egypt	Conditionally	Egyptians may acquire a foreign nationality with prior governmental permission and may declare the intention to retain Egyptian nationality; skipping the permission step risks complications	A permission-based regime where procedure is everything — verify current practice with Egyptian counsel

Two structural observations help you use the table. The global trend is toward tolerance — Germany (2024) and South Africa (2025) are the newest arrivals, and Brazil’s own EC 131/2023 is part of the same wave. And the hard “no” group is stable and East-Asian/South-Asian centered: Japan, China, and India have shown no sign of moving, which makes those combinations planning-critical: the decision to naturalize in Brazil is, for those nationals, a decision to hold only Brazilian citizenship.

Speak to counsel — every row above is a starting point, not a ruling. Nationality statutes carry exceptions for minors, military obligations, public office, and prior-permission channels that no summary table can capture, and several of these rules changed within the last three years. Before you naturalize anywhere, verify the current rule, in both directions, with a lawyer licensed in the relevant country.

What about triple citizenship?

Brazil imposes no numerical limit. Nothing in article 12 distinguishes a second nationality from a third or fourth, and after EC 131/2023 each additional acquisition is as irrelevant to the Brazilian side as the first. “Triple citizenship” involving Brazil is common in practice — Brazil–Italy–US and Brazil–Portugal–UK stacks appear constantly in families with European descent lines, and children born abroad to Brazilian parents often start life with two nationalities before adding a third by residence. Our guides on citizenship by descent and on children born abroad with dual nationality map those acquisition routes.

The constraint, as always, is each other country’s law, applied pairwise: a stack works only if every non-Brazilian country in it tolerates the others. Adding a US naturalization to a Brazil–Japan dual national does not create a triple citizen — it creates a Brazil–US dual citizen, because Japanese law exits automatically. And one nuance from the table bears repeating: a country’s tolerance can be category-specific (Spain’s exemption covers Ibero-American nationalities; Nigeria’s covers citizens by birth), so the same third passport can be fine in one stack and fatal in another.

What changed in 2023 — and what it means if you lost citizenship before

Until October 2023, art. 12, §4º, II declared nationality lost upon voluntary naturalization abroad, saving only those who held the other nationality by birthright recognition or naturalized because the foreign state demanded it as a condition of staying or working. The rule was litigated for decades and produced real casualties — most visibly in extradition proceedings against former Brazilians. EC 131/2023 revoked both the rule and its exceptions, replacing them with the express-request model and adding the anti-statelessness safeguard and the §5º reacquisition guarantee.

What the amendment did not do is automatically re-nationalize people who had already lost citizenship under the old text. For them, the path is reacquisition — an administrative request processed through the Ministry of Justice, with consular intake for applicants abroad. Policy since 2023 has moved clearly in favor of restoring these cases, but the procedural details (forms, channels, whether the restored status is nato or naturalized in character — a question with real consequences for public offices reserved to native-born Brazilians) have evolved and deserve current, case-specific confirmation before filing. Treat any pre-2023 loss as solvable but not self-solving.

Legal basis: the former loss rule was art. 12, §4º, II, “a” and “b” of the Constitution (pre-2023 text); its revocation and the current regime are Emenda Constitucional nº 131/2023; reacquisition is processed under the framework of Lei nº 13.445/2017 and its regulations.

What does it cost and how long does it take?

Dual-citizenship questions rarely involve large government fees; the money is in documents and the time is in queues. All figures are illustrative, as of August 2026, at an assumed rate of ~R$5.4/US$1 — confirm current values before budgeting.

Keeping Brazilian citizenship while naturalizing abroad: R$0. No Brazilian filing, fee, or declaration is required. Your Brazilian passport simply remains renewable as usual (consular passport fees apply on their ordinary schedule).

Naturalizing in Brazil. Federal processing fees are modest (on the order of hundreds of reais); the real budget lines are apostilles and sworn translations of foreign documents — commonly a few hundred to a few thousand reais depending on volume — plus any counsel you retain. Processing time for ordinary naturalization commonly runs from several months to a couple of years end-to-end, varying with the queue and the completeness of the file.

Reacquisition after a pre-2023 loss. Comparable document costs; timelines have fluctuated as consulates and the Ministry of Justice absorbed the post-EC-131 wave — plan in months, not weeks, and confirm the current queue with the intake consulate.

The other country’s side. Foreign naturalization fees vary enormously (from roughly US$800 in the US to four figures elsewhere) and are outside Brazilian counsel’s lane — verify locally.

Speak to counsel — timelines are queue-dependent. Naturalization and reacquisition processing times shift with ministry backlogs and consular staffing. The ranges above are honest as of August 2026 but are planning ranges, not commitments.

Hypothetical illustration — not a real client.

Imagine a Brazilian software engineer who moved to Munich in 2019. In 2022 she deliberately postponed German naturalization: under the then-current rules, Germany would have demanded renunciation of her Brazilian citizenship, and pre-EC-131 Brazil might have treated the acquisition as a loss event anyway. She revisits the plan in 2025. On the German side, the 2024 reform has abolished the renunciation requirement; on the Brazilian side, EC 131/2023 means the naturalization has no effect on her Brazilian nationality. She naturalizes, holds both passports, registers nothing in Brazil because nothing requires registering, and renews her Brazilian passport at the consulate on the normal schedule. Her brother, who had naturalized in Japan in 2021, faces the opposite geometry: Japanese law extinguished nothing on the Brazilian side, but his Japanese plans would have ended his Brazilian citizenship’s practical twin — and no Brazilian rule could have saved it.

Every distinguishing detail here is invented. Real situations turn on their own facts, dates, and documents, and require individual analysis. Nothing in this example predicts any outcome.

What are the most common mistakes?

• Relying on pre-2023 information. Half the internet still says Brazil strips citizenship on foreign naturalization. That rule was revoked by EC 131/2023; decisions made on stale summaries — including postponed naturalizations — cost real opportunities.
• Asking Brazil’s law a foreign question. Whether you keep US, Japanese, or Dutch citizenship is decided by US, Japanese, or Dutch law. No Brazilian filing can preserve a nationality another country’s statute extinguishes.
• Treating the US oath’s renunciation wording as a Brazilian renunciation. The express request under art. 12, §4º, II is a specific, formal act before Brazilian authorities. A foreign ceremony’s boilerplate does not trigger it.
• Assuming EC 131/2023 restored pre-2023 losses automatically. It did not; reacquisition is a real but separate procedure with its own file and queue.
• Ignoring category-specific rules. Spain’s exemption is for Ibero-Americans; Nigeria’s tolerance is for citizens by birth; the Netherlands’ exceptions are fact-specific. The same move can be safe for one person and fatal for their spouse.
• Forgetting the borders. Dual citizens should present themselves as Brazilian when entering Brazil and follow the other country’s mirror rule (the US requires its citizens to use US passports). Two passports means two sets of border obligations, not a free choice.
• Confusing citizenship with tax. Naturalizing abroad does not end Brazilian tax residency, and keeping Brazilian citizenship does not create it. The tax exit is its own procedure — see our dual-citizen tax compliance checklist.
• Renouncing casually. The express request is designed to be hard to trigger accidentally — but where genuinely made (some countries’ naturalizations effectively demand it), remember §5º preserves reacquisition, and weigh that path before and after.

Brazil and dual citizenship at a glance

Question	Answer	Basis
Does Brazil allow dual citizenship?	Yes — fully, with no numerical cap	CF art. 12, §4º (EC 131/2023)
Does naturalizing abroad cost Brazilian nationality?	No — the old loss rule was revoked in Oct/2023	EC 131/2023
How is Brazilian nationality lost today?	Only by express request (barred if it causes statelessness) or judicial cancellation of a fraudulent/hostile naturalization	CF art. 12, §4º, I–II
Must foreigners renounce to become Brazilian?	No — no renunciation requirement exists	Lei 13.445/2017
Can a pre-2023 loss be reversed?	Generally yes, via reacquisition — not automatic	CF art. 12, §5º; Lei 13.445/2017 framework
Who decides if the other citizenship survives?	That country’s law, exclusively	Sovereignty over nationality
Clear “yes” countries	US, UK, Canada, Argentina, Portugal, France, Italy, Germany (since 2024), Spain (for Brazilians), South Africa (since 2025)	See country table
Clear “no” countries	Japan, China, India	See country table
Nuanced regimes	Netherlands, Nigeria, Israel, Egypt	See country table

Key terms

• Brasileiro nato / naturalizado — native-born versus naturalized Brazilian; certain offices are reserved to natos, and only naturalized citizenship can be judicially cancelled.
• Perda da nacionalidade (loss of nationality) — now limited to judicial cancellation (fraud/attack) and the express request.
• Pedido expresso (express request) — the formal, voluntary act before Brazilian authority that is now the only self-initiated route to loss.
• Apatridia (statelessness) — having no nationality; a request for loss that would cause it is barred.
• Reaquisição (reacquisition) — the procedure restoring Brazilian nationality after a loss, preserved by art. 12, §5º.
• Jus soli / jus sanguinis — birthright citizenship by territory / by descent; the acquisition routes that most often create dual nationals at birth.
• OCI (Overseas Citizen of India) — India’s visa-like substitute status; not citizenship.
• StAG — Germany’s Nationality Act, amended in 2024 to permit multiple nationality.

Key takeaways

• Brazil allows dual citizenship — cleanly, since EC 131/2023. Voluntary naturalization abroad no longer touches Brazilian nationality.
• Loss is now essentially opt-in: an express request before Brazilian authorities (blocked if it causes statelessness), or judicial cancellation of a naturalization obtained by fraud or turned against the democratic order.
• Brazil demands no renunciation from foreigners naturalizing as Brazilian — the Migration Law’s requirements simply do not include it.
• The live risk sits in the other country’s law. Japan, China, and India strip automatically; the Netherlands allows only exception cases; Spain exempts Brazilians as Ibero-Americans; Germany and South Africa recently flipped to tolerance.
• Triple citizenship is fine with Brazil — there is no cap; the stack holds only if every other country in it tolerates the rest, pairwise.
• Pre-2023 losses are fixable but not self-fixing — reacquisition is a real procedure with current-rules details worth confirming before filing.
• Passports and taxes run on separate tracks: enter Brazil as a Brazilian, follow the mirror rule abroad, and remember tax residency — not citizenship — drives Brazilian taxation.
• Foreign-law rows in this guide are context, not counsel — verify the other country’s current rule with a lawyer licensed there.

Related guides on this site

• Dual citizenship in Brazil
• Dual citizenship in Brazil — the complete guide
• Loss and reacquisition of Brazilian citizenship
• Brazilian citizenship by descent (jus sanguinis)
• Brazilian citizenship by naturalization — the guide
• Children born abroad: Brazil, CRBA, and dual nationality
• Tax compliance checklist for Brazil dual citizens

How ZS Advogados can help

Dual-citizenship questions are sequencing questions in disguise: which country’s step to take first, whether a pre-2023 loss needs repairing before anything else, how a naturalization interacts with tax residency and succession planning, and what a child born abroad must register, where, and by when. The Brazilian side of each of those questions — nationality, reacquisition, naturalization, documents, and the tax and family-law consequences that follow the passport — is work we do daily, in English and Portuguese.

What we deliberately do not do is advise on foreign law. Where your plan depends on the American, German, or Japanese side of the table, we help you frame the exact question and coordinate with counsel licensed in that jurisdiction, so that both halves of your dual-citizenship analysis rest on someone’s professional responsibility rather than on a summary — ours included.

• International law — nationality analysis, reacquisition after pre-2023 loss, cross-border document strategy, coordination with foreign counsel
• Immigration — Brazilian naturalization applications, residence permits, and the CRNM track that precedes citizenship
• Tax law — tax-residency planning around naturalization, the definitive-exit declaration, and dual-citizen compliance

Book a consultation to have the Brazilian side of your dual-citizenship plan reviewed before you take an oath anywhere.

Technical review by the ZS Advogados Associados team, including co-founding partner Karina Peres Silvério (OAB/SP 331.050) and founding partner Zachariah Zagol (OAB/SP 351.356). Contact: contato@zsassociados.com — +55 (18) 3908-1653 — Presidente Prudente, SP.

Sources and legal basis

• Constituição Federal, art. 12 — nationality (Planalto)
• Emenda Constitucional nº 131/2023 (Planalto)
• Lei nº 13.445/2017 — Lei de Migração (Planalto)
• Ministério das Relações Exteriores — perda da nacionalidade brasileira (consular guidance)
• US Embassy — Dual Nationality (US Department of State)
• UK Government — Dual citizenship
• Government of Canada — Dual citizenship
• Germany — Staatsangehörigkeitsgesetz (StAG), consolidated text (Gesetze im Internet)
• Spain — Código Civil, arts. 23–24 (BOE consolidated text)
• Japan — Nationality Act, official English translation (Ministry of Justice)
• Netherlands — Losing Dutch nationality (IND)
• India — OCI scheme FAQ (Ministry of Home Affairs)
• China — Nationality Law of the PRC, English text (National People’s Congress)
• South Africa — Democratic Alliance v Minister of Home Affairs, CCT 184/23 (Constitutional Court)

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This guide is for informational and educational purposes only, in line with Provimento No. 205/2021 of the Brazilian Bar Association (OAB). It is not legal advice, an opinion, or an offer of services, does not refer to any specific case, and does not guarantee any result. It describes Brazilian law; every statement about another country’s nationality rules is factual context drawn from official sources of that country and must be verified with counsel licensed there — ZS Advogados practices Brazilian law only. Nationality rules change: Germany’s reform took effect in 2024 and South Africa’s Constitutional Court ruling in 2025, and further changes after the date of writing are not reflected. Rules and provisions are cited as of August 2026. Each situation requires individual analysis by a licensed attorney. Last updated August 2026.