The prevalent conceptual approach used to assess multiple citizenship legislation is based on analysing a set of selected elements of the relevant legal framework. This paper argues that the evolution of legal rules on dual citizenship cannot be comprehensively analysed using methods created for comparative analyses and based on a narrow selection of legal rules that reflect either a restrictive or an open ap-proach to dual citizenship. The simplified approach that focuses on the analysis of selected fragments of explicit legislation generates results that may be misleading. Therefore, the terms of reference for comparative study of multiple citizenship should be elaborated and extended. A comprehensive compar-ative method also has to take into account the migration context as well as relevant aspects of the legal and political context. This article explores these issues through an analysis of Polish legal rules in the field of dual citizenship.

As the adoption of the Hungarian simplified naturalisation scheme raised much tension both in the neighbouring countries of Hungary and in the main host countries of EU citizens, this paper summarises the nature of such reactions and the most frequent fears that EU states expressed. The main aim of the study is to show what effects a country’s modification of its citizenship rules may have on the situations of other EU member-states and European Union citizens. The article also raises one practical aspect of the situation that evolved as a result of the answer by Slovakia to the Hungarian modifications – namely the ex lege withdrawal of Slovakian citizenship if a person acquires a new one from another country. It introduces in detail the free-movement aspects of ethnic Hungarians losing their Slovakian citizenship, while not leaving their homeland in Slovakia, arguing that people in such a situation may rightfully and immediately be eligible for permanent residence rights, which would provide them with a higher level of protection.