Migrants into Members: Social Rights, Civic Requirements, and Citizenship in Western Europe

Gregory C. Baldi

Gregory Baldi is an Assistant Professor at Western Illinois University.

Sara Wallace Goodman

Sara Wallace Goodman is an Assistant Professor at the University of California, Irvine.

How do states in Western Europe turn outsiders into insiders? In a West European Politics article,[i] we argue that immigration has generated - and continues to generate - distinct national membership conditionality structures (MCS) that uniquely characterize each country’s approach toward managing new populations. These structures are characterized by three policy spheres: access to status (including citizenship but also other statuses, such as permanent residency), social benefits eligibility, and civic integration requirements (e.g., language and country knowledge). We illustrate how linkages across these policy sectors shape different membership-making processes for third-country nationals (TCNs) by examining the MCS variation in Germany and Britain, two countries that both experienced significant migration inflows beginning in the first postwar decades. As a contrast to these two “mature” MCS cases, we also include a study of Spain as a “nascent” case, whose recent experience with large-scale immigration provides an opportunity to consider an MCS under active construction. 

In Germany and Britain, we observe the common deployment of status access, civic integration, and benefit eligibility policies in response to the immigration of TCNs that began in both countries after World War II. At the same time, however, we find variation in these national structures. In aggregate, we describe German policy interactions as producing an inhibitory MCS, in which the citizenship regime has been moderated from its historical ethno-cultural orientation but the obligation costs - reflected in benefit and civic integration requirements and restrictions - serve effectively to elevate permanent residence as an additional barrier to naturalization. While citizenship has become more accessible to non-ethnic newcomers, its achievement has been linked to a demonstration by permanent residents of their ability to remain self-sufficient without relying on social assistance, to participate in the Germany’s core contributory programs, and - by the 2000s - and to obtain language and country knowledge proficiency. This chain of obligations in exchange for the status of full membership and rights with ‘no strings attached’ sustains a policy configuration that is largely exclusionary for significant portions of the migrant population. While we see liberalization of membership on paper, and generous access to welfare state provisions in principle, we see in practice continued restriction.

In Britain, by contrast, we observe the confluence of policies yielding a more promotive MCS. This designation does not imply that it is necessarily fairer or more generous to newcomers than the German MCS, but that the membership structures in Britain emphasize individual promotion and responsibility, demonstrated in restrictions upon entry and the rise of language and country knowledge requirements for newcomers, but not ones that act as barriers to full citizenship. We see this reflected in the general lifting of benefit restrictions and utilization penalties following settlement and the citizenship incentivization design of civic integration. These observations are supported in our article most visibly in the very different patterns of citizenship acquisition in Britain since 2000 compared to those in the FRG.

Spain’s experience with newcomers differs from the British and German cases, although these differences may prove to be more of timing and degree rather than of kind. Immigration is almost completely a twenty-first century development for Spain.  Developments in the country since 2000 bear more than a passing resemblance to Britain and Germany in the first postwar decades, which were marked initially by large-scale inflows of migrants to both countries but concluded with the recessionary 1970s that brought an end to labor migration and the beginning of the social benefit contractions. The Spanish MCS has largely been driven by the status access component, and specifically its ethno-national citizenship policy that has given preference to newcomers from Ibero-American nations, descendants of Spanish emigrants, and most recently, dual citizenship to Sephardic Jews who can trace their ancestry to expulsion in 1492.

We anticipate the austerity and unemployment of the recent economic crisis will lead to a greater deployment of the tools of social policy, and potentially even civic integration, as part of a changing Spanish membership strategy.  In other words, Spain may not remain an outlier for much longer. The precise orientation, however, of Spain’s future membership promotion structure is difficult to predict. On one hand, the general absence of politicization over new arrivals and emerging prohibitions on non-settled TCNs’ access to social benefits point towards a more promotive structure, like in Britain. On the other hand, legacies of Spanish citizenship policy may lead to a more inhibitory, German-style of membership promotion. 

In general terms, the sources of the policies examined in our paper can be found in the common challenges to long-standing conceptions of membership in European nation-states. created by the experience of immigration to the continent that began in the postwar period.  As countries matured as immigrant-receiving nations, they began to deploy and develop ‘internal’ mechanism for the regulation of membership to fashion a myriad of formal and symbolic relationships between newcomers and the state. As we argue in our article, however, the status access, civic integration and welfare benefit eligibility components of national membership promotion structures have been utilized in different ways and to different effect. We believe this observation demonstrates how nation-states facing broadly similar conditions of international migration, can combine new tools with existing policy instruments in variable ways to regulate national membership in the twenty-first century.



[i] Baldi, Gregory, and Sara Wallace Goodman. 2015. “Migrants into Members: Social Rights, Civic Requirements, and Citizenship in Western Europe.” West European Politics (ahead-of-print): 1–22.


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