RSCAS PP 2013/15
Robert Schuman Centre for Advanced Studies
EUDO Citizenship Observatory
Membership and/or rights? Analysing the link between
naturalisation and integration policies for immigrants in
Europe
Thomas Huddleston and Maarten Peter Vink
European University Institute
Robert Schuman Centre for Advanced Studies
European Union Democracy Observatory on Citizenship
Membership and/or rights? Analysing the link between
naturalisation and integration policies for immigrants in Europe
Thomas Huddleston and Maarten Peter Vink
RSCAS Policy Paper 2013/15
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© Thomas Huddleston and Maarten Peter Vink, 2013
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Robert Schuman Centre for Advanced Studies
The Robert Schuman Centre for Advanced Studies (RSCAS), created in 1992 and directed by Brigid
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EUDO CITIZENSHIP
EUDO CITIZENSHIP is part of the European Union Democracy Observatory and publishes two kinds
of working papers: (1) peer reviewed and previously unpublished manuscripts on topics of citizenship
laws and policies covered by the observatory and (2) collections of edited contributions to EUDO
CITIZENSHIP Forum Debates. For more information, visit our website at http://eudo-citizenship.eu
Series editors:
Rainer Bauböck (European University Institute, Political and Social Sciences)
Iseult Honohan (University College Dublin, School of Politics and International Relations)
Jo Shaw (University of Edinburgh, Law School)
Maarten Vink (University of Maastricht, Department of Political Science)
This policy paper was produced in the context of the project ‘Access to Citizenship and its Impact on
Immigrant Integration (ACIT)’ co-funded by the European Fund for the Integration of Non-EU
immigrants (European Commission Grant Agreement: HOME/2010/EIFX/CA/1774).
The views expressed in this publication cannot in any circumstance be regarded as the official position
of the European Union.
Abstract
Traditionally, there are two contrasting views on the way in which European states instrumentalise
naturalisation, residence, and rights policies as part of a broader agenda of immigrant integration.
First, the ‘complementary’ view sees access to membership as a complementary strategy to access to
rights. Second, the ‘alternative’ view sees the granting of social and political rights, independent of
citizenship status, as an alternative to granting access to formal membership through naturalisation.
Whereas there are theoretical and normative reasons to support either perspective, surprisingly, there
has been no systematic comparative work on how in practice states instrumentalise membership and
rights for immigrants. In this paper, we analyse the relation between naturalisation and integration
policies in 29 European states. We find strong empirical evidence in Europe that extending
membership and rights are generally used as complementary strategies of immigrant incorporation.
Naturalisation policies are not simply one of several integration policy alternatives. Hence states with
inclusive naturalisation policies also tend to be inclusive in terms of extending rights to foreigners in
diverse areas of public life, such as political participation, anti-discrimination, education, labour
market access and family reunion. We conclude that naturalisation policies are at the heart of a state’s
integration policy and one of the best predicators of its overall approach to integration. Exclusive
naturalisation policies signal the lack of an inclusive immigrant integration agenda.
Keywords
Citizenship; immigrant integration; naturalisation; comparative analysis.
1. Introduction*
How are naturalisation policies related to immigrant integration policies in Europe? Integration
debates focus not simply on access to formal membership through naturalisation, but also on a wide
array of statuses, rights, support, and opportunities that influence immigrants’ participation in society.
Traditionally, there are two contrasting views on the way in which European states instrumentalise
naturalisation, residence, and rights policies as part of a broader agenda of immigrant integration.
Firstly, the ‘complementary’ view believes that naturalisation policy is at the heart of a state’s national
integration policy. Access to national citizenship is seen as a necessary complementary strategy to
extending rights and opportunities to foreigners. All of these integration policies—naturalisation, longterm residence, political participation, and so on—are supposedly shaped by the state’s underlying
approach to immigrant inclusion. Secondly, the ‘alternative’ view sees naturalisation policy as one of
the various integration policy alternatives. The ‘alternative’ view sees the granting of social and
political rights, independent of citizenship status, as an alternative or substitute to granting access to
formal membership through naturalisation. Within a state’s national integration policy, full
participation can be promoted through naturalisation or long-term residence or political participation
or employment or education—and the list goes on. Contradictions or trade-offs may even arise
between two areas; most notably, should the state grant political rights to foreigners or facilitate their
naturalisation? Whereas there are theoretical and normative reasons to support either perspective,
surprisingly, there has been no systematic comparative work on how in practice states instrumentalise
membership and rights for immigrants.
Our aim in this paper is thus to contribute to the literature on the relative importance of
naturalisation policy for integration by exploring the hidden links between naturalisation and
integration policies in 29 European states. Building on the most comprehensive and rigorous datasets
on naturalisation and integration policies, this paper analyses bivariate correlations between
naturalisation policy and six areas of integration policy: labour market mobility, family reunion,
education, political participation, long-term residence, and anti-discrimination law. The core of this
analysis explores the dimensionality of naturalisation and integration policy with Categorical Principal
Component Analysis (CATPCA). Our conclusion summarises the findings and considers the future
implications for research and policy debates.
2. Theorising the link between naturalisation and integration policies
The overall link between naturalisation and integration policies
The academic literature on naturalisation and integration policies has always been intertwined. Since
its beginnings in the twentieth century, immigration studies have turned to naturalisation as the key
area of integration (e.g. Walzer 1983, Hammar 1985, Brubaker 1992, Castles 1995, Aleinikoff and
Klusmeyer 2002, Bloemraad 2006). Political theorists such as Brubaker (1992), Bauböck (2007), and
Hansen (2009) could be called ‘naturalisationists’ in the sense that they attach great importance to
naturalisation for understanding integration processes and policies. Their work draws on broader
theories of democracy that have traditionally spoken of citizens and national citizenship as the
fundamental status for the preservation and use of civic and political rights. Full citizenship rights are
conditional upon an individual process of application for formal membership, whereby the state
determines who is a national citizen. By extension, national citizenship is seen as the best guarantor of
immigrants' citizenship rights, equal treatment, and recognition in society. Many naturalisationists
*
We heartily thank Rainer Bauböck for his valuable comments on an earlier draft of this paper.
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Thomas Huddleston and Maarten Peter Vink
conclude that naturalisation should be promoted and facilitated in a welcoming country of
immigration. The radical proposal from the naturalisationists camp (Rubio-Marin 2000) would be to
require automatic naturalisation of all long-term residents because shared national citizenship is vital
for democratic cohesion. These theorists pay particular attention to naturalisation as full political
membership, political rights, and greater access to political power. The democratic inclusion of
immigrants is emphasised as one of the guiding principles behind both integration and naturalisation
policies (Bauböck 2005). In that sense, naturalisation is presented as a means—but not necessarily the
end—of the immigrant integration process, which evolves with the changes in the distribution of
opportunities and power within society (i.e. the societal integration or inequalities agenda).
‘Naturalisationists’ have been challenged by so-called ‘post-nationalists’ or, perhaps more fitting in
this context, ‘post-naturalisationists’, who downplay the symbolic and practical importance of national
citizenship. These theorists observe that European liberal democracies, or at least their educated elites,
are in the process of constructing a civic culture based on residence and not on nationality. Most social
and economic rights have been decoupled from nationality through European integration and the
global human rights framework (Soysal 1995 and Joppke 2010). This rights framework in Europe is
often cited as ‘the’ explanation for the low naturalisation rates among immigrants who are citizens of
EU Member States or developed states such as the US or Canada. These theorists point to these freemoving citizens (and often are ones themselves) as evidence of the insignificance of national
citizenship for most people, including immigrants. Their work associates naturalisation with the
history of nationalism (Kostakopoulou 2003) and the potentially ‘illiberal’ powers of the state (Guild
et al. 2009). These theorists want to devalue national citizenship by disconnecting rights from
nationality status and deriving them from legal residence. In lieu of naturalisation, they advocate for
the extension of all national citizenship rights, including national voting rights, to all legal residents,
under the banner of residence-based citizenship or a rights-based approach. The radical proposal in the
post-naturalisationist camp would be automatic civic registration for all law-abiding legal residents
(Kostakopoulou 2006, 2010). In such proposals, citizenship rights would be collective rights of all
residents and membership would be self-declared by all those who wish to be, say, British or French.
National citizenship would be a legally inconsequential form of membership. As a result,
naturalisation would be neither a means nor end of the integration process, since all residents would
already have the legal means for societal integration.
While there are theoretical and normative arguments supporting either perspective, there is
surprisingly little theory or empirical study of the relationship between naturalisation and integration
policies for immigrants. Two generally contrasting views have emerged on the ways in which
European states instrumentalise citizenship and other targeted policies to reflect their broader approach
to immigrant integration.
The ‘alternative’ view sees granting economic, social and political rights, independent of national
citizenship, as an alternative to granting access to formal membership through naturalisation. Postnaturalisationists and even a few naturalisationists end up inadvertently in the ‘alternative’ camp.
Building their arguments for facilitated naturalisation or residence-based citizenship, they tend to cast
their approach as the ‘better’ alternative to the other, as if governments faced a trade-off or choice
between the two. Post-naturalisationists consider the extension of rights as an ‘alternative’ to
naturalisation, but rarely consider whether the extension of rights to foreigners is related to
immigrants’ opportunities to naturalise. As we will see, this approach to equal rights for foreigners as
an ‘alternative’ to naturalisation is similar to the so-called ‘denizenship’ model where states grant
equal economic, social, and (certain) political rights to foreigners, but without facilitated
naturalisation. The ‘naturalisation as alternative’ logic can also be found among a few
naturalisationists, including Pickus 1998 and Schuck 1989, who argue that extending residence-based
rights devalues national citizenship by reducing immigrants’ incentives for naturalisation. As we will
see, this approach has much in common with the so-called ‘republican’ model, which privileges
naturalisation over equal rights for foreigners.
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Membership and/or rights? Analysing the link between naturalisation and integration policies for immigrants in Europe
The ‘complementary’ view sees access to membership through naturalisation as a complementary
strategy to extending rights to foreigners. The complementary view is often held among
‘naturalisationist’ theorists and comparative legal scholars and political scientists. A general link
between states’ naturalisation and integration policies has been conceptualised by several
‘naturalisationist’ theorists, including Aleinikoff and Klusmeyer, Bauböck, Carens, and Hammar. Both
naturalisation and residence-based rights for foreigners enhance the equal treatment, rights, and
participation of immigrants. Moreover, equal rights for foreigners means that naturalisation will not be
an instrumental choice for immigrants simply seeking equal rights. Instead, equal rights for foreigners
strengthen the voluntary commitment that immigrants make to their country of residence through
naturalisation (Bauböck 1994). Beyond the political theorists, legal scholars regularly take a state’s
naturalisation requirements and tests as the frame for contemporary ‘integration’ debates where
immigrants are expected to act as the ‘ideal citizen’ (Carrera 2009, van Oers et al. 2010, Anderson
2013). Moreover, comparative political scientists regularly select naturalisation requirements as the
main indicators for a state’s broader approach to integration. Within the on-going debate about socalled ‘national models of integration,’ certain naturalisation requirements are interpreted to be proxies
for national political philosophies of assimilation, multiculturalism, republicanism, and so on. The
results of these indicators are invoked both in arguments for the existence of national models of
integration (Hammar 1985, Brubaker 1992, Castles 1995, Banting and Kymlicka 2012) and against
their existence (Favell 2003 and Bertossi and Duyvendak 2012). Comparative political scientists also
point to these results as evidence of integration policy convergence across Europe (Joppke 2007a,
Carrera 2009, and Banting and Kymlicka 2012) or of divergence (Jacobs and Rea 2007 and Koopmans
et al. 2012).
Whatever one’s position in these comparative political science debates, it is striking how most
participants readily assume a strong positive link between states’ naturalisation policies and their
integration policies in other areas of public life. But even in the comparative empirical studies, the
links between the two are usually mentioned in passing, not as an explicit finding with an underlying
theory. Indeed, most of these international policy indicators or indexes focus solely on naturalisation
policies (e.g. Howard et al. 2009, Goodman 2010, Janoski 2010, and Koning 2011). So far, around
half-a-dozen measured naturalisation and other integration policies (Waldrauch et al. 1997,
Huddleston et al. 2010, Ruhs 2011, Banting and Kymlicka 2012, Koopmans et al. 2012, IMPALA and
IMPIC forthcoming). Of these, only the 2010 MIPEX (Huddleston et al. 2010) started to investigate
correlations between naturalisation and other integration policies. As a result, integration researchers
often focus on naturalisation at the expense of other integration policy areas.
The ‘alternative’ vs. ‘complementary’ view regularly resurfaces in the integration debate, for
instance in the latest EUDO-Citizenship Forum debate: ‘Should EU citizens living in other Member
States vote there in national elections?’ (Bauböck, Cayla and Seth 2012), which discussed the
proposed ‘Let me Vote’ EU Citizens’ Initiative. Most contributions slid into the ‘naturalisation as
alternative’ logic. Either naturalisation was presented as the established and realistic path to full
national membership and rights (Bauböck, Brun, and Owen), or extending national voting rights was
seen as the preferable alternative means to remedy the democratic deficit (Kochenov, Kostakopoulou,
and Wilhelm). Only a few contributors adopted the ‘naturalisation as complementary’ argument,
sometimes as a compromise position. Groenendijk advised not to raise the two issues ‘in isolation.’
Going further, MEP Swoboda saw the two as ‘closely interlinked, in a possibly virtuous dynamic.’
Barbulescu boldly opposed the ‘naturalisation as alternative’ logic based on empirical observations:
“Most contributions in this forum have presented enfranchisement by naturalisation and by voting
rights as mutually exclusive alternatives. In fact, the two options tend to go hand in hand with each
other. For instance, those Member States that have a more open access to citizenship also give
long-term residents the right to vote in local elections.”
The main hypothesis of this paper is that naturalisation policies are ‘complementary’ to integration
policies across the 29 European states studied. A strong positive relationship is assumed across Europe
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Thomas Huddleston and Maarten Peter Vink
between a state’s openness on membership (ordinary naturalisation law) and its approach to equal
rights and equal treatment (integration policies). Naturalisation policies and integration policies will be
used by policymakers as complementary integration strategies, rather than as alternative ways to
include immigrants in the polity. Integration and naturalisation policies will have a certain internal
coherence and thus can be categorised in terms of an inclusive vs. restrictive approach. Changes in
naturalisation policies are expected to reflect and shape changes in integration policies. States that
embrace the objective of comparative rights, responsibilities, and opportunities for immigrants and
nationals will grant equal rights for foreigners in various areas of life and facilitate the ordinary
naturalisation of foreigners. States that reject this equal treatment approach will have more restrictive
naturalisation and integration policies. This paper hypothesises that so-called ‘republican’ or ‘denizen’
models are exceptions rather than the rule across Europe, due to specific political circumstances in
these outlier states (e.g. history of immigration, political philosophy on immigrant integration or
broader policies on minorities). Drawing on the literature, this paper also theorises several underlying
links between naturalisation policies and specific integration policies, such as political participation,
anti-discrimination, and family reunion, and, to some extent, long-term residence.
Political rights for foreigners
Facilitating naturalisation and political rights for foreigners are sometimes seen as ‘complementary’
strategies for the political empowerment of immigrants. Both policies affect the franchise and the
democratic deficit (Hammar 1990), reflecting the principles of ‘territorial inclusion’ (Bauböck 2005)
and European principles of integration, according to the Council of Europe and European
Commission.1 In contrast, the restriction of these rights would reflect an ‘ethnic nationalist’ or
‘exclusionist’ approach (Bauböck 2005). In these states, a politically active foreign population is seen
as a potential threat to the democratic order and legitimacy of the state. As such, political rights are
reserved for foreigners who pass the restrictive integration requirements for naturalisation.
Not all states fit within this spectrum of ‘territorially inclusive’ and ‘exclusionist’ states. In
between the two lies the ‘republican’ model, which privileges naturalisation over political rights for
foreigners in order to guarantee equal and full membership for members of the electorate (Bauböck
2005). Policies ascribed to this model preserves the value and incentives for naturalisation through a
facilitated naturalisation policy and a significant ‘rights gap’ between foreigners and national citizens.
Democratic inclusion comes solely through naturalisation and multiple nationality. Conversely, a
‘denizenship’ model is ascribed to states with political rights for foreigners but without citizenship
reform. Policies ascribed to this model preserve a link between national citizenship and national
belonging defined in ethno-national terms through a reduction in the rights gap between foreigners and
national citizens. Foreigners can easily become long-term residents and even voters at local levels, but
not national citizens. Several policy goals can be attributed to this approach: to reduce immigrants’
incentive to naturalisation, to deflect criticism of a restrictive policy framework, and to signal to the
population that naturalisation is reserved for culturally assimilated immigrants. ‘Republican’ and
‘denizenship’ regimes face obstacles shifting to a ‘territorially inclusive’ approach. Politicians in states
granting immigrant voting rights may use them as a justification for restrictive naturalisation laws (e.g.
Baltic and Central European states), while those in states facilitating naturalisation may oppose voting
rights with the same argument (e.g. Canada, France, and the US). Advocates may be forced to make a
pragmatic ‘false choice’ to promote one over the other, as in political debates previously in Belgium
(Jacobs 1999) and currently in France and Italy. Empirically, Groenendijk (2008), Andrès (2013), and
Pedroza (2013) have used qualitative methods to approximate a relationship between inclusive
1
For more, see the Council of Europe’s 1992 Convention on the participation of foreigners in public life at local level and
the 1997 European Convention on Nationality as well as European Commission (2005), A Common agenda for
integration – framework for the integration of third-state nationals in the European Union, Brussels, Belgium,
COM/2005/0389 final.
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Membership and/or rights? Analysing the link between naturalisation and integration policies for immigrants in Europe
political participation and naturalisation policies. Huddleston (2009) and Arrighi (2013) note not only
a correlation between naturalisation and political participation policies, but also a few outlier states
with ‘mutually exclusive’ regimes, i.e. citizenship-based regimes in France and Germany vs.
denizenship-based regimes in Estonia, Denmark, Hungary, Lithuania, and Slovenia. Notwithstanding
these outliers, this paper theorises a generally positive relationship across Europe; the more states
promote political rights for foreigners, the more they also tend to facilitate the naturalisation of
foreigners.
Anti-discrimination law
At first glance, the idea of a link between anti-discrimination and naturalisation laws seems counterintuitive. EU anti-discrimination law does not cover nationality discrimination against non-EU citizens
(De Schutter 2009). Hardly any European states address discrimination within the naturalisation
procedure (Huddleston 2013). Indeed, the 1965 UN Convention on Racial Discrimination goes so far
as to state in Article 1.3 that “nothing in this Convention may be interpreted as affecting in any way
the legal provisions of states parties concerning nationality, citizenship, or naturalisation, provided
that such provisions do not discriminate against any particular nationality.” Theoretically, there could
even be a negative relationship between naturalisation and anti-discrimination law. Facilitated
naturalisation is arguably not necessary if all residents are strongly protected from discrimination
based on race/ethnicity, religion, and nationality/citizenship. Alternatively, states facilitating
naturalisation could argue that this is a sufficient legal guarantee for equal treatment.
Several scholars observe a hidden link between facilitating naturalisation and promoting antidiscrimination. For Goldston (2006), both express principles of equal treatment and ‘genuine and
effective links.’ Joppke (2007b) sees them as ‘logically complementary’ components of horizontal
convergence based on liberal democratic principles. Facilitated naturalisation ensures that citizenship
is no longer seen in nationalistic terms as cultural assimilation, while strong anti-discrimination laws
help individuals fight unequal treatment based on ethno-nationalistic concepts of race and ethnicity.
Similarly, De Schutter (2009) argues that prohibitions of nationality discrimination in EU law and the
majority of EU Member States put pressure on governments to eliminate unequal treatment between
foreigners and nationals, which could constitute indirect discrimination if nationality serves as a proxy
for race, ethnicity or religion. Similar domestic political pressures may also drive reforms of antidiscrimination and naturalisation law; “the institution of citizenship strongly frames the process of
problematisation of racial discrimination” (Gehring 2009). Restrictive naturalisation maintains the
frame of the immigrant as a foreigner, without a legitimate claim to recognition and equal treatment
(Hansen and Weil 2001). In these societies, integration problems may be seen as a sign less of
discrimination from the receiving society than of immigrants’ inability or unwillingness to integrate
(Gehring 2009). Facilitated naturalisation leads to more naturalised citizens with a greater entitlement
to equal treatment, which creates greater pressure for effective anti-discrimination laws. Koopmans
(2005) finds that pro-immigrant and anti-racist mobilisation is strongest in states with inclusive
citizenship laws. In this sense, the promise of equal citizenship makes real-life examples of unequal
treatment more problematic for society.
Family reunion for non-EU citizens
Recent trends have been identified on the restriction of family reunion for non-EU citizens (MIPEX
2010) and even for national citizens (Strik et al. 2013). In addition, a link is often made between
restrictions of naturalisation and family reunion laws. States transpose requirements for naturalisation
onto family reunion in the form of language/integration tests and economic resource requirements
(Carrera 2009, Van Oers 2010). Similarly, states reinforce the naturalisation requirements for spouses
of national citizens (Goodman 2010) in keeping with their family reunion requirements, such as
integration tests and the fight against fraud and ‘marriages of convenience’ (Kofman 2004, Block and
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Thomas Huddleston and Maarten Peter Vink
Bonjour 2013). The presumed link between naturalisation and family reunion laws may be driven by
similar political discussions of restricting marriage migration, including for the second generation
(Goodman 2011, Wray 2013, Strik et al. 2013). These restrictions also aim to remove incentives for
immigrants to naturalise in order to sidestep restrictive family reunion laws (Cinar 2010). This paper
therefore assumes a strong positive relationship between naturalisation policies and family reunion
policies for non-EU citizens.
Long-term residence policies as an alternative?
Traditionally, facilitating access to long-term residence in Europe has been seen as an ‘alternative’ to
facilitating naturalisation. In the 1970s, the end of the Gastarbeiter systems created greater access to
long-term residence and equal rights for foreigners, but not necessarily to facilitated naturalisation.
Long-term residence has been designated positively as ‘denizenship’ (Hammar 1990) or negatively as
a discriminatory form of second-class citizenship (Groenendijk 2006). This perceived negative
relationship between national long-term residence and naturalisation policies has been reinforced
through debates about the EU long-term residence directive 2003/109/EC. The directive aimed to
create a clear path to long-term residence and an EU ‘civic citizenship’ (Commission 2003) in
opposition to restrictive naturalisation laws (Bauböck 2005). EU long-term residence has thus been
debated as either a ‘bad’ or ‘good’ alternative to EU citizenship. Atikcan (2006) regrets that the
Maastricht Treaty did not base EU Citizenship on long-term residence and decries EU long-term
residence as ‘Union Denizenship.’ Whereas Acosta Arcarazo (2011) sees it more favourably as a
potential ‘subsidiary form’ of EU citizenship, which could bridge the rights gap between EU and nonEU citizens at EU level.
Other legal scholars tend to favour the idea of a positive (e.g. complementary) relationship between
long-term residence and naturalisation policies, as a reflection of a state’s overall approach to legal
integration. Groenendijk (2004) argues that a state adopts either inclusive or restrictive requirements
for both, depending on whether legal status is seen as a means to promoting integration or a reward for
completed integration. For example, Groenendijk, Guild and Dogan (1998) grouped together states
with liberal naturalisation and long-term residence policies (France, Netherlands, and UK) and those
with restrictive policies (Austria, Germany, and Switzerland). Weil (2001) expected more inclusive
requirements for long-term residence and naturalisation across Europe, as states recognise themselves
as countries of permanent immigration. In contrast, Carrera (2009) and van Oers (2010) expect
convergence around more restrictive requirements. Long-term residence policies are presented as a
reproduction of naturalisation policy, especially in terms of language and integration tests. The EU
long-term residence directive is seen as promoting national(istic) concepts most visible in
naturalisation policies (Guild et al. 2009).
Given that these scholars have identified trends towards liberalisation, restriction, and something in
between, it is not surprising that other scholars do not see a consistent relationship across Europe. EU
long-term residence may have led to greater harmonisation of national long-term residence policies,
while greater variation may remain in states’ ordinary naturalisation policies in the absence of EU
standards. In addition, harmonisation on long-term residence is uneven. Some national legal
frameworks are more susceptible than others to European legal trends, depending on the legal and
political context (Groenendijk 2005). Setting EU standards may simultaneously lead to greater
openness and greater restriction (Commission 2011). An empirical comparison of long-term residence
and naturalisation policies (Huddleston 2009) led to more than just two ‘liberal’ vs. ‘restrictive’
categories of states, depending on the restrictiveness of the requirements and rights for both statuses:
residence-based citizenship; civic citizenship without democratic citizenship; facilitated national over
civic citizenship; facilitated civic over national citizenship; second-class citizenship; and exclusionary
citizenship. Depending on the state, the relationship between long-term residence and naturalisation
policies may be positive, negative, or insignificant. As a result, this paper hypothesises that, unlike
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Membership and/or rights? Analysing the link between naturalisation and integration policies for immigrants in Europe
other integration policy areas, long-term residence policies are not related to naturalisation policies
across Europe.
3. Data
The Migrant Integration Policy Index (MIPEX) offers the most extensive, rigorous, and referenced
policy indicators on national integration policies. The MIPEX measures policies in seven areas: labour
market mobility, family reunion, education, political participation, long-term residence, access to
nationality, and anti-discrimination (see Table 1 for a list of variables). Other recent comparative
policy indexes offer fewer and less detailed indicators in these areas (see Waldrauch et al. 1997,
MIPEX 2004, 2007, 2010, Ruhs 2011, Banting and Kymlicka 2012, Koopmans et al. 2012, IMPALA
forthcoming, IMPIC forthcoming). For each of the seven policy areas, MIPEX identifies the highest
standards aimed at achieving equal rights, responsibilities and opportunities for all residents. The
highest standards are drawn from Council of Europe Conventions or European Union Directives.
Where only minimum standards exist at international level, European-wide policy recommendations
are used from international research and NGOs. The MIPEX results for 2004, 2007, and 2010 have
been used for comparison and evaluation by political scientists and sociologists as well as advocates
and policymakers.2 The 2010 dataset covers the situation as of 1 June 2010 in the 27 EU Member
States at the time, Norway, Switzerland, Canada, and the United States.
Each MIPEX policy indicator is a question relating to a specific policy component of one of the
seven policy areas. For each answer, there are three options. The maximum of three points is awarded
when policies meet the highest standards for equal treatment. Comparative researchers design each set
of indicators and national independent legal experts collect and anonymously peer review the data at
national level. MPG's central research coordinator conducted a check of the clarity and consistency of
the experts’ answers as well as a validity check against external comparative policy sources. The
central research coordinator undertook the scoring of indicators by converting the initial 1, 2, 3 scale
into a 0, 50, 100 scale for dimensions and policy areas, where 100% is the top score. Within each of
the seven policy areas, the indicator scores are brought together in a simple average to give one of four
dimension scores which examine the same aspect of policy. The four dimension scores are averaged
together to provide a score for each of the seven policy, which, averaged together one more time, lead
to the overall MIPEX score for each state.
The comparative analysis of ordinary naturalisation policies uses, in addition to the MIPEX Access
to Nationality indicator, a combined indicator measuring both the law (CITLAW) and administrative
procedure (CITIMP). This indicator (CITLAW_CITIMP) is based on new publically-available
indicators within the EU Democracy Observatory on Citizenship (http://eudo-citizenship.eu). These
indicators measure the situation as of 31 December 2011 based on a common typology,
comprehensive qualitative database, and expert state reports (CITLAW) as well as questionnaires to
national independent legal experts (CITIMP).3 Both sets of indicators drew inspiration from the
existing MIPEX indicators on Access to Nationality, but since they have been independently
constructed, they can serve as validating measure (see e.g. Helbling 2013 on the importance of
validating citizenship and integration policy indicators). The two datasets include the same states as
MIPEX as well as a half-a-dozen non-EU European states (Croatia, Iceland, Macedonia, Montenegro,
and Serbia). Both sets of indicators included many additional aspects of naturalisation not covered by
MIPEX and coded applying a 0-to-1 coding scale. This report measures ordinary naturalisation
2
3
Check out the different public uses of MIPEX http://www.mipex.eu/use and specifically the research uses of MIPEX
http://www.mipex.eu/use?tg=59&st=All&ct=All
For this typology, see Bauböck et al (2006a, 2006b, 2007); and in particular Waldrauch (2006a, 2006b). For the
methodological reports behind the CITLAW and CITIMP indicators, please see Jeffers, Honohan, and Bauböck (2012)
and Huddleston (2013).
7
Thomas Huddleston and Maarten Peter Vink
policies through a simple average of the CITLAW combined indicator on the ordinary naturalisation
law (ANATORD) and the overall indicator on ordinary naturalisation administrative procedures
(CITIMP). The averaging of the law and the procedure is necessary to capture both the legal and
administrative obstacles to ordinary naturalisation. After all, some states have many legal obstacles but
few procedural obstacles, while others have few legal obstacles but many procedural obstacles
(Huddleston 2013). Hence, any comprehensive indicator measuring the inclusiveness of naturalisation
policies needs to include both aspects because formal requirements as well as implementation can be
viewed as ways to facilitate or restrict the access to citizenship for immigrants.4
4
The resulting CITLAW_CITIMP average correlates highly with the MIPEX indicator on Access to Nationality (r = .711,
see Table 2 below). The correlation is not perfect, since the MIPEX-AN indicator also includes access to citizenship for
second and third generation immigrants, whereas CITLAW_ANATORD and CITIMP are focused exclusively on first
generation immigrants.
8
Membership and/or rights? Analysing the link between naturalisation and integration policies for immigrants in Europe
Table 1 lists all variables included in our analysis, covering variable labels and a brief description of
what is measured by these variables.
Table 1. List of variables
MIPEX – Measure of inclusiveness of national integration policies. This variable is the simple average of seven policy areas:
labour market mobility, family reunion, education, political participation, long-term residence, access to nationality, and antidiscrimination
MIPEX_AN – Measure of inclusiveness of access to nationality for ordinary immigrants and their descendants. This variable
is the simple average of four dimensions, composed of twenty indicators: eligibility (residence requirements for first
generation and presence of ius soli for second and third generation); conditions (inclusiveness of language, integration,
economic resource, criminal, and good character requirements as well as time limit and fees); security of status (level of
discretion and judicial oversight in the procedure and limits on loss of citizenship); dual nationality (right to dual nationality
for the first and second generation).
MIPEX_PP – Measure of the political opportunity structure for non-EU citizens. This variable is the simple average of four
dimensions of political participation, composed of 15 indicators: electoral rights (passive and active voting rights at regional
and local level); political liberties (right to form political associations, political parties, and media); consultative bodies
(presence and strength at national, regional, and local level); implementation policies (presence of state information
campaigns on political rights and funding for immigrant political associations).
MIPEX_LMM – Measure of the inclusiveness of labour market policies for non-EU citizens. This variable is the simple
average of four dimensions of labour market mobility, composed of 16 indicators: access (equal legal access to all job
sectors); access to general support (equal legal access to employment services, education, training, and recognition of
qualifications); targeted support (policies to address specific needs of unemployed immigrants); workers’ rights (equal rights
in terms of social security, working conditions, and unions).
MIPEX_ED – Measure of the inclusiveness of the national educational system for immigrant pupils. This variable is the
simple average of four dimensions of targeted education policies, composed of 21 indicators: access (equal legal access to all
levels of the education system); targeting needs (strength of targeted policies on language learning, additional training,
teacher, and financial resources); new opportunities (strength of policies on immigrant languages and cultures, school
integration and immigrant parental outreach); intercultural education (strength of state support of curriculum on the
appreciation of cultural diversity).
MIPEX_LTR – Measure of inclusiveness of access to long-term residence for ordinary non-EU citizens. This variable is the
simple average of four dimensions, composed of seventeen indicators: eligibility (residence requirements); conditions
(inclusiveness of language, integration, and economic resource requirements as well as time limit and fees); security of status
(level of discretion and judicial oversight in the procedure); rights associated (equal economic and social rights as nationals)
MIPEX_AD – Measure of the strength of anti-discrimination law on the grounds of race/ethnicity, religion/belief, and
nationality/citizenship. This variable is the simple average of four dimensions of anti-discrimination law, composed of 26
indicators: definitions and concepts (definitions on all three grounds includes direct, indirect, multiple by association, based
on assumed characteristics, as well as application to public and private sector); fields of application (prohibition of
discrimination on all three grounds in all areas of life); enforcement mechanisms (access to multiple procedures and strength
of procedural supports to victims); equality policies (powers of equality body and role of state in promoting equality).
MIPEX_FreU – Measure of inclusiveness of right to family reunion for ordinary non-EU citizens. This variable is the simple
average of four dimensions, composed of twenty indicators: eligibility (residence requirements and inclusiveness of
definition of the family); conditions (inclusiveness of pre-departure, language, integration, and economic resource
requirements as well as time limit and fees); security of status (level of discretion and judicial oversight in the procedure);
rights associated (equal economic and social rights as sponsor and access to a residence permit autonomous of the sponsor).
CITLAW_CITIMP – Measure of inclusiveness of access to nationality for ordinary immigrants and their descendants. The
variable captures both the inclusiveness of the legal eligibility criteria (i.e. residence, language, integration, economic
resources, criminal record/good character, and renunciation of foreign nationality) as well as the inclusiveness of
implementation measures (i.e. promotion activities, documentation requirements, administrative discretion, bureaucratic
procedures, and judicial review). The variable is calculated as the arithmetic mean of scores for CITLAW Indicator
‘ANATORD’ and CITIMP Indicator ‘CITIMP’.
9
Thomas Huddleston and Maarten Peter Vink
4. Analysis of the links between naturalisation and specific integration policies
We start our analysis with an exploration of the bivariate correlations between ordinary naturalisation
policies and various integration policies based on the hypotheses presented in section 2. Correlations
were checked between the integration policy indicators (MIPEX) and both the two variables for
ordinary naturalisation (CITLAW_CITIMP and MIPEX_AN). The bivariate correlation analysis
largely confirms our hypotheses about the hidden links between ordinary naturalisation policies and
specific integration policies. These correlations are presented in Table 2 below.
Table 2: Correlation matrix (all variables included in the analysis)
MIPEX_AN
MIPEX_AN
MIPEX_
PP
MIPEX_
LMM
MIPEX_
ED
MIPEX
_LTR
MIPEX
_AD
MIPEX_
FreU
1
MIPEX_PP
,717**
1
MIPEX_LMM
,532**
,567**
1
MIPEX_ED
,651**
,714**
,696**
1
,123
,085
,518**
,295
1
,577**
,308
,254
,253
,010
1
MIPEX_FreU
,418*
,206
,606**
,426*
,643**
,370*
1
CITLAW_IMP
,711**
,595**
,554**
,620**
,211
,451*
,507**
MIPEX_LTR
MIPEX_AD
*. Correlation is significant at the 0.05 level (2-tailed); **. Correlation is significant at the 0.01
level (2-tailed).
N = 29
We start by exploring the strongest bivariate correlation between ordinary naturalisation policies and
integration policies, namely with participation policies for non-EU citizens. Figure 1 shows that states
with restrictive naturalisation policies, such as Austria, Cyprus, Malta and the EU Member States in
Central Europe, tend to grant fewer political rights. The more states facilitate the naturalisation policy,
the more they also tend to grant political rights (i.e. a majority of EU-15 states, such as Benelux states,
Sweden, Portugal, and the UK).5 Interestingly, the relationship with naturalisation policies is strong for
most dimensions of political participation policies measured in MIPEX, with the notable exception of
electoral rights. Whether or not a state grants voting rights does not seem to affect naturalisation. The
absence of a statistically significant relationship across Europe is due to outliers corresponding to
Arrighi’s ‘denizenship-based regimes’ and republican ‘citizenship-based regimes.’ Electoral rights are
facilitated over naturalisation in Denmark and Switzerland, and, to a certain extent, Finland, Norway,
and The Netherlands. Naturalisation is facilitated over electoral rights in France and Germany.
5
Note that the UK policy scores reflect the situation after the retraction of the restrictive ‘earned citizenship’ legislation on
naturalisation and permanent residence.
10
Membership and/or rights? Analysing the link between naturalisation and integration policies for immigrants in Europe
Figure 1. Relationship between naturalisation and political participation policies
A moderately strong positive relationship emerges between ordinary naturalisation policies and antidiscrimination laws across Europe. States with facilitated naturalisation policies tend to have stronger
anti-discrimination laws on the grounds of race/ethnicity, religion, and nationality. In particular, states
with more inclusive naturalisation laws tend to have stronger enforcement mechanisms for their antidiscrimination laws. This relationship is not as strong as expected due to several major outliers in
Central Europe with strong anti-discrimination laws but restrictive ordinary naturalisation. These
states have strong anti-discrimination laws due to their large Roma and national minority populations,
whereas the naturalisation policy is rather restrictive for ordinary immigrants, even if several maintain
very inclusive naturalisation policies for their co-ethnics.6
6
See CITLAW indicators for Bulgaria, Hungary, Romania, and Slovakia: http://eudo-citizenship.eu/indicators
11
Thomas Huddleston and Maarten Peter Vink
Figure 2. Relationship between naturalisation policies and anti-discrimination laws
Ordinary naturalisation policies are somehow related to non-EU family reunion policies, but not as
expected. Overall, family reunion and naturalisation policies tend to be either generally inclusive (e.g.
Belgium, Portugal, and Sweden) or restrictive (e.g. Austria, Bulgaria, Denmark, and Switzerland).
Looking in detail, the dimensions most strongly correlated with naturalisation policies are the security
of status and rights associated with family reunion; states that facilitate naturalisation tend to grant a
secure and equal legal status to reunited families. Contrary to expectations, no correlation emerges
between ordinary or family-based naturalisation policies and the eligibility or conditions for non-EU
family reunion. In other words, restrictions of ordinary or family-based naturalisation are not generally
related to restrictions of non-EU family reunion.
In addition to these positive correlations, moderately strong relationships emerged between
ordinary naturalisation policies and several targeted employment and education policies, as measured
by MIPEX. States with more inclusive naturalisation policies also tend to provide greater rights and
access to general training for non-EU workers as well as more targeted education policies for
immigrant pupils, especially strong intercultural education programmes and strong support to access
the education system. A few outliers arise here and there; states such as Ireland and the UK tend to
facilitate naturalisation without many targeted policies on employment and education, while Austria
and Estonia tend to provide many strong targeted policies without facilitating naturalisation. These
relationships may be related to the findings on political participation policies; states facilitating
naturalisation often do more to consult immigrants and support their participation through information
campaigns and financial support for their NGOs. More generally, states that facilitate naturalisation
also tend to provide more equal rights and targeted support to foreigners.
As expected, the relationship between ordinary naturalisation policies and long-term residence
policies is ambiguous. Long-term residence emerges as the one integration policy area in MIPEX that
is not correlated with naturalisation policies. The relationship is visualised in Figure 3 below:
12
Membership and/or rights? Analysing the link between naturalisation and integration policies for immigrants in Europe
Figure 3. Relationship between naturalisation and long-term residence policies
Overall, whether or not states across Europe facilitate long-term residence seems to have little to do
with their naturalisation policies. Looking deeper into the dimensions of both policies, states with
more restrictive long-term residence conditions do tend to have slightly more restrictive naturalisation
conditions, according to MIPEX, and more demanding integration assessments, according to
CITLAW. However these relationships are not consistent across CITLAW/CITIMP and the MIPEX
Access to Nationality indicators. The only dimension of long-term residence related to naturalisation
policy is the security of long-term residence. States with a more discretionary and insecure long-term
residence status tend to also have restrictive naturalisation policies. This list of states includes most
Central and South-eastern European states, Austria, Denmark, and Switzerland. In contrast, states that
grant a more secure long-term residence status also tend to have inclusive naturalisation policies. This
list includes most Western European states, such as most Benelux and Nordic states, France, Germany,
Portugal, and the UK.
Looking in greater detail at the outliers in Figure 3, two distinct patterns between naturalisation and
long-term residence policies emerge across Europe. Long-term residence emerges as some sort of
substitute or alternative for naturalisation in the 15 states highlighted in red, mostly Central European
countries, new countries of immigration (e.g. Malta and Spain) as well as Austria, Denmark, and
Norway. All these states generally restrict ordinary naturalisation, independent of their long-term
residence policy. For example, even though states such as the Czech Republic, Denmark, and Poland
facilitate long-term residence more than Bulgaria, Romania, or Slovakia, they all restrict ordinary
naturalisation to a similar degree. The distinction between these states is whether the long-term
residence policy provides a ‘good’ or ‘poor’ substitute for full national citizenship rights. While in the
14 other European states, mostly in Western Europe, a slightly positive relationship seems to emerge
between long-term residence and naturalisation policies. Both long-term residence and naturalisation
are generally restricted in Cyprus, Switzerland, Ireland, France, and Germany and facilitated in
Belgium, Portugal, Sweden, and the UK. In these 14 states, long-term residence and naturalisation
policies are used as complementary strategies for regulating access to a secure residence status. From
these two patterns, long-term residence policies seem unrelated to the restrictive naturalisation policies
in new immigration destinations mostly in Central Europe, while long-term residence policies
generally reflect the naturalisation policy in many established immigration destinations in Western
Europe.
13
Thomas Huddleston and Maarten Peter Vink
5. Analysis of the overall relationship between naturalisation and integration policy
The main thrust of our analysis of the overall relationship between naturalisation and integration
policy begins with an exploration of the bivariate correlation between the overall MIPEX indicator
(measuring the overall inclusiveness of integration policies) and the MIPEX sub-indicator for Access
to Nationality (measuring the inclusiveness of citizenship policy). Figure 4 below shows the strong
and positive correlation (r = .836) between both indicators, which can be interpreted as empirical
support for the view that access to membership through naturalisation is a complementary—rather
than an alternative—strategy to the extension of rights to foreigners. In other words, the more
inclusive naturalisation policy is in a state, the more inclusive we would also expect integration and
residence policies to be in that state (e.g. Portugal and Sweden). Vice versa, states with restrictive
naturalisation policies also tend to have restrictive integration and residence policies (e.g. the Baltic
states, Austria, Bulgaria, Cyprus, Malta, and Slovakia).
Figure 4. Relationship between naturalisation and integration policy in 29 European states
The correlation illustrated in Figure 4 is of course partly endogenous as the MIPEX Access to
Nationality is a sub-indicator of MIPEX Overall. However, Table 3, which presents the correlations
between the MIPEX overall score and the seven MIPEX policy areas, shows that, in fact, the
correlation between the MIPEX Overall and MIPEX Access to Nationality is the strongest bivariate
correlation.
14
Membership and/or rights? Analysing the link between naturalisation and integration policies for immigrants in Europe
Table 3: Correlation matrix between MIPEX overall score & seven integration policy areas
MIPEX Overall
MIPEX_AN
,836**
MIPEX_PP
,787**
MIPEX_LMM
,828**
MIPEX_ED
,826**
MIPEX_LTR
,447*
MIPEX_AD
,566**
MIPEX_FreU
,666**
CITLAW_IMP
,748**
The six other policy areas are less strongly related to the overall score for the inclusiveness of
integration policies (MIPEX). Compared to the correlation between the overall score and access to
nationality, the correlation with the overall score are nearly as strong for political participation policies
for non-EU citizens MIPEX-PP), non-EU labour market mobility policies (MIPEX-LMM) and
targeted educational policies for immigrant pupils (MIPEX-ED). A positive, significant, but somewhat
less strong correlation with the overall score also emerges with the long-term residence policies for
non-EU citizens (MIPEX-LTR), the anti-discrimination laws (MIPEX-AD), and the family reunion
policies for non-EU citizens (MIPEX-FreU).
In order to analyse whether there is a single statistical dimension that represents most of the
variation in our two naturalisation policy indicators (MIPEX_AN and CITLAW_CITMP) and the six
other MIPEX integration policy areas for the 29 European states studied, we continue the analysis on
the basis of these separate indicators. We thus analyse whether or not a strong underlying dimension
structures the variation in both naturalisation and integration policies, as hypothesised by the
complementary perspective. We approach this question through Principal Component Analysis (PCA),
though given our dataset of ordered categorical data, it would be erroneous to use standard PCA,
which assumes linear relationships between numerical variables. For that reason, Categorical Principal
Component Analysis (CATPCA) is used for this analysis, which allows variables to be scaled at
different levels and works with modelling non-linear relationships (Linting et al. 2007). A spline
ordinal scaling level is selected for all variables, which implies that the information in the observed
variable is preserved in the optimally scaled variable for both the grouping of objects in categories and
the order of these categories. Unlike linear PCA, CATPCA does not assume that there are equal
intervals between consecutive categories. Nonlinear and linear PCA are very similar in objective,
method, results, and interpretation and the output of the CATPCA analysis can be interpreted in a
largely similar manner as standard PCA (Linting et al 2007: 27-28). We therefore present component
loadings, which can be understood as indicators for relations between the included variables and the
underlying dimension(s).
15
Thomas Huddleston and Maarten Peter Vink
Table 4: Component loadings
Principal component analysis for categorical data (CATPCA)
Dimension
MIPEX_LMM
MIPEX_ED
MIPEX_PP
MIPEX_LTR
MIPEX_AD
MIPEX_FreU
MIPEX_AN
CITLAW_CITIMP
Cronbach’s Alpha
Percentage of variance
accounted for
1a
,920
,910
,596
,681
,836
,847
,921
1b
,922
,918
,595
,665
,837
,843
,921
,914
,920
67,96
67,64
N = 29
Variable principle normalisation
Sources: MIPEX, EUDO CITIZENSHIP
Table 4 shows the component loadings of the CATPCA analysis with the number of dimensions in the
solution set at one. The results displayed represent two separate analyses, with the use of the two
alternative citizenship policy indicators in models 1a (MIPEX-AN) and 1b (CITLAW-CITIMP). As is
clear from both the component loadings of the individual indicators, as well as the measure for the
overall cohesion of the two alternative dimensions, there is no substantive difference between using
either of these two indicators of citizenship policy.7 We thus continue the discussion of the results on
the basis of model 1a, but could equally have opted to discuss model 1b.
Firstly, this output highlights that there is a single dimension underlying naturalisation and
integration policies. The high Cronbach’s alpha score (.921) confirms the strong internal consistency
of this dimension and the explanatory variance indicates that the model is also empirically relevant,
accounting for 68 percent of variation in the scores for the seven indicators included in the model,
across these 29 European states. Secondly and more substantively, the analysis confirms the
‘complementary’ perspective which holds that policy-makers across Europe see naturalisation and
integration policies as complementary strategies of immigrant inclusion (or exclusion) and do not
generally use these policies as alternative strategies. In other words, relating to the title of this report,
membership and rights do not appear as different paths to inclusion. Rather, membership and rights
often come together or else they are not available at all.
Finally, an examination of the scores of individual states along this underlying dimension identifies
two very clear outliers. Sweden offers by far the most inclusive integration policies in Europe,
measured systematically across the seven naturalisation and integration policy. The naturalisation and
integration policy in Portugal is also clearly demarcated from the rest of Europe though to a lesser
extent. Following these two outliers, a middle group of states emerges with overall moderately
inclusive policies, as measured by these seven indicators, namely Spain, Belgium, Finland, the
Netherlands and Luxembourg. The more restrictive end of the continuum is represented by Austria,
the Baltic States, Bulgaria and Cyprus. These states consistently score on the exclusive side on all
seven indicators.
7
Alternative analyses were also run with dimensions set at two and three, respectively, but these analyses did not produce
sufficiently consistent additional dimensions (Cronbach alpha scores < .6).
16
Membership and/or rights? Analysing the link between naturalisation and integration policies for immigrants in Europe
6. Conclusion
This paper has found a strong coherence across Europe between various integration policies and
naturalisation policies, with naturalisation policies emerging as strongest predicator of these states’
overall approach to integration. Whether a state adopts an inclusive vs. restrictive ordinary
naturalisation policy usually reflects its policies in all six other MIPEX areas. These results confirm
the importance accorded to naturalisation by the so-called ‘naturalisationist’ theorists and by empirical
researchers who use naturalisation to explain differences in integration policies and processes across
Europe. Ordinary naturalisation policies are generally at the heart of a state’s integration policy.
These empirical results provide support for the ‘complementary’ view on extending membership
and rights to immigrants. No contradiction emerges between facilitated naturalisation and residencebased citizenship. For example, there is generally no trade-off between facilitating naturalisation and
political participation policies for foreigners. Instead, countries granting more political rights to
foreigners tend to have more inclusive naturalisation policies. This is important, first of all because it
has been shown that inclusive naturalisation policies positively affect naturalisation rates among
immigrants (Vink, Prokic-Breuer and Dronkers, 2013). Furthermore, inclusive naturalisation policies
are generally related to strong anti-discrimination laws that promote equal treatment and fight
discrimination on the grounds of race/ethnicity, religion, and nationality/citizenship. Long-term
residence does appear to function as a ‘good’ or ‘bad’ substitute for naturalisation in many new
countries of immigration and Central European states. Yet long-term residence and naturalisation
policies do seem positively related in most established Western countries of immigration. In addition,
voting rights for non-EU citizens are not used as a substitute for naturalisation. Immigrant voting
rights are generally unrelated to naturalisation policies across Europe, due to a few ‘denizenshipbased’ and republican ‘citizenship-based’ regimes, which facilitate one but not the other. Overall, the
empirical results largely debunk the ‘alternative’ view. No European state studied consistently
facilitates equal rights without also facilitating naturalisation. Naturalisation policies are not simply
one of several integration policy alternatives. On the contrary, an inclusive naturalisation policy is part
of a comprehensive integration policy promoting equal rights and opportunities for all residents,
including both naturalised and non-naturalised immigrants. In contrast, a restrictive naturalisation
policy usually reflects a weak state commitment to equal treatment and rights for immigrants, whether
naturalised or non-naturalised.
These results also have implications for future academic research and debates among
naturalisationists and post-naturalisationists. Naturalisationists may be interested to explore the
potentially mutually reinforcing relationships between naturalisation policies and other areas of
integration policy. The immigrant electorate may also play a role in the policy dynamics behind
reforms of both naturalisation and integration policies.8 Post-naturalisationists may wish to consider
whether and how to incorporate naturalisation into their broader theories about the extension of rights
and the electorate. On their own, arguments against the relevance of naturalisation may undermine
support for the broader argument for equal rights and membership. Naturalisation may be a desirable
choice for various types of immigrants and for the general public to promote integration in a country
of immigration. Critiques of the current naturalisation debate can focus on the changing nature and
meaning of naturalisation and national citizenship within a liberal democracy, looking beyond Europe
to traditional and other new countries of immigration.
8
For more on the potential impact of naturalised immigrants on the extension of citizenship rights, see or non-naturalised)
Koopmans et al. (2012). For an example of the impact of local immigrant voting rights on municipal social policies in
Sweden, see Vernby (2013).
17
Thomas Huddleston and Maarten Peter Vink
List of references
Acosta Arcarazo, D. (2011) The Long-term residence status as a subsidiary form of EU citizenship,
Brill: The Hague, The Netherlands.
Aleinikoff, T.A. and Klusmeyer, D. Citizenship policies for an age of migration, Carnegie Endowment
for International Peace, Washington, DC.
Anderson, B. (2013) Us and Them? The dangerous politics of immigration control. Oxford University
Press, Oxford, UK.
Andrès, H. (2013) Le droit de vote des résidents étrangers est-il une compensation à une fermeture de
la nationalité ? Le bilan des expériences. Migrations société, Vol. 25, N° 146, mars-avril 2013,
pp.103-115.
Arrighi, J., Bauböck, R., Collyer, M., Hutcheson, D., Moraru, M., Khadar, L. and Shaw, J. eds (2013)
Franchise and electoral participation of third state citizens residing in the European Union and of
EU citizens residing in third states, Study for European Parliament Directorate General for Internal
Policies: Policy Department C: Citizens’ Rights and Constitutional Affairs.
Atikcan, E. (2006) ‘Citizenship or denizenship: the treatment of third-country nationals in the
European
Union,’
Sussex
European
Institute
Working
Paper
No.
85.
www.sussex.ac.uk/webteam/gateway/file.php?name=sei-working-paper-no-85.pdf&site=266
Banting, K. and Kymlicka, W. (2012) ‘Is there really a retreat from multiculturalism policies? New
evidence from the multiculturalism policy index,’ Comparative European Politics, 11(5).
Bauböck, R., P. Cayla and C. Seth, eds. (2012) ‘Should EU Citizens Living in Other Member States
Vote There in National Eelections? EUI Working Paper RSCAS 2012/32. Available at http://eudocitizenship.eu/docs/RSCAS_2012_32.pdf.
Bauböck, R., Ersboll, E., Groenendijk, K., Waldrauch, H. (2006) eds. Acquisition and loss of
nationality: Volume 2: Comparative Analysis, Amsterdam University Press, Amsterdam, the
Netherlands.
Bauböck, R. (2005) ‘Expansive citizenship: Voting beyond territory and membership,’ Political
Science and Politics, Vol. 38, No. 4, pp. 683-687.
Bauböck, R. (2005) ‘Civic citizenship: a new concept for the New Europe,’ IN: Süssmuth, R. and
Widenfeld, W. (2005) Managing integration: the European Union’s responsibilities towards
migrants, Bertelsmann Stiftung, Gütersloh, Germany. pgs. 122-138
Bauböck, R. ed. (1994) From Aliens to Citizens. Redefining the Status of Immigrants in Europe,
Avebury, Aldershot, United Kingdom.
Bertossi, C. and J. W. Duyvendak (2012) ‘National models of immigrant integration: The costs for
comparative research,’ Comparative European Politics, 10(3), pgs. 237-247
Block, L. and Bonjour, S. (2013) ‘Fortress Europe or Europe of Rights? The Europeanisation of
family migration policies in France, Germany, and the Netherlands,’ European Journal of
Migration and Law 15 (2013), pgs. 203-224.
Bloemraad, I. (2006) Becoming a Citizen: Incorporating Immigrants and Refugees in the United States
and Canada. University of California Press, Berkeley, United States.
Boucher, Gest and Helbling, (2011) ‘Comparing migration, naturalisation and asylum policies: The
International Migration Law and Policy Analysis Database (IMPALA).’ IMPALA launch article,
presented at the European Consortium of Political Research conference in August 2011.
18
Membership and/or rights? Analysing the link between naturalisation and integration policies for immigrants in Europe
Brubaker, R. (1992) Citizenship and Nationhood in France and Germany. Harvard University Press,
Cambridge, United States of America.
Carrera, S. (2009) In Search of the Perfect Citizen? The intersection between integration, immigration
and nationality in the EU, Brill: The Hague, The Netherlands.
Carens, J. (2005) ‘The Integration of Immigrants,’ Journal of Moral Philosophy, Vol. 2, Number 1,
pgs. 29-46(18).
Castles, S. (1995) ‘How Nation-States Respond to Immigration and Ethnic Diversity,’ New
Community, Vol. 21, No. 3, pgs. 293-308.
Cinar, D. (2010) EUDO-Citizenship Observatory State Report: Austria, European University Institute,
Florence, Italy.
De Schutter, O. (2009) Links between migration and discrimination, European network of legal
experts in the non-discrimination field, European Commission, Brussels, Belgium.
European Commission (2011) Report on the application of Directive 2003/109/EC concerning the
status of non-EU citizens who are long-term residents, COM(2011) 585 final, Brussels, Belgium.
European Commission (2003) Communication on immigration, integration and employment, COM
(2003) 336, Brussels, Belgium.
Favell, A. (2003) ‘Integration Nations: The Nation-state and research on immigrants in Western
Europe,’ Comparative Social Research, Yearbook vol.22, pgs.13-42.
Gehring, J. (2009) ‘Hidden connections: Citizenship and anti-discrimination policy in Europe,’ IN:
Zapata-Barrero, R., Citizenship policies in the age of diversity: Europe at the crossroads, CIDOB
Foundation book.
Goldston, J. (2006) ‘Holes in the rights framework: Racial discrimination, citizenship, and the rights
of non-citizens,’ Ethics and International Affairs, Vol. 20, Issue 3, pages 321-347.
Goodman, S.W. (2011) Controlling immigration through language and state knowledge requirements,
West European Politics, Vol. 34, 2. pgs. 235-255.
Goodman, S.W. (2010) Naturalisation policies in Europe: Exploring patterns of inclusion and
exclusion, EUDO-Citizenship Comparative Report, RSCAS/EUDO-CIT-Comp. 2010/7.
Groenendijk, K. (2008) ‘Local voting rights for non-nationals in Europe: what we know and what we
need to learn,’ Migration Policy Institute, Washington, United States of America.
Groenendijk, K. (2006) ‘The Legal integration of potential citizens: Denizens in the EU in the final
years before the implementation of the 2003 Directive on long-term resident non-EU citizens,’ IN:
Bauböck, R. et al. (2006) eds. Acquisition and loss of nationality: Volume 1: Comparative
Analysis, Amsterdam University Press, Amsterdam, the Netherlands. pgs. 385-410.
Groenendijk, K. (2004) ‘Legal concepts of integration in EU migration law,’ European Journal of
Migration and Law, Brill: The Hague, The Netherlands, Vol. 6, No 2. pgs. 111-126.
Groenendijk, K. (1998) Security of residence of long-term migrants, Council of Europe Publishing,
Community relations, Strasbourg, France, 1998.
Guild, E., Groenendijk, K. and Carrera, S. et al. eds. (2009) Illiberal liberal states: Immigration,
citizenship, and integration in the EU, Ashgate, Farnham, United Kingdom.
Hammar, T. (1990) Democracy and the nation state: Aliens, denizens and citizens in a world of
international migration, Avebury, United Kingdom.
Hammar, T. (1985) European immigration policy: A comparative study. Cambridge University Press,
Cambridge, UK.
19
Thomas Huddleston and Maarten Peter Vink
Hansen, R. (2009) ‘The Poverty of postnationalism: Citizenship, immigration, and the new Europe,’
Theory and Society, Vol 38, Issue 1, pgs. 1-24.
Hansen, R. and Weil, P. (2001) Towards a European Nationality: citizenship, immigration and
nationality law in the EU, Palgrave, New York, New York.
Helbling, M. (2013) ‘Validating integration and citizenship policy indices,’ Comparative European
Politics, 11(5), pgs. 555-576.
Howard, M. (2009) The Politics of Citizenship in Europe, Cambridge University Press, Cambridge,
UK.
Huddleston, T. (2013) ‘The Naturalisation procedure: measuring the ordinary obstacles and
opportunities for immigrants to become citizens,’ EUDO-Citizenship Observatory, Florence, Italy.
Huddleston, T., Niessen, J. and Ni Chaoimh, E. (2010) Migrant Integration Policy Index: third edition.
Brussels: British Council and Migration Policy Group. Brussels, Belgium.
Huddleston, T. (2009) ‘Promoting citizenship: the choices for immigrants, advocates, and European
cooperation,’ IN: Zapata-Barrero, R., Citizenship policies in the age of diversity: Europe at the
crossroads, CIDOB Foundation book.
ILO International Labour Organisation (2010), ‘Situation testing: Discrimination in access to
employment based on ILO methodology.’
IMPALA (forthcoming) International Migration Policy And Law Analysis. Sydney University et al.
IMPIC (forthcoming) Immigration Policies in Comparison, WZB Berlin Social Research Center
Jacobs, D. and Rea, A. (2007) ‘The End of National Models? Integration courses and citizenship
trajectories in Europe,’ IJMS: International Journal on Multicultural Societies. 2007, Vol.9, no.2,
pgs. 264-283.
Jacobs, D. (1999) ‘The debate over enfranchisement of foreign residents in Belgium,’ Journal of
Ethnic and Migration Studies, Vol. 25, Issue 4, pgs. 649-663.
Janoski, T. (2010) The Ironies of Citizenship: Naturalization and Integration in Industrialized
Countries, Cambridge University Press, Cambridge, UK.
Joppke, C. (2010) ‘The Inevitable Lightening of Citizenship,’ European Journal of Sociology, Vol. 51,
Issue 1, pgs. 9-32.
Joppke, C. (2007a) ‘Transformation of immigrant integration in Western Europe: Civic integration and
anti-discrimination policies in the Netherlands, France, and Germany,’ World Politics, Vol. 59, N.
2, pgs. 243-273.
Joppke, C. (2007b) ‘Transformation of citizenship: Status, rights, identity,’ Citizenship Studies, Vol.
11, n. 1, pgs. 37-48.
Joppke, C. and Morawska, E. (2003) Toward Assimilation and Citizenship: Immigrants in liberal
nation-states, Palgrave Macmillan, New York , USA.
Kofman, E. (2004) ‘Family-related migration: a critical review of European Studies,’ Journal of Ethnic
and Migration Studies, 30:2, pgs. 243-262.
Koning, E.A. (2011) ‘Ethnic and Civic Dealings with Newcomers. Naturalization Policies and
Practices in 26 Immigration Countries.’ Ethnic and Racial Studies, first published as iFirst online
article on March 10, 2011.
Koopmans, R., Michalowski, I. and Waibel, S. (2012) ‘Political processes and cross-national
convergence in Western Europe, 1980-2008, American Journal of Sociology, Vol. 117, No. 4. pgs.
1202-1245
20
Membership and/or rights? Analysing the link between naturalisation and integration policies for immigrants in Europe
Kostalopoulou, T. (2010) ‘Matters of control: Integration tests, naturalisation reform and probationary
citizenship in the United Kingdom, Journal of Ethnic and Migration Studies, Vol. 36, Issue 5, pgs.
829-846.Kostakopoulou, T. (2006) ‘Thick, Thin and Thinner Patriotisms: Is This All There Is?’,
Oxford Journal of Legal Studies, Vol. 26, Issue 1, pgs. 73-106.
Kostakopoulou, D. (2003) ‘Why Naturalisation?’ Perspectives on European Politics and Society, Vol.
4, Issue 1, pgs. 85-115.
Linting, M., Meulman, J.J., Groenen, P.J.F. and Van der Kooij, J.J (2007) ‘Nonlinear principal
components analysis: Introduction and application,’ Psychological Methods, 12, pgs. 336–358.
Martiniello, M. (2005) ‘Political participation, mobilisation, and representation of immigrants and
their offspring in Europe,’ IN: Bauböck, R ed. (2005) Migration and Citizenship: Legal Status,
Rights, and Political Participation, State of the Art Report for the IMISCOE Cluster B3.
Pedroza, L. (2013) Citizenship before Nationality: How Democracies Redefine Citizenship by
Debating the Extension of Voting Rights to Settled Migrants. PhD Dissertation. Bremen
International Graduate School of Social Sciences.
Pickus,N. (1998) Immigration and Citizenship in the Twenty-First Century, Rowman and Littlefield,
Lanham, Maryland, United States.
Rubio-Marin, R. (2000) Immigration as a Democratic Challenge. Cambridge University Press,
Cambridge, UK.
Ruhs, M. (2011) 'Openness, Skills and Rights: An Empirical Analysis of Labour Immigration
Programmes in 46 High- and Middle-income Countries', COMPAS Working Paper.
www.compas.ox.ac.uk/publications/working-papers/wp-11-88/
Schuck, P. (1989) ‘Membership in the liberal polity: the devaluation of American citizenship,
Georgetown Immigration Law Journal, Volume 3, pgs. 1-18.
Soysal, Y. (1995) Limits of Citizenship: Migrants and post-national membership in Europe, University
of Chicago Press, Chicago, United States of America.
Strik, T., de Hart, B. and Nissen, E. (2013) Family reunification: a barrier or facilitator of integration?
University of Nijmegen, the Netherlands.
Van Oers, R. Erboll, E. and Kostakopoulou, D. eds. (2010) A Redefinition of Belonging? Language
and Integration Tests in Europe, Brill: The Hague, The Netherlands.
Vernby, K. (2013) ‘Inclusion and public policy: Evidence from Sweden’s Introduction of Noncitizen
suffrage,’ American Journal of Political Science. Vol. 57, Issue 1. pgs. 15-29
Vink, M. (2005) Limits of European Citizenship: European Integration and Domestic Immigration
Policies. Basingstoke: Palgrave Macmillan.
Vink, M., T. Prokic-Breuer and J. Dronkers (2013). Immigrant Naturalization in the Context of
Institutional Diversity: Policy Matters, But to Whom? International Migration 51(5) 1-20.
Waldrauch, H. and Hofinger, H. 1997. “An Index to Measure the Legal Obstacles to the Integration of
Migrants.” New Community 23(2): pgs. 271–85.
Walzer, M. (1983) Spheres of Justice, Basic Books, Inc. New York, New York, United States.
Weil, P. (2001) ‘Access to Citizenship: comparison of 25 nationality laws’ IN: Aleinikoff, T. et al.
(2001) eds. Citizenship today: global perspectives and practices, Carnegie Endowment for
International Peace, Washington, DC.
Wray, H. (2013) Regulating marriage migration into the UK: a Stranger in the home, Ashgate
Publishing, Farnham, UK.
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