Journal of Ethnic and Migration Studies

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

The Impact of the Far Right on

Citizenship Policy in Europe:
Explaining Continuity and Change
Marc Morjé Howard
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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;
Bauböck et al. 2006; Hansen and Weil 2001, 2002; Howard 2005, 2006; Joppke
2008; 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 Morjé 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: mmh@georgetown.edu.

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

DOI: 10.1080/13691831003763922
 736 M.M. Howard

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 apply
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to 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 to
fairly 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, the
new CPI draws on the tremendous research*by individual country experts, within a
 Journal of Ethnic and Migration Studies 737

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 country’s territory can acquire that country’s 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.
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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 soli at birth and jus soli after birth (whereas the
old CPI only measured jus soli at birth), with separate scores for both of these
elements of jus 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 country’s 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 expressly
forbid it. But it now gives intermediate scores to countries that have a large
 738 M.M. Howard

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 of change, 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 country’s 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
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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
Naturalisation Dual citizenship
Jus soli requirements for immigrants CPI SCORE
Country (02) (02) (02) (06)

Germany 0.00 0.00 0.00 0.00

Austria 0.00 0.50 0.00 0.50
Restrictive

Luxembourg 0.00 0.50 0.00 0.50

Italy 0.00 0.72 0.00 0.72
Greece 0.00 0.00 1.25 1.25
Spain 0.50 0.75 0.00 1.25
Denmark 0.00 1.43 0.00 1.43
Finland 0.00 1.72 0.00 1.72
Medium

Sweden 0.00 1.72 0.00 1.72

Portugal 0.75 0.00 1.00 1.75
Netherlands 1.50 1.22 0.00 2.72
France 1.50 1.22 1.50 4.22
Liberal

Ireland 2.00 1.11 1.25 4.36

Belgium 1.50 1.75 1.75 5.00
UK 1.75 1.72 2.00 5.47
 Journal of Ethnic and Migration Studies 739
Table 2. The three main components of citizenship policies for the EU-15 in 2008
Naturalisation Dual citizenship
Jus soli requirements for immigrants CPI SCORE
Country (02) (02) (02) (06)

Austria 0.00 0.00 0.00 0.00

Med. Restrictive

Denmark 0.00 0.00 0.00 0.00

Greece 0.00 0.00 1.00 1.00
Spain 0.50 0.38 0.50 1.38
Italy 0.00 0.25 1.25 1.50
Germany 0.75 0.54 0.75 2.04
Luxembourg 1.00 0.00 1.25 2.25
Netherlands 1.50 1.22 1.50 4.22
Finland 1.00 1.32 2.00 4.32
Portugal 1.75 1.07 1.50 4.32
Liberal

Ireland 2.00 1.36 1.50 4.86

France 1.50 1.47 2.00 4.97
UK 1.75 1.22 2.00 4.97
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Sweden 1.50 1.72 2.00 5.22

Belgium 1.50 2.00 2.00 5.50

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 different
combinations 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
 740 M.M. Howard
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Figure 1. Citizenship Policy Index, 1980s and 2008

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 is
clear 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 remained
quite restrictive? Can one identify common patterns that apply across countries,
 Journal of Ethnic and Migration Studies 741

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 argue
that elites have pursued conscious strategies and fought open battles, and that these
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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 to
explain 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 of ‘postnational’ 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 these
arguments, since most of the countries that changed became more liberal in their
 742 M.M. Howard

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.

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. 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

 Journal of Ethnic and Migration Studies 743

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,
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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:

Demographic
transformation
(increasing numbers of
foreigners, de facto
continent of immigration)

International norms
(human rights,
‘modernising’ to Decision-makers Public opinion
European standards) (political elites (anti-immigrant and
and political xenophobic
sentiments in the
parties in the population)
Interest groups government)
(businesses, employer
associations, immigrant
groups)

Courts and judges

(judicial system generally
supports the rights of
immigrants)

Figure 3. Latent pressure on national citizenship policies

 744 M.M. Howard

Liberalisation unlikely
No
Part 1: Is a leftist government in power?
Yes
Liberalisation possible

Liberalisation unlikely
Part 2 : Does anti-immigrant public opinion Yes
become ‘activated’, either by a strong
far-right party or by public mobilisation? No
Liberalisation possible

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

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 mechanism
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through 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 Joppke’s
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 country’s connections to its émigrés (which he calls ‘re-ethnicisation’).
In other words, the expectation is that citizenship liberalisation will be much more
likely 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).
Joppke’s 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 leftist
government 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 far right 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 the
case, then liberalisation will essentially be blocked, since no government (whether on
 Journal of Ethnic and Migration Studies 745

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-right
mobilisation, 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-
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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 in
each 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 capita or by higher levels of annual growth*would be more
likely to have the extra ‘margin’ to afford citizenship liberalisation, since they would
 746 M.M. Howard

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) than
those 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 country’s 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 explanatory
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factor. 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 the
correlation 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 and
did not liberalise their citizenship laws;
 Journal of Ethnic and Migration Studies 747
Table 3. Bivariate correlations between country-level factors and citizenship
liberalisation
Variable Expected direction Correlation Significance N

GDP per capita  .10 .38 11

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

. 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 no
liberalisation.
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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,

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

 748 M.M. Howard

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-
right’s 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
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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 Irish
soil 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. Much
more analysis and evidence are needed. But the cross-national comparison in this
 Journal of Ethnic and Migration Studies 749

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 Bauböck and
funded primarily by the European Commission. Its findings have been published by
Amsterdam University Press in two volumes (Bauböck 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 to
adjust the scores to reflect the possibility for immigrants to actually benefit from these
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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 country’s citizenship policies.
[5] Luxembourg’s 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 for
immigrants, 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 after the 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 employment
requirements that many poorer immigrants do not fulfill.
 750 M.M. Howard

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