Dublin solicitor shares opinion paper with ministers and political representatives, raising concerns over residency rules, language tests and financial requirements.
Dublin-based solicitor and notary public Imran Khurshid has shared an opinion paper on the proposed Irish Nationality and Citizenship (Amendment) Bill 2026 with Minister Jim O’Callaghan and his team, Minister Colm Brophy, Catherine Ardagh, John Lahart TD, Martin Daly TD, and Cllr. Uruemu Adejinmi, Vice President of Fianna Fáil.
In his paper, Khurshid calls for closer scrutiny of the proposed citizenship changes, arguing that reforms should recognise applicants’ circumstances and the expectations of people who moved to Ireland under existing rules. While supporting aspects of the proposed framework, he identifies several areas where he believes greater flexibility is needed.
Residency Requirements: Protect Those Who Relied on Existing Rules
Khurshid raises concerns about what his paper describes as a progression in residency requirements from three years for refugees to five and then eight years within a short period.
He argues that the pace of change risks making Ireland a less attractive destination, particularly for skilled workers, while raising fairness questions for people who relocated under the rules in place at the time.
The paper recommends that applications already in progress should continue to be assessed under the law under which they were submitted. It also calls for a grace period for new applications, recognising that people came to Ireland trusting the existing rules.
English Language Tests: Recognise Employment and Everyday Integration
Khurshid questions the need for an English language test for applicants who have demonstrated sustained employment and economic activity in Ireland.
His paper argues that people working in Ireland already interact with local communities daily and are likely to have developed working proficiency by the time they qualify for citizenship. He also notes that skilled workers in critical roles are often well-educated and fluent before arriving.
He proposes a waiver for applicants who can demonstrate a sustained record of employment and economic participation in Ireland.
Irish Language and Sign Language Alternatives: Questions About Practical Value
The paper considers the inclusion of Irish language or sign language as an alternative, acknowledging that the idea has merit in principle.
However, Khurshid questions its practical justification, arguing that English is the dominant language used in everyday speech and writing in Ireland. On that basis, he expresses reservations about the case for a separate pathway.
Financial Self-Sufficiency: Assess Individual Circumstances
Khurshid warns that applying a financial self-sufficiency requirement across the board could disadvantage people facing circumstances beyond their control.
He identifies economic downturns, unemployment, illness and disability as factors that can disrupt a person’s financial position regardless of their effort or commitment.
The paper calls for individual assessments, with waivers or a more flexible approach for applicants experiencing genuine hardship, rather than treating financial self-sufficiency as an absolute condition that automatically excludes them.
Social Welfare: Temporary Support Should Not Undermine Eligibility
Khurshid raises similar concerns about any rule preventing applicants from having relied on social welfare during a specified period before applying.
He argues that such a restriction could penalise people who needed temporary assistance during a difficult period. In his view, receiving that support does not establish how integrated a person is or how committed they are to life in Ireland.
Civic Knowledge: A Positive Step for New Citizens
The paper welcomes the proposed civic knowledge requirement.
Khurshid considers a basic understanding of Irish society, institutions and government a useful addition to the citizenship process, benefiting both new citizens and the wider country.
Aligning with EU Norms While Keeping Fairness in Focus
Khurshid supports the principle of aligning Ireland’s citizenship framework with EU norms, but argues that the details require careful consideration.
His central message is that reform should allow flexibility, recognise individual hardship and consider the position of people who built their lives in Ireland under existing arrangements.
“Ireland aligning its citizenship framework with EU norms makes sense. But the details matter, and right now several of them need more flexibility,” he concludes.
