Split nationality households: A strategic response to optimise the citizenship constellations of transnational families

Introduction

Chinese nationals who migrate to and settle in Australia face a ‘citizenship dilemma’ (Ho, 2011). They may apply to naturalise after 4 years of residency, however the People's Republic of China (hereafter ‘China’) does not permit dual nationality and so a decision to become an Australian citizen is also a decision to relinquish Chinese citizenship together with the local-level membership conferred by hukou status and the related benefits nested therein (Stevens, 2023; Vortherms, 2015). For most, this is a difficult choice, particularly as China does not have clear mechanisms for citizenship reinstatement (Liu & Ahl, 2018).

Studies of dual nationality often focus on the acquisition of ‘compensatory citizenship’ by those disadvantaged in global hierarchies of citizenship, yet generally privileged in comparison with their co-nationals, strategically seeking additional national membership(s) that may or may not be used for actual emigration (Altan-Olcay & Balta, 2020; Harpaz, 2019; Liu-Farrer, 2016). This paper, like Pan (2021), re-frames those same instrumental processes through the dilemma facing Chinese migrants – to naturalise or to not naturalise in Australia? Where one country does not permit dual nationality, strategies of flexible accumulation may involve choosing to not take citizenship in another, especially where the rights and benefits afforded citizens and permanent residents are similar.

Findings are drawn from a qualitative study of labour migrants from China living in Perth, Western Australia. This paper explores participants’ reasons for preferring either Australian citizenship or the alternative of Australian permanent residency (PR) combined with Chinese citizenship, including their nested local Chinese hukou status. Cases illustrate the ‘instrumental turn’ in citizenship (Joppke, 2019) and examine how and why families decide to combine different legal statuses of membership and belonging within one household, even within one marriage, to maximise the benefits and achieve complementary or sometimes conflicting objectives across multiple jurisdictions and at different points in the life course. However, the ways participants narrate their decisions reveal the emotional complexities that underlay ostensibly strategic choices and the complications between affective and instrumental citizenship. The affective dimensions of citizenship, including patriotism and national or local belonging, but also feelings of profound anxiety around the vulnerabilities of non-citizenship and confusing, punitive or exclusionary migration policies (Fortier, 2017), can be seen to fundamentally shape the ways that people strategise under macropolitical circumstances that they cannot control.

Migrants who do not naturalise argue that combining Chinese citizenship with Australian PR offers the greatest accumulation of rights across jurisdictions. Those who do naturalise prefer the security of Australian citizenship in the context of uncertain immigration regimes and regional diplomatic instability. Many create split nationality households where some members take Australian citizenship, while others remain Chinese nationals. These findings extend Bauböck's (2010) constellations approach, beyond a consideration of the individual as the unit of analysis, to include a more complex network of national, provincial and local memberships that may be simultaneously held by members of the same family.

Strategic citizenship in transnational families

Citizenship has become a commodified resource, a form of capital that facilitates (or inhibits) movement across borders (Altan-Olcay & Balta, 2020; Kim, 2019; Mau et al., 2015; Ong, 1999; Shachar, 2018, 2021; Stevens, 2023). The liberalisation of citizenship regimes (Faist et al., 2004; Joppke, 2007) combined with the centrality of citizenship within global im/mobility regimes, have given rise to strategic approaches to acquiring, divesting and changing citizenship status (Harpaz & Mateos, 2019). Access to mobility, that is, the capacity to cross national borders, secure visas, and remain, work and settle within the territorial jurisdiction of a given state, is unequally distributed through what Shachar (2009) has characterised as a ‘birthright lottery’. This hierarchy of citizenship regimes that conditions international migration means that some passports carry greater symbolic and material power than others, as they represent ‘citizenship with transnational value’ (Altan-Olcay & Balta, 2020, p. 170).

For people who are part of transnational families, who must move, live, love and care across borders, citizenship takes on a particularly compelling role as the facilitator or inhibitor of relationships and togetherness, and of plans for the future. Immigration regimes worldwide increasingly privilege the movement of young, highly educated and professionally credentialled people (de Haas et al., 2018), while limiting the settlement of older, less skilled or otherwise undesirable migrants (Braedley et al., 2021; Stasiulis, 2020). Under such circumstances individuals and households strategise to meet personal objectives and fulfil care obligations that change over time. Strategies range from investing in temporary and permanent visas for short-term visits or longer-term relocations (Baldassar et al., 2022; Nguyen et al., 2022), to complicated citizenship strategies that anticipate multiple alternative future patterns of residency in or circulation between multiple national contexts (Ho, 2019; Stevens, 2019, 2023).

Bauböck (2010) has argued that to understand citizenship choices and claims in today's complexly mobile world, citizenship is best conceptualised as ‘constellations’ of multiple nested and/or overlapping memberships. A citizenship-constellation perspective helps make sense of the varied, contingent responses to structural opportunities facing migrants from different backgrounds and different national or subnational origins. Individuals and – as this paper demonstrates – families may be simultaneously linked to two or more territorial political entities, subject to the laws and party to the benefits accorded members in different jurisdictions. These links generate complex, highly personalised interests in relation to competing citizenship statuses: webs of rights, obligations and affective ties that operate at varying geographical scales.

For Chinese citizens, membership constellations involve evaluating not only citizenship rights conferred at the national level but also those linked to the local-level hukou status nested within Chinese citizenship. The hukou or household registration system is the key point of interface between individual citizens and Chinese public administration, affecting access to welfare, housing, education and health services, work rights, employee insurance and pensions, and even family planning permits (Fan, 2008; Wang, 2005). Hukou is administered by local governments, with significant discretionary power to vary the tangible benefits available to individual citizens (Woodman, 2018; Woodman & Guo, 2017). In effect, hukou is experienced as a ‘local citizenship institution’ that produces highly differential experiences of citizenship (Vortherms, 2015). For Chinese citizens resident overseas, hukou is an important dimension of the citizenship constellations that conditions naturalisation decisions, with people whose hukou status carries the tangible benefits of membership in wealthier urban areas more likely to value Chinese national membership than those disadvantaged in China's institutionalised hierarchies of place (Stevens, 2023).

A further relevant dimension of competing memberships is the relative value of denizen status conferred through PR compared to full citizenship. Like other forms of ‘quasi-citizenship’ (Knott, 2022), PR remains a more precarious, less settled status as it operates through a visa that may be cancelled under Australian migration law. However, despite the risks and differentiated rights of such diluted partial membership for migrants holding ‘permanent’ visas (Knott, 2022), PR remains a feature of citizenship constellations that delivers many similar advantages as full citizenship.

Under these circumstances, choosing to not acquire Australian citizenship while retaining primary citizenship is a strategic choice within an individual's particular constellation. However, families may take this approach a step further by employing the strategy of split nationality households to optimise the benefits and limit risk across relevant jurisdictions.

This new insight demands a further modification of a constellations approach to membership. Rather than viewing citizenship constellations as opportunity structures in which migrants ‘differ with regard to their placement within the structure and their individual interests and orientation’ and exercise ‘individual choice between alternative citizenship statuses’ (Bauböck, 2010, p. 855, my emphasis), the case studies presented in this paper demonstrate that the household may be a more appropriate unit of analysis than the atomised migrant. This expanded analysis of how webs of complementary and/or competing rights and obligations act on individuals within their broader family relations increases our understanding of how migrants may interpret and operationalise their local, state, national and supranational memberships across various global contexts.

Methods and positionality

The findings presented are based on 16 months of fieldwork conducted from November 2014 to February 2016 in Perth, Western Australia. Ethnographic methods, including participant observation and semi-structured interviews, resulted in documenting the life history narratives of 55 key participants, with a further 60 people appearing more briefly in fieldnotes. Throughout this paper, pseudonyms are used to preserve anonymity.

The majority of participants were trade-skilled migrants or the wives of trade-skilled migrants, an unusual cohort in the context of Chinese Australia that is predominantly middle-class (Stevens, 2022). ‘Trade-skilled migrants’ here describes men – the primary visa applicants were all men – who had trained as welders, mechanics, plasterers or similar trades in China and then migrated to Australia during the mid-2000s on employer-sponsored visas. At the time of their initial out-migrations, heavy trade skills were in high demand in Western Australia, and so most of this cohort secured PR, making them eligible for Australian citizenship after meeting residency requirements.

Yet despite occupational similarities both in China and Australia and despite sharing similar migration pathways, this cohort of trade-skilled migrants was not homogenous. On the contrary, there were many points of difference between participants. At the time of interview, they ranged in age from late twenties to early fifties, with most being middle-aged and the parent of a teenage child. Similarly, there was great variation in place of origin, including people from large industrial cities of North China as well as those from rural areas disadvantaged in China's sociospatial hierarchies. I and others have written elsewhere about how trade-skilled migrants’ classed backgrounds condition processes of migration and citizenship (Gong & Wu, 2024; Stevens, 2022, 2023). However, these differences are not a focus of this paper as the cases presented below all feature trade-skilled migrants originating from large first- and second-tier cities in China.

Locating my ‘field’ and this unusual cohort of trade-skilled migrants involved an iterative process of recruitment, reflection and readjustment of research focus. Throughout the study I adopted an abductive analytical paradigm (Tavory & Timmermans, 2014), creatively tacking between my theoretically informed expectations regarding migration, settlement and citizenship and the novel insights generated through information shared by participants. My interpretation of and responses to this information, the kinds of knowledge shared, as well as my later approach to the thematic coding of interview data and fieldnotes, were deeply shaped by my own personal experiences of migration to Australia.

Although I am not Chinese, and therefore was undoubtedly seen by participants as an ethnic and racial outsider, in practice I found that other shared dimensions of our lives, such as parenting in a foreign land away from family, produced a dialectic between ‘moments of insiderness and outsiderness’ (Van Mol et al., 2014, p. 70) and a consequent fluid space of connection and explanation that facilitated our collaborative production of meaning and knowledge (Ergun & Erdemir, 2010; Van Mol et al., 2014; Voloder, 2014). My life story as a migrant who sequentially held three different temporary and permanent visas before acquiring Australian citizenship was an important site of shared identity. Rather than simply hearing participants’ tales of immigration woe, we could instead exchange views and compare scenarios. Although I was already a citizen, a loved relative was trying to obtain PR at the time of this fieldwork. My anxiety was real and contributed to authentic conversations about navigating changing regulations in an uncertain policy landscape.

Calculating the relative value of Chinese and Australian national citizenships

Whether or not to take Australian citizenship was a common topic of conversation among participants, frequently discussed as a significant and stressful life decision in light of unpredictable migration governance in both Australia and China.

Migration law in Australia is complex and subject to frequent change, characterised for many by unpredictable outcomes. Since the 1990s, Australia has seen the expansion of temporary visas and increasingly complex and demanding application criteria (Boese & Robertson, 2017; Castles et al., 2014). Labour migrants to Australia often experience protracted temporariness and uncertainty, churning through a series of visas without dependable pathways to settlement (Robertson, 2019; Stevens, 2019). However, in comparison with the dizzying range of temporary and permanent subclasses that face migrants without a settled status, maintaining PR status is quite simple, requiring visa renewal every 5 years, a process that has remained remarkably stable since its introduction in 1994. Similarly, there is a clear path to citizenship for migrants with permanent status who meet residency requirements and complete a citizenship test.

In China, migration is managed under the Entry and Exit Administration Law 2012 that came into force 1 July, 2013. While this legislative reform delivered significant changes and improved transparency (Liu & Liu, 2013), my fieldwork commenced shortly after the new regulations and so earlier public administration of migration is more relevant to the emic perspectives of participants in this study. Prior to the new legislation, Chinese migration law was complicated, piecemeal and opaque, administered under a complex combination of laws and regulations that functioned as a ‘bureaucratic barrier to migration’ (Liu, 2008, p. 317, 2011), resulting in significant uncertainly for individuals regarding their own rights and interests (Liu, 2008; Pieke, 2012). Even after legislative reform, pathways to return migration remain uncertain for Chinese former nationals, particularly those deemed to have fewer skills of value to national development (Liu & Ahl, 2018).

These two national policy contexts, together with the precarity of residency status and uncertain futures that they produce in individuals’ lives, shape the ways that participants evaluate the relative value of Chinese versus Australian citizenship, and the kinds of strategies they devise to manage transnational risk for themselves and their families within the citizenship constellations available.

Calculating the instrumental value of Chinese citizenship

Migrants from China living in Perth gave three main reasons for choosing to retain a Chinese passport and not naturalise in Australia. First, there are the practicalities of returning to China for short visits, longer stays or possible retirement migration. Applying for Chinese visas is inconvenient: it costs money and takes time. Furthermore, visa regulations, like other aspects of Chinese public administration, are perceived as opaque, open to subjective interpretation and subject to unpredictable future changes, potentially resulting in permanent exclusion. The second, and closely related, concern involves the hukou and related access to public services. Finally, some migrants feel their citizenship as legal status reflects their identity, loyalty to and pride in the Chinese nation.

Of these three concerns, the last was least emphasised by participants. Some highlighted the strength of their national identity, citing their need to belong in China as a compelling reason to not naturalise. ‘No, I haven’t [taken citizenship], I love China!’ exclaimed Zhang Hui, a full-time parent married to a welder. She had seriously considered applying for Australian citizenship, even studying in preparation for the test, but eventually decided against it. Zhang Hui here points to the ‘identification component of formal membership’, which Pogonyi (2019, p. 3; see also Bauböck, 2019) argues remains salient despite shifts towards the instrumentalisation and commodification of citizenship.

However, while most participants echoed Zhang Hui's patriotic tone, expressing deep affection for China, on the whole their discussions of legal status were overwhelmingly pragmatic in tone. This practical approach was exemplified by Sarah, who said, ‘China is developing and there are lots of opportunities there, so it's better to keep the Chinese passport’. Paul agreed with this view but also spoke of his emotional connection to his homeland. He enjoys going back whenever his work and the children's schooling permit, and will not risk limiting his right to return:

I have feelings for China. It's where I grew up. I like being able to go back there when I want to. If we take Australian citizenship and then China makes changes [to immigration policies] then maybe it would be difficult to go back … Later on, when we retire, maybe we’ll spend more time there, perhaps 18 months in China and 18 months here, something like that.

For most participants who were unwilling to give up their Chinese citizenship, their concerns centred on the loss of the hukou status that accompanies national membership. Most trade-skilled migrants who participated in this research first went overseas in their thirties or even forties, after one or two decades of working in factories in China. Those employed through urban work units had typically made contributions to pension schemes throughout that time and looked forward to being able to draw on those funds once they reached a pensionable age. This is a powerful financial incentive to retain Chinese citizenship and the local hukou membership nested therein (Stevens, 2023). For people like Paul who harbour future imaginaries of return or circular migration following retirement (Stevens, 2019), keeping their home city hukou is essential since they do not want to consider growing old in China without access to health care and similar services.

However, the extent to which hukou is valued as a reason to retain Chinese citizenship varied between participants based on their place of origin within China. The strategic benefits of local membership afforded through hukou are most tangible for urban residents, particularly those with membership of larger, wealthier cities, and those with employment in large work units ‘inside the system’ of the post-reform socialist state (Solinger & Hu, 2012; Tang & Tomba, 2013; Wu, 2010). Although not a focus of this paper, differential local membership is reflected in the strategic citizenship calculations of permanent residents in Australia, with people with rural hukou backgrounds likely to value Chinese citizenship less highly than their compatriots who enjoy administrative membership of first-tier cities (Stevens, 2023).

Finally, Australian citizenship is not highly valued when compared to the denizen rights accorded permanent residents. Alongside her strong patriotic sentiments, Zhang Hui also feels that Chinese citizenship has too great an instrumental value to be given up lightly, certainly not for the benefits of Australian citizenship, which she perceives to be no better than those of PR:

Keeping Chinese citizenship means we can always go back after they [her children] have grown up. It's a kind of insurance … It only costs $200 to become an Australian citizen. But if you wanted to become a Chinese citizen you could spend any amount of money and you still probably wouldn’t get it.

This disregard for the democratic component of citizenship was common among participants. With few exceptions, people in this cohort were uninterested in Australian politics and saw little value in participating in elections.

Calculating the instrumental value of Australian citizenship

Despite the widely recognised benefits of Chinese citizenship, for many there remain compelling reasons for choosing Australian citizenship. These reasons relate to higher education and employment, to the risks of visa cancellation for non-citizens, and to the anxiety engendered by uncertain diplomatic relations between China and Australia.

Some participants felt higher education loans were a reason to naturalise. Since 2005 these government loans have been restricted to Australian citizens, humanitarian migrants, and certain temporary visa holders, such as New Zealand citizens living in Australia since childhood. To access these loans, parents reported either taking citizenship together with their teenage children, or advising children to naturalise independently at the age of 18. Harry, a welder and father of two, said this is better than parents having to pay university fees, which he thinks makes young people lazy and too reliant on their families. He told me, ‘I won’t give them money or pay their fees though. When my son goes to university, I will make him take citizenship and then he can get a government loan. He can get a job and earn enough money for his daily expenses’.

Other parents think Australian citizenship improves employment opportunities. Chen, another welder, will always retain his Chinese citizenship because he claims a pension through his former work unit in China. ¹ However, Chen thinks his son should naturalise because he is currently completing his undergraduate degree and will soon enter the workforce. Chen believes employers discriminate against Chinese names, but having Australian citizenship might help him find work.

Other factors, particularly reforms to Australian migration legislation, cause some migrants to consider applying for citizenship. Although the denizen rights afforded migrants with PR closely approximate those of naturalised Australians, permanent residents remain non-citizens under the Migration Act, whose visas may be cancelled.

In December 2014, while fieldwork was underway, the Migration Amendment (Character and General Visa Cancellation) Bill 2014 came into effect. Following this amendment, visa holders who failed the ‘character test’ ² became subject to mandatory rather than discretionary visa cancellation. News of this change and fear of detention and deportation caused feelings of disquiet, even among law-abiding migrants. Participants reported deciding they would take Australian citizenship because it is ‘safer’. As David explained, ‘If you have PR then it's just a visa. If you do something wrong, then it's easy to cancel it. If you are Australian then you might get a fine, or possibly go to jail, but you still have your passport’.

Zhao, a small-workshop owner, reported that dealing with government agencies is easier with an Australian passport, rather than foreign identity documents. He also says he feels safer after having become a citizen. Before naturalising, he was afraid that if he did something wrong, such as incorrect administration when employing sponsored migrants, ‘there could be serious consequences for a permanent resident while a citizen will just get a fine’. His interpretation of the law here was flawed, as a minor offence incurring a fine would not result in visa cancellation. However, whether correct or not, his (mis)understanding of possible legal consequences formed part of the rationale for his decision.

Rose, a stay-at-home mother who has chosen Australian citizenship for herself and her children, articulated the tension between fearing disruption to life in Australia through lost legal status, and the practical problems of giving up a Chinese passport:

My husband still has PR. But he thinks maybe he should become a citizen since Immigration have tightened controls over PR. Before you could only lose your PR if you did a serious crime like kill someone. Now you can lose it even for things like illegal driving. But if he takes citizenship then that means every time that he goes back, he must apply for a visa. His parents are there so he goes back frequently.

Many participants fear future changes to Australian migration legislation that might limit their right to remain. Although the PR renewal process is quite simple, Australian migration policy is perceived as unpredictable and constantly changing. This is not surprising; most migrants have struggled with frequent amendments to application criteria when applying for temporary or permanent visas. Tales abound of would-be migrants who have made mistakes navigating the complex legislative landscape and been forced to leave. Even long-settled permanent migrants usually know other, more recent, arrivals who still battle with changing visa criteria and an insecure temporary status (Stevens, 2019).

It is highly unlikely that Australia will revoke the right to visa renewal for locally domiciled permanent residents. Nonetheless, participants feel insecure in their non-citizen status. Perceptions of Australian migration law inform migrants’ decisions, no matter whether they are based on reliable sources or on hearsay and rumours. When other visa regulations can change so rapidly, it is reasonable that people should similarly fear changes to PR regulations.

Some participants further expressed concern that deteriorating diplomatic relations between Australia and China could affect their right to remain. At the time of the fieldwork, China was engaged in a programme of island building in the South China Sea, causing consternation among other territorial claimants to the hydrocarbon- and fisheries-rich region. In 2015, the United States conducted freedom of navigation exercises in the region, and in early 2016, media reports suggested the Australian navy might do the same. China, meanwhile, rejected external intervention, framing its territorial claims with reference to historical fisheries and the ‘nine-dash line’ (Denemark & Chubb, 2016; Townshend & Medcalf, 2016).

Following the American naval exercises, Chinese media outlets published several articles arguing that Chinese island building was not expansionist, and portraying international responses as neo-colonial, likening them to the ‘Eight Nation Alliance’ (baguo lianjun) of 1901. Such reports were widely reproduced in the Chinese-language media in Australia.

Participants were universally supportive of China's actions, agreeing that Australia should not oppose China's regional claims. One day, while lunching with two welders discussing the maintenance work performed on Australian navy vessels, they light-heartedly debated the ethics of servicing ships that might one day be used against China. ‘You should have left a screw loose!’ laughed one. They were speaking in jest, but their political views were clear.

However, somewhat paradoxically, several people said that escalating diplomatic tensions were a good reason for acquiring Australian citizenship. Sarah explained:

Having citizenship is safer because if the two countries are no longer friendly (tuanjie) then Australia could cancel the visas and make Chinese people go back. But I think if you have become an Australian citizen then they will protect you.

This, too, is a reasonable fear. Less than a century has passed since 15,000 civilians were interned in wartime Australian camps because of their German, Italian, Japanese or other ‘enemy’ country of birth (Neumann, 2006). The response proposed by many of my participants, that is, to take Australian citizenship while simultaneously expressing patriotic support for China, is further evidence of instrumental choices and the dissociation of legal citizenship from nationhood and national belonging (Joppke, 2010). However, it would be a mistake to conflate instrumental citizenship with a dispassionate analysis of citizenship choices. On the contrary, the ways that participants describe the decision-making process and the ways they strategise around status are deeply inflected with emotion, particularly fear, anxiety and powerlessness in the face of unpredictable national policies and broader geopolitical change. Given the insecurities inherent in non-citizen status in either country, for many families the preferred strategy is for some members to take Australian citizenship while others retain Chinese identity documents. Split nationality households are seen to offer the best protection in both jurisdictions.

Split nationality households: citizenship strategies of families in Perth

Sarah and Alan have adapted their family citizenship strategies over time. When we first met, Alan, Sarah and their eldest child held PR, while their youngest was an Australia-born citizen, and they had for several months been actively debating their citizenship options.

Like many other trade-skilled migrants, Sarah and Alan departed China as sojourners, with short-term migration objectives and plans to return (Stevens, 2017). Although they had to resign from reliable jobs and leave the familiar neighbourhood where they had grown up, a decision they did not take lightly, they felt it was worth the sacrifice to have 4 years of work in Australia and then return with savings to start their family.

However, Sarah reflected, time can change a person. They had initially found life in Australia very difficult and so when Alan's boss offered to sponsor them for PR, they initially declined. They just wanted to work out the contract and return home. Friends told them this was a mistake, that in time they would feel differently, that they should take PR and only then consider their future choices. Fortunately, the offer from Alan's employer was still there a few months later, and so Sarah and Alan secured their permanent visas.

It was during this early period that Sarah became pregnant with their first child, born before their PR was approved. Sarah flew back to China to give birth, and then quickly returned to Alan and her job in Australia, leaving the baby with family. This proved a poor solution as the growing toddler was passed from pillar to post, sleeping most nights with her ageing paternal grandmother but spending the days and evenings with various aunts, friends and cousins, with no routine or opportunity to develop regular eating and sleeping habits. This went on for 4 years before she was finally brought to Perth; Sarah still frets about the impact this difficult start may have had on her first-born child.

Once they had PR and no longer faced the employment restrictions of their temporary visa, Alan found a new job in a more convenient location. Before starting, Sarah and Alan went back to their hometown to spend 6 months with their families and young daughter. This was a much-anticipated trip, their first long visit home in over 3 years. And yet home was not how they remembered it. The North China winter felt colder than before, the pollution was oppressive, and the seasonal sandstorms that swept through the city were thoroughly unpleasant. They also found daily life more challenging than in the past. Laughing, Sarah remembered that when they tried to get jobs done, like going to the bank, they would find themselves at the back of the queue, no longer able to assert their way through the crowd. They realised they had grown accustomed to a slower pace of life and were ill-equipped for the hustle of a big Chinese city.

Returning to Perth, they started to imagine a more settled life in Australia. Now they are homeowners and reunited as a family, with a second child born in Perth an Australian citizen. Yet they are not certain what the future holds, and Sarah hopes one day to return to China to live near their siblings; she certainly has no plans to trade her Chinese citizenship for an Australian passport.

Although Sarah is not sure she will live in Australia forever, for the foreseeable future it seems the best option, perhaps the only practical one for her youngest child. ‘If we go back now’, she mused, ‘then I don’t know how they will go to school. My eldest will be fine as she has her hukou, but this one, perhaps she could go to a privately run school, but then when she grows up, if she doesn’t have a hukou …’. She trailed off, uncertain how a life might be managed outside of Chinese systems of identity and administration.

Alan, meanwhile, worried that deteriorating diplomatic relations could prevent them renewing their permanent visas, should Chinese nationals become unwelcome in Australia. After long deliberations, they eventually decided that Alan and their elder child would apply to be Australian while Sarah remained Chinese. Sarah thinks a split nationality household is the safest option because, ‘that way we will be OK on both sides’.

Having a spouse in both camps is a common strategy to hedge the decision to remain in Australia. Jasmine and Mark, like Sarah and Alan, began their Australian lives as temporary migrant workers, leaving their school-aged child behind with grandparents so his Chinese education would not be interrupted while they went overseas for a few years. Over time, however, they came to prefer life in Australia.

After getting PR, they brought their child to Australia to finish high school and have since had a second, much younger, child. He was born Australian, and about whom Jasmine says, ‘there is no point having Chinese citizenship because he doesn’t get a hukou because he was born outside of China’. Both parents and their eldest child are still permanent residents. When their first 5-year visas were due to expire, they considered taking citizenship rather than applying for return resident visas. Yet, when the time came, they decided to keep their Chinese passports. They are sure they will remain in Australia, as they see no future in China for their youngest: he does not speak Mandarin, only their family's local dialect, and is not learning to write Chinese.

Jasmine recognises that losing their hukou matters little if they plan to remain, and yet is still loath to renounce her Chinese citizenship. She says that a split nationality household is the best option for their circumstances but is still choosing to wait another few years. Their new 5-year visas have allowed them to defer the decision a little longer and, although they will regret losing Chinese citizenship, they are now sure that the best strategy will be for one of the couple to naturalise. However, when I asked Sarah which of them would become an Australian, she laughed, ‘Ha! I don’t know. Neither of us wants to. I tell him he should naturalise and he tells me I should naturalise!’.

Another approach for those unwilling to surrender their home city hukou membership is to rely on the Australian citizenship of a dependent child to protect the parents’ right to remain in Australia. This is Zhang Hui's approach, the strategy that she says will allow her and her husband to ‘stay here forever’:

We will probably stay here. We feel safe here as both our children are citizens. No one is going to make us leave. We’ll see after they turn eighteen. Maybe we’ll be [permanent] migrants, maybe we’ll go back to China.

Zhang Hui's understanding of migration law is flawed. There have been cases where one or both parents of dependent child Australian citizens have faced detention or deportation (Ashton, 2017; Mares, 2016). However, Zhang Hui, like other participants who have not naturalised because they have an Australian-born child, is likely to succeed in her objectives. Her PR is unlikely to be revoked, while she keeps all future options through the ‘insurance’ that is her Chinese citizenship.

Discussion and conclusion

This paper has explored the strategic citizenship choices of Chinese migrants living in Australia who must evaluate the relative benefits of Australian versus Chinese legal citizenship. The examples presented illustrate the challenging and often emotionally fraught decision-making process for families living in Perth, Western Australia, including those who elect to create split nationality households, dividing their family members across different national legal statuses.

Although Australian citizenship is perceived to entail some material benefits, particularly in relation to employment opportunities and student loans, the most substantive benefits of national membership, such as access to free primary and secondary education, welfare eligibility, and health services may equally be accessed by permanent residents. Full political membership, including the right to vote and stand for election, is rarely considered a reason to naturalise, certainly not at the cost of losing Chinese citizenship. The benefits of hukou status that are nested within national membership carried particular weight for the participants featured in this paper who all enjoy the privileges of residency rights and related access to public services in major Chinese cities. For other Chinese migrants, particularly rural residents who have experienced lifelong exclusion from both urban administrative benefits and cultural belonging, a Chinese passport may carry significantly less value (Stevens, 2023). These differences illustrate how citizenship experiences, aspirations and practices may be conditioned not only by the nationality/ies and other legal statuses available to individuals and families, but also by other factors and resources, such as class, gender, religious orientation, family composition or life stage (Balta & Altan-Olcay, 2016, 2017).

However, despite participants all reporting highly instrumental reasons for choosing one citizenship status over the other, typically portraying themselves as rational and calculated actors, the narratives of their decision-making processes reveal that seemingly strategic decisions are not made in an emotional vacuum. For most participants, citizenship decision-making was primarily shaped by the risks of non-membership and associated feelings of fear and uncertainty.

Non-citizenship in China is understood as risking the right to return home even for short visits and certainly for longer stays or retirement in older age. Although China has recently introduced visa-free travel for Australian citizens (SBS, 2024), this does little to help former Chinese citizens who are planning for return or circular migration in retirement (Stevens, 2019), and is unlikely to allay the fears of more lasting exclusion should diplomatic relationships worsen in the future. Yet non-citizenship in Australia also carries risk as visas may be cancelled, no matter their supposedly ‘permanent’ duration. During the period of my fieldwork, Australian bordering and migration policy became increasingly restrictive, while Sino-Australian relations deteriorated, heightening anxieties for non-citizen permanent residents.

Given the insecurities inherent in non-citizen status in either country, many families decided the best strategy would be for some members to take Australian citizenship while others retain Chinese citizenship in combination with Australian PR. Forming these split nationality households aims to optimise the benefits and limit risk across all jurisdictions. For some, like Zhang Hui, this involves only the children holding Australian citizenship, acquired either through birth in Australia or through application upon reaching adulthood, an approach that parents see as a form of ‘insurance’ that will ensure they can remain together as a household in Australia. For others, like Jasmine and Mark, one spouse chooses to naturalise in Australia while the other remains Chinese, an approach that underscores both their commitment to life in Australia with their Australian-educated children, alongside their ongoing attachment to Chinese membership and both the instrumental benefits and affective connection to their national homeland that this entails.

These kinds of citizenship practices extend Bauböck's (2010) concept of citizenship constellations, beyond a consideration of the individual as the unit of analysis, to include a more complex network of family memberships. Such an analysis of how webs of complementary and/or competing rights and obligations act on individuals within their family relations has application beyond these specific and situated cases and can improve our understanding of how migrants interpret the value of local, state, national and supranational memberships in various global contexts.

From an Australian policy perspective, irredeemably guilty of a receiving country myopia, a constellations of membership approach can explain variances in naturalisation rates, with reference to the balance of entitlements and obligations, affective and instrumental ties that inform citizenship decisions. A recent Australian government review of the migration system (Parkinson et al., 2023) highlighted the policy objective of encouraging a higher rate of citizenship uptake among long-term Australian residents. It argues a higher naturalisation rate may increase social cohesion through the democratic congruence of the resident population since only citizens elect lawmakers. However, despite highlighting this policy objective, nowhere in the report did the reviewers examine how competing citizenship statuses and valuable homeland ties, whether instrumental, affective or both, might affect citizenship decisions among transnationally engaged Australian residents.

China is among the five source countries for permanent migrants to Australia with the lowest naturalisation rates, alongside others with similarly restrictive and unitary homeland citizenship regimes (Pan, 2021, p. 6). Engaging a constellations lens permits the re-evaluation of denizen statuses, in this case Australian PR, since both permanent residents and naturalised citizens are positioned within those same constellations, maintaining their interests and sustaining mobile future imaginaries in both countries of origin and destination.