Citizenship Policies and Politics in European Union Member States

Djordje Sredanovic

Djordje is an Adjunct Professor at the School of Foreign Languages and Literature, Translation and Interpreting, University of Bologna

Comparative studies of citizenship legislation have now more than 20 years of history. Citizenship and the rules for its acquisition and loss have a number of consequences for the life of the population, migrant or not, and therefore it is entirely understandable why there is interest in the choices and legal provisions that states make. Europe has been a privileged locus for comparative studies, and the EUDO Citizenship database ( is a precious resource for all scholars of citizenship. The database is currently enlarging its scope to the Americas, while the AfriMAP project offers comparative data on citizenship in Africa (

A diverse number of factors have been invoked to explain change, differences and convergences in citizenship legislation. These include culture, institutional history, institutional imitation, general democratic norms, demography, economy, and the strength of judicial power. Comparative studies have become more complex over the years, and an explanation based on a single factor is no longer plausible. My aim in this study was not therefore to build an explanatory model covering all the possible factors, but rather to explore whether politics is a plausible factor among those determining the direction of citizenship legislation change in EU countries, and if so, in what way.

I started by coding the changes in key citizenship norms in the 28 current EU member states between 1992 and 2013. I considered: the norms regulating ordinary naturalization based on residence; naturalization for the spouse of a citizen; language and cultural tests or requirements; toleration of dual citizenship; and the determination of citizenship of children born in the national territory from non-citizens.

I then examined whether these changes showed links with the parties in power, coding the governments along a left-center-right divide, and, according to the European Parliament, groups to which its parties belonged (the latter being a more viable alternative to the traditional “political families” approach).

Having this data, I explored two positions. Firstly, I looked at how many of the citizenship legislative changes enacted by center-left, center-right and center (or great coalition) governments were inclusive (i.e. made obtaining citizenship easier), and how many were restrictive. I did this same analysis for all of the governments that included party members of a given EU parliamentary group. Secondly, I coded all the governments in power between 1992 and 2013, and I looked at how often inclusive and restrictive reforms happen in the presence of a given type of government. The first analysis can tell us whether a specific political position is linked more with inclusive or restrictive reforms, and the second, how probable is that a given kind of reform passes with a given kind of government.

The results of the analysis confirm that politics – in the sense of the parties in power – is a plausible factor in influencing citizenship legislative change. Center-left governments enact reforms that tend to be more inclusive than center governments and center-right governments. Among the main EU parliament groups, Greens-Socialists-Liberals-Populars works as a scale that goes from more inclusive to more restrictive tendencies.

Obviously, these are only tendencies – I pointed out that no single factor can be considered adequate to explain the entire phenomenon of citizenship legislative change, and indeed center-left governments have enacted restrictive reforms, and center-right governments have enacted inclusive ones.

What is interesting is that the picture changes if one distinguishes between the first 15 states to become members of the European Union and the other 13 that acceded starting in 2004 (mostly East European states, plus Cyprus and Malta). On one hand, the differences between left and right become more clear-cut looking only at EU15 states. On the other hand, differences between right and left are less clear in the other 13 states, and, according to the specific definition chosen, the polarity can even become inverted, with the left enacting restrictive change and the right resulting inclusive change. While there are also significant differences in immigration levels between the two groups of EU countries, I think that the most plausible reason for this difference is the fact that the party systems are not entirely comparable between the two contexts.

More surprising are the results that I found when examining the far right. Marc Morjé Howard has conducted one of the most advanced analyses of the interplay of politics and citizenship legislation in Europe, concluding that while left-wing is associated with inclusive reforms and right-wing with restrictive ones, the presence of a significant far-right party or anti-immigrants mobilization can halt any inclusive reform[1].

My analysis came to a rather different conclusion, namely that the far-right is not a determinant factor in comparative perspective. However, this is limited to the relation between parties in power and the content of citizenship legislation change, and does not include parliamentary debates, public politic debates,[2] or the anti-immigrant mobilizations considered by Howard.

Keeping this caveat in mind, my data suggests that the presence of a far-right party in parliament does not seem to influence the ratio between inclusive and restrictive reforms or, that it increases slightly the probability of a restrictive reform, and that in fact it actually increases the probability of an inclusive reform.

This does not mean that far-right parties are without influence – some single country analyses[3] show clearly how such parties have a significant role in specific contexts. Rather, what my analysis suggests is that other contexts, in which no significant far-right party exists in parliament, do not show different tendencies in the changes to citizenship legislation. In other words, far-right parties are not necessarily powerless – rather, where they are missing there are often other forces that play a similar role, forces coming from the mainstream right.

My analysis suggests that politics does play a role in orienting legislation change in the field of citizenship. In particular there seems to be a link between left-wing and inclusiveness and right-wing and restrictiveness, especially in the EU15, and that the far-right does not seem to be the main cause of restrictive reforms or lack of inclusive ones.

There are two main directions in which these aspects would need to be further studied. The first would be extending the comparison beyond Europe – something that databases like EUDO Citizenship and others are starting to make easier. The other would be to deepen the analysis, in particular looking at actual debates and votes in national parliaments – an analysis that would, however, need new databases to collect such data in a comparable form.    


Djordje Sredanovic's full article from the International Political Science Review can be found here:

[1] Howard, Marc Morjé (2009) The Politics of Citizenship in Europe. Cambridge: Cambridge University Press.

[2] But for example the media analysis of political debate of Meyer and Rosenberger also shows that the far right does not have a determining role in setting the terms of debate about emigration. Meyer, Sarah and Rosenberger, Sieglinde (2015) Just a Shadow? The Role of Radical Right Parties in the Politicization of Immigration, 1995–2009. Politics and Governance, 3(2): 1-17.

Open access at

[3] See for example Ersbøll on Denmark -

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