So according to Free movement rights: retained rights of residence guidance: To meet the conditions of regulation 10(5)(d)(i) the applicant must have: • been married to, or in a civil partnership with, the European Economic Area (EEA) national for at least 3 years immediately before beginning procee...

Now I got it. No, she wasn't an EU country citizen from birth. She acquired citizenship in 2017 only.

She was eligible for citizenship of one of the EU countries through her parents. I think it's not that relevant to the question, so I didn't expand it in the original post.

Hi all, I will really appreciate an advice or pointing to a relevant guidance that would be applicable in my case. I'm a non-EEA citizen married to a non-EEA wife since 2012. In December 2014 I came to the UK on a Tier-2 ICT visa, my wife came with me as a dependant on my visa. In October 2017 my wi...