The three Baltic States – Estonia, Latvia and Lithuania – were independent between the two world wars but were absorbed by the Soviet Union in 1940. After the dissolution of the Soviet Union, they sought to rebuild their nation-states and identities. This explains the differences in their citizenship strategies.
After regaining their independence in 1991, Latvia and Estonia introduced restrictive policies granting citizenship only to those who possessed it before the Soviet occupation and to their descendants. As a result, about one-third of the populations of these countries – former citizens of the USSR – were deprived of citizenship. Russian-speaking people of Russian, Belarusian and Ukrainian ethnicity, who were believed to pose a threat to the national identity and language, were particularly disadvantaged by this policy. They were declared to be “non-citizens” (nepilsoņi in Latvian), or of “undetermined citizenship” (kodakondsuseta isik in Estonian).
In the 1990s, international institutions, including the United Nations, the European Union, the OECD, the Council of Europe, Helsinki Watch and Amnesty International, criticized the citizenship policy and the exclusive Citizenship Act in Latvia and Estonia. In response to this pressure, Latvia and Estonia introduced amendments to facilitate the acquisition of citizenship. The citizenship restrictions were meant to restore the legal status and ethnic demography of the interwar period. The naturalization process in the two countries was aimed at encouraging non-citizens and people with undetermined citizenship to adapt to the majority society.
In Estonia, the naturalization process has proven more dynamic and effective than in Latvia. The number of people with undetermined citizenship fell from 32 percent in 1992 to 5.7 percent in 2019; it is currently at 76,148 persons. In Latvia, nearly 150,000 people have been naturalized since the Citizenship Act was launched in 1995. But 237,759 people, or 11 percent of the population, are still non-citizens.
In recent years, Estonia has introduced mechanisms to further reduce the number of people with undetermined citizenship. Persons who have a long-term or permanent residence permit and who were settled or born in Estonia before 1 July 1990 can apply for citizenship. They must be fluent in Estonian, have a legal source of income, a place of residence in Estonia, and proven loyalty to the Estonian state. Since 2015, people over the age of 65 are exempted from the written language exam. All children born in Estonia after 2016 whose parents have had their permanent residence in Estonia for at least five years are automatically granted Estonian citizenship.
A similar solution has just been approved by the Latvian parliament. Children who have reached the age of 15 can apply for citizenship; those under the age of 15 can become naturalized together with their parents. This applies also to applicants fluent in Latvian, with five years of permanent residence, and with a legal source of income.
Non-citizens in Latvia enjoy protection under the law, as do people with undetermined citizenship in Estonia. They may become members of civil organizations and they have the right to visa-free travel within the EU. Despite these guarantees, the political and economic rights of non-citizens or those with undetermined citizenship are restricted. They cannot vote, they lack protection under national minority legislation, they cannot work in the civil service, as state officials, judges, lawyers, police officers or soldiers, and their access to technical professions is restricted.
Lithuania, unlike Latvia and Estonia, chose the liberal “zero variant”, which allowed people registered there to obtain citizenship regardless of their nationality, length of residence, or knowledge of Lithuanian. Less than 0.1 percent of people in Lithuania are stateless. The country’s inclusive policy results from three sources. Lithuania has a history of being a multinational country; at independence, the percentage of minorities in the population was relatively low; and the country needed to stabilize relations with its neighbours. But this changed with the Citizenship Act of 2002, which limited the citizenship opportunities for people without Lithuanian roots. This significantly influenced the naturalization process, especially for migrants with Soviet-era citizenship. Like Estonia, Lithuania does not allow dual citizenship: holding another nationality makes it impossible to obtain Lithuanian citizenship.
In contrast to Lithuania, non-citizen status in Estonia and Latvia has affected the residents’ political, economic and social position, harming their social integration. Gradually liberalizing citizenship has improved interethnic cohesion, particularly in Estonia, but a considerable number of non-citizens are still unwilling to naturalize after 30 years of independence.
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The article was published in the Atlas of the Stateless in English, French, and German.