Five countries, five different words for the thing at the end of a descent claim, and the word is not decoration: it tells you whether the document creates your citizenship or merely records it, which authority issues it, and whether your children are affected by the date on it.
This is the glossary the rest of this site refers back to. Every later post uses these terms exactly as they are defined here, and none of them re-explains them.
The five grants, side by side
| Country | What it is called | Who issues it | Creates or records? |
|---|---|---|---|
| Ireland | Entry on the Foreign Births Register | Department of Foreign Affairs | Creates — citizenship dates from the entry |
| Canada | Certificate of citizenship, applied for as proof of citizenship | Immigration, Refugees and Citizenship Canada | Records |
| Germany | Staatsangehörigkeitsausweis — certificate of citizenship | Bundesverwaltungsamt, via a German mission abroad | Records |
| Italy | Riconoscimento — recognition, entered in a comune’s civil register | Consulate, comune, or a court | Records |
| Poland | Potwierdzenie posiadania obywatelstwa polskiego — confirmation of possession | The voivode (wojewoda) of the relevant province | Records |
Four of the five are findings about a status you already hold. Ireland’s is the exception, and it is the reason you may already be a citizen is a post of its own.
Ireland: entry on the Foreign Births Register
The register is kept by the Department of Foreign Affairs, which publishes the application and the current fee on its Foreign Births Register page. Under the Irish Nationality and Citizenship Act 1956, as amended, citizenship acquired this way runs from the date of the entry rather than from your birth.
The consequence is the whole of the Irish rule: a child of yours born before your entry does not inherit the line, and a child born after it does. The Foreign Births Register is the post that takes that apart; the filing itself is the documents in order.
Canada: the certificate of citizenship
IRCC issues one certificate, and it is what a descent claimant applies for when they apply for “proof of citizenship”. There is no separate grant for someone claiming by descent: either the Citizenship Act made you a citizen at birth, in which case the certificate records it, or it did not, in which case there is nothing to certify.
Since 15 December 2025, when Bill C-3 changed the first-generation limit, the question for someone born abroad to a Canadian parent also born abroad is whether that parent spent at least 1,095 days in Canada before the birth. Checked on 5 September 2026 against IRCC’s eligibility page, last modified 18 February 2026. Applying for proof covers the filing.
The same certificate is also what Canadians already resident in Canada replace when they lose theirs, which is why searching for it turns up a great deal of writing that has nothing to do with a descent claim.
Germany: the Staatsangehörigkeitsausweis
Germany separates the status from the proof more sharply than any other country here. Under section 4(1) of the Staatsangehörigkeitsgesetz you are German from birth if a parent was; the Staatsangehörigkeitsausweis — literally the certificate of citizenship — is the document by which the Bundesverwaltungsamt establishes that with binding effect. Its own English guidance is the starting point, and the German missions in the United States publish the consular half at germany.info.
Two neighbouring documents are not the same thing and are frequently confused with it:
- The declaration under section 5 StAG, which is how a line broken by the old rules on maternal descent and unmarried fathers is repaired. It is a declaration you make, within the window opened in August 2021 for ten years — see the section 5 declaration.
- Naturalisation under section 15 StAG, and restoration under Article 116(2) of the Basic Law, for the descendants of those deprived of citizenship on political, racial or religious grounds. Those are routes to citizenship, not certificates of one you hold.
The German line sets out which of the three applies to which family.
Italy: riconoscimento
Italian law does not grant descent citizenship; it recognises it. Under Law no. 91 of 5 February 1992 the status runs from birth, and the riconoscimento is the administrative act that acknowledges it and results in your entry in the civil register of a comune, after which Italian civil documents can be issued to you.
Where it is done is the practical question, because there are three forums with different queues: the consulate for the district where you live, a comune in Italy if you are resident there, and a court where the route requires one. The Ministry of Foreign Affairs publishes the consular procedure on its citizenship pages. The decree-law of 28 March 2025, converted with amendments into law in May 2025, narrowed who may be recognised, generally to those with an Italian-born parent or grandparent; the Italian line is the verdict on what that did.
Poland: potwierdzenie
The Polish document says what it is on its face: confirmation of possession of Polish citizenship. A voivode examines the record and finds either that you hold Polish citizenship, or that you do not, or that an ancestor lost it and when. gov.pl describes the procedure on its service page.
Because it is a finding on a historical record, the difficulty in a Polish claim is usually archival rather than legal, and a decision can go against you on a document you never saw. The Polish line covers the loss rules that those decisions turn on.
The three documents none of these are
A passport. Every country here treats the passport as a separate application made after the status is established. Timelines quoted for one are not timelines for the other.
A visa or a residence permit. Nothing in this post is an immigration route. Where a line does not hold, what remains is usually an immigration question, and that is a different subject.
A US Certificate of Citizenship. United States Citizenship and Immigration Services issues a document with almost exactly that name to people who acquired US citizenship through a parent. It is a real document and it has nothing to do with any claim on this site. A search for “certificate of citizenship by descent” returns a great deal about it.
Why the word matters when you are reading anything else
Once you know which word your country uses, you can tell within a sentence whether a page is describing your route or somebody else’s — and whether the person who wrote it knew the difference.
A page that says an Italian claim is “granted”, or that an Irish registration “proves” a citizenship you already had, has the mechanism backwards, and the mechanism is what decides whether your children inherit. That test is worth applying to anything you are about to pay for: which claims need a lawyer applies it to quotes.