Moving to Scotland from the US: Visas & British Citizenship

Can Scottish Ancestry Help You Move to Scotland?

Scotland remains a popular destination for Americans to visit and potentially relocate. In 2023 alone, over 794,000 trips were made by American visitors to Scotland, driven by a mix of heritage, tourism, and cultural fascination.

An estimated 25 million Americans have Scottish ancestry, including 35 US Presidents. Can Scottish heritage give you the right to live or work in the UK or even claim British citizenship?

Does Scottish Ancestry Equal British Citizenship?

Not automatically. While Scotland is part of the United Kingdom, UK nationality law is complex. Having a Scottish-born grandparent may open the door to British citizenship by descent in limited cases. A UK Ancestry visa may be a more viable route in other situations.

To assess your eligibility, three key factors matter:

Where You Were Born

“Double descent” citizenship—where you inherit British citizenship through a grandparent— applies if you were born outside the UK, where all three generations meet specific requirements. If you were born in the US, you may be eligible depending on your grandparents and parents' circumstances.

When You Were Born

British citizenship law changed significantly on 1 January 1983. Before that date, the transmission of citizenship was more flexible. However, since 1 January 1983, citizenship by descent has typically been limited to just one generation born abroad.

If you were born on 1 January 1983, you may have a path to citizenship by descent. If born after that outside the UK, the options narrow significantly—though discretionary visa routes may still be available.

Child's entitlement if Grandparent Was Born in Scotland (or the UK)

For a child born outside the UK on or after 1 January 1983, there may be a path towards British Citizenship if the grandparent was born in Scotland or the UK; hence, the grandparent was British otherwise than by descent. If the parent was born outside Scotland or the UK, hence British by descent, the child born outside the UK will not usually be automatically British. There are 2 possibilities to register the child as British before turning 18:

1. If the British by descent parent lived in the UK for 3 consecutive years without absence of more than 270 days in this period, before the birth of the child; or
2. The child and parents (including the British by descent parent) lived in the UK for 3 consecutive years without being absent for over 270 days during this period.

Not Eligible for Citizenship? Consider the UK Ancestry Visa or other Visa routes

Even if you don't qualify for citizenship, you may still be eligible for a UK Ancestry visa if you have a Scotland or UK-born grandparent. This visa allows you to live and work in the UK for five years, with a path to Indefinite Leave to Remain and eventual citizenship.

Other popular routes among US citizens include Partner or Family Visas, Skilled Worker Visas, Global Talent Visas, Innovator Founder Visas, High-Potential Individual visas, and one of the Global Business Mobility Visas.

If you have Irish ancestry, a claim to Irish Citizenship may also open the path to living and working in the UK, as Irish Citizens are treated as settled persons with no restrictions. Once you have accumulated 3 to 5 years of UK residence, you may then naturalise as a British citizen.

Dual Citizenship: Understanding the UK and US Positions

Both the United Kingdom and the United States permit dual citizenship. This means that US citizens can acquire British citizenship without renouncing their US nationality. Similarly, British citizens can be naturalised as US citizens without losing their British status. However, it's important to note that while the US recognizes dual nationality, it does not encourage it due to potential complexities. For instance, dual nationals are required to obey the laws of both countries, which may lead to conflicting obligations. Additionally, US citizens, including dual nationals, must use their US passports when entering and leaving the United States. Given these considerations, consulting with legal experts is advisable to fully understand the implications of holding dual citizenship.​

Does this apply if I'm not a US citizen?

While this article focuses on US nationals, the rules around British citizenship by descent apply broadly, regardless of your current nationality. Whether you're from Australia, Canada, New Zealand, South Africa, or elsewhere, the key factors remain the same: where and when you were born and your ancestral connection to the UK. However, visa options may vary slightly depending on your country's relationship with the UK.

Get Support with UK Visa Applications

British nationality law is complex and highly specific to individual circumstances. If you are exploring whether your ancestry may qualify you for British citizenship, considering options like the UK Ancestry visa, or would like to know if you qualify for other UK visa types, it is important to understand how the rules apply to your unique case.

To discuss your case, please contact the team or book your UK immigration consultation today.