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The Impact of the Far Right onCitizenship Policy in Europe:Explaining Continuity and Change

Marc Morje Howard

Over the past decade, the empirical study of national citizenship policies has emerged as

a fast-growing area of research. This article contributes to that literature by focusing on

the question of continuity and change in the 11 historically restrictive countries within

the 15 older member-states of the European Union. It explains why six of the countries

have liberalised their citizenship policies since the 1980s, whereas five have not. The

article develops an explanation that focuses on the politics of citizenship. The main

finding is that, while citizenship liberalisation is more likely to occur with a leftist

government, the most important factor is the relative strength of far-right parties, which

can serve to mobilise latent anti-immigrant public opinion, and thereby trump the

pressures for liberalisation.

Keywords: Citizenship; Immigration; Public Mobilisation; Far Right; Europe

Introduction

In the last ten years the empirical study of national citizenship policies has emerged

as a fast-growing area of research (Aleinikoff and Klusmeyer 2000, 2001, 2002;

Baubock et al. 2006; Hansen and Weil 2001, 2002; Howard 2005, 2006; Joppke2008; Vink 2005). The boundary of citizenship allows rich states to draw a line that

separates their citizens from potential immigrants from poor countries, and to

create internal distinctions between citizens and foreign residents*by associating

certain rights and privileges with national citizenship (Brubaker 1992). Despite

predictions about the disappearance or decreased importance of national citizenship

(Sassen 1996, 1998; Soysal 1994), distinctions between citizens and foreigners

remain an essential and enduring feature of modern life*whether in terms of

Marc Morje Howard is Associate Professor in the Department of Government at Georgetown University.Correspondence to: Dr M.M. Howard, Dept of Government, Georgetown University, 681 ICC Washington, DC

20036, USA. E-mail: [email protected].

ISSN 1369-183X print/ISSN 1469-9451 online/10/050735-17 # 2010 Taylor & Francis

DOI: 10.1080/13691831003763922

Journal of Ethnic and Migration Studies

Vol. 36, No. 5, May 2010, pp. 735751


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politics and elections, welfare-state benefits, public-sector employment, social

integration, or demographics and pension systems*even in the supra-national

European Union (Howard 2006). In fact, many EU states have recently been

revising and adapting their laws and policies that determine who can become a

national citizen and under what conditions.This article contributes to this burgeoning literature by exploring the question of

continuity and change in national citizenship policies. It focuses in particular on the

11 historically restrictive countries within the 15 older member-states of the EU,

and seeks to explain why Finland, Germany, Luxembourg, the Netherlands, Portugal

and Sweden have liberalised their citizenship policies since the 1980s, whereas

Austria, Denmark, Greece, Italy and Spain have not. In other words, the four

historically liberal countries within the EU-15*Belgium, France, Ireland and the

UK*are excluded from our analysis for the very simple reason that, since their

citizenship policies were already liberal, the question of liberalisation does not applyto them in the same way.

In order to address this question, I develop an argument that emphasises the

politics of citizenship. This political explanation stresses not only whether parties of

the left or the right have been in power, but also the extent to which the issue of

citizenship became a contentious and politicised issue that received wider public

debate and mobilisation. I then consider arguments and hypotheses*adapted from

the broader literature on comparative immigration*that emphasise economic and

socio-economic factors (GPD per capita, economic growth and unemployment),

demographics (the number and percentage of immigrants) and public opinion(measuring anti-immigrant sentiment).

After presenting the arguments, I turn to an empirical analysis that evaluates the

bivariate relationships between each of the hypotheses and citizenship liberalisation.

The results show that the alternative factors do not work out empirically, but the

association between the political factors and citizenship liberalisation is very strong.

In short, while citizenship liberalisation is more likely to occur when the left is in

power, the most important factor is the relative strength of far-right parties, which

can serve to mobilise latent anti-immigrant public opinion and thereby trump the

pressures for liberalisation. Although this cross-national analysis remains limited tofairly rigid measures on a common set of factors, it helps to show the broad patterns

involved and to explain why some of the restrictive countries liberalised, while others

remained restrictive.

A New Citizenship Policy Index (CPI)

The Citizenship Policy Index (CPI) that constitutes the empirical starting-point of

this article represents a significant improvement over a version that I published in

two previous articles (Howard 2005, 2006). Whereas the earlier CPI was based on my

own coding of the citizenship laws on a few key elements of citizenship policy, thenew CPI draws on the tremendous research*by individual country experts, within a

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common methodological framework*that went into a major project known as

NATAC.1 It also incorporates a very recent development that most studies of

comparative citizenship have not yet dealt with systematically, namely the new

language and civic integration requirements that a number of countries have

mandated as a condition for naturalisation (Jacobs and Rea 2007; Joppke 2008).Like the earlier version, the new CPI consists of the simple aggregation of the

following three factors:

. whether or not a country grants jus soli* i.e. whether or not children of non-

citizens who are born in a countrys territory can acquire that countrys citizenship

(either immediately at birth or automatically after a certain number of years

residence);

. the minimum length of its residency requirement for naturalisation (for both

immigrants themselves and immigrant spouses who are married to citizens); and. whether or not naturalised immigrants are allowed to hold dual citizenship.

Each component is scored on a 02 scale, yielding a 06-point range for the

total index.

Although space limitations preclude a full description and presentation of all the

scores, the new CPI now includes several more-fine-grained distinctions, along with

better contextual information, thus yielding a final index that is more precise and

accurate. More specifically, on jus soli, the new index now allows for more options, in

two respects: first, it captures both jus soliat birth and jus soliafter birth (whereas the

old CPI only measured jus soli at birth), with separate scores for both of these

elements ofjus soli, along with a final score that is the average of the two; second, for

jus soli at birth, it provides several intermediate scores between 0 and 2 points,

corresponding to the strictness of the parental residency requirement and whether or

not a country allows so-called double jus soli.

The coding of naturalisation requirements is also much more precise in the new

CPI. It now considers both the requirements for an individual immigrant to become

a naturalised citizen (which I refer to as immigrant naturalisation) and those for an

immigrant who is married to a citizen (spousal naturalisation). These are the two

most common ways for an immigrant to acquire a countrys citizenship. In addition,

the new score penalises countries that have added civic integration requirements*

such as mandatory language and civics tests*that add restrictions to naturalisation.

It also uses actual naturalisation rates as a check to ensure that the relative

inclusiveness or restrictiveness of the policies are also reflected in the extent of people

really naturalising, by reducing (to different degrees) the scores of countries with low

levels of naturalisation rates.

The final component of the CPI*dual citizenship for immigrants*still gives 2

points for countries that have no restrictions on allowing immigrants to retain

their prior citizenship upon naturalisation, and 0 points for those which expresslyforbid it. But it now gives intermediate scores to countries that have a large

Journal of Ethnic and Migration Studies 737


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number of dual citizenships in practice, have created numerous and explicit

exceptions to the formal prohibition on dual citizenship, or do not require proof

of renunciation of the prior citizenship, thereby not really enforcing its official

ban on dual citizenship. These scores are then corrected, or reduced, by the same

naturalisation rates criterion described above.2 Overall, the new CPI provides a

much more refined and accurate index that allows us to assess and compare the

citizenship policies across countries.

In order to conduct an analysis of the presence or absence ofchange, it is important

to start with two clearly defined points in time as benchmarks. One, which I call the

1980s, is admittedly somewhat arbitrary, but that time period can serve as a general

proxy for previous laws and traditions. Indeed, in most cases, the laws in the 1980s

were identical to*or closely in line with*the historical origins of each countrys laws

(Hanson and Weil 2001). Using this general label allows us to account for any changes

that may have occurred at any time during that decade.3 The second point in time is

the contemporary period, based on existing laws and practices at the end of 2008.

Comparison of the two time periods*using the same methodological criteria*allows

us to explore the causes of both liberalising change and restrictive continuity.

Turning to the empirical results of the new CPI, Table 1 shows the country scores for

the EU-15*with the countries ordered from lowest to highest in terms of their total

CPI score*on each of the three components in the 1980s; Table 2 presents the same

scores for the contemporary period. Each table distinguishes between three groups of

countries, depending on whether their citizenship policies can be characterised as

restrictive (scores between 0 and 1.5), medium (over 1.5 but less than 4) or liberal

(4 and above).4 Both tables show a great deal of variation on each of the three CPI

Table 1. The three main components of citizenship policies for the EU-15 in the 1980s

Country Jus soli

(02)

Naturalisationrequirements

(02)

Dual citizenshipfor immigrants

(02)CPI SCORE

(06)

Restrictive

Germany 0.00 0.00 0.00 0.00

Austria 0.00 0.50 0.00 0.50Luxembourg 0.00 0.50 0.00 0.50Italy 0.00 0.72 0.00 0.72Greece 0.00 0.00 1.25 1.25Spain 0.50 0.75 0.00 1.25Denmark 0.00 1.43 0.00 1.43

Medium Finland 0.00 1.72 0.00 1.72

Sweden 0.00 1.72 0.00 1.72Portugal 0.75 0.00 1.00 1.75Netherlands 1.50 1.22 0.00 2.72

Liberal France 1.50 1.22 1.50 4.22

Ireland 2.00 1.11 1.25 4.36

Belgium 1.50 1.75 1.75 5.00UK 1.75 1.72 2.00 5.47

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components, as the scores span the full spectrum of the 02 range on just about all of

them. The total scores also display wide variation in both time periods.

Table 1 shows that seven countries (Austria, Denmark, Germany, Greece, Italy,

Luxembourg and Spain) could be characterised as historically restrictive in the

1980s, although obviously some were more so than others. Finland, the Netherlands,

Portugal and Sweden were in the medium category, though with differentcombinations of scores distinguishing the Nordic and non-Nordic countries. Finally,

the four-country group of Belgium, France, Ireland and the UK constituted the

historically liberal category, with quite inclusive scores on all three components of

the CPI. Overall, the table indicates that the historical variation in citizenship policies

in what later became the EU-15 was very pronounced.

This historical pattern was rather rapidly undone, however, over the next decade or

two. As Table 2 shows, five of the seven countries (Austria, Denmark, Greece, Italy

and Spain) still remain in the restrictive category, while Germany and Luxembourg

moved up to the medium group. At the same time, Finland, the Netherlands,Portugal and Sweden all moved up from medium to liberal. As a result, a slight

majority of the EU-15 can now be considered to have liberal citizenship policies.

Figure 1 compares the two time periods more explicitly, showing the overall CPI

scores both in the 1980s and at the end of 2008. The figure shows that most of the

countries displayed relatively small changes of less than 1 point, but six countries

saw their CPI scores liberalise considerably. The Netherlands increased by 1.5,

Luxembourg by 1.75,5 Germany by just over 2 points, Portugal and Finland by

more than 2.5 points and Sweden by 3.75 points. The only country that moved

markedly in a negative direction was Denmark, dropping from 1.43 to 0 on account

Table 2. The three main components of citizenship policies for the EU-15 in 2008

Country Jus soli

(02)

Naturalisationrequirements

(02)

Dual citizenshipfor immigrants

(02)CPI SCORE

(06)

Restrictive Austria 0.00 0.00 0.00 0.00

Denmark 0.00 0.00 0.00 0.00Greece 0.00 0.00 1.00 1.00Spain 0.50 0.38 0.50 1.38Italy 0.00 0.25 1.25 1.50

Med.

Germany 0.75 0.54 0.75 2.04Luxembourg 1.00 0.00 1.25 2.25

Liberal

Netherlands 1.50 1.22 1.50 4.22Finland 1.00 1.32 2.00 4.32Portugal 1.75 1.07 1.50 4.32Ireland 2.00 1.36 1.50 4.86France 1.50 1.47 2.00 4.97UK 1.75 1.22 2.00 4.97Sweden 1.50 1.72 2.00 5.22Belgium 1.50 2.00 2.00 5.50



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of its lengthening of the residency requirement for both immigrant and spousal

naturalisation, as well as new citizenship and language tests.

Looking at the changes in aggregate, a comparison of the overall scores from the

1980s to the end of 2008 shows that the average score increased from 2.17 to 3.12*

corresponding to quite a large change. In other words, within the EU-15 as a whole,

the recent liberalisation of citizenship policies is undeniable. And in this sense, it isclear that a relative convergence of citizenship policies has taken place. However,

whether this becomes an absolute convergence*in the sense of reaching a single,

common policy, as with so many other areas of institutional harmonisation within

the EU*is still very uncertain, and appears unlikely in the foreseeable future (Joppke

1999). Indeed, although the cross-national differences are not nearly as vast as they

were a few decades ago, they remain quite wide.

Figure 1 also shows how the EU-15 countries can be grouped into three particular

types. The first group, at the bottom of the figure, consists of countries that have

displayed restrictive continuity, meaning that their historically restrictive citizenship

policies have remained impervious to the liberalising trends of the past decades. The

six countries in the second group, liberalising change, have all liberalised their

citizenship policies considerably since the 1980s*increasing their CPI scores by at

least 1.5 points and in most cases much more*thus moving up to either the

medium or the liberal category as a result. Finally, the historically liberal countries

are at the top but, since by definition they cannot be considered cases of restrictive

continuity or liberalising change, they are not included in the analysis that follows.

Having established an empirical baseline that shows the extent of continuity and

change since the 1980s, we can now turn to causal analysis. Why have some countries

liberalised, while others have resisted the pressures of liberalisation and remainedquite restrictive? Can one identify common patterns that apply across countries,

Figure 1. Citizenship Policy Index, 1980s and 2008

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despite the national idiosyncrasies that inevitably apply to policy-making? In each

case, the decisive actors who actually determine citizenship policy are, of course,

domestic political elites and political parties, but they do not act without constraints.

What, then, are the factors that have influenced them, and how have they functioned?

The Argument: The Politics of Citizenship

In order to address these important questions, I introduce a perspective that I call the

politics of citizenship. I seek to understand how political actors have navigated

the potentially treacherous waters on this volatile issue, how they have dealt with the

various pressures for both liberalisation and restrictiveness, and how they have

attempted to implement their choices into new laws and policies. Although it is

certainly possible that lack of change simply represents a form of institutional inertia*

where the old policies continue to persist simply because they already existed*I arguethat elites have pursued conscious strategies and fought open battles, and that these

contingent political factors were decisive in shaping citizenship policy change.

Latent Liberalising Pressures

Since the social science literature on comparative citizenship is still quite recent, there

exist few off the shelf theories, hypotheses and measures that can readily be

incorporated into empirical analysis. Instead, one can look to the related and more

long-standing literature on immigration to find arguments that have been used toexplain policy change. As it turns out, the immigration field is much stronger on

providing theoretical reasons for liberalisation than for restrictiveness. Indeed, several

arguments have been developed to explain increasing liberalisation, with some

emphasising global causes and others stressing domestic factors. On the global level,

scholars have stressed economic globalisation (Sassen 1996, 1998), neo-functional

economic cooperation (Philip 1994), and new norms ofpostnational human rights

(Soysal 1994), to explain liberalisation. And on the domestic level, scholars have

considered interest-group politics*whereby organised groups and businesses often

exert influence quietly on policy-makers to expand immigration (Freeman 1992)*or

domestic courts and the judicial system in general, which have often sided with

immigrants, thereby putting added pressure on political elites to adjust the policies

themselves (Joppke 1998).

Despite the quite different points of emphasis, each of these arguments has the

expectation of increasing liberalisation across the countries of the EU. Indeed,

scholars have usually applied them with a broad sweep to the entire advanced

industrialised world, rather than as a differentiated source of variation between

countries. In other words, according to these arguments, the entire region of Europe

should have liberalised.

In some senses, the empirical baseline presented above provides support for thesearguments, since most of the countries that changed became more liberal in their



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attribution of citizenship. But these arguments do not help us account for the

countries that did not liberalise. What can explain the lack of liberalisation in some

countries? This perspective has been less explored in a literature that primarily

focuses on (and predicts) liberalisation.6

While these latent liberalising pressures are certainly real and influential, they in

fact only tell part of the story, for on the other side lies an important latent pressure

for restrictiveness: public opinion. Indeed, a common and perhaps unifying feature

throughout the EU is the strong hostility to immigrants on the part of many, if not

most, Europeans (Norris 2005; Schain et al. 2002). For example, Figure 2 presents the

data on the 11 relevant countries7 from a 2000 Eurobarometer survey, which included

the following five anti-immigrant statements, with which respondents could either

tend to agree or tend to disagree:

. The presence of people from these minority groups is a cause of insecurity.

. The presence of people from these minority groups increases unemployment in

[country].

. There is a limit to how many people of other races, religions or cultures a society

can accept.

. [Our country] has reached its limits; if there were to be more people belonging to

these minority groups we would have problems.

. People belonging to these minority groups are so different, they can never be fully

accepted members of [nationality] society.

The figure shows the average percentage of respondents who tend to agree with these

five statements. As it turns out, over 40 per cent of people in all countries, and in

most cases substantially over 50 per cent, agree with these very harsh statements.8

Figure 2. Average agreement rate with five anti-immigrant statements

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What is particularly noteworthy about the figure is that, while the scores are certainly

not uniform or identical across countries, the variation is fairly limited. Anti-

immigrant sentiment seems to be consistently high throughout the region.

As a result, it seems clear that*in contrast to the latent pressures for liberalisation

identified above*anti-immigrant public opinion serves as a latent pressure for

restrictiveness. The question, of course, is whether*or, more precisely, where*it has

an influence. For if political outcomes were a direct implementation of the popular

will, liberalisation would not have occurred in most countries, if at all. Indeed, as

Douglas Massey (1999: 313) writes, Most citizens [ . . .] are poorly organised and

politically apathetic, leaving immigration policies to be determined quietly by well-

financed and better-organised special interests operating through bureaucratic

channels. On the other hand, if public opinion were entirely irrelevant, liberalisation

might have already occurred everywhere, since the liberalising pressures are often

more direct and better organised (Cornelius et al. 2004). The key question, therefore,

is how political decision-makers in individual countries respond to the common

pressures of liberalisation and restrictiveness in order to implement policy.

Figure 3 and 4 attempt to answer this question, and to provide a crystallisation of

my argument about the politics of citizenship. Figure 3 recaps the various latent

pressures on each side, showing that the increasing demographic change within

Europe, the rise of new international norms, the long-standing impact of interest

groups, and the role of the courts all provide pressures on political decision-makers

to liberalise their citizenship policies. On the other side, of course, public opinion

remains staunchly and consistently anti-immigrant.

Latent pressures Latent pressures for liberalisation: for restrictiveness:

Decision-makers(political elitesand politicalparties in thegovernment)

Public opinion(anti-immigrant andxenophobicsentiments in thepopulation)

Demographictransformation(increasing numbers offoreigners, de factocontinent of immigration)

Courts and judges(judicial system generallysupports the rights ofimmigrants)

Interest groups(businesses, employerassociations, immigrantgroups)

International norms(human rights,modernising toEuropean standards)

Figure 3. Latent pressure on national citizenship policies



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The Mobilisation of Anti-Immigrant Sentiment

So far this only explains pressures that are latent; in other words, they are in the

background without necessarily being active or dominant. But is there a mechanismthrough which we can determine which types of pressure lead to which outcomes?

Figure 4 presents my two-part political model for explaining why citizenship

liberalisation generally does or does not occur. Part 1 draws on Christian Joppkes

argument about the distinctive politics of centre-left and centre-right governments on

citizenship issues. As Joppke (2003) shows, leftist governments are typically in favour of

increasing the citizenship rights of immigrants (which he calls de-ethnicisation),

whereas right-of-centre governments want to resist such impulses while simultaneously

expanding the countrys connections to its emigres (which he calls re-ethnicisation).

In other words, the expectation is that citizenship liberalisation will be much morelikely to occur if a leftist government is in power. In that case, liberalisation is possible

(though certainly not guaranteed), whereas if a centre-right government is in place,

liberalisation remains unlikely (though not impossible).

Joppkes argument is largely supported by the fact that, of the six countries that

liberalised their citizenship policies, Finland, Germany, Portugal and Sweden all had

left-of-centre governments at the time the reform was passed, and the Netherlands

had multiple grand coalition governments that included the Social Democrats; only

Luxembourg had a centre-right government. In other words, one can argue that the

first step applies to five of the six cases in question, and that having a leftistgovernment is more of a necessary than a sufficient condition for citizenship

liberalisation.

The more important part of the argument on Figure 4*and the particular

contribution of this analysis*is Part 2. It focuses on the latent pressure for

restrictiveness provided by public opinion, and asks whether this anti-immigrant

sentiment becomes activated politically. In other words, the issue is not whether a

centre-left or a centre-right government is in power, but whether the farright is active

and mobilised on the issue of immigration and citizenship reform.9 This can happen

either in the form of a successful far-right party, a popular movement or a

referendum of some kind on the issue of immigration or citizenship. If this is thecase, then liberalisation will essentially be blocked, since no government (whether on

Liberalisation unlikelyNo

Part 1: Is a leftist government in power?Yes

Liberalisation possible

Liberalisation unlikelyPart 2 : Does anti-immigrant public opinion Yes

become activated, either by a strongfar-right party or by public mobilisation? No

Liberalisation possible

Figure 4. A two-part political model for explaining citizenship liberalisation

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the left or right) will be able to overcome the intensity of this mobilisation, because it

has so much resonance in the population. In other words, politicians can easily

overlook public opinion when it remains dormant, restricted to private beliefs about

an issue; but once that sentiment becomes mobilised politically, politicians can only

ignore it at their own peril (Givens and Luedtke 2004). If there is no far-rightmobilisation, however, then citizenship liberalisation is possible as an outcome. In

short, the mobilisation of anti-immigrant sentiment can essentially trump the

liberalising pressures and a leftist government, and thereby block liberalisation.

Operationalisation of the Argument

As with many concepts in social science, it is often easier to define a term and spell

out an argument in abstract language than it is to assign clear and systematic

measures based on existing data from the real world. The activation of anti-immigrant public opinion is difficult to measure using data that can apply to all of

the relevant countries. Mobilising events such as referenda or petition campaigns are

not only relatively rare, but they are also very context-specific, thereby defying a

common measure that could be applied across countries. The best systematic

operationalisation of this concept captures the electoral support that far-right

parties*those whose main platform emphasises opposition to immigration and

immigrants*have received. Although this measure does not cover all aspects of the

concept explained above, it does get at the core of it. I therefore incorporate a

measure of the average electoral strength of far-right parties in national elections ineach country between 1992 and 2006.10

Before turning to a more causal analysis of the relationship between the factors

identified in my political model and the variation in the occurrence of citizenship

liberalisation, we need to address some possible alternative arguments that could

account for that variation.

Alternative Explanations

In this section, I briefly discuss some alternative arguments that derive primarily from

the literature on immigration. These arguments lead to hypotheses that emphasise

economic and socio-economic factors, demographics and public opinion (Givens and

Luedtke 2005).

The field of political economy has established many powerful relationships

between economic factors and political outcomes. Although these types of argument

have not been applied specifically to citizenship policy, it seems plausible that there

would be a meaningful relationship between variation in either economic levels or

economic growth and the liberalisation in citizenship laws. The expectation would

therefore be that countries with more successful economies*as indicated by either

higher levels of GDP per capitaor by higher levels of annual growth*would be morelikely to have the extra margin to afford citizenship liberalisation, since they would



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have more resources available to absorb a greater number of immigrants as new

citizens.

An important socio-economic factor that often enters into discussions about

immigration is the unemployment rate. It is typically assumed that countries with

lower unemployment rates can more easily absorb new workers (and citizens) thanthose which cannot fully employ their own populations already.

Since the practice of citizenship acquisition depends in part on the extent to which

immigrants live in a given country, it seems logical that there would be a connection

between these two factors. In principle, the greater the number of foreigners living in

a country, the greater the pressure on that countrys policy-makers to liberalise the

granting of citizenship. I include two measures of this factor: the raw number of

immigrants, which of course is much higher in the larger countries; and the

percentage of foreigners within the overall resident population.

A final alternative explanation incorporates public opinion as an explanatoryfactor. According to this approach, the policies chosen by elites in power should

reflect the views and preferences of their constituents. Countries whose citizens

display relatively low levels of anti-immigrant sentiments should be more likely to

liberalise their citizenship policies, whereas high levels of xenophobia should be

linked to continuing restrictiveness. There are many possible survey measures of anti-

immigrant sentiment, and indeed the results can easily shift from one question to the

next, depending on how each question is phrased. In the analysis below, I include the

composite measures shown above, based on the 2000 Eurobarometer survey.

Evaluating the Evidence

Having introduced a series of arguments that emphasise a variety of different possible

causal factors, we can now turn to the empirical evidence. Since the N of 11

countries is too small for multivariate statistical analysis, we must rely on bivariate

relationships between each of the variables and the outcome to be explained, namely

the change in CPI scores from the 1980s to the end of 2008.

Table 3 puts all of the competing explanations together*with the alternative

explanations at the top*

summarising the expected direction, and showing thecorrelation and statistical significance for each hypothesis. It shows the regression

results for all seven separate bivariate regressions and makes clear that several of the

alternative arguments actually have the opposite of the predicted sign, and none of

them even comes close to statistical significance. In contrast, the support for far-right

parties has the strongest of the relationships with CPI liberalisation, with the expected

sign and a relatively strong correlation of (.50 and*given the small sample size*a

reasonably high level of statistical significance.

Figure 5 shows three clear clusters of countries:

. Austria, Denmark and Italy, which have very high levels of far-right support anddid not liberalise their citizenship laws;

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. the six liberalising countries, all of which had low levels of support for far-right

parties at the time of citizenship liberalisation;

.

Greece and Spain, the two countries with weak far-right movements yet still noliberalisation.

In short, as predicted by Part 2 of the political model from Figure 4, liberalisation

has only occurred without the presence of a significant far-right party or

movement. And when such a party flourished, the pressures for liberalisation

were effectively blocked.

The cases of Greece and Spain, which have not liberalised, help to draw

attention to an important feature of my argument about the importance of far-

right parties. While the presence of a strong anti-immigrant movement seems to

be a necessary and sufficient factor that prevents citizenship liberalisation, the

absence of the far right is a necessary but not sufficient condition for

liberalisation. In other words, given the current constellation of political forces,

Table 3. Bivariate correlations between country-level factors and citizenshipliberalisation

Variable Expected direction Correlation Significance N

GDP per capita ' .10 .38 11Economic growth ' (.03 .46 11Unemployment ( (.10 .38 11Number of foreigners ' (.06 .43 11Percentage of foreigners ' (.03 .47 11Anti-immigrant sentiment ( (.25 .23 11Support for far-right parties ( (.50 .06 11

Figure 5. The relationship between far-right parties and CPI change



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there is probably a much greater chance for liberalisation in Spain and Greece

than there is in Austria or Denmark.

Conclusion

Although this measure of the mobilisation of anti-immigrant sentiment is probably

the best single indicator available, it only captures part of the larger political story.

The reaction of more mainstream conservative parties to the challenge of the far-

rights message can be just as effective in blocking liberalisation. And public referenda

and other forms of social mobilisation, which are not captured by the far-right

measure, can in some ways result in more rapid and decisive restrictions than the

standard process of elite and party politics. For example, this alternate form of far-

right pressure was critical to citizenship developments in the case of Germany, where

anti-immigrant public opinion was activated through a massive petition campaign,rather than a far-right party (such parties are closely watched and often banned in

Germany), and which led to a restrictive backlash that diluted the extent of

citizenship liberalisation in 2000.

Moreover, looking for a moment at the historically liberal countries, the case of

Ireland highlights the role of public mobilisation outside party politics. Although

Ireland does not have an organised far-right movement, proponents of restrictions

on citizenship acquisition succeeded in implementing a controversial referendum,

which passed overwhelmingly (with 80 per cent support) in June 2004, to limit

the jus soli rights of the children of non-citizens, so that children born on Irishsoil can only receive Irish citizenship if at least one of their parents has resided in

Ireland or the UK for three of the previous four years.11 This remarkable

development shows the tremendous salience of this issue when it becomes publicly

mobilised*and the result is almost always change in the direction of restrictive-

ness. The same phenomenon has occurred repeatedly in Switzerland (which is not

an EU member-state, and therefore not included as a case in this study), where

voters have consistently rejected referenda that would have liberalised the

extremely restrictive Swiss citizenship law.

Finally, expanding the analysis further to include other historically liberal countries,

we see that Belgium and France*both of which have fairly strong far-right movements,

with 19922006 average far-right returns of 12.3 and 13 per cent respectively*have

seen immigration and citizenship emerge as highly polarising political issues. These two

countries have either experienced (in the case of France in the mid-1990s) or are

currently experiencing (in the case of Belgium) some tinkering with their citizenship

laws as a result of the pressure of the far right.

In short, while the evidence above shows that my argument about the impact of

far-right parties helps to account for whether or not liberalising change has

occurred, it certainly does not provide the final word on the topic of citizenship

policies and how they have adjusted to new pressures and circumstances. Muchmore analysis and evidence are needed. But the cross-national comparison in this

748 M.M. Howard


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article provides a valuable starting-point for understanding the complex social and

political processes involved.

Notes[1] The NATAC project, also called the The acquisition of nationality in EU Member States:

rules, practices and quantitative developments, was directed by Rainer Baubock and

funded primarily by the European Commission. Its findings have been published by

Amsterdam University Press in two volumes (Baubock et al. 2006), which provide the

most detailed, comprehensive and systematic analyses of citizenship policies in the

EU-15 that exist to date, thus representing a tremendous resource to scholars in

this area.

[2] Although technically the reduction should be applied strictly to naturalisation

requirements, in my view the application of a liberal dual-citizenship policy is ultimately

meaningless if very few people can actually become citizens. It is therefore important toadjust the scores to reflect the possibility for immigrants to actually benefit from these

policies. The result is a more sensitive and meaningful final score on dual citizenship for

immigrants.

[3] In a sense, therefore, the effective cut-off date for this time period is 1990.

[4] Note that my use of the word liberal in this article is mainly with reference to the issue of

citizenship policies, not to the various meanings and traditions associated with the concept

of liberalism. In other words, the categories liberal and restrictive are essentially measures

of the inclusiveness of each countrys citizenship policies.

[5] Luxembourgs liberalisation process took place in two steps. The 2001 reforms reduced the

residency requirement from ten to five years, while also adding a new language requirement.

The 2008 change eliminated the renunciation requirement, thus allowing dual citizenship forimmigrants, while also increasing the residency requirement for immigrants and spouses to

seven years and adding to the civic integration requirements. Both changes represent

liberalisation, but with some restrictive movement as well.

[6] For one important exception, see Money (1999).

[7] Note that I am still excluding the four historically liberal countries, because this article

focuses on liberalisation. In actual fact the results for Belgium, France, Ireland and the UK

are not at all different from the other EU countries in terms of their high levels of anti-

immigrant sentiment.

[8] Data from the 2002 European Social Survey paint a similar picture, showing high levels of

anti-immigrant sentiment throughout the EU countries (Sides and Citrin 2007).

[9] Note that I use the term far right to refer to what others sometimes call the radical right or

extreme right.

[10] For the six countries that liberalised, the average far-right scores go up to the year of

citizenship liberalisation, since the strength of the far right afterthe change has gone through

is no longer relevant to the question of liberalisation. Indeed, in some countries such as the

Netherlands, the far right became much stronger after the law was liberalised, precisely in

opposition to that law.

[11] However, it should be pointed out that, while the new law is certainly more restrictive than it

was previously, Ireland still grants jus soli, and in fact is still more liberal than most other

countries*such as Germany*which have lengthier residency requirements for the parents

of children born in the host country, and which sometimes include employmentrequirements that many poorer immigrants do not fulfill.



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