Dual Citizenship in Germany 2026: The Rules

Dual citizenship (the "Doppelpass") has been generally possible in Germany since the Act to Modernize Nationality Law (Gesetz zur Modernisierung des Staatsangehörigkeitsrechts, StARModG) came into force on 27 June 2024. The reform abandoned the former principle of avoiding multiple citizenship; the old provisions § 12 (acceptance as an exception), § 25 (loss upon acquiring a foreign citizenship; the retention permit was § 25 para. 2) and § 27 StAG (loss through adoption as a child) were repealed without replacement. The Act Amending the Nationality Act and Further Provisions (Gesetz zur Änderung des Staatsangehörigkeitsgesetzes sowie weiterer Vorschriften) of 27 October 2025 (BGBl. 2025 I Nr. 256, in force 30 October 2025) left the Doppelpass untouched — only the recently introduced 3-year track of entitlement-based naturalization was abolished. Whether two citizenships can actually be held in a specific case depends solely on the law of the country of origin (Herkunftsstaat) — not on German law.

Dual citizenship (also: multiple citizenship, Mehrstaatigkeit; colloquially "Doppelpass") describes the legal status of a person who simultaneously holds the citizenship of two or more states. In this form the term is defined neither in the Basic Law (Grundgesetz) nor in the Nationality Act — it describes a legal situation that arises from the interplay of German and foreign nationality law.

Under German law, citizenship is governed by Art. 116 para. 1 GG and the Nationality Act (Staatsangehörigkeitsgesetz, StAG). Acquisition classically occurs through:

• Birth as the child of a German parent (principle of descent / ius sanguinis, § 4 para. 1 StAG),
• Birth in Germany to foreign parents, if one parent has lawfully resided in Germany for at least five years and holds an unlimited right of residence (birthplace principle / ius soli, § 4 para. 3 StAG),
• Naturalization upon application (in particular § 10 StAG),
• Declaration in special constellations (§ 5 StAG, for example for persons who under old law were excluded from citizenship derived from German mothers),
• Admission as an ethnic German repatriate (Spätaussiedler) under the BVFG in conjunction with § 7 StAG.

Multiple citizenship can arise in two ways:

1. Originally by birth: A child inherits different citizenships from two parents, or acquires an additional one by birth in an ius soli state.
2. Subsequently by acquisition: A person acquires a second citizenship through naturalization or declaration without losing the first.

Until the 2024 reform, the second variant was systematically impeded in Germany: § 10 StAG required giving up the previous citizenship, and § 25 StAG ordered the automatic loss of German citizenship upon acquiring a foreign one (with exceptions via the retention permit — Beibehaltungsgenehmigung — under § 25 para. 2 StAG a. F. [former version]). This architecture has been history since 27 June 2024.

A systematic treatment of the acquisition and loss provisions that still exist is provided by the main article on the Nationality Act (StAG). This article focuses on the multiple-citizenship situation and its practical consequences.

Terminology. "Doppelpass" is not a legal technical term; German law speaks of "multiple citizenship" (Mehrstaatigkeit). Both terms mean the same thing — the passport itself is only the technical document; the legal substance is the citizenship.

The Act to Modernize Nationality Law (StARModG) of 22 March 2024 (BGBl. 2024 I Nr. 104) came into force on 27 June 2024. The reform was the largest modernization of German nationality law in 25 years and affects the Doppelpass on four structural levels.

Abandonment of the Principle of Avoiding Multiple Citizenship

The former guiding principle of avoiding multiple citizenship was abandoned. The explanatory memorandum of the Federal Cabinet (BMI cabinet version of the StARModG, August 2023) states that naturalizations will henceforth take place "in principle while accepting multiple citizenship". Giving up the previous citizenship is no longer an element of entitlement-based naturalization.

§ 10 StAG — Obligation to Renounce Eliminated

The former no. 4 of § 10 para. 1 StAG required the applicant to give up or lose their previous citizenship. This element has been deleted. Anyone who meets the requirements of § 10 StAG — five years of lawful residence, B1 language skills, an independently secured livelihood, the commitment and loyalty declaration, no violation of § 11 StAG — is naturalized without having to surrender the old passport.

§§ 12, 25 and 27 StAG Repealed Without Replacement

Three provisions were completely deleted by the reform because they became moot under the new guiding principle:

• § 12 StAG formerly governed the acceptance of multiple citizenship as an exception (e.g. where renunciation was impossible, for EU/Swiss nationals, the Iran clause, and hardship cases). If acceptance is now the standard case, no exception rule is needed.
• § 25 StAG ordered the automatic loss of German citizenship when a German national acquired a foreign one. This automatic loss is incompatible with the new principle and was abolished.
• § 27 StAG a. F. governed the loss of German citizenship through adoption as a child (Annahme als Kind — adoption by a foreigner). This provision, too, fell away with the 2024 reform. The retention permit (Beibehaltungsgenehmigung), by contrast, was governed by § 25 para. 2 StAG a. F. and became moot with the elimination of § 25.

The three "repealed" sections are marked accordingly in the federal consolidation service at gesetze-im-internet.de/stag/.

Option Requirement for ius soli Children Eliminated

Children who acquired German citizenship under § 4 para. 3 StAG by birth in Germany to foreign parents previously had to choose, under the old law, between the ages of 18 and 23, between German and parental citizenship (option requirement, former § 29 StAG). This option requirement was eliminated without replacement by the 2024 reform — German citizenship remains permanently, regardless of whether the foreign citizenship still exists after the 23rd birthday.

Commitment and Loyalty Declaration — New Requirements Remain in Force Unchanged

With the 2024 reform, the commitment to the free democratic basic order (§ 10 para. 1 no. 1 StAG) was supplemented by the new loyalty declaration under § 10 para. 1 sentence 1 no. 1a: recognition of Germany's special historical responsibility arising from the National Socialist unjust regime, in particular for the protection of Jewish life, together with a commitment to reject antisemitic, racist and other misanthropic acts. These requirements apply independently of the Doppelpass question and are not in tension with its possibility: anyone who commits to the free democratic basic order and submits the loyalty declaration can keep their previous citizenship.

To place the situation as of July 2026 accurately, three reform steps must be distinguished. Only the first step introduced the Doppelpass; the two that followed regulated other matters and left the Doppelpass situation untouched.

Step 1 — StARModG of 22 March 2024 (BGBl. 2024 I Nr. 104, in force 27 June 2024)

Content: Doppelpass as the standard case, the residence period under § 10 StAG shortened from 8 to 5 years (with a narrowly tailored 3-year track for special integration achievements), a new loyalty declaration referring to NS responsibility, the elimination of the option requirement, and the repeal without replacement of §§ 12, 25, 27 StAG.

Step 2 — Act Amending the Nationality Act and Further Provisions of 27 October 2025 (BGBl. 2025 I Nr. 256, in force 30 October 2025)

Content: the repeal without replacement of the 3-year track (§ 10 para. 3 StAG a. F.) that was in force between 27 June 2024 and 30 October 2025. The Bundestag adopted it on 8 October 2025 (450 to 134 votes, 2 abstentions); the Bundesrat raised no objection on 17 October 2025 (BR-Drs 545/25). A constitutional complaint against the deletion was not accepted for decision by the Federal Constitutional Court by order of 19 December 2025, 2 BvR 1792/25; the Court pointed to § 8 StAG (discretionary naturalization) as a fallback in individual cases.

Effect on the Doppelpass: none. The amending act of 27 October 2025 leaves §§ 4, 5, 8, 9, 10 (except for the 3-year track deleted there) unaffected; multiple citizenship remains the standard case.

Step 3 — Further Changes 2025/2026

At the turn of the year 2025/2026, further StAG amendments came into force which, however, do not affect the Doppelpass architecture and are treated in a separate article. This article focuses on the multiple-citizenship situation; all Doppelpass-related statements in this article reflect the reform status of the amending act of 30 October 2025 (BGBl. 2025 I Nr. 256).

Important clarification against confusion online. The amending act of 27 October 2025 is occasionally summarized in reporting as a "rollback of the 2024 reform". This shorthand is inaccurate: only the 3-year track was deleted. Doppelpass, the 5-year period, the B1 level and the loyalty declaration remain in force unchanged.

The practical significance of the 2024 reform depends decisively on the nationality law of the country of origin. Three constellations can be distinguished.

Constellation A — Country of Origin Generally Permits Multiple Citizenship

Examples: Turkey (with the Mavi Kart construction), Russia, Ukraine (facilitated since 2024), Morocco, many Latin American and sub-Saharan states.

Here the Doppelpass was already realistic in practice before the reform — giving up the citizenship of origin was often not reasonably feasible (a tough release procedure, high fees, sometimes refusal). The 2024 reform now turns a de facto acceptance into a legal matter of course: it is sufficient to meet the requirements of § 10 StAG in Germany. The special permission under the former § 12 StAG is eliminated entirely.

Constellation B — Country of Origin Generally Prohibits Multiple Citizenship

Examples: China, Singapore, Saudi Arabia, the United Arab Emirates.

In these states, the citizenship of origin ends automatically or mandatorily as soon as the German naturalization takes effect. The 2024 reform changes nothing about this constellation — German law no longer makes loss a condition, but the law of the country of origin may independently provide for loss. Anyone who accepts the German passport thereby effectively gives up — though not legally under German law — the citizenship of origin.

Constellation C — Country of Origin Requires an Explicit Declaration of Renunciation

Examples: some states require the person concerned to actively declare to their own diplomatic mission that they give up the citizenship of origin. If they do not, the citizenship of origin remains — even after German naturalization. Here the actual Doppelpass choice is a matter for the applicant.

Data on Actual Frequency

The naturalization statistics of the Federal Statistical Office (Destatis, table 12511, Genesis-Online) have recorded the acceptance of multiple citizenship as the standard case since 2024. The Destatis press release of spring 2025 on the 2024 naturalization statistics shows that the majority of naturalizations took place while retaining the previous citizenship — former renunciation rates have effectively become obsolete since the reform.

Passport and Visa-Free Travel

Two citizenships typically come with two passports. The German passport opens visa-free access to the EU, the Schengen states and a broad list of countries worldwide. The passport of the country of origin can be advantageous in some constellations — for example when traveling to states that do not admit German travelers without a visa (such as Russia, India, China).

Important: on entry, the passport of the state being entered — whose citizenship one holds — is generally to be used; on departure from Germany, German passport law applies. In consular terms, a person traveling to their country of origin is regularly treated as a citizen of that state — German consular protection does not apply in the country of origin (see the Vienna Convention on Consular Relations, Art. 5 lit. e).

Voting Rights (Germany and Country of Origin)

With German citizenship, a person acquires the active and passive right to vote for the Bundestag (§§ 12, 15 BWahlG) as well as for state and municipal parliaments — depending on the respective electoral law. Voting rights in the country of origin are generally retained insofar as the law there provides for them; some states, however, considerably restrict or entirely exclude the voting rights of their citizens living abroad.

Inheritance Law and Inheritance Tax

For inheritance law, the substantive law of the state of the last habitual residence applies (Art. 21 para. 1 of the EU Succession Regulation 650/2012) — however, German citizenship opens a choice-of-law option in Art. 22 of the EU Succession Regulation. In the case of multiple citizenships, the person can freely choose which national law they designate for the succession. The German Inheritance and Gift Tax Act (ErbStG) otherwise ties to the domicile or habitual residence of those involved and is unaffected by multiple citizenship.

Tax Law — Double Taxation and FATCA

Germany generally taxes according to the domicile or habitual residence principle (§§ 1 para. 1, 8 AO; § 1 para. 1 EStG). Citizenship is generally not decisive for German tax liability — anyone who lives and works in Germany is subject to unlimited tax liability here, regardless of whether they hold one, two or three citizenships. The Federal Republic has concluded double taxation agreements (Doppelbesteuerungsabkommen, DBA) with more than 90 states, which avoid double burdens.

Special case: the USA. The United States taxes its nationals worldwide under the citizenship-based taxation principle — with tax liability in the USA regardless of domicile. Anyone who holds US citizenship (for example through birth in a US consulate or through US parents) and is simultaneously naturalized has a continuing US tax liability. Added to this is the Foreign Account Tax Compliance Act (FATCA) regime, which obliges German banks to report accounts of US persons to the US tax authority. A concrete assessment of this constellation belongs in the hands of a tax advisor with US tax experience; civitas. does not provide tax advice on this.

Military Service in the Country of Origin

Some countries of origin have compulsory military service for their citizens even abroad (examples: Turkey, Israel, South Korea, Switzerland). With the acquisition of German citizenship in addition to the original one, military service in the country of origin may continue, insofar as the law there provides for it. In Germany, general conscription has been suspended since 2011; it nevertheless remains legally in force and can be reactivated by political decision. Anyone affected by compulsory military service in their country of origin should clarify the current status with the respective diplomatic mission before a planned trip there.

Consular Protection

Dual nationals generally enjoy German consular protection in a third state (that is, neither in Germany nor in the country of origin) like all other Germans. In the country of origin, by contrast, that state may treat its citizens as taking priority under Art. 5 lit. e of the Vienna Convention, and German consular protection is regularly limited. This restriction must be taken into account when traveling to the country of origin.

Cooperation in Criminal Proceedings — Extradition

German nationals enjoy the protection under Art. 16 para. 2 GG: extradition to another state is permitted only under narrow conditions (in particular to EU member states or the ICC). Dual nationals have this protection insofar as they are in Germany. In the country of origin, on the other hand, they are subject to that country's criminal jurisdiction as its own citizens.

Social Benefits, Right of Residence, Freedom of Establishment

With the acquisition of German citizenship, the need for a residence title under the Residence Act (AufenthG) ends. The person has free choice of residence within the federal territory, free choice of occupation, freedom of establishment throughout the EU (Art. 21 TFEU — Union citizenship), access to all social benefits like other Germans, and an unrestricted right to family reunification. The additional foreign citizenship, moreover, provides — depending on the state — different or supplementary rights (e.g. residence in the country of origin, acquisition of property, pension claims from an insurance record there).

The following constellations shape German Doppelpass everyday life more than others — either through high application numbers or through typical legal particularities. The overview below summarizes whether two citizenships actually remain after German naturalization. What is decisive here is not German law — which, since the 2024 reform, consistently accepts multiple citizenship — but the law of the respective country of origin.

The column "Doppelpass possible?" reflects the interplay of German and country-of-origin law: since 27 June 2024, German law no longer requires giving up the previous citizenship (§ 10 StAG; StARModG, BGBl. 2024 I Nr. 104); whether the citizenship of origin remains is determined solely by the foreign law referenced there. The information on the country of origin comprises generic classifications without guarantee and may change; binding information is provided by the respective diplomatic mission. Overviews: Federal Foreign Office — Consular Information, asyl.net — Multiple citizenship, BMI — FAQ on the nationality law reform.

Turkey — Mavi Kart and Doppelpass

Turkey generally permits the Doppelpass for its own nationals; however, giving up Turkish citizenship was long common because German law required it until 2024. Anyone who had given up Turkish citizenship in favor of the German one could retain many civil rights in Turkey with the Mavi Kart ("Blue Card") — acquisition of property, inheritance rights, residence without a visa. With the 2024 reform, switching via the Mavi Kart is practically obsolete: anyone naturalized in Germany today can keep their Turkish passport. For an in-depth treatment of this topic, see the article Naturalization with Turkish citizenship.

Ukraine

Ukrainian law long did not recognize multiple citizenship; in 2024 Ukrainian nationality law was amended and multiple citizenship was permitted for citizens of selected states — including Germany. The 2024 reform in Germany and the amendment in Ukraine together make the Doppelpass systematically possible for Ukrainians for the first time since 2024. In depth: Naturalization with Ukrainian citizenship.

Russia

Russia generally accepts the Doppelpass; the Russian constitution, however, provides for a reporting obligation for the acquisition of a foreign citizenship. Since 2024, German law no longer imposes any requirements regarding the renunciation of Russian citizenship; persons concerned should check whether the Russian reporting obligation must be observed in the specific case.

Syria

Syria permits renunciation of its own citizenship only under narrow, barely achievable conditions. Even before the 2024 reform, multiple citizenship for Syrian nationals in Germany was therefore regularly accepted in practice (a hardship case under the former § 12 StAG). With the reform, the hardship character has fallen away — acceptance is now the explicit standard case.

Iran

Iran practically does not permit renunciation of Iranian citizenship under Iranian law. Anyone who acquires German citizenship legally retains Iranian citizenship. The 2024 reform has thus superseded, without replacement, the Iran special hardship case of the former § 12 StAG: acceptance was an exception until 2024, and is now the rule. One specific constellation remains: anyone traveling to Iran is regularly treated there as an Iranian citizen; German consular protection is limited.

USA — Citizenship-based Taxation

The USA accepts the Doppelpass and maintains no prohibition of multiple citizenship of its own. Anyone who is a US national by birth or declaration and is naturalized in Germany retains US citizenship. The particularity lies in US tax law (see Section 5 above): continuing worldwide US tax liability, the FATCA reporting obligation of German banks, high administrative effort. US citizenship can, in exceptional cases, be given up voluntarily ("renunciation"), which in turn may itself trigger tax consequences (exit tax). Tax assessment is a matter for specialized US tax advisors.

Morocco

Morocco has the principle of inalienable citizenship: anyone born in Morocco or descended from Moroccan parents remains Moroccan for life — renunciation is legally practically impossible. The 2024 reform changes nothing about this, but makes the German procedure considerably simpler: no hardship argument is needed anymore.

United Kingdom (UK) and EU States

With Brexit, the UK has been a third country since 1 January 2021. The UK permits multiple citizenship without restriction; German-British dual nationality was, even under the old German law, at least in the EU citizenship constellation (before Brexit) automatically acceptable. Since the 2024 reform, German-British dual nationality is structured as the standard case. Citizens of the EU/EEA states and Switzerland were exempt from the renunciation obligation even before 2024; the 2024 reform turns this special rule into the general standard for all applicants.

Brazil, Mexico, Argentina and Other Latin American States

These states generally permit multiple citizenship; giving up the citizenship of origin is often legally difficult to enforce. Even before 2024, German naturalizations in these constellations were regularly granted while accepting multiple citizenship. With the reform, the special procedure is dispensable — naturalization follows the standard scheme of § 10 StAG.

"Applying for" a Doppelpass is no longer the subject of a separate procedure in Germany — multiple citizenship arises automatically from the interplay of the naturalization or acquisition procedure and the law of the country of origin. Three routes typically lead to multiple citizenship:

1. Entitlement-based naturalization under § 10 StAG — the standard case. Application to the responsible naturalization authority, fulfillment of the requirements (5 years of residence, B1, the test, the commitment, the loyalty declaration, a secured livelihood, no criminal record above the minor-offense threshold). Since 27 June 2024, the German authority no longer requires giving up the previous citizenship; it does not independently examine what the law of the country of origin provides. For the complete requirements, see Requirements for Naturalization.

2. Birth in Germany to foreign parents — the birthplace principle under § 4 para. 3 StAG; German citizenship arises in addition to the parental one, insofar as the foreign one is not lost by birth. The option requirement was eliminated in 2024, and the dual status remains permanent.

3. Restitution naturalization under Art. 116 para. 2 GG in conjunction with § 15 StAG for persons persecuted under National Socialism and their descendants. Responsible: the Federal Office of Administration (Bundesverwaltungsamt, BVA) in Cologne. Multiple citizenship has long been accepted here in practice; all the more so with the 2024 reform.

The detailed bureaucratic review — which documents, which confirmations from the country of origin, which translations — is a matter for the specific procedure. civitas. accompanies this digitally and checks the completeness of the documents; the actual law of the country of origin, however, remains outside the civitas. service and must be clarified with the relevant diplomatic mission where necessary.

The handover of the German naturalization certificate likewise does not change the existence of the citizenship of origin — it merely triggers German citizenship. Anyone who wants to know whether the country of origin itself orders a loss consequence should inquire in advance at the embassy or consulate general. A confirmation from there protects against unpleasant surprises on later trips.

Is the Doppelpass really generally permitted in Germany since 2024?

Yes. With the StARModG of 22 March 2024 (BGBl. 2024 I Nr. 104, in force 27 June 2024), the principle of avoiding multiple citizenship was abandoned. Anyone naturalized under § 10 StAG can keep their previous citizenship — insofar as the law of the country of origin permits it.

Did the 2025 StAG amendment abolish the Doppelpass?

No. The Act Amending the Nationality Act and Further Provisions of 27 October 2025 (BGBl. 2025 I Nr. 256) deleted only the 3-year track (§ 10 para. 3 StAG a. F.) that was in force between June 2024 and October 2025. Doppelpass, the B1 language level, the loyalty declaration and the 5-year period remain unchanged.

Do I need a retention permit if, as a German, I acquire a foreign citizenship?

No. The retention permit under the former § 25 para. 2 StAG was eliminated without replacement by the 2024 reform. Since then, German nationals no longer automatically lose their German citizenship upon acquiring a foreign one. A permit is no longer required.

What happens to my old citizenship if I am naturalized in Germany?

That depends solely on the law of the country of origin. Some states (Turkey, Morocco, Iran) permit multiple citizenship — the old citizenship remains. Others (China, Singapore) order its loss automatically as soon as another is acquired. Still others require an explicit declaration of renunciation. The German authority does not examine this.

Do I lose my German citizenship if I later acquire a third citizenship?

No. With the 2024 reform, the loss provision of the former § 25 para. 1 StAG was also eliminated. Anyone who, as a German, acquires further citizenships retains their German citizenship unchanged.

Does the Doppelpass have practical disadvantages?

In most cases, no. The main points are: military service in the country of origin (e.g. Turkey), limited consular protection in the country of origin, and — as an exceptional case — the continuing US tax liability for US nationals. The precise assessment belongs in the hands of a tax or legal advisor with reference to the specific country of origin.

Can my children inherit German citizenship if I am a dual national?

Yes. § 4 para. 1 StAG (principle of descent) makes the transmission of German citizenship independent of whether the German parent is a dual national. The parents' additional citizenship may likewise be inherited under the law of the country of origin; that is a matter of the law there.

I am a German national by birth in Germany and also hold Turkish citizenship. Do I still have to make a choice?

No. The former option requirement (former § 29 StAG) — a choice between the ages of 18 and 23 — was eliminated without replacement by the 2024 reform. German citizenship remains permanently.

As a dual national, do I have voting rights in both countries?

In principle yes, insofar as the respective electoral law of the home state provides for it. The Federal Elections Act ties to the holding of German citizenship, to domicile, and to entry in the electoral register; the second citizenship is irrelevant for German voting rights. In the country of origin, voting rights — in particular for citizens living abroad — depend on the law there.

What risks are there when traveling to the country of origin?

In the country of origin, the person is regularly treated there as its own citizen; German consular protection is limited (Art. 5 lit. e of the Vienna Convention on Consular Relations). Existing military service obligations, tax obligations or criminal proceedings of the country of origin can be enforced on the spot. Before traveling to the country of origin, an up-to-date assessment of the situation from the Federal Foreign Office and, where applicable, the diplomatic mission of the country of origin is advisable.

My country of origin does not allow dual citizenship — what applies to German naturalization?

For German naturalization this is irrelevant. Since the StARModG (in force 27 June 2024), Germany requires neither the renunciation of the previous citizenship nor the consent of the country of origin; the former provisions § 12, § 25 and § 27 StAG have fallen away (each marked as "(weggefallen)" — repealed — in the official statutory text at gesetze-im-internet.de/stag/). Whether the citizenship of origin is retained in the specific case is determined solely by the law of the country of origin — some states order its loss by operation of law as soon as German naturalization takes effect. The German naturalization authority does not independently examine this foreign law. How the law of the country of origin is to be assessed in an individual case is bindingly clarified by the relevant diplomatic mission; the decision on naturalization itself is made by the responsible authority. The complete eligibility requirements are set out under Requirements for Naturalization.

Do children of foreign parents born in Germany keep both citizenships?

Often yes. Under the birthplace principle, a child born in Germany to foreign parents acquires German citizenship if one parent "has lawfully had their habitual residence in Germany for five years" and "holds an unlimited right of residence" (§ 4 para. 3 StAG). This German citizenship arises in addition to one inherited from the parents under the law of the country of origin — whether the foreign one remains permanently alongside the German one is determined by the law of the respective country of origin. A choice between the two no longer has to be made: the former option requirement was eliminated without replacement by the 2024 reform. For the system of acquisition provisions: Nationality Act (StAG).

What was § 25 StAG (loss upon acquiring a foreign citizenship) — does it still apply?

No. § 25 StAG a. F. ordered that a German national automatically lost their German citizenship as soon as they acquired a foreign one upon application — unless they had obtained a retention permit (formerly § 25 para. 2 StAG) in advance. This automatic loss was abolished with the StARModG (27 June 2024); in the official statutory text, all that now stands at this point is "§ 25 (weggefallen)" — repealed. Anyone who, as a German, acquires a foreign citizenship since 27 June 2024 retains their German citizenship without needing a permit. The only thing to observe is the cut-off-date law: for an acquisition before 27 June 2024 without a retention permit, the loss consequences of the time are not retroactively cured.