Who Belongs? Citizenship, Nationality, and Exclusion in Italy and Uruguay

Who belongs to a nation?

Two very different countries, Italy and Uruguay, are grappling with this question through their citizenship laws.

In Italy, an ancestry-based citizenship framework means that people born or long-resident in the country without Italian blood often remain non-citizens. In Uruguay, an unusual constitutional opinion developed in the 1940s classifies naturalized citizens as somehow not truly "Uruguayan." Both cases highlight legal frameworks that foster exclusion and social division, often with underlying racial or cultural dimensions.

Below, I compare how Italy's ongoing citizenship debate and Uruguay's nationality paradox each exclude certain groups and what that means for those affected. In Italy, nationality is termed "citizenship," so I will use citizenship when speaking of Italian nationality and nationality to refer to Uruguayan nationality. In reality, the terms, as used in international law and most nations, are synonyms.

Italy: Ancestry-Based Citizenship and "Invisible" Italians

Italy's citizenship law is rooted in ius sanguinis (right of blood). Under the main law (No. 91/1992), only those with at least one Italian citizen parent automatically receive nationality at birth. In Italy, jus soli (right of soil that provides nationality to those born in a nation) is only available in minimal cases. For example, a person born in Italy to foreign parents can apply for citizenship upon turning 18, but only if they meet strict conditions and apply before age 19. This small one-year window, combined with Italy's notorious bureaucracy, makes it extremely easy for qualified applicants to fall through the cracks. If they miss the deadline, they must start the process over, often facing a 10-year residency requirement as if they were new immigrants.

The result is that tens of thousands of people born and raised in Italy remain non-citizens well into adulthood. Rome-born TV reporter Sonny Olumati is one high-profile example. The son of Nigerian immigrants, Olumati has lived his entire life in Italy, yet at 34 years old he is still waiting to be recognized as an Italian citizen. He is one of nearly a million such individuals in Italy, often called the "invisible Italians," who, due to having no Italian ancestry, grow up culturally Italian but are denied legal citizenship.

These Italians without citizenship face fundamental rights restrictions. They cannot vote or run for office, and many public-sector jobs, scholarships, and even military or law enforcement roles are off-limits to non-citizens. For instance, public employment and official tenders are reserved for Italian citizens, automatically excluding such non-national second-generation Italians from those opportunities.

There are practical hardships in everyday life as well. Without Italian citizenship, individuals must continually renew residency permits to live and work; any lapse can jeopardize their legal status. One activist, Fatjona Lamçe, who moved to Italy from Albania as a child, recounted how a bureaucratic mix-up nearly led to her deportation despite living in Italy since age 11. She had a long-term residence permit through marriage to an Italian, but when authorities missed a scheduled home visit, they wrongfully assumed her marriage was fake and issued an expulsion order.

Even routine matters like healthcare become uncertain. Lamçe noted that when her permit temporarily expired around the time she gave birth, she was told she would have to pay all maternity costs out-of-pocket because her health coverage vanished with her permit.

In short, growing up Italian in every sense but "on paper" leaves these individuals in a precarious position: they must constantly navigate immigration paperwork in their own birthplace and prove their right to stay, work, and access services in the country they call home. Any slip (a document filed late, a parent's job loss affecting a permit) could upend their lives.

Beneath the legal arguments lies an undercurrent of social and racial bias. Italy's population has grown more diverse since 1992, but the laws have not kept pace. Many politicians and voters still cling to an image of Italian identity that is exclusively ancestral and ethnic. This prevailing attitude suggests that the reluctance to reform citizenship laws is not just about bureaucracy or tradition; it's also about who is considered "truly" Italian. Children of African, Asian, or Eastern European origin, even if born on Italian soil, often struggle against the perception that they are outsiders. The lack of legal recognition reinforces this social exclusion, sending a message that Italian nationality is a bloodline club.

Current developments: These issues have spurred a growing movement to change the law. Grassroots groups like Italiani senza cittadinanza ("Italians without citizenship") campaign for reform. The debate has reached a head with a referendum on citizenship scheduled for June 8–9, 2025. This popular referendum proposes to loosen the rules slightly by halving the required residency period for naturalization from 10 years to 5 for non-EU immigrants.

While this change wouldn't introduce full jus soli, it could indirectly benefit second-generation youths. If a child's foreign parents can become Italian in 5 years instead of 10, the child can more easily acquire citizenship through them (as minors often get citizenship alongside a newly naturalized parent). Advocates see this as a small but important step to recognize Italy's de facto multicultural society. Critics argue that Italian citizenship should remain tightly controlled by lineage and long assimilation, reflecting ongoing resistance.

Regardless of the referendum's outcome, the very fact it's happening shows Italian society wrestling with the legacy of an ancestry-based system that has left hundreds of thousands of young, Italian-raised people feeling like foreigners in their own homeland.

Uruguay: Citizens Without Nationality, A Legal Paradox

On the surface, Uruguay's citizenship laws look far more inclusive than Italy's. Uruguay grants jus soli citizenship: anyone born on Uruguayan soil is a citizen by birth, and even children of Uruguayan nationals born abroad are considered citizens by descent. Immigrants can also become citizens ("legal citizens") after a few years of residence and meeting certain criteria.

However, a peculiar opinion about Uruguay's Constitution created a deep divide in status: naturalized citizens are not considered "nationals" of Uruguay. In other words, Uruguay recognized two classes of citizens: "natural citizens" (Uruguayans by birth or parentage) and "legal citizens" (naturalized immigrants). Only the former were regarded as part of the Uruguayan nation.

This quirk traces back to the 1934 Uruguayan Constitution, which introduced specific language about nationality. Article 81 declared, "Nationality is not lost by naturalization in another country... Legal citizenship is lost by any other form of subsequent naturalization." In essence, once a Uruguayan national (by birth), always a national, whereas a legal citizen (naturalized) could lose their status if they moved elsewhere.

Though the text does not demand this interpretation, by force of tradition, Uruguayans are taught that this means that only naturalized citizens are nationals because nationality cannot be lost. Thus, legal citizens, not included in the statement about nationality, must not be "nationals." Crucially, the Constitution otherwise does not address Uruguayan "nationality" at all.

Formerly influential legal scholars from Uruguay's twentieth-century past, like Justino Jiménez de Aréchaga, argued that nationality in Uruguay is an innate, irrevocable status that comes only from the "natural bond" of birth and a mystical union of those born in a nation to the territory. "First, nationality appears to us as a natural bond, derived from birth, from blood... The quality of nationality depends on one fact: birth within the territory of the State," Aréchaga wrote, articulating the opinion (one hundred and fifteen years after the fact) that the original Constitutional framers saw the Uruguayan nation as composed only of those born into it.

Under this interpretation, an immigrant could live virtually their whole life in Uruguay and even hold Uruguayan citizenship, yet never be a Uruguayan national in the eyes of the law.

For decades, this distinction was largely academic. Naturalized citizens in Uruguay could vote, work, and enjoy civil rights similarly to natural-born citizens (with a few exceptions, such as a three-year wait to hold certain public offices after naturalization). However, in practice, the state "refused" to treat them as nationals in official documents issued since 1994.

The issue came to a head in the 2010s with the advent of biometric passports and stricter global travel rules. International standards (set by the International Civil Aviation Organization, ICAO) require passports to list the holder's nationality or citizenship. Uruguay mistakenly interpreted this requirement for years as only allowing "nationality" as conceived uniquely in Uruguay to be listed on passports. Because Uruguay had no legal mechanism to confer nationality on naturalized persons, its authorities resorted to bizarre passport designations: for any citizen not born in Uruguay, the passport would list their country of birth as their "nationality."

The consequences were severe. Thousands of naturalized Uruguayans suddenly found their Uruguayan passports functionally useless for travel. Immigration officers in other countries were baffled or alarmed: a passport might say "Nationality: Russia" (or India, or Tajikistan, etc.) despite claiming to be an Uruguayan document. As a result, holders of these passports were often treated not as Uruguayan travelers but as nationals of their birth country, whether they were such nationals or not (or as stateless persons).

They had difficulty with visa-free entry that Uruguayan nationals normally enjoy, or were even outright refused entry at borders. Some European countries, like France and Switzerland, did not recognize these passports as valid Uruguayan passports and told travelers to produce their original country's passport instead. In effect, a naturalized Uruguayan could not reliably travel as a Uruguayan. In extreme cases, there was a fear that if such a person ran into legal trouble abroad, they could be deported to their birth country rather than Uruguay, since legally the passport implied they belonged elsewhere.

A striking example is the case of Gulnor Saratbekova, a woman from Tajikistan who has lived in Uruguay for over 20 years. When she gave up her Tajik citizenship (Tajikistan doesn't allow dual nationality) to become a Uruguayan citizen, the change meant she had no other nationality; yet her new Uruguayan passport still didn't recognize her as Uruguayan. With Tajikistan revoking her passport and Uruguay listing her as Tajik by nationality (or leaving it blank), Gulnor said she felt "in a limbo where I'm from two places, but at the same time I'm from nowhere... as if I had a father and mother, and neither recognizes me as their legitimate child."

Her poignant words underscore the identity crisis created by this system: despite being a fully naturalized citizen with deep ties to Uruguay, she was not acknowledged as part of the Uruguayan nation. Many others—an estimated 16,000 foreign-born Uruguayans as of recent counts—faced the same predicament. About 1,500 new "legal citizens" were added each year, each receiving a passport that might label them with the nationality of a country they had left behind.

Uruguay's approach was unique globally. In fact, observers noted that Uruguay stood alone in offering immigrants citizenship but no path to nationality, a "local and unusual conception" of citizenship. Most countries, including neighbors like Argentina, allow naturalized citizens to become full nationals of the state, but the outdated Constitutional opinion held by some in Uruguay did not.

This unusual framework of exclusion can be traced to Uruguay's historical self-definition. Like many Latin American countries, Uruguay's legal system is rooted in European civil law traditions (stemming from Spanish colonial law and later influenced by European scholarship). And Uruguay's national identity was forged at a time of massive European immigration, especially from Italy.

Perhaps, then, the fact that both Italy and Uruguay share some of the most exclusionary and racially tinged nationality policies is not entirely an accident. It is estimated that around 44% of Uruguay's population is of Italian ancestry, and Italian immigrants are considered foundational in Uruguayan society. Perhaps as a result, Uruguay developed a concept of nationhood that, ironically, mirrors Old World notions: much as Italy defines Italian-ness by blood lineage, Uruguay came to define Uruguayan nationality by the accident of birth on its soil. The first generation immigrant could contribute to the country and even gain political rights, but, in a sense, they would always remain an outsider to the Uruguayan nation.

This dynamic of two tier-citizenship created a subtle social division. Naturalized citizens in Uruguay have long been referred to as ciudadanos legales as opposed to Uruguayos. The very terminology reinforces that they are a separate category, which can affect social inclusion. Although Uruguay is a racially homogeneous society by Latin American standards (over 90% of European descent), the principle at work is comparable to a cultural or quasi-ethnic exclusion: you must be born into the Uruguayan family to belong to it fully.

Recent change: Faced with mounting criticism, Uruguay is now moving to fix this issue. In late April 2025, the government rolled out a new passport format that finally identifies naturalized citizens as Uruguayans in the nationality/citizenship field. The passport now uses "nationality/citizenship: URY" for all citizens, whether by birth or naturalization, eliminating the confusing reference to country of birth.

This administrative fix was a crucial step to restore international travel rights and dignity to legal citizens. It came after pressure from human rights organizations; the issue even reached the Inter-American Commission on Human Rights, which scheduled a hearing in 2024 to examine Uruguay's denial of nationality to naturalized people.

While the passports are now corrected, fully resolving the underlying problem requires an interpretative law setting aside forever the suspect opinions of former legal scholars that Article 81 of the Constitution (on the loss of nationality) implies that legal citizens are not nationals. Uruguay's National Human Rights Institution and civil society groups (such as Somos Todos Uruguayos) are pushing for legal reform that explicitly recognizes naturalized citizens as Uruguayan nationals equal to those by birth.

In sum, Uruguay is confronting the legacy of an exclusionary legal doctrine that, for decades, made a segment of its citizens feel less than fully part of the nation.

Two Faces of Exclusion: Comparing Italy and Uruguay

Despite their different contexts, Italy and Uruguay offer a telling comparison of how citizenship frameworks can exclude and divide.

In Italy, the exclusion is generational and racial: the second generation (children born in Italy to immigrant parents) often grows up Italian in culture and loyalty but remains legally foreign for many years.

In Uruguay, the exclusion has been legalistic and technical, mostly affecting the first generation of immigrants who, even after naturalization, were not legally acknowledged as belonging to the nation.

Yet both systems echo a similar underlying notion: that true nationality is something inherent (by blood or by birthplace) and cannot easily be acquired later in life. This notion leads to a class of "almost but not quite" members of society in both countries.

The Italian and Uruguayan systems echo a similar underlying notion: true nationality is something inherent (by blood or birthplace) and cannot easily be acquired later in life. This notion leads to a class of "almost but not quite" members of society in both countries.

The Key Impacts are Similar

Denied Political Voice: In Italy, non-citizen residents, even those born in the country, cannot vote or hold public office, silencing the voices of nearly a million residents who often know no other home. In Uruguay, naturalized citizens can vote, but their lack of nationality still puts them at risk of not being protected as Uruguayans abroad and being considered "foreigners" at home. Both frameworks send a message that these individuals are not full members of the polity.

Barriers to Opportunities: Italian law reserves various jobs, especially public sector careers and military/police roles, for citizens. This means talented young people who grew up in Italy are shut out of serving the country in many professional capacities. In Uruguay, formal job restrictions were fewer, but an immigrant-turned-citizen might still face an implicit glass ceiling. Moreover, the psychological impact of being labeled a "legal" as opposed to a "natural" citizen can be an obstacle to social acceptance and advancement. In both cases, there is a sense that no matter how integrated you are, you'll always be a bit of an outsider.

Travel and Mobility: One practical area where the two situations converge is freedom of movement, albeit in different ways. An Italian-born person without citizenship is typically forced to rely on a foreign passport (often their parents' country's passport) for travel. This can be limiting. For example, a young person of African or Asian origin in Italy might hold a passport that requires visas for European travel, whereas an Italian passport would grant freedom of movement in the EU. Uruguay's naturalized citizens experienced the flip side: they had a Uruguayan passport, but it was treated as dubious or indicating statelessness, making travel equally fraught. In both instances, people's ability to move freely, study abroad, or visit family was curtailed by their not being recognized as nationals of the country where they live.

Identity and Belonging: Perhaps the deepest consequence is psychological and social. In Italy, second-generation individuals often report a sense of alienation. They might speak the dialect, cheer for the local football team, and embody Italian culture, yet they constantly confront questions like "Where are you really from?" These questions are reinforced by their legal status. The law's emphasis on Italian bloodlines implicitly casts doubt on their Italian-ness, contributing to racial and cultural marginalization. Uruguay's policy, while not about race per se, effectively told immigrants, "You can live here and even become citizens, but you'll never truly be one of us." Naturalized Uruguayans like Gulnor described feeling like they had no country willing to claim them. In both countries, the policies foster an "us vs. them" narrative: a core national group (native-born/ancestry) versus a group of perpetual outsiders. This runs counter to social cohesion in increasingly diverse societies.

Cultural and Racial Dynamics: It's worth noting that Italy's and Uruguay's frameworks, though stemming from different legal philosophies, each carry cultural or racial overtones. Italy's reluctance to adopt jus soli is often intertwined with fears about immigration and national identity, fears which often target non-European, non-white immigrants. On the other hand, Uruguay's case looks back to a 19th-century worldview in which the nation was an ethno-cultural family. Given Uruguay's overwhelmingly European-descended population, the distinction between those born into the nation and those not could be seen as a holdover of an ethnic nation concept (even if most immigrants historically were ethnically similar Europeans). In today's world, as Uruguay sees new immigrants from places like Latin America, Asia, and Africa, that old doctrine has taken on a racial dimension. While Uruguayans claim the denial of nationality is not based on race or national origin, non-European newcomers who seek to become Uruguayan primarily suffer this discrimination.

In both countries, then, the legal barriers to citizenship have been accompanied by (and arguably bolster) a narrative that true national identity is something you inherit, not something you earn. This notion tends to disadvantage racial and cultural minorities, whether it's Black and brown Italians born in Rome, or an Asian or African professional who chooses to settle in Montevideo.

The Future of Nationality in Each State

Italy and Uruguay illustrate two sides of the same coin: citizenship and nationality laws that lag behind reality, entrenching exclusion.

In Italy, an outdated, bloodline-based law means a large population of Italian-born young people remain foreigners in the only country they call home, a situation widely criticized as unjust and harmful to social unity.

In Uruguay, a quirkish constitutional opinion (born of an old scholarly interpretation) meant that immigrants can never fully shed the "foreigner" label, even after committing to Uruguay and obtaining citizenship. The practical outcomes, from denied rights and opportunities to emotional dislocation, are painfully similar.

Both countries are now facing pressure to reform. Italy's 2025 referendum is an attempt to inch toward inclusivity by making naturalization easier for long-term residents. Uruguay, confronted with international human-rights scrutiny, has taken steps to recognize naturalized citizens as Uruguayans in passports and is contemplating deeper legal changes.

Ultimately, the experiences of Sonny Olumati in Italy and Gulnor in Uruguay (and countless others like them) underscore a key lesson: nationality is not just a legal technicality, but a source of identity, security, and belonging. When the law draws rigid lines based on ancestry or birthplace alone, it risks creating a disenfranchised underclass of people who are integral to their societies yet treated as outsiders.

As the world becomes more interconnected and populations more diverse, nations must reconcile their legal definitions of citizenship with the lived reality of their people. Italy and Uruguay are beginning to do so, learning in their own ways that a more inclusive notion of nationality is crucial for social cohesion.