Country guide · Estonia

Does Estonia allow dual citizenship with the USA?

Citizenship-by-Descent.com·Last reviewed November 2026

Educational information only — not legal advice. Always verify with the relevant authority, consulate or registry office.

Not on paper. The Citizenship Act says an Estonian citizen may not hold another citizenship. In practice, Estonians by birth, including descendants claiming through a parent or grandparent, do hold US citizenship alongside it, because the Constitution protects citizenship acquired by birth. Naturalised Estonians get no such protection: they must give up their old citizenship and lose Estonian citizenship if they take a new one. The position for citizens by birth rests on the Constitution and official practice, not on any section of the Act that says you may. Two bills now before the Riigikogu could change the details, so this page says exactly where things stood on 6 November 2026.

The short answer

  • American claiming Estonian citizenship by descent: if you are a citizen by birth, you aren’t required to give up US citizenship.
  • Estonian by birth who later becomes American: the loss provisions aren’t applied to citizens by birth, according to the Interior Minister. The Act itself doesn’t say so.
  • Naturalised Estonian who takes another citizenship: loses Estonian citizenship.
  • American naturalising in Estonia: must prove release from US citizenship, after eight years’ residence and language and civics exams.
  • Someone who was naturalised as a child and holds a second citizenship: must choose within three years of turning 18.

What the law actually says

Read on their own, the Act’s sections look like a flat ban:

  • Section 1(2): an Estonian citizen may not simultaneously hold the citizenship of another state, subject to the special rules in Section 3.
  • Section 3(1): a person who as a minor acquires Estonian and another citizenship must renounce one of them within three years of turning 18.
  • Section 22: a person ceases to be a citizen on release, on deprivation, or when they accept the citizenship of another state.
  • Section 29(1): the authority treats a person as having ceased to be a citizen when they accept another citizenship or renounce Estonian citizenship in favour of another.

Against that stand three protections for citizenship acquired by birth:

  • Section 8(3) of the Constitution: “No one shall be deprived of Estonian citizenship acquired by birth.”
  • Section 5(3) of the Act repeats this.
  • Section 28(3) of the Act: the government’s powers to deprive someone of citizenship don’t apply to people who acquired it by birth.

Notice the gap. Those protections are about deprivation. Sections 22(3) and 29 are about loss, and they contain no exception for citizens by birth. So a claim that “the law allows it” goes too far, and so does a claim that “the law forbids it”.

How the gap is handled in practice

Official statements fill most of it, and they consistently treat the two groups differently.

  • The Chancellor of Justice, 2008. In a memorandum to the Interior Minister, the Chancellor found that the ban in Section 1(2) is compatible with the Constitution, but that Section 3 conflicted with it so far as it required a citizen by birth to give up Estonian citizenship, and that Section 29 conflicted with it so far as it let a citizen by birth be treated as having lost citizenship. The ministry had confirmed that Section 29 had only been used on naturalised citizens. The Chancellor welcomed that, but warned that an unconstitutional provision left standing leaves people uncertain, because its use may depend on the official or on executive guidance.
  • The Interior Minister, 2013. In a letter of 22 February 2013, recorded by the Chancellor, the minister said Section 1(2) covers both groups, but that because the Act doesn’t say accepting a foreign citizenship counts as a wish to give up Estonian citizenship, Sections 29 and 30 are not applied to people who acquired it by birth.
  • The Tallinn Circuit Court, 2024. In case 3-22-2566 the court said citizens by birth and naturalised citizens are two different categories, the first protected by Section 8(3) of the Constitution, and that treating them differently in cases of deprivation or loss is not arbitrary.

We didn’t find a Supreme Court ruling that settles the point for citizens by birth, or a current page from the Police and Border Guard Board (PPA) or the ministry that sets it out. A 2026 bill’s explanatory note, covered below, also speaks of citizens by birth who lost citizenship under Section 29 or gave it up. Treat the practice as well established but not guaranteed by statute.

Citizens by birth and naturalised citizens compared

  • By birth. You are a citizen by birth if at least one parent was Estonian when you were born (Section 5(1)). Your other citizenship doesn’t change that. You can’t be deprived of citizenship, even on the grounds in Section 28 such as attempting to overthrow the constitutional order or joining a foreign security service. You can still give it up by applying for release (Sections 23 to 27).
  • Naturalised. You must prove you have been or will be released from your previous citizenship (Section 12(2)), unless you have international protection and can’t renounce (Section 3(2)). Taking another citizenship later brings loss under Section 29. The explanatory note to bill 932 SE gives the PPA’s figures for Section 29 decisions: 85 people in 2022, 68 in 2023, 70 in 2024 and 92 in 2025.

In 2024 the Tallinn Circuit Court upheld loss for someone naturalised more than 30 years earlier, agreeing that the law gives the PPA no discretion and that exceptions are for the legislature. One narrow group is treated differently: people who acquired both Estonian citizenship by naturalisation and another citizenship before 26 February 1992. The Chancellor recommended in 2013 that the ban shouldn’t be applied to them.

The choice at 18

Section 3(1) has read “as a minor” since 1 January 2016. On its face it could reach a child born to an Estonian and an American. But the Chancellor’s 2008 memorandum, written about the earlier wording, found that forcing a citizen by birth to give up Estonian citizenship breaches Section 8(1) of the Constitution, and the government’s own account of how the rule works, in the note to bill 932 SE, concerns people who gained Estonian citizenship by naturalisation as minors. Those people are told in the proceedings that they must give up the other citizenship, and if they don’t within a reasonable time, the PPA treats them as having lost Estonian citizenship. Bill 1059 SE would write the exception for citizens by birth into Section 3, which shows the text doesn’t clearly say so yet.

What descendants claiming Estonian citizenship need to know

Everything depends on being a citizen by birth rather than a naturalised citizen, so the chain of descent matters.

  1. The starting point. A decision of the Supreme Council on 26 February 1992 restored the 1938 Citizenship Act as it stood on 16 June 1940. It treated as citizens those who were citizens by birth under that Act or had acquired citizenship under it. Section 1(1) of today’s Act carries those people forward.
  2. Each link. Under Section 5(1), citizenship passes to a child if a parent holds it at the birth. So a break in the chain, such as an ancestor who was not a citizen when their child was born, stops it.
  3. People who opted for Estonian citizenship in Russia. From 2003 to 2015 the PPA treated their descendants as citizens by birth, whether or not the person who opted moved to Estonia. It changed course in 2015. In 2018 the Supreme Court said an unfinished option meant the children didn’t acquire citizenship at birth, and the Chancellor told the PPA to re-examine its practice and that people the state had recognised shouldn’t suffer for its mistake. If this is your family’s history, get advice.
  4. No grant, just recognition. Citizenship by birth arises by law, so you don’t apply for it. The PPA says a first-time passport applicant must show an Estonian document proving citizenship, or an original document showing a parent or grandparent had Estonian citizenship plus proof of the blood relationship. It sends you to the National Archives for the ancestor’s record.

See our guides on how to apply for Estonian citizenship and Estonian citizenship by descent.

If your family lost Estonian citizenship

Restoration is narrow. Under Section 16, the right belongs to people who lost citizenship as a minor, and they must live permanently in Estonia on a residence permit or right of residence. Under Section 17(2) they must also prove release from their previous citizenship. Anyone else starts again through naturalisation. Bill 1059 SE would add a right of restoration for people who were citizens by birth, without the release requirement, but it keeps the need to live in Estonia and wouldn’t extend to their descendants.

The 2026 bills

1059 SE: dual citizenship for citizens by birth

Filed on 14 October 2026 by the Reform Party and Estonia 200 groups and taken up the next day. Its stated aim is to set out clearly when a citizen by birth may hold another citizenship. It would exempt citizens by birth who also hold the citizenship of an EU or EEA state, the United States, Australia, Canada, Switzerland or New Zealand, or a state with a mutual treaty. Other countries, such as Russia, would not be covered. Its planned start date is 2 January 2027. It has not had a first reading.

932 SE: a government bill that rewrites Section 29

Mainly about stateless children, this bill was sent to third reading on 28 October 2026 and is planned to take effect on 1 January 2027. It would repeal Section 28(1)(5), which covers citizens of another state who haven’t been released from Estonian citizenship, and move that case into Section 29. That matters because the exemption for citizens by birth in Section 28(3) sits in Section 28, and the new Section 29 text has no such exemption. The bill’s explanatory note says its changes don’t concern citizens by birth. Bill 1059 SE assumes 932 SE will pass and adds an exception for its listed countries. If 932 SE passes alone, citizens by birth would still be relying on practice rather than a written exception.

The US side

The US government recognises dual nationality and permits Americans to hold other nationalities, though it says it doesn’t encourage it. You must enter and leave the United States on a US passport, with limited exceptions. See our guide to European citizenship by descent for Americans.

Practical steps

  1. Work out how you are Estonian. Find out whether you hold citizenship by birth or by naturalisation. If you aren’t sure, ask the PPA before doing anything else.
  2. Collect the chain. Get the archive record for your ancestor, then the birth and marriage records for each generation. Documents not in Estonian or English need a sworn or notarised translation. Our document chain guide covers this.
  3. If you are naturalised, don’t take a second citizenship without accepting that you will lose Estonian citizenship.
  4. Watch bills 932 SE and 1059 SE. If you plan to naturalise abroad as a citizen by birth, check the current text first, and ask the PPA in writing if your case is unusual.

To check whether you have a claim, use our free citizenship by descent checker. For other countries, see dual citizenship by descent, country by country, including Estonia’s neighbours in Latvian dual citizenship and Lithuanian dual citizenship.

Frequently asked questions

Does Estonia allow dual citizenship with the USA?

Not as a general rule. Section 1(2) of the Citizenship Act says an Estonian citizen may not hold another citizenship. But the Constitution says no one may be deprived of citizenship acquired by birth, and Estonia’s Interior Minister has said the loss provisions aren’t applied to citizens by birth. So Estonian Americans by birth hold both in practice. No statute says they may, though a bill filed in October 2026 would.

Do I have to give up US citizenship to claim Estonian citizenship by descent?

If you are an Estonian citizen by birth, nothing in the Act makes you prove release from US citizenship. That requirement, in Section 12(2), applies to people acquiring citizenship by naturalisation. A descendant of an Estonian citizen is claiming citizenship by birth, and the Police and Border Guard Board deals with it when you first apply for an Estonian document.

Do Estonians have to choose a citizenship at 18?

The text of Section 3(1) says a person who acquires both citizenships as a minor must renounce one within three years of turning 18. In the Chancellor of Justice’s view this can’t constitutionally force a citizen by birth to give up Estonian citizenship. The government’s 2026 bill describes the Police and Border Guard Board enforcing it against people naturalised as minors.

I’m Estonian by birth. Can I become a US citizen and stay Estonian?

On the official position so far, yes in practice: the Interior Minister said in 2013 that Sections 29 and 30 aren’t applied to citizens by birth. But the Act hasn’t been changed to say so. Section 22(3) still lists accepting another citizenship as a way of ceasing to be a citizen, with no exception, and the Chancellor of Justice warned that this leaves people uncertain.

What happens to a naturalised Estonian who takes another citizenship?

They lose Estonian citizenship. The Police and Border Guard Board treats them as having lost it under Section 29, and the Tallinn Circuit Court has upheld this even for someone who had been Estonian for 30 years. Between 2022 and 2025 it made such decisions about 68 to 92 people a year.

Is Estonia changing its dual citizenship law?

Two bills are in the Riigikogu. Bill 1059 SE, filed in October 2026 by the Reform and Estonia 200 groups, would let citizens by birth also hold US, Canadian, Australian, New Zealand, Swiss, EU or EEA citizenship. Bill 932 SE, a government bill at third reading, rewrites Section 29. Neither was law on 6 November 2026.

My grandfather fled Estonia in 1944. Does the dual citizenship problem affect me?

If he was an Estonian citizen and each generation down to you was a citizen at the next one’s birth, you would be a citizen by birth, the group that the loss rules aren’t applied to, and nothing in the Act would make you give up US citizenship. You prove the link when you apply for your first Estonian document, using archive evidence of his citizenship and your family’s birth records.

Official sources

Checked against these sources on 6 November 2026, when bill 932 SE was awaiting third reading and bill 1059 SE awaited a first reading. The Chancellor’s letters and court judgments were read in Estonian and the summaries here are ours. The 1992 decision is described from the Chancellor’s 2013 letter, not its original text. Only the PPA and the Estonian courts can decide your case; confirm with the PPA or an Estonian embassy before you rely on this.