u/Efficient-Pianist-22

Really need your insights. Please comment. Hi everyone,

I’m trying to understand the correct interpretation of "Article 3-bis, letter d (Law 91/1992, as amended by Law 74/2025)" and "Circolare n. 36356 (July 24, 2025)".

From the circolare, it states that the parent may have acquired Italian citizenship “by any title,” including "iure sanguinis", and that for "iure sanguinis" the reference point for calculating the 2-year residency requirement is "from birth.

However, I’ve seen different interpretations in practice. Some say that letter d only applies to parents who acquired Italian citizenship "after birth" (e.g., naturalization or later recognition), and not to those who were already Italian from birth. Others even claim it is mainly intended for people who were "recognized as Italian later in life", rather than those born Italian in Italy.

My question is:

👉 Does Article 3-bis letter d exclude parents who were Italian by birth, or does it also apply to them based on the circolare’s wording?

In my case:

• My father was born Italian in Italy and lived thwere for many years • I was born abroad (Philippines) in 2002 • He moved to Cuba only years after my birth • Never renounced Italian citizenship, died as an Italian citizen in 2020 in Cuba.

So based on the circolare, it seems like the requirement could be satisfied (2+ years residence in Italy after “acquisition,” counted from birth).

But I’d really appreciate insights from:

• Anyone who applied under letter d • People with consulate experience • Or those who have seen how this is being interpreted in practice

Thanks in advance!

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u/Efficient-Pianist-22 — 14 days ago