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How do countries with mandatory military service handle obligations for dual nationals living abroad (comparative examples)?
Executive summary
Countries handle dual nationals’ conscription differently: some treat dual citizens like any other citizen and can require service on arrival or even while they live abroad (U.S. State Department warns of this) [1], while other states or bilateral arrangements may exempt or defer service—historical protocols and limited country lists have created carve-outs in some cases [2] [3]. Coverage in the supplied sources is uneven and mostly general; specific country-by-country rules and up-to-date treaties are not comprehensively listed in these materials (not found in current reporting).
1. How states frame the problem: citizenship = obligations
Governments that maintain compulsory service often treat citizenship as a bundle of rights and duties that applies wherever the person is a national; the U.S. Department of State’s guidance plainly warns that dual nationals “may have to do military service in the foreign country where they are a national,” and that such liability “may be imposed immediately upon arrival or when attempting to leave the country” [1]. Analyses aimed at expatriates likewise stress that dual nationality can carry civic obligations such as conscription, jury duty and tax liabilities — and that residence or physical presence often matters for how those obligations are enforced [4] [5] [6].
2. Practical enforcement: arrival, travel and residence matter
Sources emphasize practical triggers for enforcement: many countries will impose conscription obligations when a dual national sets foot in the country or applies for exit, making travel itself a fraught moment for people with a second passport [1]. Advisory and immigration-oriented sites reinforce this point, noting that the primary state of residence often has the “primary right” to demand military service, and that permanent residency or physical location therefore frequently determines who will call someone up [6] [7].
3. International law and historic exceptions: a limited framework
There is an older international framework that tried to address competing obligations: the 1935 League of Nations Protocol on double nationality included specific language about military obligations and exemptions for certain cases (for instance, an exemption during minority where renunciation is possible), showing that treaty solutions have long been contemplated [2] [8]. Those historic instruments demonstrate the possibility of formal exceptions, but they do not by themselves describe modern, comprehensive country practices [2].
4. Country-level carve-outs and U.S. practice: selective exemptions exist
The Selective Service system and related commentary show that exemptions for dual nationals are not unheard of: historically, the U.S. listed certain countries whose dual nationals were exempt from induction into the U.S. military in the event of a draft, and a 2006 list appeared on the Selective Service site (examples and the practice were documented online), but the administration of such exemptions has changed over time and the publicly available list was later removed [3]. That patchwork underscores that exemptions can be narrow, conditional and subject to administrative change [3] [9].
5. Common patterns across comparative examples
From the available reporting, three comparative patterns appear: (a) unconditional conscription regardless of residence — some countries require service of all nationals no matter where they live [5] [10]; (b) residence-based enforcement — the state of permanent residence typically takes precedence and the person normally serves where they live [6] [7]; and (c) treaty or administrative exemptions — specific bilateral or internal rules can exempt some dual nationals, but these are limited and often time- or country-specific [3] [2].
6. What expatriates should watch and what sources do not provide
Practical advice in these sources stresses checking the foreign country’s laws before travel, because obligations can attach on arrival or departure and because agreements that affect military obligations are rarer than tax treaties [6] [4]. The materials supplied do not provide a current, country-by-country table of who is required to serve while living abroad or which modern bilateral treaties remove obligations; detailed, up-to-date national statutes and consular guidance are not included in the supplied reporting (not found in current reporting).
7. Conflicting perspectives and hidden incentives
Government travel pages and expatriate-advice sites align on basic warnings, but they serve different audiences: state travel pages emphasize legal risk and consular limits [1], while citizenship-advice and commercial mobility sites highlight the benefits of dual nationality and downplay changeability — an implicit commercial incentive to present second passports as broadly advantageous [4] [7]. Historical treaty texts highlight the legal possibility of exemptions but do not equate to modern, uniform protections [2].
If you want a brief country-by-country snapshot for specific nationalities (e.g., Israel, South Korea, Turkey, Russia), I can search for current consular and statutory texts and return a sourced, comparative table — the present sources do not contain up-to-date, individual-country enforcement rules (not found in current reporting).