Comparative Report: Citizenship in Central Asia (PDF)

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As the author of the report, Medet Tiulegenov, highlights, Citizenship was developed from scratch by the countries of Central Asia as they had to engage in simultaneous nation- and state building after the collapse of the USSR. He believes the nation- building process can only partially explain citizenship policies adopted by the Central Asian states.

According to the author, concerning various issues, the Central Asian countries have developed a similar and standard approach while on some issues they diverged. There was an overall trend for the post-Soviet states to start with universal approaches to citizenship policies and then over time to undergo particularisation of their laws to reflect their specific contexts.

Particularisation of citizenship policies have taken place due to different political regimes and unequal power of the state in matters of in defining citizenship, and due to ethnic composition and policies towards adjacent countries. Besides, recent statehood, strong sub-national identities and labour migration affected the way citizenship policies are formulated in Central Asian countries. On many issues which are commonly present in laws there were no provisions in the legislation of Central Asian states. Institutionalization of ambiguity has been argued to be characteristic of Russia and this could be said about Central Asia as well.

All countries rely on the ius sanguinis principle in their citizenship policies and their residence terms ordinary naturalisation are similar. There are some policies on dual citizenship in the region though they vary from country to country. Although, for example, Kyrgyzstan has provisions regarding dual citizenship in the law, it has not implemented these in practice, and Turkmenistan had in the past such provision, but abolished it.

For Medet Tiulegenov, divergence is manifest regarding policies towards co-ethnics, which are prevalent in cases of less homogenous countries. Granting citizenship to the former USSR citizens is a result of similar legacies of being successor countries. According to the author, ongoing labour migration from Central Asia, primarily to Russia, would not only affect relationship among these counties, but also citizenship policies. Adjacent countries may find themselves in more precarious positions unlike more distant countries who may tolerate dual citizenship amongst each other.