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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.

  7. I hold both Canadian and British passports. What’s to stop me entering the Schengen zone with my UK passport and staying the maximum 90 days? At that point, I leave Schengen for a day and re-enter with my Canadian passport. Can I then stay another 90 days?

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TRAVEL NEWS

REVEALED: Countries fear non-EU travellers face delays under new EES border checks

A number of countries in Europe's Schengen area admit they fear delays and insufficient time to test the process ahead of new, more rigorous EU border checks that will be introduced next year, a new document reveals.

REVEALED: Countries fear non-EU travellers face delays under new EES border checks

Schengen countries are tightening up security at the external borders with the introduction of a new digital system (EES) to record the entry and exit of non-EU citizens in May 2023.

The EES will enable the automatic scanning of passports replacing manual stamping by border guards. It will register the person’s name, type of the travel document, biometric data (fingerprints and facial images) and the date and place of entry and exit. The data will be kept in a centralised database on a rolling three-year basis that is re-set at each entry. 

What the EES is intended to do is increase border security, including the enforcement of the 90-day short-stay limit for tourists and visitors.

EU citizens and third-country nationals who reside in a country of the Schengen area will not be subject to such checks as long as they can prove residency in an EU country however they will still be caught up in any delays at passport control if the new system as many fear, causes longer processing times.

READ ALSO: Foreigners living in EU not covered by new EES border checks

But given its scale, the entry into operation of the system has been raising concerns on many fronts, including the readiness of the physical and digital infrastructure, and the time required for border checks, which could subsequently cause massive queues at borders.

A document on the state of preparations was distributed last week by the secretariat of the EU Council (the EU institution representing member states) and published by Statewatch, a non-profit organisation that monitors civil liberties.

The paper contains the responses from 21 countries to a questionnaire about potential impacts on passenger flows, the infrastructure put in place and the possibility of a gradual introduction of the new system over a number of months.

This is what certain the countries have responded. Responses from Denmark, Spain and Sweden do not appear in the report but the answers from other countries will be relevant for readers in those countries.

READ ALSO: What the EU’s new EES border check system means for travel

‘Double processing time’

Austria and Germany are the most vocal in warning that passport processing times will increase when the EES will become operational.

“The additional tasks resulting from the EES regulation will lead to a sharp increase in process times”, which are expected to “double compared to the current situation,” Austrian authorities say. “This will also affect the waiting times at border crossing points (in Austria, the six international airports),” the document continues.

“Furthermore, border control will become more complicated since in addition to the distinction between visa-exempt and visa-required persons, we will also have to differentiate between EES-required and EES-exempt TCN [third country nationals], as well as between registered and unregistered TCN in EES,” Austrian officials note.

Based on an analysis of passenger traffic carried out with the aviation industry, German authorities estimate that checking times will “increase significantly”.

France expects to be ready for the introduction of the EES “in terms of passenger routes, training and national systems,” but admits that “fluidity remains a concern” and “discussions are continuing… to make progress on this point”.

Italy is also “adapting the border operational processes… in order to contain the increased process time and ensure both safety and security”.

“Despite many arguments for the introduction of automated border control systems based on the need for efficiency, the document makes clear that the EES will substantially increase border crossing times,” Statewatch argues.

‘Stable service unlikely by May 2023’

The border infrastructure is also being adapted for collecting and recording the data, with several countries planning for automated checks. So what will change in practice?

France will set up self-service kiosks in airports, where third-country nationals can pre-register their biometric data and personal information before being directed to the booth for verification with the border guard. The same approach will be adopted for visitors arriving by bus, while tablet devices such as iPads will be used for the registration of car passengers at land and sea borders.

Germany also plans to install self-service kiosks at the airports to “pre-capture” biometric data before border checks. But given the little time for testing the full process, German authorities say “a stable working EES system seems to be unlikely in May 2023.”

Austria intends to install self-service kiosks at the airports of Vienna and Salzburg “in the course of 2023”. Later these will be linked to existing e-gates enabling a “fully automated border crossing”. Austrian authorities also explain that airport operators are seeking to provide more space for kiosks and queues, but works will not be completed before the system is operational.

Italy is increasing the “equipment of automated gates in all the main  airport” and plans to install, at least in the first EES phase, about 600 self-service kiosks at the airports of Rome Fiumicino, Milan Malpensa, Venice and in those with “significant volumes of extra-Schengen traffic,” such as Bergamo, Naples, Bologna and Turin.

Switzerland, which is not an EU member but is part of the Schengen area, is also installing self-service kiosks to facilitate the collection of data. Norway, instead, will have “automated camera solutions operated by the border guards”, but will consider self-service options only after the EES is in operation.

Gradual introduction?

One of the possibilities still in consideration is the gradual introduction of the new system. The European Commission has proposed a ‘progressive approach’ that would allow the creation of “incomplete” passenger files for 9 months following the EES entry into operation, and continuing passport stamping for 3 months.

According to the responses, Italy is the only country favourable to this option. For Austria and France this “could result in more confusion for border guards and travellers”. French officials also argue that a lack of biometric data will “present a risk for the security of the Schengen area”.

France suggested to mitigate with “flexibility” the EES impacts in the first months of its entry into service. In particular, France calls for the possibility to not create EES files for third-country nationals who entered the Schengen area before the system becomes operational, leaving this task to when they return later.

This would “significantly ease the pressure” on border guards “during the first three months after entry into service,” French authorities said.

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