Citizenship Regimes in the EU Countries and the Inclusion of the Immigrant Population in the Political Community

Abstract

The article is devoted to the analysis of differences in the approaches of European Union member states to the inclusion of migrants into the political community by granting them citizenship. These differences are operationalized through the category of “citizenship regimes”. The article distingui shes three types of citizenship regimes — liberal, restrictive, and mixed. Whether a particular regime can be categorized into one of these citizenship regime types is determined on the basis of three indicators: (1) application/nonapplication of birthright citizenship (jus soli), (2) the presence of the institution of dual (multiple) citizenship, and (3) the relative simplicity/complexity of the naturalization procedure. At the same time, due to the lack of the comprehensive statistical data, which would allow assessing all possible components of this procedure, in order to evaluate the degree of the simplicity/complexity of the procedure, the authors focus on such a parameter as the minimum time period of residence in the country required to apply for citizenship. Having considered the evolution of the legal systems of the EU states, the authors reveal important differences in the approaches to the naturalization of migrants along the axis between the “old” countries of the European Union, on the one hand, and new members of the United Europe from the former socialist countries, on the other. While the “old” EU members tend to gradually liberalize citizenship regimes, the new ones are leaning towards a restrictive model, which manifests itself both in the difficult conditions of naturalization and rejection of the birthright citizenship law. The convergence of the positions of these two groups of countries on this issue is not visible.