Contributive Belonging: A New Principle for European Citizenship & Residency

Citizenship acquisition is undergoing a reset. In Europe, the closure of investor citizenship models and the landmark EC v Malta ruling have highlighted the need for frameworks that embed substance in citizenship decisions. Traditional doctrines such as the ICJ’s “genuine link” and EU integration policies provide only partial guidance.

Jean-Philippe Chetcuti introduces Contributive Belonging as a principled response:

“Contributive Belonging is the principle that the grant of long-term residency or citizenship should rest not only on formal criteria but on demonstrable integration and contributions - economic, social, cultural, or civic - that create reciprocal value for the host state.” - Jean-Philippe Chetcuti

This publication situates Contributive Belonging in international and European jurisprudence, showing how it offers a sustainable, fair, and forward-looking framework for states and families

Europe has seen a decisive shift away from transactional models of citizenship. The Court of Justice in EC v Malta (C-181/23, 29 April 2025) held that granting nationality without requiring residence or integration is incompatible with EU law. The Court stressed that nationality is a Member State competence, but where EU citizenship rights are engaged, the manner in which it is exercised must respect European law.

The ruling underscored that citizenship cannot be reduced to a commercial transaction. It must reflect substantive belonging - ties of residence, integration, or contribution that justify access to the rights of Union citizenship.

Rottmann (C-135/08)

In Rottmann v Freistaat Bayern (2010), the CJEU held that a Member State may withdraw nationality acquired by deception, but such a withdrawal “must observe the principle of proportionality” when it entails loss of EU citizenship (para. 55). The Court required national authorities to balance the seriousness of the deception with the consequences of statelessness and loss of rights.

This judgment shows that EU law penetrates the domain of nationality where EU citizenship rights are at stake, emphasising proportionality and fairness. It reflects the idea that rights cannot be withdrawn or denied arbitrarily but must reflect a reasoned balance of interests.

Contributive Belonging complements this reasoning by proposing that acquisition should similarly be tested against a standard of proportionality: rights are justified where individuals demonstrate not only ties but contributions that justify the bond of citizenship.

Tjebbes (C-221/17)

In Tjebbes and Others v Minister van Buitenlandse Zaken (2019), the CJEU upheld a Dutch law providing for automatic loss of nationality for citizens long resident outside the EU. The Court stressed, however, that decisions must include “an individual examination of the consequences of that loss for the persons concerned” (para. 44). The Court underscored that the loss of nationality must be consistent with the principle of proportionality and fundamental rights under EU law.

This ruling highlights the continuing importance of ties: nationality can be lost when links are absent, but safeguards are essential.

Contributive Belonging advances this logic by clarifying that belonging should not be measured only by territorial presence. For globally mobile families, integration can be established by contributions such as economic investment, philanthropic engagement, or cultural participation even where physical presence is limited.

Integration as EU Policy

The Council of the European Union’s Common Basic Principles on Integration (2004) define integration as “a dynamic, two-way process of mutual accommodation by all immigrants and residents of Member States” (Principle 1). This has informed EU policy for nearly two decades, but it does not establish a normative legal standard or recognise global belonging.

Contributive Belonging transforms this principle into a testable framework. It retains the idea of mutual accommodation but adds reciprocity in measurable contributions and adapts to the reality that global citizens often maintain multiple residences.

The EC v Malta judgment crystallised the problem: purely transactional citizenship without ties or integration undermines the substance of EU citizenship. What the Court did not do was propose a positive framework for legitimate acquisition.

Contributive Belonging provides that framework. It requires:

1. Integration through ties - proven by family life, cultural adaptation, professional networks, or educational presence in the host state.
2. Contributions that benefit the host state - economic investment, philanthropy, cultural support, or innovation that strengthen society.
3. Recognition of global belonging — acknowledging that many individuals spend only a few months per year in any one jurisdiction, but remain engaged through sustained contributions.
4. Reciprocity as foundation — ensuring rights are matched by obligations, thereby establishing mutual trust.

Contributive Belonging thus complements the Court’s reasoning by articulating the constructive test missing from EC v Malta.

Defining 'Contributive Belonging'

Contributive Belonging integrates the lessons of Nottebohm, Rottmann, Tjebbes, and EC v Malta into a single normative standard. Its essential features are:

• Integration through demonstrable ties.
• Contributions creating reciprocal value.
• Recognition of global mobility.
• Reciprocity between individual and state.

Contributive Belonging thus addresses the shortcomings of both the genuine link doctrine and EU integration policies by combining integration with contributions in a way that reflects global realities.