Refusal of citizenship by descent: reasons and reapplication in five countries

In brief

• In Bulgaria 16,268 people received citizenship in 2024 and 5,946 were refused a decree. Since 2021 the key requirement is an official document of kinship with a Bulgarian ancestor up to the third degree.
• In Hungary language decides. There is no exam, but the officer at filing speaks to you in Hungarian, and without a free conversation citizenship is not granted.
• In Romania since 15 March 2025 descendants need a B1 certificate. Article 11 cases take years, and a new application can be filed 6 months after a refusal.
• In Austria 8,795 people received citizenship under section 58c in 2024. The procedure is free, and an appeal against refusal usually has four weeks.
• In Israel children and grandchildren of a Jew are eligible, great-grandchildren are not. Refusals most often follow when descent is not confirmed by documents.

Why applications are really refused

In short: refusals are not for lack of roots but for lack of a document. Six reasons recur in all five countries: no record of the ancestor's nationality, a broken chain, different names, an ancestor outside the law, language and doubts about authenticity.

If you break down the refusals we have reviewed over recent years, the list is short. It is the same for all five countries; only the weight of each reason changes.

• No document stating the ancestor's nationality or citizenship. There is grandfather's birth certificate, but the nationality line is blank or says something else. For Bulgaria and Israel this is the main reason.
• A break in the chain. There is a great-grandfather's birth record and your own certificate, but nothing linking great-grandfather to grandfather. The chain must run through every generation without gaps.
• Different names in different documents. In the birth record great-grandfather is Ivan, in the military record Jan, in the Soviet passport Johann. For the authority these are three people until you show a name change document or a court decision.
• The ancestor is outside the law. Romania requires citizenship lost involuntarily. Austria requires Nazi persecution and departure before 15 May 1955. Descent exists, the legal ground does not.
• Language. Hungary checks conversational level on the spot, Romania requires a B1 certificate.
• Doubts about authenticity. If the authority cannot confirm a document with its issuer, that alone is enough to refuse. Since Law 14/2025 Romania says so expressly.

What this means for you. The first thing we do after a refusal is read it word for word. The wording decides what comes next: archives, language study or an appeal.

Bulgaria: one line in one document

In short: you need an official document naming a parent, grandparent or great-grandparent as Bulgarian, and a chain of documents from them to you. Since 2021 the agency certificate does not work without it. In 2024, 5,946 people were refused a decree.

Citizenship by Bulgarian origin is granted under Article 15 of the Bulgarian Citizenship Act. The law does not require language, residence, income or giving up your passport. It requires one thing: proof that at least one ancestor up to the third degree, a parent, grandparent or great-grandparent, was Bulgarian. Bulgarian by origin, not merely a resident of Bulgaria.

Until March 2021 the basis was a certificate from the State Agency for Bulgarians Abroad, often obtained on community recommendations and a questionnaire. After the amendments published in State Gazette No. 21 of 2021 that is no longer enough: the application must include official documents issued by Bulgarian or foreign authorities with the ancestor's name and link to the applicant. Birth, marriage and death records, population register extracts, Bulgarian Orthodox Church registers, old passports and military papers all qualify.

This is what a refusal brought to us usually looks like. A family from a Bessarabian village where everyone was Bulgarian. Grandfather has a Soviet birth certificate from the 1950s with no nationality line, great-grandfather has no documents at all. The applicant brings an agency certificate issued before 2021, a community letter and certificates. A year later comes a refusal: "contradictory data on Bulgarian origin". In such cases the answer is most often in the archive: early 20th century parish registers recorded nationality, and one extract naming great-grandfather as Bulgarian changes the outcome of a new filing.

The application is filed in person at the Ministry of Justice in Sofia or at a Bulgarian consulate; a power of attorney is not accepted. An interview is held at filing. If there are no kinship documents, proceedings are terminated, not suspended. If documents raise questions, the minister may allow 14 days for more papers or pass the case to the agency's advisory council. The Interior Ministry and the State Agency for National Security then check the application, the Citizenship Council reviews it, and only then the Vice President signs a decree.

Figures for 2024 from the Presidency report: 16,268 people received citizenship, most from Ukraine, Turkey, Moldova, North Macedonia and Albania, 474 from Russia. 5,946 people were refused a decree. Another 38 lost citizenship already granted for concealing a criminal record or submitting forged origin documents.

What this means for you. Look not for a certificate but for an entry in a primary record that names the ancestor as Bulgarian. If the paper chain breaks, two routes remain: a claim in a Bulgarian court to establish origin, or assessment by the agency's advisory council.

Hungary: a conversation, not an exam

In short: there is no exam, but at filing you are spoken to in Hungarian, and without a free conversation citizenship is not granted. The second reason for refusals is a document chain missing intermediate generations or marriage records on the female line.

Simplified naturalisation under section 4(3) of the Hungarian Citizenship Act requires no residence in Hungary and no constitution exam. It requires three things: an ancestor who was a Hungarian citizen or came from Hungary, Hungarian language, and no criminal record or threat to security.

The officer receiving the application checks the language. There is no formal test, but the conversation is two-way: you will be asked about family, work and why you are applying, and you must understand and answer without an interpreter. Dialect and mistakes are fine; silence is not. Hungarian consulates state plainly that with insufficient language a positive decision should not be expected, and the level can be checked again at any stage, even when the passport is issued. Everyone from age 14 is checked.

The second common problem is documents. The ancestor is proven by a birth, marriage or death record, a church register extract with volume, page and entry number, a military book, a work book or a school certificate. Civil registration in Hungary began on 1 October 1895; anything earlier is in church registers. For families from Transcarpathia, Transylvania, Vojvodina and southern Slovakia the registers are in the archives of Ukraine, Romania, Serbia and Slovakia, not Budapest.

A refusal we see often: the Hungarian line runs through the maternal grandmother. The applicant brings her birth record and their own certificate but not her marriage certificate. The surname in the birth record and the mother's documents do not match, and the chain breaks. Consulates say it directly: on the maternal line, documents for maiden and married names are required.

A little-known advantage: if a relative has already been naturalised under the simplified procedure, the ancestry documents need not be collected again; that relative's details are enough. After a positive decision the oath must be taken within a year or the decision lapses.

What this means for you. A Hungarian refusal is almost always fixable. Bring conversational Hungarian to a confident level, close the gaps in the chain and file a new application.

Romania: language, deadlines and the queue

In short: since 15 March 2025 descendants need a B1 Romanian certificate. Filing is free, the queue lasts years, and a new application after a refusal is accepted 6 months later.

Restoration of citizenship under Article 11 of Law 21/1991 is open to those who lost Romanian citizenship involuntarily and to their descendants up to the third degree. It is the main route for families from Moldova and the Chernivtsi and Odesa regions of Ukraine: according to the Romanian government, 41% of all applications come from citizens of Moldova.

Since 15 March 2025 Law 14/2025 has added a condition: a descendant proves Romanian at B1 or above. Certificates are issued by accredited Romanian universities, the Romanian Language Institute, the Romanian Cultural Institute and its branches abroad. Three years of study in Romanian can replace the certificate. Former citizens applying themselves and applicants over 65 are exempt. For applications filed after 15 March 2025 without a certificate, the government in March 2026 extended the deadline to submit it by a year, to March 2027. If it is not submitted in time, the application is rejected as unsupported.

Filing is free; only the citizenship card is paid for. Applications are lodged in person at ANC in Bucharest, its offices in Iasi, Galati and Suceava, or Romanian consulates, with biometrics taken at filing. If the commission asks for more documents, up to four months are given, otherwise refusal. Law 14/2025 extended the time for the commission's report to two years with a possible six-month extension, and in practice the queue is longer.

After a refusal a new application can be filed 6 months later. A refusal can also be challenged in court, but if the reason is a missing certificate or document, fixing it and refiling is faster.

What this means for you. Without a B1 certificate an Article 11 application makes no sense today. Language first, then documents, then the application, with time to spare for the queue.

Austria: free, but strictly by definition

In short: the procedure is free with no generational limit, but the ancestor must fit section 58c exactly: lived in Austria and left before 15 May 1955 because of persecution. No proof of departure or persecution means refusal. A court appeal is usually due within four weeks.

Descendants of people persecuted by the Nazi regime acquire Austrian citizenship under section 58c of the Citizenship Act by a simple declaration. No residence in Austria, no exam, no income test and no giving up your passport. There is no generational limit: children, grandchildren, great-grandchildren and further down the direct line, including those adopted as minors. The procedure is free; no fees are charged for the declaration or the decision.

The scale is large. In 2024, 8,795 people received citizenship under section 58c, 99.9% of them living abroad, most of them citizens of Israel, the United States and the United Kingdom. In 2025 there were more than 9,500.

Refusals follow when the ancestor does not meet the definition. They must have been an Austrian citizen, a national of a successor state of Austria-Hungary or stateless, lived in Austria and left before 15 May 1955 because of persecution or its threat. Since 1 May 2022 this also covers those who could not return to Austria in 1933-1945, deportees and those who perished. A typical refusal: the family remembers that great-grandfather "fled Vienna in 1938", but the file has neither a Vienna residence registration nor a departure document. Such documents are sought in the Vienna City Archives, the Austrian State Archives and the archives of the countries the family moved to.

The right is also lost by those who held Austrian citizenship themselves and lost it after 1 May 2022 by acquiring another. The decision is made by the Vienna provincial government, department MA 35. As a general rule an administrative authority must decide within six months; if that is missed, a complaint for delay is available.

What this means for you. A refusal is appealed to the Vienna Administrative Court, usually within four weeks of service. Missing archive documents are sought before the appeal is filed.

Israel: proving the ancestor's nationality

In short: children and grandchildren of a Jew and their spouses are eligible; great-grandchildren have no independent right. Refusals follow when Jewish descent is not confirmed by a document, and on section 2(b) grounds.

The Law of Return gives Jews the right to immigrate, and under section 4A also children and grandchildren of a Jew and their spouses. Great-grandchildren have no independent right under that section. Eligibility is proven with documents on the ancestor's Jewish origin: birth records, civil registry entries, documents that state nationality directly.

A typical problem for families from the former Soviet Union: grandfather's birth certificate has a blank nationality line or says "Russian". Other documents from the same period are then sought: rabbinate records, parish registers, archive questionnaires, military papers, evacuation cards. Section 2(b) lets the Minister of the Interior refuse even where descent is proven: for activity against the Jewish people, a threat to public health or state security, or a criminal past.

What this means for you. A decision of the Population and Immigration Authority is appealed internally and then by an administrative petition to the district court. The deadlines are short and counted in weeks, so decide on an appeal in the first days after a refusal.

Five countries in one table

In short: in Bulgaria and Israel the document on the ancestor's nationality decides, in Hungary and Romania the language, in Austria whether the ancestor's story fits the legal definition.

A refusal by descent is almost always a story about papers, not people. In half the cases that reach us after a refusal, the needed document exists. It sits in a district archive, a parish register or a military record; nobody looked for it. We start with the text of the refusal and only then go to the archives.

Daniel KovachSenior International Law Attorney, BRIDGES

How to reapply

In short: first the refusal text and the appeal deadline, then the archive and the chain check, and only then a new filing. With the same package the result does not change.

• Get the refusal text. Without the wording and the legal ground you will fix the wrong thing.
• Check the appeal deadline. In Austria and Israel it is short. Miss it and only a new application remains. In Romania a new application can be filed after 6 months.
• Find the missing documents. Birth and church registers, civil registry records, military and census records, departure documents.
• Check the chain. Names, dates and places must match across all generations. Discrepancies are explained by a name change document or a court decision.
• Cover the language if it is required. Hungary and Romania grant citizenship to nobody without it.

What this means for you. Reapplying with the same documents repeats the refusal. Time is better spent finding one missing document than on a second blind attempt.

Where families go wrong most often

In short: almost all repeat refusals come from the same five mistakes.

1. Filing the same package again. The authority has already said what is missing. A new filing without it repeats the refusal and costs another year.
2. Relying on certificates instead of primary records. A community letter or an organisation certificate does not replace a birth record naming the ancestor as Bulgarian, Jewish or Hungarian.
3. Leaving name spellings unexplained. Ivan, Jan and Johann in three documents are three people until there is a name change document.
4. Missing the appeal deadline. In Austria and Israel it is counted in weeks. After that only a new application remains.
5. Putting the language off. In Hungary and Romania no archive helps without the language.

What to check before refiling

In short: six points without which it is too early to refile.

What to do now

• Keep the refusal text and the date you received it.
• Identify the type of reason: documents, language, legal ground or security.
• If the appeal period is still running, decide whether to appeal or refile.
• Order archive documents; searching takes weeks and months.
• If the ground does not fit, check other countries: many families have roots in two or three states.

How this material was prepared

Prepared by Daniel Kovach, Senior International Law Attorney at BRIDGES. Facts were checked against the laws and official publications of the five countries on 11 October 2026; typical refusal reasons come from cases we reviewed after refusals.

• Bulgaria - Bulgarian Citizenship Act, Articles 15 and 33-36, as amended by State Gazette No. 21 of 2021; Ministry of Justice document list; annual Presidency report for 2024.
• Hungary - Act LV of 1993 on Hungarian citizenship, section 4(3); Hungarian consulates' requirements for simplified naturalisation.
• Romania - Law 21/1991 on Romanian citizenship as amended by Law 14/2025; ANC information on Article 11; Romanian government statement of 12 March 2026 on extending the certificate deadline.
• Austria - Citizenship Act, section 58c; guidance of the Austrian Foreign Ministry; Statistics Austria data for 2024 and 2025.
• Israel - Law of Return 1950, sections 2(b), 4A, 4B; information of the Population and Immigration Authority.
• Typical refusal reasons and reapplication procedure - our practice.
• All facts checked on 11 October 2026.