British, French or Irish? Or all Three?

Caylus - from above
The village near which we have lived for 21 years

I don’t write about politics on this blog. Of course, I have my views, but I generally keep them to myself. So I haven’t mentioned the ‘B’ word (okay, Brexit) in my posts so far. However, I can’t ignore it – and haven’t. With the increasing likelihood of a hard Brexit after 29th March next year, those of us who live permanently in France have some choices to make, even though the implications are far from clear.

We have lived in France for almost 21 years, have run a French company, pay our taxes here and are fully integrated into the health system, and so on. My husband is Swedish, and so he will remain a citizen of an EU country after Brexit. I don’t for a moment think that I will be kicked out of France (although, theoretically, that is a possibility), but life might become more difficult in certain ways.

As things stand, the situation is utterly shambolic and full of uncertainty for those of us who moved here thinking our position was secure under EU rules. Our French friends think the whole thing is bonkers and are totally sympathetic, although powerless to help.

I am fortunate to hold a carte de séjour, which grants me residency. However, this states that I am a ressortissant (national) of an EU country. My status post-Brexit will be Third Country National (TCN). Will France require TCNs to re-apply for a different type of carte de séjour post-Brexit, with the documentary paper chase this would involve?

What are the options?

  1. Wait to see what the French government’s requirements will be?
  2. Apply for French citizenship?
  3. Apply for citizenship of another EU country if eligible?

As far as I am concerned, doing nothing is not an option.

French citizenship

I have, in fact, intended for years to apply for French citizenship, but since procrastination is my middle name, I haven’t yet done so. Having lived out of the UK for more than 15 years, I am no longer eligible to vote there (and, by the way, was thus unable to vote in the referendum that affects me personally). In France, I am allowed to vote in the municipal elections and the EU elections (presumably not for much longer), but not for the president or the Assemblée Nationale. That was my main reason for wanting to apply for French citizenship; Brexit has reinforced my intentions.

But…the process is currently taking around two years or more, appointments are full at the Préfecture for the foreseeable future and the list of documents required is eye-wateringly long. In addition, all documents not in French must be translated by an approved translator. For someone inclined to put off until next month what they ought to do today, this is something of a disincentive.

Irish citizenship

I have another option, though. Irish citizenship. A grandparent was born in Ireland, which makes me eligible to become an Irish citizen. The process is simpler, the number of documents required fewer and easier to get hold of and it currently takes about six months, provided the application is approved. Ireland remains an EU country.

This raises a number of issues, though. While the Irish government seems to be welcoming people with open arms, would I be utterly cynical by taking citizenship when I don’t plan ever to live there?

I would still be unable to vote fully in France, so I would want to apply for French citizenship as well once I have the Irish one. I can’t do it simultaneously, since they require originals of many documents and not photocopies.

Also, would I be permitted to hold three separate citizenships? My researches so far show that it’s a complex issue and that all three countries might have to agree.

One thing is clear. I want to stay here and I have absolutely no desire to live in the UK again.

My writing friend Alison Morton, who is in a similar position, has written an interesting post on this subject.

You might also like:

Carte de Séjour – French Identity Card: Round 1

Carte de Séjour – French Identity Card: Round 2

Carte de Séjour – French Identity Card: Round 3

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41 comments

  1. Anne – how have you resolved this. With an Irish grand-parent you are automatically an Irish citizen – you do NOT need to become an Irish national – there’s a difference. I don’t think France allows a person to have 2 nationalities; you can have 2 passports. One from the country in which you were born, presumably UK, and then Irish because of the way the Irish regard those who have direct Irish ancestors as Irish citizens – but not nationals. I think there is a difference.

    Liked by 1 person

    • Anne, thank you for your comment. I presume your comment was directed to Anne Grose who had a lengthy discussion with David below and is a reader of this blog, and not to me, Vanessa, the owner and writer of the blog. Anne is unlikely to see this to comment further. However, your comments about Irish citizenship make me think you have mixed up the two of us.

      I am the one who has applied for (and now got) Irish citizenship and an Irish passport by virtue of having an Irish grandmother. You are right, I have sloppily mixed up nationality and citizenship, and it is the latter I have as an Irish citizen. I will amend this in the post when I have a moment. I remain a British national with a British passport. Having a direct Irish ancestor does indeed qualify one for Irish citizenship, but you still have to prove it and make a formal application for it to be recognised. I believe France does allow one to hold three passports, but I have yet to test that out.

      You’ll notice that this post was written in August 2018, and things have clearly moved on somewhat since then.

      Best wishes,

      Vanessa

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    • Well, this was a blast from the past that popped up in my inbox. I see Vanessa has replied regarding her Irish citizenship so I will confine my comment to saying that France allows dual nationality so no problem there. And, 3 years after getting Nick’s EU carte de sejour we are about to do a straight swap for a Brexit one.

      Liked by 1 person

      • Thanks for replying, Anne (Grose). I think this lady might have thought you were the writer of the post. Despite also being an Irish citizen, I’ve applied for the straight swap, having had a CdS for about 23 years! I understand Montauban are now sending out convocations, although I haven’t had one yet.

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  2. Real question as I’ve followed the whole Brexit debacle from quite a distance.

    Why are so many emigrated British citizens, especially those living in the EU worried about their status after the UK leaves the EU?

    If they’re a permanent resident of another country, why should that change? Being a member or not of the EU may impact short term residents, but long term is long term, it has to do with what you do in the country more than your country of origins. And France (as well as other EU countries) have tons of long term and permanent residents that are not from the EU. UK citizens will just be some of them, won’t they?

    And in your case, as you’re married to an EU national, you should have nothing to worry about.

    Am I missing something here?

    Liked by 1 person

    • Because the only reason Britains have been allowed to live here without any additional paperwork or proving anything is because they were EU citizens and had the right of free movement across Europe. After Brexit they will be like any other citizen of a foreign country and will have to prove they have sufficient funds to support themselves and produce a tonne of paperwork to prove who they are and where they have come from.

      It will make no difference whether they are short or long term residents. That is the reason why Brits are so worried.

      Liked by 1 person

    • I think Anne’s reply makes a lot of sense.

      There has been a certain amount of scaremongering about this issue. And I find it hard to believe that anyone will be marched over the border on 30th March. However, there is unlikely to be a verified agreement by then and so far the French residency requirements after 29th March are not clear. The likelihood is that, even if you’ve lived in France for a long time, you will still have to apply for some form of visa or revised carte de séjour, with all the additional paperwork that this involves. And with Préfectures struggling to keep up with demand at the moment, that may leave some people in an uncomfortable limbo for some time.

      I’m not sure it makes a lot of difference to me that I’m married to a national of an EU country. The rule currently is that non-EU family members in France must hold a residence permit. I do hold one – but it’s as a citizen of an EU country.

      I am not especially worried, but I am hedging my bets.

      Liked by 1 person

      • From what I have read, they are encouraging Brits to apply for an EU Carte de Sejour now to stop the hundred’s of thousands of applications when they announce what they need. They have also said that it should be a simple straight swap after they have decided what the Brits will have with no additional paperwork. We are applying for Nick’s Carte de Sejour on the basis he is married to an EU national (ie me as a naturalised French citizen) and that is much less paperwork

        Liked by 1 person

      • I understand better. But the situation that Anne describes is EU nationals (Brits or else) who are living in another EU country without a carte de séjour (or local equivalent).
        That actually is illegal.

        Being a EU national allows us to go in and out of any EU country as we please, but staying in another country is different. To be able to do so, you do need a residency card. Of course thousands is not more of EU nationals live in another country without one, because, well, there is no way to really enforce it. Especially if they only live part-time in the other country.

        Those people, may indeed get in trouble after the UK leaves the union, but they need to keep in mind that they’re already staying illegally in the first place.

        Once again, people who already carry a carte de séjour have nothing to worry about.

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        • No David, you are wrong. There is no requirement for an EU national living in another EU country to get a Carte de Sejour. It is perfectly legal to live and work (and be retired) whereever you want without having to get a residency card according to EU laws. That is what the Schengan area was all about, freedom of movement and freedom to live and work where you please.

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      • Are you totally positive about that?

        A few years ago, I had an Italian roommate who was there for just a year and didn’t bother with the administrative work, and then when he got a small job, it had to be “au noir” because of that.
        Similarly, one of my good French friend moved to Belgium a while ago, and she had to apply for residency before being able to be in the system.

        Once again it is possible to stay within the Schengen area without being bothered with immigration laws when you’re a EU citizen, but if you live in another country is different from just being there. Schengen agreement is about free circulation, not free stay.

        Also, Britain is not part of Schengen area (I remember the pain in the back it was to enter the country for my wife – Japanese citizen – because she didn’t have a valid visa (but she had a valid Carte de Séjour, which is all that matters to stay in France)).

        Some more information about staying more than three months in another EU country:
        https://europa.eu/youreurope/citizens/residence/documents-formalities/registering-residence/index_en.htm

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        • I think I will leave you two to argue this one out. All I can add is that when we sought to renew our cartes de séjour five years ago, we were informed by the Préfecture that it was not a requirement to have one (they may have been wrong). We actually had to include a letter with our renewal applications saying why we wanted a carte de séjour.

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        • I am absolutely certain for France and Spain but you may be right that Italy has different rules. I seem to remember reading when we were thinking of travelling over there in our camper van that you had to register with the police if you were going to be there longer than a month. I guess some countries can impose rules about needing a Carte de Sejour but certainly in France, it is not a legal necessity and, in fact, when Brexit was mooted some Brits in parts of France were being turned away by Prefectures as they said we didn’t need a CdS.

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      • Maybe not France then.

        But my Italian roommate’s situation is odd then (it was not in Italy, he was Italian, but it was in France).

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        • Was your room mate in the tax system? When we arrived in France we registered as residents in the tax system and have paid French tax and have a carte vitale. I suspect your room mates problem wasn’t about a Carte de Sejour but about not being a tax resident.

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      • Maybe. It was more than 10 years ago, I forgot the details.
        I remember clearly my French friend in Belgium (as she’s still my friend and she’s still in Belgium), but maybe the Belgian law is different indeed.

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        • Reading that link you posted, it would appear that individual EU countries can make whatever rules they want as to how you declare “residency”.

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  3. I recently discovered your blog, and this is an interesting post. Myself and my partner decided to move to France earlier this year, and are in the process of buying a house now.It might seem foolhardy, when no-one really knows what our position will be for sure after next March, but we decided to simply go for it. I don’t think the position will be finally settled for some time after that date, so we decided to move whilst we still could!
    For your part, I can’t see that you need to rush to take French nationality.unless it turns out in due course that there is a real threat to your ability to stay.

    Liked by 1 person

    • Good luck with your move. I think you’re right that it will take a long time for any final position to be worked out after 29th March. I don’t feel particularly threatened – and I’m doing something about it – but I know people who are terribly worried and anxious at a time in their lives when they shouldn’t have to go through that. My dilemma is more about which nationality to take. Since I’m here for the long term, French might be more sensible. But knee-jerk reactions are clearly not a good idea when so much remains unclear.

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  4. It’s a mighty pot mess and one thing is certain …. those of us who have chosen for whatever reason to live outside of Britain are overlooked in the bun fight which is playing out like a rather tawdry pantomime. We have always intended to take French Nationality but my concern is that this necessary pause in the US (my husband is a US Citizen in addition to being a British National but I am only a Green Card holder here) may make things more difficult. Technically, I am able to start the process next month but I am not in country and I am concerned that this will be a stumbling block despite our still owning property, paying taxes etc etc. Whatever happens, like you, I won’t return to live in Britain. I think, were I you, I would take the Irish option even though it might feel uncomfortable.

    Liked by 1 person

    • I am on the horns of a dilemma at the moment. The Irish option is the easy one but may not be the best one long term, especially if I am not allowed to hold three nationalities at once. I only have myself to blame for not pursuing French nationality before Brexit was a gleam in anyone’s eye, but who could have known how things would turn out? I only know that I don’t want to go back to the benighted nation that is now the UK.

      Liked by 1 person

      • I do feel for you. Who of us could possibly have predicted not just the narrow victory for the Brexit camp but the absolute refusal of the Government to do the right thing and have a second vote some while later, giving both sides the opportunity to properly inform the voters. The signs even days afterwards and certainly now are that a second vote would be to remain. You are on the horns of a dilemma indeed but try to stay calm. One way or another the right solution will present itself to you.

        Liked by 1 person

        • My husband was saying this morning that, in two years’ time, we will probably be taking the same view of this as we did of the Millennium Bug threat – i.e. that it was vastly over-exaggerated. As far as Brexit is concerned, this remains to be seen, of course. I certainly don’t want to take any course of action that would be difficult or impossible to revoke later on. I am angry, rather, at the appallingly bad handling of the whole thing.

          Liked by 1 person

          • Your anger and mine are aligned. It is the way that this has been handled since the vote rather than the vote itself that sparks my ire. People were misinformed, many of those who will be most effected did not vote at all and only understood the implications after the event. The man who triggered it all ran for the hills. I have never had a Carte de Séjour because I didn’t need one. Now I am faced with finding out whether I can even apply for one when I am not living in France and won’t be for another 2 years. We own property and pay taxes in France and my husband has a small pension from his decade of working there in the 80s. I read him your article and your friend’s article last night. Finally, laid back as he ever is, he has sat up and taken notice. But what the result will be who knows. I hope your husband is right but I know what that gnawing feeling of uncertainty is like. The definition of pressure is a the feeling of being at the effect of something known (a work deadline, for example) the definition of stress is the feeling of being at the effect of something unknown. Stress is notoriously the more difficult to manage. And this is super-stressful. The irony for us is that after all the shenanigans and vast paper chase over nearly 5 years to get me my Green Card, we now find that the timing could not have been more off. The known, however, is that whatever happens, whatever the obstacles, whatever the difficulties that lie ahead, I will never live in Britain again.

            Liked by 1 person

            • Things are especially complicated for you, since you are effectively living out of France for a couple of years. Looking on the positive side, though, it might give you a breathing space during which things will hopefully become clearer about residency requirements for Brits in France. The Brexit and anti-Brexit campaigns were marked by complacency and misinformation. The post-vote “handling” (if you can call it that) of the situation has the same features, but with total mismanagement added. Like you, my inclination is never to live in Britain again.

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            • And we will meet up one of these days, and it will be in France and we will share stories and laughs and good food and drink. ‘All shall be well and all shall be well and all manner of thing shall be well’. 😊

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  5. Carte de sejour permanente, but will it be after brexshit? We have assembled files of documents for each of us but each time I visit the prefecture in cahors website there are no RV available….arghhhh!

    Liked by 1 person

    • It’s all so unclear. I have a carte de séjour permanente, which is still valid for another 5 years – but it’s predicated on the assumption that I am a citizen of an EU country. What an almighty mess.

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  6. Thank you for this. You’ve made me think. Like many I’ve dithered about what to do. I’m not normally a “wait and see” person but I can’t help but think there’s still going to be at least one if not more twists in this tale. RIFT (remainers in france together) have produced lots of good info on this subject.

    Liked by 1 person

    • Yes, I’ve found RIFT to be very helpful, especially as regards people’s personal experience of applying for French citizenship. I just have a feeling that one has to take control of one’s own destiny here, rather than hoping that the politicians will act in our interests.

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  7. I am so glad I applied for nationality back in 2015. The process was easier for me – even though it still involved a truck load of paperwork – as I was among the first to apply in the Tarn et Garonne. We are off next week to get Nick’s Carte de Sejour, which according to Connexion will probably be a straight swap without additional paperwork when the whole sorry, shambolic mess that is Brexit has been sorted.

    I have enjoyed voting in my first presidential election and the research that entailed as to what the political parties stood for and I enjoy telling people that I am French.

    Liked by 1 person

    • You’re fortunate in that you decided to do it when you did. I could have done it years ago, but didn’t. I hope you’ll be there to wave me off from the quayside…

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  8. “While the Irish government seems to be welcoming people with open arms, would I be utterly cynical by taking nationality when I don’t plan ever to live there?”

    We live in a world where corporations choose their headquarters based on tax choices. Did you know that Apple makes most of its profit in Ireland? They transferred their intellectual property to a subsidiary there. Many large companies have done this. Ever heard of a “flag of convenience”? Any ship you see on the seas is likely registered in Panama or LIberia or something.

    On the personal level, you can bet all the wealthy people in Britain/France/US/etc have tax advisors doing their best to minimize the taxes they pay. That arrange layer after layer of corporations that they own but that enable them to avoid being sued. And so on.

    If you have the option to take Irish citizenship then I don’t think why you should have any 2nd thoughts. Certainly the movers and shakers in the world don’t hesitate to take advantage of any laws or rules (often ones they had created) for their own benefit.

    Liked by 1 person

    • Thanks for your thoughts. I am simply torn between the short-term solution of Irish citizenship and the longer-term solution of French citizenship, which, frankly, would be more useful as I plan to stay in France long-term. The Irish solution would be a short-term expedient, but I’m not sure it would promote my interests in the long term. It would be better if we’d never been placed in this position…

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  9. You are writing this at the absolutely right time. It’s so complicated and such a mess going on in the UK with no clear cut thinking or clear promises, as what will happen to expats, or vice versa, that I find it all completely maddening. Like you I’m a procrastinator and when someone told me what was involved in becoming a French citizen, I lost all will! 🙂
    I’m just keeping my fingers crossed that there will be a final vote on whatever the government proposes for March … many people are beginning to understand much better about what leaving the EU means and also there is a young generation who couldn’t vote during the referendum, who would hopefully vote on a final vote.
    I just hope that house owners will, at least, be allowed to stay and the big worry for me is that health care for us may just finish altogether, unless you do it privately. But I’m an optimist … I can’t see how this floundering government can take us out of the EU with any confidence. I’m certainly not going to try and live in the UK and if we do crash out, I will brace myself and go for French citizenship!

    Liked by 1 person

    • I can’t see myself ever moving back to the UK, although I realise one should never be categorical about these things. I have been here for 21 years and I feel like a fish out of water when I visit the UK, which is not that often these days. I suppose I have to bite the bullet and go through the French citizenship process at some point, but there is no point doing it now because the system is clogged up. Hence the Irish option…

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  10. Best of luck with whatever you decide! As you know, my partner has taken Irish citizenship, so I guess we’re OK, Brexit-wise. I might well still take French citizenship when I become eligible, just to make double-sure.

    Liked by 1 person

    • Thank you. You too. It’s difficult to know what to do. Long-term, French citizenship probably makes better sense for me; short-term, Irish citizenship gives me security as a citizen of an EU country. What a horrible mess the whole thing is!

      Liked by 1 person

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