In this paper I distinguish residential, intergenerational and derivative citizenship regimes. I argue that empirically they correspond roughly to local, member state and supranational level citizenship in the EU. I argue further normatively that, given the constitutional architecture and political telos of the EU, the combination of the three regimes is defensible and even attractive when compared to possible alternatives. The current legal framework for citizenship in the EU shows, however, several deviations from a model that combines the three regimes in a coherent way and I claim that these deviations are problematic. Among them are (1) a lack of harmonization in access to member state citizenship, (2) local voting rights as a privilege of EU citizens, (3) a risk of either no representation or double representation of mobile EU citizens in national elections and the European Council. I suggest that the best solution for the latter problem is an external franchise in national elections for all EU citizens residing in other member states.
