Citizenship tests in Europe: four exams, four pass marks
If you are following Portugal's new citizenship test from outside the country, the most useful thing to know is that Portugal is late to a club that already has written rules. Four European states run civic knowledge exams for naturalisation and publish enough detail to compare them properly: Spain, Germany, Denmark and the United Kingdom. Their pass marks range from 51.5% to 80%.
That spread is the headline, and it is also a trap. The pass mark is not what makes one of these exams easy and another hard. What does is whether the questions are drawn from a set published in advance — and that is the question to ask about Portugal the day its regulation appears. The Portuguese state of play is in our guide to the 2026 citizenship test; this page is the comparison that puts it in context.
- Pass marks range from 51.5% (Germany) to 80% (Denmark) — but that is not what decides real difficulty.
- What decides it is whether the questions come from a set published in advance: Germany and Spain publish one, the UK publishes only the material, Portugal publishes nothing.
- Denmark is the only country where part of the exam (10 of 45 questions) cannot, by design, be studied in advance.
- The plausible range for Portugal: 24 to 45 questions, 45 to 60 minutes, a pass mark somewhere between half and four fifths.
The four exams with published numbers
Spain — the CCSE. The Instituto Cervantes publishes the exam specifications as a PDF: 45 minutes, 25 questions grouped into five tasks, and a pass at 15 correct out of 25 (60%). Each year's preparation manual — the pool the year's questions come from — is published free as a PDF.
Germany — the Einbürgerungstest. The Federal Office for Migration and Refugees states it plainly: «you will be given a test form containing 33 questions… If you answer at least 17 questions correctly, you have passed», within 60 minutes, four options per question. Thirty questions cover living in a democracy, history and responsibility, and people and society; three are about your federal state. Fail and you may retake it.
Denmark — the indfødsretsprøve. Denmark regulates its exam by decree, Bekendtgørelse no. 2069 of 18 November 2021. Section 9 sets 45 multiple-choice questions and, at subsection 5, a 45-minute duration; section 2 says the exam is held twice a year. The pass rule is the strictest of the four: «En prøve er bestået, hvis minimum 36 ud af de 45» — 36 correct out of 45, or 80%.
United Kingdom — the Life in the UK Test. GOV.UK gives the whole thing on one page: 24 questions in 45 minutes, a 75% pass mark, and a £50 fee. Retakes are unlimited — «You can rebook the test as many times as you need» — but you pay each time. Under-18s and over-65s do not sit it at all.
Austria is left out of the table deliberately. The exam exists, but its content varies by federal state, and the City of Vienna's official page names the three subject areas without publishing a question count there. It does say something almost nobody else does: «Der Staatsbürgerschaftstest und die Lernunterlagen sind kostenlos» — the test and the study materials are free.
| Country | Questions | Duration | Pass mark | Public bank? |
|---|---|---|---|---|
| Germany | 33 | 60 min | 51.5% (17/33) | Yes — full catalogue |
| Spain | 25 | 45 min | 60% (15/25) | Yes — annual manual |
| UK | 24 | 45 min | 75% | Material only, not the questions |
| Denmark | 45 | 45 min | 80% (36/45) | Partial — 35 of 45 |
Why the pass mark tells you less than you think
In order: Germany 17 of 33 (51.5%), Spain 15 of 25 (60%), the UK 75%, Denmark 36 of 45 (80%). Read on its own, that ranking says Denmark runs the hard exam and Germany the soft one. It is the wrong reading, and the reason is in what each country hands out beforehand.
Germany publishes its full question catalogue. Spain publishes the annual manual its questions are drawn from. In both, a candidate can in principle see every question that could be asked. A 51.5% pass mark on a closed, published set is a different exam from 51.5% on an unknown one — the same number describing two unrelated levels of difficulty.
So the rule worth carrying into the Portuguese case is the opposite of the intuitive one: difficulty lives in how much of the material is public, not in the pass mark.
And there are three rungs here, not two — a distinction most comparisons miss. On the top rung sit Germany and Spain, which publish the questions. On the second sits the UK, which publishes the materialand says outright that nothing outside it is tested — «You'll only be tested on information from the official Guide for New Residents» — but does not publish the question set. Denmark is on that second rung for 35 of its 45 questions and off it entirely for the other ten. On the third rung sits Portugal today: no questions, no manual, no syllabus. That is the difference between revising a set, revising a book, and revising a topic.
Denmark asks, by design, what it did not publish
Section 9 of the Danish decree says something the other three do not. Of the 45 questions, «35 af de 45 spørgsmål ligger inden for rammerne af det læremateriale» — 35 come from the study material the ministry publishes. The other ten do not: five concern current events in Danish society, and five concern Danish values, expressly described as questions «hvortil svaret ikke fremgår af lærematerialet» — whose answer is not in the study material.
Put the two together: the highest pass mark of the four, and ten questions in 45 that by design cannot be revised from the official source. A candidate who masters everything published still has to get some of the unpublished part right. That is a deliberate policy choice, written into a legal instrument, not an accident of drafting.
One more difference matters more than it looks. Denmark holds the exam twice a year. Failing in one sitting means waiting for the next, which is months away. The UK lets you rebook whenever you like; Germany lets you retake. Across all four, the real cost of failing is the wait, not the fee.
The Danish decree adds one feature none of the others has. Section 9(4) fixes the language level of the civic exam itself: «Det dansksproglige niveau for prøven er niveauet for Prøve i Dansk 3.» The civic test is written at a statutorily defined level of Danish, which makes it partly a language exam too. Portugal keeps the two apart — language and civic knowledge are separate requirements, proved separately, which is worth understanding before you plan anything; that is the subject of our guide to the two exams the process can require.
Costs are just as scattered, and worth quoting only where the state publishes them. The UK charges £50 per attempt. Denmark sets the fee in section 3(2) of the decree at 815 kroner — with the caveat, in section 3(3), that the figure is expressed at 2021 levels and is uprated. Vienna says the test and its materials cost nothing. The practical point for anyone budgeting: in every one of these countries the exam fee is the small line. The application fees are the large one.
What this does and does not tell you about Portugal
It brackets the plausible range: something between 24 and 45 questions, 45 to 60 minutes, multiple choice, a pass mark somewhere between half and four fifths. None of the four invented an exotic format, and it would be strange for Portugal to be the first.
It tells you nothing about the actual Portuguese numbers. The question count, pass mark, fee and retake rules all depend on a regulation provided for in Lei Orgânica no. 1/2026 that has not been published. As of 14 August 2026, when this article was written, no such instrument appears in the Diário da República. Anyone quoting you a Portuguese figure today has taken it from another country or made it up.
What it does give you is the right checklist for the day the regulation lands. In order of importance: is there a published question bank? How many sittings per year? How many attempts are allowed? The pass mark — the number every headline will lead with — is the least informative of the four.
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