User:Mr248/Citizenship and nationality

This is my draft for an alternative to the current content of Wikipedia:Citizenship and nationality. If no editor objects, I plan to replace the contents of that essay with the below. (If other editors do object, I may adjust my plans depending on the details of their objection(s).)

See also: Wikipedia:Manual_of_Style_(biographies) § Opening paragraph

The terms citizenship and nationality are related yet distinct terms. The precise distinction between them, however, differs from context to context, and different speakers may use these terms in different ways. Both are legal terms, and this essay will endeavour to give an overview of the legal distinction between "citizenship" and "nationality"; both are also used in non-legal contexts in ways distinct from their legal use, and this essay will also attempt to provide an overview of the different non-legal ways in which those two terms are used.

This essay contains a number of "Suggestions", which contain advice on certain particular issues around the use of these terms on Wikipedia; but it does not attempt to propose any formal guidelines for their use. Its primary aim is to educate editors in the variety of ways the two terms are used–possibly that education may eventually form the basis of more formal editorial guidelines.

The most important takeaway from this essay, hopefully, is that "citizenship" and "nationality" is a very complex topic, and there is no universal agreement on how those terms are defined or ought to be used.

Legal definitions

Legally the concepts of nationality and citizenship can be distinguished as follows:

• nationality is a relationship between an individual human being (a natural person) and a sovereign state, characterised by mutual obligation: the national owes the state allegiance and obedience to its laws; the state owes the national a duty of protection
• citizenship is political and civil rights in a particular state, such as the right to vote and stand for election

A person can have the nationality of one state only (a sole national), or they can have the nationality of two different states simultaneously (a dual national), or even three or more (multiple nationality). It is also possible to not be a national of any state (statelessness).

Citizenship requires nationality, but the reverse is not necessarily true; some states have a category of "non-citizen nationals" who possess nationality yet lack citizenship. At least one state (the UK) has several different types of citizenship, even with the possibility to possess two different types of citizenship simultaneously (it is possible for a British national to be both a British citizen and a British Overseas Territories citizen at the same time.)

Approaches

In contemporary legal systems, three main approaches to the relationship between nationality and citizenship can be observed:

• All nationals are citizens and all citizens are nationals. Under the laws of some states, every national is also a citizen, there is no category of "non-citizen nationals". While some legal textbooks may still draw the traditional technical distinction between nationality and citizenship, in legal practice the two terms tend to be used interchangeably. An example of a country which takes this approach is Australia – there is no distinction under Australian law between "Australian citizenship" and "Australian nationality". Given that legal reality, some Australian editors may be inclined to treat "citizenship" and "nationality" as synonyms and use the two words interchangeably (that said, in Australian English, the term "citizenship" is far more popular than the term "nationality")

• The vast majority of nationals are also citizens, but there are a small minority of nationals who lack citizenship. This is the approach taken by the US and the UK. Under US law, the vast majority of US nationals are also US citizens, but there are a small minority of "US nationals without citizenship". US nationals without citizenship have the right to a US passport and the right to live in the mainland US, but they lack the right to vote in US elections. Today, the only major category of US nationals without citizenship are American Samoans; however, historically, the category was much more numerous – prior to Philippine independence, most Filipinos were classed as American nationals without citizenship. Similarly, UK nationality law has a category of "British subjects without citizenship" who possess British nationality but lack British citizenship–unlike the US case, British subjects without citizenship are not entitled to enter into or remain in the UK, but they are entitled to a British passport. However, in both the US and the UK case, since "nationals without citizenship" are a numerically tiny group of which most people are unaware, for many practical purposes legal nationality and legal citizenship are synonymous, and hence there can also be a tendency in practice to treat the two terms as synonyms and use them interchangeably

• Nationals become citizens upon reaching the legal age of majority. This is the model adopted in Mexico and a number of other Latin American legal systems. A person born in Mexico (or born aboard to Mexican parents) will (generally speaking) become a Mexican national at birth, but will only become a Mexican citizen when they turn 18. Also, under Mexican law, a Mexican citizen can lose their citizenship if they (for example) accept a noble title from a foreign government, but if they lose their Mexican citizenship in such a case they will still retain their Mexican nationality.

Suggestions: It makes sense to note legal nationality/citizenship (where known) in Wikipedia biographical articles. In the majority of cases, it does not make sense to separately note legal nationality and legal citizenship, since in many cases they will be the same – always for those countries which adhere to the rule of "all nationals are citizens", and almost always for countries which adhere to the rule of "the vast majority of nationals are citizens"; and even in countries such as Mexico, their citizenship will almost always automatically follow from the combination of nationality and age. The exceptional circumstances in which it may make sense to separately note a person's legal nationality and legal citizenship are (i) they are a non-citizen national of a state (such as an American Samoan who is legally a "US national without citizenship"; or a "British subject without citizenship"); (ii) they have lost their citizenship (but not their nationality) due to some act, such as the case of a Mexican national who loses their Mexican citizenship due to accepting a foreign title of nobility.

Statelessness

A person who is not a national of any state is legally classified as stateless. This is a dangerous situation to be in – it can leave one without legal right to live anywhere on earth. The Universal Declaration on Human Rights (and a number of international human rights treaties) declare that everyone has the right to a nationality. Despite this, it can still happen, due to various legal technicalities or political decisions, that a person ends up with no nationality at all. Through the 1961 Convention on the Reduction of Statelessness, and other international agreements, states have accepted an international legal obligation to seek to reduce the incidence of statelessness.

Since legal citizenship requires legal nationality, a person who is not a national of any state is also not a citizen of any state. Hence, stateless persons, as well as lacking nationality, also lack citizenship. However, the reverse is not true – there are people who are nationals of a state but are not citizens of any state. For example, a person who is a "British subject without citizenship" has British nationality, but lacks British citizenship, and if they also lack any other legal nationality, they will be without the legal citizenship of any state. However, despite not legally being a citizen of any state, they are still not legally considered stateless, since they possess British nationality. (They may effectively be exposed to disadvantages very similar to those of statelessness, since their British nationality does not entitle them to live in the UK, and lacking any other nationality, they may lack legal rights of residence anywhere on earth.)

Some people may be refused a passport by the state of their nationality, due to political or other reasons, even while it continues to legally view them as its nationals. Such people are not technically stateless, but may be effectively considered so. Sometimes this distinction is explained in terms of de jure vs de facto statelessness; de facto statelessness is also called effective statelessness. While de jure statelessness has a clear legal definition and clear legal consequences, the legal significance of de facto statelessness is more controversial, especially since there can be a greater degree of subjective judgement in determining whether it exists.

Suggestions: If it is established by reliable sources that an individual is (or was) stateless, this may well be an important biographical fact about them. It would seem justifiable to record this fact in an infobox (such as using "nationality" or "citizenship" parameters). When an individual is formerly stateless, it may makes sense to include that fact in their infobox along with a parenthetical remark indicating the years in which it applied, if that fact can be established from reliable sources. If reliable sources establish that a person is effectively stateless, but not stateless in a strict legal sense, it may be better to only cover that fact in the main body of the article and not the infobox, since it may be difficult to convey the nuance of being "effectively-but-not-strictly-legally" in an infobox.

Acquisition of nationality

These are the main ways in which one may legally acquire the nationality of a state:

• by birth in the territory of the state (jus soli). This often also includes birth in international waters onboard a ship or aircraft registered to the state. Often, children of foreign diplomats are excluded. Some states also exclude children of illegal immigrants.
• by birth to parents having nationality of that state (jus sanguinis). Rules differ on whether nationality can be inherited from both parents, or only from the father, or only from the mother. Some states exclude illegitimate children, or apply different rules to legitimate and illegitimate children. It is common (but not universal) to have a limit on the number of generations by which one may inherit citizenship by birth abroad.
• by marriage: historically, it was common that a woman automatically acquired the legal nationality of her husband upon marriage. (Rules providing that a husband would automatically acquire the legal nationality of his wife were very rare, if not non-existent.) Often it was assumed (due to coverture) that a wife would automatically have the same nationality as her husband. Nowadays such rules are increasingly rare, since they are generally viewed as incompatible with gender inequality; that said, even when such rules are abolished, the abolition is not retroactive, so they can still be important in determining the nationality of people in the present.
• by naturalisation: this is where a foreign national applies to become a national of the state. Often there are requirements for some number of years continuous lawful permanent residency, citizenship tests, good character tests (such as absence of any serious criminal record), and various other requirements. Often there is an element of government discretion involved, but it varies from country to country. Some states also have a simplified procedure for acquiring nationality – often with reduced or waived residency requirements – for certain classes of people, for example former nationals or foreign nationals descended from nationals. Some states call such a simplified procedure registration rather than naturalisation.

Different states have different laws, but generally some combination of the above four routes exist. Some states (for example, Germany prior to the 1999 legal reforms) reject jus soli and hence a person born on their territory to non-national parents does not acquire the state's nationality no matter for how many generations their ancestors may have lived in that state.

Acquisition of citizenship: In very many cases, acquisition of nationality automatically implies acquisition of citizenship. For example, acquisition of Australian nationality automatically entails acquisition of Australian citizenship, since Australian law does not draw any practical distinction between Australian nationality and Australian citizenship. Even for states like the US and the UK which maintain a concept of "non-citizen nationals", the vast majority of people who acquire nationality acquire citizenship at the same time. Anyone born in the mainland US (except those whose parents are foreign diplomats) acquires both US nationality and US citizenship at birth; anyone naturalised in the mainland US also acquires both at the same time. A person born in American Samoa would by birth there acquire US nationality but not US citizenship – but, less than one thousand people are born in American Samoa each year, compared to 3–4 million in the US as a whole, so US nationals born without citizenship are vastly outnumbered by those born with it. By comparison, in the case of Mexico, whether one acquires citizenship with one's nationality depends on the age at which one acquires it – if one becomes a Mexican national by naturalisation, then one becomes a Mexican citizen as well immediately if one is already aged 18 or over, whereas those naturalised as Mexican nationals prior to their 18th birthday have to wait until the day of their 18th birthday to automatically receive their Mexican citizenship. Likewise, anyone acquiring Mexican nationality at birth (whether by birth in Mexico or by descent) has to wait until the day of their 18th birthday to receive their Mexican citizenship.

Suggestions: Where the laws of a state provided that people born on its territory are automatically nationals from birth, Wikipedia can assume the existence of legal nationality even in the absence of a reliable source explicitly stating it exists. For example, consider the case of a person born in the United States and who has lived their entire life there – such a person can be assumed to be a United States national (and hence a United States citizen) unless there is some reason known why they would not be (e.g. their parents were foreign diplomats stationed in the US at the time of their birth). If there is no evidence they've emigrated from the United States, it can also be assumed they have not renounced their US nationality, since the US government does not permit renunciation of US nationality by residents of the United States.

Loss of nationality

The main ways in which nationality can be lost are:

• renunciation: by lodging a sworn declaration (and sometimes also payment of a fee) at a foreign embassy or consulate of that nation. Few nations permit renunciation of nationality within their territory. Many (but not all) also require that one have some other nationality, to avoid people making themselves stateless by renouncing their sole nationality
• by acquiring another nationality: many states have laws against multiple nationality, and provide that nationality is lost upon acquiring a foreign nationality. Under some state's laws the loss of nationality is automatic; in other cases, it is not automatic but requires government action. Some states make an exception to the rule against multiple nationality in cases of nationalities acquired at birth – so a person can acquire a foreign nationality at birth (such as by descent from a foreign national parent) without losing their nationality, but any acquisition of a foreign nationality after birth will cause their nationality to be lost. Yet other states provide that a person born with multiple nationalities must choose upon reaching a certain age to either renounce the foreign nationalities or else their nationality of that state will automatically be lost.
• due to fraud during naturalisation: many states provide that a person who lies during their naturalisation process can have their naturalisation invalidated. For example, if they committed serious crimes prior to their naturalisation and did not disclose them during the naturalisation process. This does not apply to crimes committed after naturalisation. In some such cases, their naturalisation may be legally annulled with retroactive effect and they may be considered to have never legally been a national of the country in question. A notable case was the Ukrainian-American John Demjanjuk, who had his US naturalisation annulled due to his failure to disclose that he had been a Nazi concentration camp guard; subsequent to the annulment of his US naturalisation, he was deported to Israel to stand trial for his involvement in the Holocaust.
• by government decree: some states provide that nationality may be withdrawn by government decree, in the interests of "national security" or if they have committed a serious crime. Often, this only applies to dual nationals, since doing that to a sole national would render them stateless
• by committing certain wrongful acts: some states provide that a person who joins a foreign army to fight against the state automatically loses their nationality due to that act of treachery.

Loss of citizenship: Since citizenship requires nationality, loss of nationality automatically implies loss of citizenship. Most states do not provide any way for nationals to lose their citizenship yet keep their nationality. Latin American states such as Mexico are the main exception – under Mexican law, a Mexican citizen who engages in certain acts (such as accepting a foreign title of nobility) automatically loses their Mexican citizenship yet retains their Mexican nationality.

Suggestions: If a reliable source indicates a person has lost their nationality, that fact should be included in a biographical article on them. In such a case, if the year in which they lost their nationality is known, it would make sense to add to the "nationality" of the Infobox the years in which they had that nationality. However, in cases of retroactive loss of nationality (naturalisation fraud cases) it is probably better to exclude that nationality from the Infobox since the retroactive nature of its loss is difficult to clearly convey in an Infobox. Since loss of nationality and loss of citizenship usually go together, there is generally no need to note that a person who has lost their nationality has also lost their citizenship. Be aware that some sources may use the terms "loss of citizenship" (or "renunciation of citizenship" or "revocation of citizenship"), but most of those sources are actually talking about loss of nationality as well, just choosing to describe the event in terms of citizenship rather than nationality. The exception would be any sources describing cases in which a person loses citizenship while retaining nationality, such as can happen to a Mexican citizen who accepts a foreign title of nobility.

Passports

Usually, nationals of a state are entitled to a passport. Even non-citizen nationals (of those states which have such a category) are usually entitled to a passport, even as they are denied rights of citizenship such as the right to vote or the right to legally permanently reside on the territory of the state.

However, there can be rare cases in which a passport is mistakenly issued to a non-national, such as due to some administrative mistake or legal confusion. In such cases, the wrongly issued passport may later be cancelled. Such cases may sometimes be described in popular or media sources as "loss of citizenship", but from a technical legal viewpoint the person was never a citizen (or national) to begin with. It may indeed be experienced as a "loss of citizenship" by the person whose passport is cancelled, since they may have honestly believed themselves to be a lawful national and/or citizen of the country which issued them the passport, even if strictly legally speaking they never were.

There can be other cases in which states knowingly issue travel documents to non-nationals – most commonly this happens in the case of refugees, who may be issued with refugee travel documents by states of which they are not nationals. While such a travel document can be used as a passport in international travel, its issuance does not make the recipient a national or citizen of the country which issued it. There are other cases in which countries may issue non-nationals with travel documents, such as stateless persons and foreign nationals who are refused a passport by the government of their state of nationality.

Although usually nationals are entitled to a passport, there are cases in which issuance of a passport can be denied, or an existing passport can be cancelled:

• if there are pending criminal charges or an open criminal investigation
• if there are unpaid taxes, unpaid debts, unpaid child support, etc
• unfulfilled military service obligations
• in cases of "national security" – sometimes some governments (especially non-democratic ones) will abuse this ground to deny passports to political dissidents

Denial or cancellation of a passport does not automatically entail loss of nationality. While in some cases a government may deny or cancel a passport because it believes the person is not (or never was) a national, or as part of the act of revoking nationality, in many other cases the denial or cancellation of a passport does not effect any loss of nationality or citizenship. Usually, when a passport application is denied, or an existing passport is confiscated or cancelled, due to criminal matters, unpaid taxes or debts, etc, no loss of nationality actually occurs.

Suggestions: Be careful with cases of passports incorrectly issued to non-nationals being withdrawn. Even though popular media sources may sometimes describe them as "loss of citizenship" or "revocation of citizenship", Wikipedia articles should not repeat that potentially mistaken framing unless reliable sources indicate that is the actual legal reality. Also be careful with some sources which may incorrectly confuse denial of a passport, or cancellation of a passport, with loss of nationality and citizenship, when the former very often does not entail the later.

National origin

Anti-discrimination laws commonly prohibit discrimination on the basis of "national origin", defined as the nation (country) in which a person or their ancestors were born. While this is a distinct legal concept from "nationality", the two concepts may be confused in some popular/non-technical sources.

There is also the non-legal concept of "national identity" (see below), which refers to the nation with which a person subjectively identifies. Some sources may use the phrase "national origin" to mean the non-legal concept of national identity. A child born to expatriates, temporary residents or diplomatic/consular staff may not consider the country of their birth to be their "national origin" even if it counts as such by some legal definitions; but in that case, they may be using the phrase "national origin" to refer to the non-legal concept of "national identity".

Suggestions: A person's "national origin", in the legal sense of that term in anti-discrimination law, is unlikely to be relevant to Wikipedia articles, unless the article is discussing anti-discrimination law or cases decided under it. Outside of that legal context, sources referring to a person's "national origin" may actually be discussing the non-legal concept of "national identity".

Other legal senses of citizenship

• Some countries have a legal concept of citizenship in subnational entities – for example, US constitutional law contains the concept of "citizenship of a state" (see the Citizenship Clause). In general, a US citizen is considered a citizen of the US state in which their primary place of residence (domicile) is presently located; a citizen of Alabama loses their Alabama citizenship and becomes a citizen of New York merely by permanently relocating their primary residence from Alabama to New York. This concept mainly comes up in discussions of the jurisdiction of US federal courts – one way to establish federal court jurisdiction over a lawsuit is to establish that the parties to the lawsuit are citizens of different states (diversity jurisdiction); it has little practical significance outside of that specific legal context.

• Some countries have a legal concept of citizenship in their overseas or dependent territories. For example, the United Kingdom has a distinct category of British Overseas Territories citizen (BOTC) separate and distinct from ordinary British citizenship. BOTC entitles one to a legal right of residency in one (or more) of the British Overseas Territories, but does not by its own terms entail any legal right to reside in the mainland UK; by contrast, ordinary British citizenship entails the legal right to reside in the mainland UK, but not the legal right to reside in the overseas territories. Nowadays, almost everyone holding BOTC is entitled to acquire ordinary British citizenship by a simplified procedure, but historically that has not always been the case.

• There is a concept of EU citizenship, which adds to (but does not replace) national citizenship of one or more EU member states. (However, there are some nationals of EU member states which lack EU citizenship – for example, Danish citizens with ties only to the Faroe Islands and not to Greenland or Denmark proper lack EU citizenship, whereas all other Danish citizens possess it.) In principle, other supranational organisations could also adopt such a supranational citizenship. Indeed, Mercosur (a union of several South American sovereign states) is currently in the process of establishing its own common citizenship, comparable to EU citizenship, the Citizenship of Mercosur.
• Tribal citizenship – in the US, membership of one of the federally recognised indigenous tribes is legally considered as tribal citizenship. See the section "Indigenous peoples as nations" (below) for more discussion of this topic.

Suggestions: Many of the above other legal senses of citizenship should not be noted in a Wikipedia biography article unless they are somehow relevant to the individual's biography. For example, the legal notion of citizenship of a US state is unlikely to be relevant to an individual's biography unless they become involved in a legal case in which federal diversity jurisdiction becomes an important legal issue. Even in such a case, while it might make sense to mention their US state of citizenship in the article text, it would be confusing to put it down as their citizenship in an infobox.

Similarly, while most citizens of EU member states possess EU citizenship, there is probably no value in adding that fact to an individual's biography article unless that fact was somehow significant to their own biography–for example, if they were involved in a legal case concerning the legal rights of EU citizens. And even in those cases when their EU citizenship was significant in their biography, it would be confusing to note it in an infobox.

Non-legal definitions

As well as legal definitions of citizenship and nationality, there are also non-legal definitions. This section will attempt to provide an overview of non-legal definitions of those terms, and what relevance those definitions could have for Wikipedia articles.

Honorary citizenship

Some countries have issued honorary citizenships. In the vast majority of cases honorary citizenship is purely symbolic and does not amount to a grant of substantive legal nationality or legal citizenship. (There may of course be rare exceptions to that generalisation.) In addition to honorary citizenships at the national level, sometimes honorary citizenships have also been awarded at the sub-national level (state, province, city, etc).

Suggestions: Since in many cases this is a rare and exclusive award, it does make sense to note it in an individual's biography. However, it is important in doing so not to cause the confusion that the person possesses substantive legal citizenship, since they very likely do not. This implies that honorary citizenships should not be listed under "nationality" or "citizenship" in Infoboxes, although they can be listed under "awards".

Citizenship in political science and political philosophy

The concept of citizenship is studied in political philosophy and political science. While there is an obvious overlap between the political/philosophical and legal concepts of citizenship, they are not identical. A political theorist may be interested in the question of what it means to be a citizen of a subnational political entity – a state, province, city, town or village – even though in legal terms such citizenship may not be an independent legal status. A political theorist may also be interested in ways in which people who lack the full legal rights of citizenship – such as lawful permanent residents – nonetheless engage in some of the processes of citizenship, such as activism, political campaigning, civic-minded volunteering, etc. The Stanford Encyclopedia of Philosophy article on Citizenship provides a good overview of philosophical perspectives on the topic of citizenship.

Global citizenship and world citizenship

Some advocate for a concept of global citizenship or world citizenship. This can be presented as a choice an individual can make to prioritise viewing themselves as a member of common humanity as opposed to belonging to a particular sovereign state or national/ethnic group. The term can also be understood, not as alternative to national citizenship, but as an additional layer on top of national citizenship, composed of rights and obligations under international law, much as EU citizenship is defined as an additional layer on top of national citizenship of the EU member states, composed of rights and duties under EU law.

However, at present, there is no consensus in international law to accept "global citizenship" or "world citizenship" as a legal concept, even though some proposals for such a concept construct it out of existing rights and obligations established under international human rights law and international humanitarian law. Some also connect the idea of "world citizenship" with proposals for the establishment of a world government.

Suggestions: Although some article subjects may identify with the "world citizen" movement, it is not appropriate to list that as their citizenship or nationality in infoboxes. Doing so could be viewed as supporting their advocacy for the concept of "world citizenship" rather than treating it neutrally.

National identity

National identity is a person's subjective sense of belonging to a particular nation or national group. That nation may be an internationally recognised sovereign state, or it might not. A person might consider their national identity to be something which others consider a subnational entity or an ethnic group. Some people use the term "nationality" as a synonym for "national identity"; others prefer the term "national identity" because it avoids any potential confusion with the legal concept of nationality.

A person can lose their legal nationality–most commonly by their voluntary renunciation, but sometimes involuntarily as well–yet still subjectively identify with that nation. For example, an American who emigrates from the United States, and then renounces their American nationality and citizenship (maybe in order to avoid paying US income tax), may still maintain for themselves a subjective national identity as an American, even though they have chosen to voluntarily relinquish the legal status of being an American national.

An American who moves to Australia and becomes a naturalised Australian citizen may view their national identity as American, Australian, both American and Australian, or as American-Australian. However, while some might call "American-Australian" a national identity, others (possibly even including some American-Australians) would insist that it is instead an ethnic group, an ethnicity, or an ancestry group, rather than a national identity.

Similarly, some Italian-Americans may consider "Italian-American" to be their national identity; others would insist that their national identity is just American, and that Italian-American is instead their ethnicity, ethnic group, ancestry or heritage. Their view on this question may or may not be influenced by the question of whether or not they hold Italian citizenship by descent, or solely US citizenship; it may also be influenced by the question of whether their Italian ancestry is from recent or more distant immigration.

Hyphenated identities such as "Italian-American" are sometimes understood as cases of a "hyphenated national identity", which may be conceptualised as distinct national identities, or as variations of a single national identity, or as combinations of two (or more) distinct national identities. Individuals differ in the extent to which they view such a hyphenated identity as a national identity or as an ethnic group identity.

Suggestions: Sometimes disputes arise about whether the "nationality" parameter in an Infobox should refer to legal nationality or subjective national identity. Might one solution to those disputes be to add a "national_identity" parameter distinct from the "nationality" parameter, and reserve "nationality" for legal statuses only?

Ethnicity, nationality and nationalisms

The relationship between ethnicity and nationhood is a matter of dispute. Some ethnic groups do identify themselves, or are identified by others, as "nations". The concept of the nation-state proposes as an ideal that each distinct nation should have its own sovereign state and each distinct sovereign state should exist to represent the interests of a single nation. In practice, some groups who identify as nations are presently denied their own sovereign states by the international community (for example, Kurdish nationalism); and not all sovereign states are nation-states, some are multinational states in which no single ethnic nation is dominant. There are also many cases in which states with a dominant national majority also contain one or more national minorities living within them. It is debated whether the ideal of "one state per a nation, one nation per a state" ought to be upheld in practice, or whether it is in fact a harmful aim, or impractical and unrealistic idealism. Even groups which support a state for a particular ethnic nation may not always extend that support to other ethnic nations, whether as a matter of principle or as a matter of realpolitik. The idea of ethnic nationhood is often associated with the concept of ethnic nationalism.

Nationalism is often classified into a number of different forms, each of which supposes a different concept of the "nation". Most of these forms have in common the belief that "nationhood" should somehow be reflected in the structures of government, although they vary from demands that the nation ought to have its own independent sovereign state (if it does not already) through to demands for some form of autonomy within a multinational state (or even a state which identifies itself as a nation-state of some other nation). The various forms of nationalism include:

• Racial nationalism: in which the "nation" is defined as members of a particular race (however the highly contested notion of "race" may be defined)
• Ethnic nationalism: in which the "nation" is defined as members of a particular ethnic group
• Cultural nationalism: in which the "nation" is defined as those who share a particular culture
• Linguistic nationalism: in which the "nation" is defined as members of a particular linguistic community, those who speak a particular language
• Religious nationalism: in which the "nation" is defined as adherents of a particular religion, or in which practicing a particular religion is viewed as necessary (but possibly not sufficient) to belong to the nation
• Civic nationalism: in which the "nation" is defined as citizens of a particular entity, or residents of a particular territory, irrespective of their race, ethnicity, culture, language or religion. The mainstream of the contemporary Scottish nationalist movement is often cited as an example of civic nationalism, since it views everyone who lives in Scotland as belonging to the Scottish nation, irrespective of their race or religion or language or ethnic identity

Each of the above definitions of nationhood in turn has the potential to produce a concept of "nationality", which is the property possessed by members of that nation, or the relationship which exists between each individual member of the nation and the nation as a whole. Since these nations can all be viewed as political constructions, those senses of "nationality" can in turn be viewed as political constructions–however, that itself is a politically controversial claim, since some adherents of nationalism will insist that the nation is a natural entity, not a political construct.

Ethnicity is generally speaking less of a politicised construct than ethnic conceptions of nationality. In many countries "ethnicity" is not considered a legal category, and is purely determined by individual self-identification, however that is not universally true – some countries have legally recognised ethnic groups which are recorded on national identity cards, and there may be legal or bureaucratic restrictions on the ability of an individual to change the ethnicity recorded on their national identity card if they do not agree with it. There can also be issues where an individual identifies with an ethnic identity which is not recognised as an ethnic identity by the state–the People's Republic of China officially recognises 56 ethnic groups, but there are also ethnic minority groups within China who are denied recognition by the Chinese government as one of those 56.

Some people may identify a member of a "nation" which is broader than any single existing sovereign state. For example, an Arab nationalist may consider themselves first and foremost as a member of the Arab nation, and view their legal nationality (as Egyptian or Syrian or Jordanian or Lebanese or whatever) as strictly secondary. Such a person may claim that their nationality is Arab even though there is not currently any singular Arab nation-state. By contrast, others may view "Arab" as an ethnic group or a collection of related ethnic groups (a meta-ethnicity), rather than as a nation per se. An Islamic nationalist may view Islam, not just as their religion, but also as their national identity and hence even nationality.

Suggestions: It is hard to propose guidelines in such a highly contested area. On the one hand, if a person identifies with a particular "nation", however that "nation" is defined, it may make sense to accept their self-identification for the purposes of an article about them. On the other hand, doing so might be seen as endorsing their political views and hence violating NPOV. In cases where the "nationality" is generally understood as an ethnicity and is not considered a legal nationality, it may make sense to record it in an Infobox as an "ethnicity" rather than a "nationality".

Nations within a nation

Some independent sovereign states are composed of multiple nations (multinational states). In some cases, the state as a whole is viewed as a nation–by at least some of its citizens–but that nation is viewed as having nations ("sub-nations?") within it. Some might also call a nation containing sub-nations a "meta-nation". Very often, in such states, there are political disputes, between those who want to maintain the unity of the state, and hence prioritise the national identity of the state as a whole, and those who seek independence for one or more of the nations within the state, and hence want to prioritise those individual national identities over the state's overall national identity–or in some cases even reject that overall national identity entirely. This essay considers two examples in particular – the constituent countries as nations within the United Kingdom, and the Québécois within Canada.

UK constituent countries

The United Kingdom is composed of four "constituent countries" – England, Scotland, Wales and Northern Ireland – who are commonly referred to as "nations", and collectively as "Home Nations". Cornwall is currently officially considered part of England, but historically had a distinctive language and culture, and hence some identify the existence of a distinct Cornish nation. The Isle of Man is a crown dependency in the Irish Sea, and its people are also sometimes identified as a distinct Manx nation. Despite this popular concept – which is at times endorsed at the official level, such as Prime Ministerial speeches – of "nations-within-a-nation", in legal terms there is only British nationality. Scottish nationality may exist in a non-legal sense, as an identity, but legally speaking the only nationality involved is British. (Of course, if Scotland were to become independent, that would change, and there would legally exist a separate Scottish nationality distinct from British nationality.)

In the UK, many people simultaneously identify as belonging to one these nations and also simultaneously to the British nation. However, a person's political views can influence how they view themselves – a Scottish nationalist may view their primary national identity as Scottish, and may view their British national identity as secondary (or even reject a British national identity for themselves); by contrast, a Scottish unionist may view their Scottish and British national identities as equal, or even view the British national identity as more important to them than a Scottish national identity. But, while often people's perception of their own national identity is influenced by their political views, a person may come to view their national identity in a particular way without necessarily holding any settled views on related political issues (such as devolution or independence).

In Northern Ireland, a person's national identification is very often determined by whether they support Northern Ireland as being part of the UK (the viewpoint of the unionist community), or whether they support a United Ireland (the viewpoint of the nationalist community). Nationalists generally identify as Irish only, and not as British. Some Unionists view themselves as both British and Irish, whereas others reject an Irish identity and view themselves as British only. People born in Northern Ireland (generally speaking) acquire British citizenship by birth, and have the legal right to receive Irish citizenship on application, and hence may legally apply for and use a passport of either (or both) countries. A person's self-conception of their national identity may influence (or be influenced by) their choice of citizenship(s) and passport(s), yet may also exist independently of it. In some cases, a person's decision to apply for Irish citizenship and an Irish passport may be motivated by pragmatic concerns (such as maintaining the rights of EU citizenship in the face of Brexit) rather than as an expression of their own national identity. Viewing "Northern Irish" as an alternative national identity to British or Irish is less common – it is mainly associated with those who don't identify with either the unionist or nationalist community, but also with those who adhere to the minority viewpoint of Ulster nationalism.

Suggestions: On the one hand, there is some precedent for using labels such as "English" and "Scottish" as nationality labels, and that comports with how many people in the UK view themselves. On the other hand, there is a risk that readers unfamiliar with the UK may misinterpret a statement that someone has "Scottish nationality" in a legal sense. Since "Scottish nationality" has no legal definition, it has no clear boundaries beyond self-identification – some may consider that "Scottish nationality" is possessed by all residents of Scotland, or at least all those born there, others may view it as only possessed by those who identify as ethnically Scottish. See also Wikipedia:Nationality of people from the United Kingdom for some further discussions of what "nationality" means in the UK context

Québécois

In 2006, the Parliament of Canada officially recognised the Québécois as "a nation within a united Canada". That declaration was politically controversial – polls at the time showed majority support for the motion by Francophone Canadians, but at the same time a majority of Anglophone Canadians were opposed to it, and considering Canada as a whole public support for it was close to 50-50.

Recognition of Québécois as a nation can be understood as implying the existence of a concept of "Québécois nationality". Indeed, you will find some sources which speak of "Québécois nationality" and "Québécois citizenship". Some of these sources are speaking of the legal concept of Québécois nationality and Québécois citizenship in the hypothetical future scenario of Quebec becoming an independent sovereign state; other sources speak of those concepts in the context of the current legal status of Quebec as a province of Canada. In that current context, the notions of "Québécois nationality" and "Québécois citizenship" generally have to be understood as non-legal rather than legal notions.

The question of who belongs to the "Québécois nation" is unclear. Does it include only French-speakers, or are English-speaking Quebecers included as well? Many of the later would not identify with the label even if some sought to include them in it.

Suggestions: On the one hand, if a person self-identifies their "nationality" as "Québécois", that could be an argument to put their nationality as "Québécois" in articles, including even Infoboxes. On the other hand, that might confuse readers who are expecting "nationality" to refer to a legal nationality, and might also be seen by some as lending endorsement to the Quebec independence movement. It cannot be assumed that a person who lives in or is born in Quebec identifies as a member of the "Québécois nation"–such an identification is more likely if they are a member of the French-speaking majority of Quebec rather than the English-speaking minority, but even in the former case cannot be guaranteed. Some French-speaking Québécois may prefer to view their sole or primary national identity as Canadian (especially those who are opposed to the independence movement.)

Indigenous peoples as nations

Some indigenous peoples identify as "nations", and are identified as such in the country in which they are indigenous. In the United States, federally recognised tribes of Native Americans and Alaska Natives are legally classified as "domestic dependent nations". The legal status of being a legally recognised member of such a tribe is called "tribal citizenship". However, since these tribes are legally recognised as "nations", tribal citizenship could be said to be a form of nationality – however, that said, tribal citizens are still legally considered to be nationals of the United States, and such "nationality" is not understood as the status of nationality under international law.

The term First Nations is also used to refer to one of the three main divisions of indigenous peoples of Canada – the other two divisions being the Inuit and Métis. The term "nation" does can be understood as implying that First Nations groups are in some sense nations; the Métis are sometimes also considered to constitute the "Métis nation", and some (but not all) Métis belong to organised communities known as "Métis nations". Subgroups of the Inuit are sometimes also known as "Inuit nations".

In Australia, some indigenous groups refer to themselves as "nations", although others prefer other terminology such as "peoples", "clans", "groups", etc. Unlike the United States, there is presently no legal recognition under Australian law of indigenous Aboriginal and Torres Strait Islander peoples as "domestic dependent nations" (or "nations" in any other sense), but of course people are free to view themselves or identify in ways not (currently) recognised by the law.

Suggestions: On the one hand, given that in the US, membership of a tribe is a legal status known as "tribal citizenship", and recognised tribes are legally viewed as "domestic dependent nations", and members of the tribes often accept and take pride in the identity of "nation" (although they are often critical of the "domestic dependent" part), it might make some sense to include tribal membership as a "nationality" and/or "citizenship" in an Infobox. On the other hand, that might confuse other readers and editors who are expecting those parameters to refer to nationality or citizenship in internationally recognised sovereign states.

See also

• Wikipedia:Manual of Style (flags)