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Émilien Fargues, Giacomo Solano & Thomas
Huddleston, Maarten Vink, Samuel D. Schmid,
Rainer Bauböck, Luicy Pedroza & Pau Palop-García,
Jelena Džankić, Ashley Mantha-Hollands
Going Global: Opportunities and Challenges
for the Development of a Comparative
Research Agenda on Citizenship Policies at
the Global Level
RSC 2022/41
Robert Schuman Centre for Advanced Studies
Global Governance Programme-472
WORKING
PAPER
RSC Working Paper 2022/41
Émilien Fargues, Giacomo Solano & Thomas
Huddleston, Maarten Vink, Samuel D. Schmid,
Rainer Bauböck, Luicy Pedroza & Pau Palop-
García, Jelena Džankić, Ashley Mantha-Hollands
European University Institute
Robert Schuman Centre for Advanced Studies
Global Governance Programme
Going Global: Opportunities and Challenges for
the Development of a Comparative Research
Agenda on Citizenship Policies at the Global Level
Edited by Émilien Fargues
ISSN 1028-3625
© Émilien Fargues, Giacomo Solano & Thomas Huddleston, Maarten Vink, Samuel D.
Schmid, Rainer Bauböck, Luicy Pedroza & Pau Palop-García, Jelena Džankić, Ashley
Mantha-Hollands, 2022
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Abstract
Thanks to the work undertaken by dierent research teams (GLOBALCIT, MACIMIDE, MIPEX…),
data on citizenship policies are becoming available on a wide range of countries worldwide. The
collection of these data makes it possible to develop new comparative research frameworks
that go beyond the dominant European/Western-centred perspective that we nd in traditional
citizenship studies. The development of cross-regional comparative frameworks allows testing
the generalisability of explanations for policy-variations more comprehensively and contributes
to formulating new hypotheses and theories to account for both convergences and divergences
across time and space. However, the need to adapt concepts and measurement tools to the
dierent realities of citizenship at the global level raises important challenges. Drawing on the
workshop ‘Going Global: Opportunities and Challenges for the Development of a Comparative
Research Agenda on Naturalisation Policies at the Global Level’ that was convened in 2021
at the Robert Schuman Centre, under the framework of the Global Citizenship Governance
programme, contributors to this working paper have been invited to reect on the promises
and diculties that the articulation of a global comparative perspective in citizenship studies
involves. Two main recommendations for the advancement of a comparative agenda at the
global level stand out from this symposium: the rst is to accommodate as much as possible
the specicities of each context within the construction of comparative frameworks; the second
is to acknowledge the biases and limitations of the perspective that we take as researchers.
It therefore emerges that in order to make a distinct contribution to scholarly knowledge by
expanding the geographical scope of their investigations, citizenship scholars need to address
the challenge of comparability.
Keywords
Citizenship, comparative research, global perspective, comparability
Acknowledgment
This project has received funding from the European Research Council (ERC) under the
European Union’s Horizon 2020 research and innovation programme (grant agreement
No 716350).
European University Institute 1
Going Global
Table of contents
Émilien Fargues, Going Global in Comparative Research on Citizenship:
Facing the Challenge of Comparability.....................................................................................2
Giacomo Solano & Thomas Huddleston, Existing Indices on Naturalisation Policies:
The Case of MIPEX ................................................................................................................ 10
Maarten Vink, Making Citizenship Regimes (More) Comparable Globally:
Exploring the New GLOBALCIT Citizenship Law Dataset ......................................................16
Samuel D. Schmid, Towards a Valid Global Citizenship Policy Index:
Three Existing Approaches and a New Hybrid Approach ....................................................... 30
Rainer Bauböck, Global Comparison of Citizenship Laws: Promises and Pitfalls .................36
Luicy Pedroza & Pau Palop-García, Without the South, It’s Not Global:
Creating Knowledge about Naturalization Jointly ................................................................... 41
Jelena Džankić, Avoiding Measure for a Measure’s Sake:
Limits and Value Added of Citizenship Law Indicators ...........................................................46
Ashley Mantha-Hollands, Concepts in New Contexts ............................................................ 53
2Robert Schuman Centre for Advanced Studies
Émilien Fargues
Going Global in Comparative Research on Citizenship:
Facing the Challenge of Comparability
Émilien Fargues*
In a recent review of the comparative studies of citizenship and migration policies, Giacomo
Solano and Thomas Huddleston (2021) note that the outstanding majority of the existing
analyses concentrate on European and Western countries. With more than one third of
immigrants worldwide settling in low or middle-income countries and three quarters of the
refugee population living in African, Asian, Latin American and Caribbean states, this Western-
centric perspective is problematic. It tends to perpetuate a conceptualisation of migration as
a phenomenon that remains limited to the major destination countries in the OECD/Europe
(Solano & Huddleston, 2021: 334).
Thanks to the work undertaken by dierent research teams, data on citizenship and
migration policies are becoming available on a wide range of countries worldwide. To take but
two examples, the 2020 edition of the policy-index Migrant Integration Policy Index (MIPEX)
measures the policies to integrate migrants in 56 countries across ve continents (Solano
and Huddleston, this collection). In turn, the Global Citizenship Observatory (GLOBALCIT)
provides a new database on the acquisition and the loss of citizenship that covers more than
190 independent states as of 2020 (Van der Baaren & Vink, 2021). The collection of these
data makes it possible to develop new comparative research frameworks that go beyond the
dominant European/Western-centred perspective that we nd in citizenship and migration
studies. The development of cross-regional comparative frameworks allows testing the
generalisability of explanations for policy-variations more comprehensively and contributes to
formulating new hypotheses and theories to account for both convergences and divergences
across time and space. However, the need to adapt concepts and measurement tools to the
dierent realities of citizenship and migration at the global level raises important challenges.
Drawing on the workshop that we convened in 2021 at the Robert Schuman Centre of the
European University Institute,1 contributors to this working paper have been invited to reect
on the opportunities and challenges in the development of a comparative research agenda on
citizenship and migration at the global level.
My own contribution aims to synthesise the main arguments made in this collection, and to
consider how they speak to each other, while delineating ways ahead for future comparative
research. I rst discuss the arguments made in favour of expanding our comparative scope
beyond the OECD/Europe. I take the example of the persistence of discriminations towards
women in citizenship transmission and acquisition as a topic worth investigating across
regional contexts, using global comparative datasets. Then, I examine the conceptual and
methodological challenges that the articulation of a global comparative perspective raises.
One key diculty that the contributors to this collection reveal is that of comparability, i.e., the
limits and possibilities for comparison across contexts where citizenship might have dierent
* Research Associate, Centre for Political Research (CEVIPOF), Sciences Po / Research Fellow, Collaborative Institute on
Migration (ICM), Collège de France.
1 The workshop ‘Going Global: Opportunities and Challenges for the Development of a Comparative Research Agenda on
Naturalisation Policies at the Global Level’ was organised with the support of the Global Citizenship Governance project,
coordinated by Liav Orgad, and hosted at the Robert Schuman Centre and the WZB Berlin Social Center. It was funded
by by the European Research Council (ERC) under the European Union’s Horizon 2020 Research and Innovation Pro-
gramme (Grant No. 716350). The recording of the workshop is available online: https://www.youtube.com/playlist?list=PLk-
AX64nYGtd_aW-yYWaM1fSKLcpEgyvjC
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Going Global in Comparative Research on Citizenship
3
meanings and functions. The issue of comparability is a major challenge that researchers
aiming to design large-N comparative frameworks should give top priority for it conditions
the very validity of their results. Based on the contributions to this working paper, two main
recommendations for the advancement of a comparative agenda at the global level stand
out: the rst is to accommodate as much as possible the specicities of each context within
the construction of comparative frameworks; the second is to acknowledge the biases and
limitations of the perspective that we, as researchers, take.
1. The promises of a global comparative agenda
As Rainer Bauböck underlines in this collection, one key ambition of citizenship studies
is to explore patterns of diusion of and resistance to state norms in nationality laws (e.g.
acceptance of gender equality, acceptance of multiple citizenships, prohibition of statelessness,
etc.). Scholars following this line of research seek to identify which causal mechanisms are
likely to explain those patterns. The recent expansion of comparative datasets beyond Europe
enables researchers to develop more comprehensive explanatory theories. In recent years,
considerable progress has been made in this direction. The MACIMIDE Global Expatriate
Dual Citizenship Dataset has for instance contributed to analysing the progress of tolerance
towards dual citizenship for expatriates from the 1960s onwards in more than 150 countries
(Vink, Schakel, Reichel, Luk & de Groot, 2019). There is thus scope for further research on the
expansion of similar changing norms at the global level.
Let us take the example of gender equality in the transmission and acquisition of citizenship.
Women have long been deprived of the right to confer citizenship on their children and spouse
on an equal basis with men. The introduction of discriminations towards women (DTW) in
nationality laws followed distinct patterns and timeframes from one country to another. As Betty
de Hart explains (2006: 52), DTW are less the ‘result of age-old patriarchal thinking’ than an
‘invention of the late-eighteenth century’, often driven by migration concerns. For example, in
the United States, it is not until 1907 that authorities passed a law to deprive of their American
citizenship women who married foreigners. In Switzerland, marriage between Swiss women
and German-Jewish refugees was also discouraged through similar legislation, but only
in 1941. Interestingly, inequalities between men and women have often been extended by
European countries to the legislations in the colonies. This largely explains why many African
states discriminated against women at the time of their independences (Manby, 2018: 98). The
history of DTW in the transmission of citizenship to children and the acquisition of citizenship
based on marriage has been common to many countries worldwide.
DTW have largely disappeared in nationality laws, often very recently.2 In Europe, formal
equality with men was only achieved in 1973 in France, in 1975 in Germany, in 1983 in
the United Kingdom, in 1986 in Austria and in 1992 in Switzerland (de Hart, 2006: 66). In
Africa, the Lusophone socialist states and the Burkina Faso of Thomas Sankara were among
the rst to introduce equality between men and women in the 1970s and 1980s, together
with Chad and Côte d’Ivoire as early as the 1960s (Manby, 2018: 98). More recently, we
have seen discussions over the elimination of DTW in other African countries, Asia Pacic,
Southern America and the Middle East.3 Those discussions have not necessarily resulted
2 Gender-based discriminations are still present in the nationality laws of European countries though, especially if we consider
discriminations in the transmission of citizenship to children that aect parents out of wedlock and LGBTIQ* parents. See
Erdilmen & Honohan, 2020.
3 For a panorama, see the Global Campaign for Equal Nationality Rights website: https://equalnationalityrights.org.
4Robert Schuman Centre for Advanced Studies
Émilien Fargues
into amendments for more gender equality, but the elimination of DTW is becoming a salient
political issue at the global level. DTW still persist in many countries situated in majority in
Africa, Asia and the Middle East, leading to serious women’s and children’s rights violations
as well as statelessness. The updated version of the GLOBALCIT database allows mapping
those countries and disaggregating discriminations by mode of citizenship transfer (see Figure
1). In the GLOBALCIT database, modes A01a (descent based on birth in the territory), A01b
(descent based on birth abroad), as well as A02a (citizenship at birth due to birth in country for
second generation) and A02b (citizenship at birth due to birth in country for third generation)
capture DTW in the transmission of citizenship to children, while mode A08 captures DTW in
the transmission of citizenship to spouses. As of 2020, at least 25 countries still discriminated
against women in the transmission of citizenship to children or spouses.
Figure 1. Discrimination against women in the transmission of citizenship to children
and spouses in 2020
The persistence of DTW is often noticed but rarely explained in comparative studies at
the global level (see Honohan & Rougier, 2018). Previous research has identied dierent
mechanisms likely to explain patterns of diusion of / resistance to gender equality across
regional contexts. For example, building on an analysis of the elimination of gender-based
discriminations in France, Germany and the United States, Diane Sainsbury (2018) insists on
the interplay between domestic and international feminist activism to account for the gradual
suppression of gender dierentiation in citizenship acquisition. To explain the elimination of
DTW in Africa, Bronwen Manby (2018) similarly underlines the crucial impact of women’s
rights networks at both the continental and the global levels. The expansion of comparative
databases such as the GLOBALCIT Citizenship Law dataset will make it possible to test the
impact of factors such as transnational feminist activism more comprehensively across other
regional contexts. At present, the latest edition of the GLOBALCIT dataset provides a snapshot
of the legislations in 190 countries as of 2020 and allows for cross-sectional comparisons (Van
der Baaren & Vink, 2021). There is potential for more comprehensive cross-sectional analyses.
European University Institute
Going Global in Comparative Research on Citizenship
5
Scholars may for instance want to test the impact of cultural and religious structures on the
persistence of DTW in more countries than what previous research has done (Frost, 2020).
Moreover, the GLOBALCIT database should soon incorporate a complete set of both amended
and unamended laws (see Vink, this collection), which will enable researchers to conduct more
comprehensive longitudinal analyses on the elimination of DTW worldwide. Such a dataset
will indeed represent a formidable starting point to investigate why certain countries or regions
of the world went faster in the elimination of DTW than others and contribute to identifying
patterns of diusion of / resistance to gender equality. This global research agenda will also
help understand why solutions that worked in some contexts did not in others and might open
up new pathways for future reform towards more equality.
The example of gender equality in the transmission of citizenship thus shows that the
construction of a global comparative research agenda in citizenship studies can be ‘theoretically
driven’ (Goodman, 2015). The geographical expansion of comparative datasets promises
even more comprehensive theories accounting for the diusion of / resistance to changing
norms in nationality laws. However, how can we ensure that this research agenda remains
both conceptually and methodologically consistent? What are the risks and limitations that
researchers should be aware of when going global? Contributors to this working paper provide
important insights on those questions.
2. The challenge of comparability
The challenge of comparability, i.e. the limits and possibilities for comparison across contexts,
represents no novelty in social sciences. Other generations of comparativists have been
confronted with the diculties that comparability raises. As Peter Mair (1998: 310) noted though,
researchers tend to frequently ignore the challenge, and this has serious consequences on
both theory-building and theory-testing:
‘Precisely because the act of comparison is itself so instinctive to both scientic and popular
cultures, [comparability] is sometimes assumed by researchers to be unproblematic and
hence is neglected. And it is this neglect, in turn, which lies at the root of some of the most
severe problems in the cumulation of research, on the one hand, and in theory‐building and
theory-testing, on the other hand’.
In contemporary citizenship studies, the expansion of comparative research at the global level
is still at its early stage and is primarily concerned with the comparison of nationality laws.
Living in a world of nation-states where regulations on the acquisition and loss of citizenship
can be found in any country, the global comparison of nationality laws may seem natural
and unproblematic. On the contrary, contributors to this collection underline that going global
in citizenship studies raises serious issues of comparability. Jelena Džankić (this collection)
warns against ‘conceptual imposition’, i.e., the presumption that the concepts we use to
compare cases have the same meanings and implications across the world. Similarly, drawing
on Giovanni Sartori (1970), Ashley Mantha-Hollands (this collection) argues that ‘travelling
problems’ are likely to aect global comparative frameworks. If we want to avoid the risk of
conceptual imposition, we need to ask ourselves how concepts can travel across contexts and
reciprocally, how contexts might challenge our own conceptual assumptions. For example,
scholars often assume that nationality introduces a sharp demarcation between ‘citizens’
and ‘foreigners’. However, the boundaries of national membership may not be as sharp,
depending on the contexts we consider. Kamal Sadiq (2008) has notably shown that in India,
Malaysia, or Pakistan, immigrants who do meet the rules conditioning the right to enter and/
or stay in the territory still enjoy most of the benets associated with formal citizenship. In
6Robert Schuman Centre for Advanced Studies
Émilien Fargues
countries where large segments of the population are undocumented and where the state
lacks eective surveillance technologies, the boundary between ‘citizens’ and ‘foreigners’ is
blurred. From Sadiq’s perspective, scholars aiming to build comparative frameworks that go
beyond European countries should be very sceptical of the ‘distinguishability assumption’ – i.e.
the idea that nationality laws establish a clear divide between ‘citizens’ and ‘foreigners’ – as it
ignores the reality of thousands of immigrants in the Global South.
Issues of comparability in the global comparison of nationality laws become particularly
salient when the comparative framework involves normative appreciations or categories (e.g.
how liberal / how inclusive is the law?), as is the case with the construction of policy indices.
Reecting on the possibilities of expanding existing policy indices measuring the inclusivity
of citizenship policies towards immigrants to a global perspective, Maarten Vink underlines
the ‘risk of violating the validity of the respective indicators’ as there may not be functional
equivalents across contexts (this collection). There may for instance be countries where the
rule of law is not guaranteed or, as we have seen, where large segments of the population do
not have access to documentation. In such contexts, inferring that a country is more inclusive
towards immigrants based on the assessment of its nationality laws is problematic as the rules
conditioning access to formal citizenship do not play the same ‘gate-keeping’ function as in other
contexts (see Ashley Mantha-Hollands on this point, this collection). To mitigate those issues,
researchers may be tempted to restrict the geographical scope using variables that make
cases more comparable to each other. To expand policy indices on the inclusivity of citizenship
laws towards immigrants, we might for example want to narrow down the scope by focusing on
democratic countries. This would arguably limit the problem that inclusivity towards immigrants
can hardly be inferred from the assessment of nationality laws in countries where the rule
of law is not guaranteed. However, limiting the comparative scope to democratic countries
may not be of great help to improve comparability. First, we see bureaucrats implementing
citizenship and migration policies taking arbitrary decisions even in democratic countries (Spire,
2008). Second, the notion that the rule of law should be considered as a dening property of
democracy and arbitrariness a dening characteristic of autocracy is highly contested (Geissel
et al., 2016; Mérieau, 2018). We should thus be careful with regime dichotomies.
Both in the construction of their comparative designs and the interpretation of their results,
scholars should resist the temptation of ready-made solutions to issues of comparability. As
Rainer Bauböck and Jelena Džankić underline in their contributions, expanding the comparative
scope at the global level carries a risk of oversimplication. As Jelena Džankić argues (this
collection), most of the large-N comparative analyses rest on a ‘vision of citizenship policies as
qubits, which prevents scholarship from identifying where legal provisions are used to promote
specic and often conicting interests, such as those of expatriate and immigrant populations’.
Similarly, Rainer Bauböck (this collection) warns against the ‘holistic assumption’ that large-N
comparative frameworks risk reproducing, i.e. the ‘implicit assumption that the rules for
acquisition and loss of citizenship status hang together to form a coherent whole’, driven by
a single purpose (e.g. selecting immigrants). According to both authors, the expansion of the
comparative scope in citizenship studies will only make a distinct contribution if researchers
acknowledge that multiple purposes drive the evolution of citizenship policies. Another
important aspect that is often subject to oversimplication in large-N comparative frameworks
is the gap between law in the books and law in action, also known as ‘implementation gap’.
Rainer Bauböck (this collection) for instance notes that ‘comparative social scientists often
treat citizenship laws simply as data that indicate how open and inclusive a political regime is
towards immigrants and diaspora populations’, and thus forget about the implementation gap.
In specic domains of citizenship policies where public authorities have traditionally enjoyed a
wide discretionary power (e.g. ordinary naturalisation or citizenship revocation), research on
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Going Global in Comparative Research on Citizenship
7
implementation should be given priority over the comparison of nationality laws as scholars
should rst interrogate the eectiveness of citizenship rules.
As Ashley Mantha-Hollands stresses (this collection), the methodological reection on the
challenge of comparability at the global level is still at its early stage in citizenship studies.
More eort should be invested to develop this reection, even more so since comparative
datasets are currently being expanded globally. We can draw two main recommendations for
the advancement of a comparative agenda at the global level from the contributions to this
collection:
(1) The importance of accommodating as much as possible the specicities of each context
within the construction of the comparative framework and the interpretation of the results.
Contributors to this working paper insist on the importance of building a global comparative
approach that is context sensitive. Ashley Mantha-Hollands (this collection) points to the
diculty that the design of large-N comparative frameworks creates as researchers will
often have ‘asymmetric knowledge’ about their cases. They therefore need to rely on local
knowledge to adjust their concepts and methods to new contexts. According to Luicy Pedroza
and Pau Palop-García (this collection), there is currently a structural imbalance in terms of data
availability between the Global North and the Global South. Local knowledge is much easier to
nd in the Global North and this explains why much of the existing comparative research has
focused on this area. Developing global comparative approaches in citizenship and migration
studies requires investing in local research in the Global South and working towards a ‘culture
of shared knowledge’ (Luicy Pedroza and Pau Palop-García, this collection).
Following the same reasoning, Samuel Schmid (this collection) also emphasises the
importance of investing in local knowledge to go global in citizenship studies: ‘to construct valid
concepts and measures, we should move from concept specication and operationalization to
concrete data and back in an iterative way’. In his contribution, he makes a stimulating proposal
towards a valid global citizenship policy index that would measure the degree of inclusivity of
citizenship regimes towards immigrants. Building on a review of past approaches to designing
policy indices (the ‘classical xed indicators approach’, the ‘policy change approach’, the
‘exible single indicator approach’), Samuel Schmid proposes a new ‘hybrid’ approach that
has the advantage of relying on a consistent conceptual framework and being more context
sensitive. Indeed, the hybrid approach allows for concept specication (i.e. it denes clear
policy components against which the restrictiveness of citizenship laws will be assessed)
and remains open to exible indicators (i.e. each policy component can be used as a exible
indicator that accommodates functional equivalents). The hybrid approach may not answer
all the questions that the challenge of comparability at the global level raises. For example,
it does not answer the question as to whether ‘inclusivity towards immigrants’ is a notion that
travels well across contexts, as Samuel Schmid admits. Still, it demonstrates that researchers
can design innovative methodological frameworks to address the challenge of comparability.
(b) The importance of acknowledging the biases and limitations likely to aect the global
comparative perspective.
Another key recommendation that stems from the contributions to this working paper is that
researchers designing global comparative frameworks should be ‘honest’ (see Jelena Džankić,
this collection) and always acknowledge what they leave out from their analyses. Limitations
should be recognised at both the levels of conceptualisation and interpretation of the results. For
example, as we have seen above, the comparative datasets that are currently being expanded
8Robert Schuman Centre for Advanced Studies
Émilien Fargues
globally concentrate on citizenship laws and do not consider the level of implementation.
This is an important limitation that has implications for the analysis of citizenship regimes.
The global comparison of citizenship laws is a promising research agenda but, as Rainer
Bauböck reminds (this collection), ‘we need to be aware that comparing the rules contained
in citizenship laws in principle only allows to test hypotheses about variation of legal norms
across time and countries’. To take another example at the level of conceptualisation, gender
dierentiation and gender restriction in citizenship laws go beyond discriminations towards
men and women. These two concepts also cover discriminations towards LGBTIQ* parents
and couples in the transmission of citizenship to children and spouses. Comparative datasets
may perfectly concentrate on discriminations towards men and women, as the new edition of
the GLOBALCIT dataset does, but it is important to acknowledge that gender dierentiation
and gender restriction are concepts that reach beyond these specic types of discriminations.
Recognising limits and biases requires that researchers develop a reection on their own
‘positionality’. As Ashley Mantha-Hollands explains (this collection), ‘scholars must not only
keep in mind that their own research training and methodological strategies will shape results
but also how their own positionality in research may inuence the questions they ask, concepts
they use, and interpretation’. Until present, such a reection on positionality has been rather
limited in citizenship studies compared to other research elds. The ongoing expansion of
comparative research at the global level will necessitate further investments in this direction.
Conclusion
Of the ve main pitfalls identied by Rainer Bauböck (this collection) in the articulation of a
global comparative agenda on citizenship, the most challenging one is probably not letting our
research be driven by available data. Data on the conguration and the evolution of citizenship
laws will become increasingly available at the global level. The next edition of MIPEX will
incorporate more than 56 countries, while new updates on the GLOBALCIT database
will provide longitudinal data on the 190 states it presently covers. These are promising
developments that will enable researchers to conduct cross-regional comparative studies
and test the generalisability of various theories, old and new, across contexts. To make a
distinct contribution to scientic knowledge, though, it is essential that researchers address
the challenge of comparability. As I have explained, there are no ready-made solutions to this
challenge. Understanding the limits and possibilities of comparison requires context sensitivity
and reexivity at every phase of the research process. This might seem an arduous task
and one that we are never certain to fully achieve. It is my hope, then, that scholars wishing
to expand comparative research on citizenship and migration globally will nd stimulating
reections in this working paper to take up the challenge.
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Going Global in Comparative Research on Citizenship
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Solano, G. & Thomas Huddleston (2021). ‘Beyond Immigration: Moving from Western to Global
Indexes of Migration Policy’. Global Policy 12 (3): 327–37. https://doi.org/10.1111/1758-
5899.12930.
Spire, A. (2008). Accueillir ou reconduire: Enquête sur les guichets de l’immigration. Paris:
Raisons d’agir.
Van der Baaren & M. Vink (2021). Modes of acquisition and loss of citizenship around the
world. Comparative typology and main patterns in 2020. Florence: RSC Working Paper
2021/90.
Vink, M., A. H. Schakel, D. Reichel, N. C. Luk, & G.-R. de Groot (2019). ‘The International
Diusion of Expatriate Dual Citizenship’. Migration Studies 7 (3): 362–83. https://doi.
org/10.1093/migration/mnz011.
10 Robert Schuman Centre for Advanced Studies
Giacomo Solano and Thomas Huddleston
Existing Indices on Naturalisation Policies: The Case of MIPEX
Giacomo Solano and Thomas Huddleston*
Introduction
Over the last years, researchers have undertaken systematic comparisons of migration policies
– mainly at the national level – by creating indicators and indices (Helbling & Michalowski, 2017;
Scipioni & Urso, 2018). These indicators and indices have been used to analyse dierences
and trends in migration policy (Czaika & de Haas, 2013; Helbling & Kalkum, 2018).
This paper addresses naturalisation policies for migrants and their descendants by presenting
the Migrant Integration Policy Index (MIPEX) 2020 – access to naturalisation strand. The
MIPEX measures policies to integrate migrants in 56 countries across six continents (Solano
& Huddleston, 2020).
Naturalisation policies have been analysed according to several existing indices.
Naturalisation policies are the most frequently indexed areas of migration policy, according to
a recent review of existing indices (Solano & Huddleston, 2021a). Of the 67 indices analysed
by this review, 39 included indicators on naturalisation policies. However, these indices focus
mainly on Western European countries (EU15). Germany, France, the Netherlands, Sweden
and the UK are the ve most frequently analysed countries, while other European and non-
European Western countries have been analysed to a lesser extent.
There are of course exceptions. The most comprehensive and up-to-date set of indicators is
the Global Nationality Laws Database from the Global Citizenship Observatory (GLOBALCIT),
covering almost 200 countries (updated to 2020).4 These indicators cover the modes of
acquisition (i.e. ius sanguinis, ius soli, ordinary naturalisation and special naturalisation) and
loss (renunciation and involuntary loss) based on 45 indicators. These were developed in
the European regional context and then adapted and expanded globally by legal experts in
national citizenship. These indicators allow for the design of citizenship regimes based on the
respective purposes of these modes of citizenship acquisition and loss. Another exception is
the MACIMIDE Global Expatriate Dual Citizenship database,5 which covers policies on dual
citizenship in 200 countries since 1960.
In general, the most common indicators on naturalisation included in indices are tolerance
of dual nationality, the presence of birthright citizenship (ius soli), and the minimum residence
duration and language/civic integration requirements for ordinary naturalisation (Solano &
Huddleston, 2021b). Other recurring indicators are the level of entitlement vs. discretion for
ordinary naturalisation, the costs/economic resource requirements, the existence of other civic
integration measures and the provisions for specic groups, such as spouses of nationals and
beneciaries of international protection.
In what follows, after illustrating the MIPEX methodology, we present the main ndings of
the MIPEX 2020 edition concerning naturalisation policies. The contribution of this new edition
of MIPEX is to expand the analysis of naturalisation policies to the so-called Global South, by
* Migration Policy Group.
4 See: https://globalcit.eu/national-citizenship-laws/
5 See: https://macimide.maastrichtuniversity.nl/dual-cit-database/
European University Institute 11
Existing Indices on Naturalisation Policies: The Case of MIPEX
including additional non-European, non-Western countries, and linking naturalisation policies
to the other areas of integration (e.g. labour market, education, permanent residence and
health).
The Migrant Integration Policy Index: description, methodology and the access
to nationality strand
The Migrant Integration Policy Index (MIPEX) is a tool which measures policies to integrate
migrants in 56 countries across six continents, including all EU Member States (including the
UK), other European countries (Albania, Iceland, North Macedonia, Moldova, Norway, Serbia,
Switzerland, Russia, Turkey and Ukraine), Asian countries (China, India, Indonesia, Israel,
Japan, Jordan, Saudi Arabia, South Korea, United Arab Emirates), North American countries
(Canada, Mexico and US), South American countries (Argentina, Brazil, Chile), South Africa,
and Australia and New Zealand in Oceania (Solano & Huddleston, 2020).6
Policy indicators have been developed to create a multi-dimensional picture of migrants’
opportunities to participate in society. In the fth edition (MIPEX 2020), the research team
created a core set of indicators that have been updated for the period 2014-2019. The policy
areas of integration covered by the MIPEX are the following: Labour market mobility; Family
reunication; Education; Political participation; Permanent residence; Access to nationality;
Anti-discrimination; and Health.
Under the ‘Access to nationality’ policy area, the following seven indicators were included:
Residence conditions for ordinary naturalisation (number of years of residence); Citizenship for
immigrant children (birthright and socialisation); Naturalisation language level; Naturalisation
integration assessment; Economic resources; Criminal records; Dual Citizenship.
For each indicator, there is a set of options with associated values (from 0 to 100, e.g.,
0-50-100). The maximum of 100 is awarded when policies meet the highest standards for
equal treatment. For each of the eight policy areas, the indicator scores are averaged together
to give policy area scores per country which, averaged together one more time, lead to the
overall scores for each country.
Questionnaires, including indicators for the years 2014-2019, were completed by national
experts (at least one per country). MPG team checked the experts’ responses to guarantee
that they properly understood the questions and answered them in a consistent manner as in
other countries, and conducted a cross-time and cross-country consistency check.7
In what follows, we describe the main ndings of the MIPEX 2020 ‘Access to nationality’
strand.
Findings
Policies on access to nationality are halfway favourable for migrants in MIPEX countries. The
average MIPEX country scores 44/100 on access to nationality policies, slightly lower than the
average score for integration policies in general (49). However, of the eight policy areas, only
education and political participation score lower than naturalisation policies (see Figure 1). This
result reveals that nationality policies are generally weaker than integration policies in other
6 See also: www.mipex.eu
7 See here for additional information on the methodology: https://www.mipex.eu/methodology
12 Robert Schuman Centre for Advanced Studies
Giacomo Solano and Thomas Huddleston
areas of integration. For example, when compared with permanent residence policies (average
score: 58), naturalisation policies are less inclusive. This is reective of the fact that in several
countries being a permanent resident is a pre-requisite to being eligible for naturalisation.
Figure 1. MIPEX Policy areas
Source: mipex.eu
Naturalisation policies are a major area of weakness in many European and non-European
countries, especially Austria, Bulgaria, the Baltics, Eastern Europe, India, Saudi Arabia and the
UAE. (see Figure 2). 22 countries (out of 56) have rather unfavourable policies, with scores
of lower than 41/100. In these countries, migrants face more obstacles than opportunities for
naturalisation. By contrast, in 17 countries, naturalisation policies create more opportunities
than obstacles (MIPEX score >59).
European University Institute 13
Existing Indices on Naturalisation Policies: The Case of MIPEX
Figure 2. Countries’ scores on access to nationality policies
Source: mipex.eu
Furthermore, ordinary rst-generation migrants face a wait of maximum ve years for
naturalisation in half of the MIPEX countries (23/56). In 20 countries however, migrants are
only eligible after more than 10 years or the majority of ordinary residents cannot access
naturalisation.
The situation is less favourable for children educated or born to foreign parents in several
countries. Citizenship entitlements, which are often linked to specic requirements (related to
the parents’ status or to other requirements, e.g., age of majority), exist in half of the countries
for such children (27/56). Among these countries, unconditional and automatic birthright
citizenship for the second generation exists only in six countries: the North and South American
countries included in MIPEX. In the other half of the countries (29/56), children must undergo
a naturalisation procedure.
There are also multiple restrictive requirements in place: only 19/56 countries have zero or
only one restrictive requirement. Requirements are particularly strict when it comes to criminal
records in most countries (34/56). Applicants are ineligible if convicted of a crime, sentenced
to imprisonment for more than ve years, charged with other oences (e.g., misdemeanours
or minor oenses) or if they have pending criminal procedures.
Requirements are less restrictive when it comes to language and integration, as well as
income. Language requirements dier signicantly across countries. Ten countries require
only A1 prociency or carry out no assessment; 19 require A2 prociency and 27 require
B1 prociency or apply discretionary procedures. Immigrants do not face an integration
14 Robert Schuman Centre for Advanced Studies
Giacomo Solano and Thomas Huddleston
requirement in nearly half of the MIPEX countries (28/56). In the other half (28/56), they need
to attend a course (only in Belgium and Luxembourg) or they must pass a test as part of the
process. Proof of income or employment is required for citizenship in the (slight) majority of
countries (37/56). 14 countries require that applicants demonstrate a minimum income, while
the remaining 23 countries impose more demanding requirements.
Finally, dual nationality is fully embraced by a slight majority of countries (31 countries,
including most recently Brazil, Moldova, Norway and Turkey), while 13 other countries only
allow dual nationality based on exceptions.
Since 2014 nationality policies have not changed, on average. Between 2014 and 2019, the
MIPEX 56 average score on nationality policies remained the same. Immigrants’ access to
nationality has improved signicantly in Brazil and Luxembourg and, to lesser extent, in China,
Latvia, Moldova, Portugal, Spain, Switzerland and Turkey. For example, in Luxembourg, the
wait for rst-generation immigrants was lowered from seven to ve years and eorts to learn
Luxembourgish are now rewarded, while the right to citizenship was regained by spouses and
extended from the third- to the second-generation.
Some countries, however, introduced restrictive policies (4/56). Nationality policies have
become more restrictive in Argentina, Denmark, Greece and Italy. Immigrants in Greece, for
example, now have to wait twelve years before being eligible for naturalisation Despite this,
in 2015 Greece introduced more favourable conditions for Greek-born children of immigrants.
Conclusions
In this short paper we presented the main ndings of the MIPEX 2020, with a focus on
naturalisation policies. Most indices addressing naturalisation policies focus on EU and
Western countries (Solano & Huddleston, 2021a), while developing countries and emigration
policies have been largely neglected. This trend follows a general bias in the wider eld of
migration studies, as shown by recent comprehensive reviews of the eld (Levy, Pisarevskaya
& Scholten, 2020; Pisarevskaya, Levy, Scholten & Jansen, 2019). There are exceptions to this
trend. For example, GlobalCit and MIPEX have expanded their focus to the Global South.
These undertakings suggest that it is possible to ‘go beyond’ the European/Western countries.
The results presented in this paper also make it clear that Western European countries do not
systematically outperform other countries.
However, several challenges emerge in the eldwork and in the analysis of the emerging
trends. As underlined by Palop-García and Pedroza (2019), a rst challenge is posed by the
dierent, non-harmonised legal and policy systems. Therefore, researchers may nd it more
feasible and methodologically sound to conduct research in EU or Western countries. Applying
European/Western standards is possible, but results need to be contextualised and cautiously
interpreted. For example, some countries - such as China - emerge as having rather favourable
naturalisation policies, as they do not set any specic language or integration requirements, but
naturalisation is only accessible to a few, high-skilled or wealthy migrants. A second challenge
is found in the fact that studies on migration polices suer from the existence of a certain
degree of discrepancy between policies on paper and policies in practice. In other words,
inclusive policies can be badly implemented. Indexes expanding to the Global South might
suer in this respect even more, as developing countries have rather weak formal institutions.
Nevertheless, there is an overall need to expand analysis beyond Western countries, to
understand the migration and integration policy frameworks of non-Western countries.
European University Institute 15
Existing Indices on Naturalisation Policies: The Case of MIPEX
References
Czaika, M., & H. De Haas (2013). ‘The Eectiveness of Immigration Policies’. Population and
Development Review 39 (3): 487–508.
Helbling, M., & I. Michalowski (2017). ‘A New Agenda for Immigration and Citizenship Policy
Research’. Comparative Political Studies 50 (1): 3–13.
Helbling, M., & D. Kalkum, (2018). ‘Migration policy trends in OECD countries’. Journal of
European Public Policy 25 (12): 1779–1797.
Levy, N., Pisarevskaya, A. & P. Scholten (2020). ‘Between fragmentation and institutionalisation:
The rise of migration studies as a research eld’. Comparative Migration Studies 8 (24):
1–24.
Palop-García, P. & L. Pedroza (2019). ‘How Do We Move Migration Policy Datasets and Indices
Further? A Proposal to Address Persisting Lacunae and Major Research Imperatives’.
Newletter of the American Political Science Association’s Organized Section on Migration
and Citizenship 7 (1): 37–52.
Pisarevskaya, A., Levy, N. & Scholten, P. and J. Jansen (2019). ‘Mapping Migration Studies:
An Empirical Analysis of the Coming of Age of a Research Field’. Migration Studies 8 (3):
455–481.
Scipioni, M., & G. Urso, G. (2018). Migration policy indexes. Ispra: Joint Research Centre
(European Commission).
Solano G. & T. Huddleston (2020). Migrant Integration Policy Index. Barcelona/ Brussels:
CIDOB & MPG.
Solano, G. & T. Huddleston (2021a). ‘Beyond immigration: Moving from Western to Global
Indexes of Migration Policy’. Global Policy 12 (3): 327-337.
Solano G. & T. Huddleston (2021b). ‘Migration policy indicators’. In P. Scholten (ed.) Migration
Studies Textbook. Dordrecht: Springer.
Vink, M. P., & R. Bauböck, (2013). ‘Citizenship congurations: Analysing the multiple purposes
of citizenship regimes in Europe’. Comparative European Politics 11 (5): 621–648.
16 Robert Schuman Centre for Advanced Studies
Maarten Vink
Making Citizenship Regimes (More) Comparable Globally: Exploring
the New GLOBALCIT Citizenship Law Dataset
Maarten Vink*
In December 2021, the Global Citizenship Observatory (GLOBALCIT) published a new
GLOBALCIT Citizenship Law Dataset (Vink et al., 2021) that makes a further step towards
the systematic comparison of citizenship laws around the world. In this contribution, I
provide a brief introduction to the new Dataset (see Van der Baaren and Vink, 2022 for a
more elaborate introduction) and subsequently explore the possibilities of the new Dataset
for global comparison. In particular, I highlight the possibilities for global comparison that are
greatly facilitated by the new structure of the Dataset and allow a) big picture analyses of the
density of citizenship laws in terms of number of modes of acquisition and loss of citizenship;
b) analyses of cross-national variation in the regulation of specic modes; c) analyses based
on aggregation across modes based on specic types of conditions; and d) analyses that
aggregate various types of conditions across various modes into a policy index. I end with
some reections on further development of the Dataset and on a global comparative research
agenda of citizenship regimes.
1. A new GLOBALCIT Citizenship Law Dataset
Previously, the Global Databases on Modes of Acquisition and Loss of Citizenship (Vink
and Vonk, 2021 [2016]) provided users with qualitative information on relevant provisions in
citizenship legislation in 175 countries in 2016, categorised within a typology of so-called ‘modes’
that facilitated the comparison of rules applicable to the acquisition and loss of citizenship
by similar target groups across countries. For example, mode A01a covers legal provisions
applicable to the descent-based acquisition of citizenship by children born in the country of
the respective citizenship; mode A01b covered similar rules applicable to those born abroad;
etcetera. This comparative typology was initially developed in the context of fteen European
Union countries (Waldrauch, 2006) and subsequently ne-tuned and systematised to allow a
global comparison of citizenship laws (see Van der Baaren and Vink, 2022 for a discussion of
the application of the functional comparative method).
The new GLOBALCIT Citizenship Law Dataset provides an update and expansion of the
existing ‘modes’ databases on four fronts. First, the geographical coverage of the Dataset
has been expanded and now includes 190 independent states, including micro-states from
Polynesia that were previously not yet covered (see Dziedzic, 2020). Second, all information
has been updated and now covers the legal situation on January 1, 2020. Third, whereas
the previous version of the database on modes of acquisition of citizenship included only
summarised information for a single A06 mode on residence-based citizenship acquisition, the
new Dataset (following Jeers et al., 2017) provides specic data for selected requirements for
residence-based citizenship acquisition, in particular:
- residence requirement, in nominal years (A06a)
- dual citizenship acceptance (A06b)
- language conditions (A06c)
- civic knowledge or assimilation conditions (A06d)
* Robert Schuman Centre for Advanced Studies, European University Institute.
European University Institute 17
Making Citizenship Regimes (More) Comparable Globally
- criminal record conditions (A06e)
- economic resource conditions (A06f)
By splitting up mode A06, comparison of specic requirements for residence-based acquisition
is now systematised and enhanced. All in all, these changes imply that the new Dataset has
9310 country-mode entries, covering 34 acquisition modes and 15 loss modes in 190 countries
(see codebook, Vink et al., 2021b for complete overview of modes covered within this revised
comparative typology).
Fourth, and most important, in addition to qualitative summary descriptions of the relevant
legal provisions on the acquisition and loss of citizenship (incl. references to the relevant
article in the law), the new Dataset now also includes a coding scheme that identies the main
categorical distinctions between legal provisions across countries. We included two types of
coding: a) a binary code to indicate whether in case of the country concerned a particular ground
for the acquisition or loss of citizenship is present in the citizenship legislation (‘1’ if the mode
is applicable and ‘0’ if the mode is not applicable); and b) a categorical code that identies, if
the mode is in eect (coded 1 in the binary scheme), the type of conditions applicable for the
acquisition or loss of citizenship in the respective country. The number of categories varies by
mode, according to the standardised list of conditions that are detailed in the codebook (Vink
et al., 2021b). While binary coding enables users to see in which countries a particular mode
is either applicable or not, categorical coding enables users to identify dierences between
those countries where a particular mode of acquisition or loss of citizenship is applicable.
Hence, in contrast with the previously existing version of the online database, users are now
able to identify and analyse patterns in terms of groupings of countries, or focus on particular
distinctions between countries (e.g. singling out gender discrimination).
2. Data exploration
In this section, I highlight various ways in which the systematised data on modes of acquisition
and loss of citizenship from the new Dataset can be used for descriptive purposes.
Frequencies I: applicable number of modes of acquisition of citizenship by country/regime
An obvious rst possibility of the newly systematised data is to use the binary versions of the
variables (A01a_bin, for mode A01a; A01b_bin, for mode A01b; etcetera) for a ‘big picture’
description of the frequency of the number of applicable modes of acquisition of citizenship
across countries (for a similar focus on loss of citizenship, see Van der Baaren and Vink, 2022).
This is visualised in Figure 1, which shows that the median number of modes of acquisition
of citizenship applicable across the 190 countries included in the Dataset is 11, out of a total
of 28 acquisition modes.8 Yet, as is clear from the normal distribution visualised in Figure 1,
there is considerable variation, with one country (Uruguay) having only two birthright-based
acquisition modes in its citizenship law (A01b, A02a), whereas in Greece up to 24 out of a total
possible 28 acquisition modes are applicable. The top 5 countries with most applicable number
of acquisition modes are all European.
Only one acquisition mode (A01b, citizenship acquisition by a person who is born abroad
to a parent who is a citizen of that country) is applicable in all 190 countries. Other frequently
present acquisition modes are those for residence-based acquisition (A06), marriage-based
8 Here I focus only on the ‘main’ modes of acquisition, incl. A06 for residence-based acquisition and leave aside modes A06a-
A06f which specify the conditions for naturalisation, where A06 is applicable.
18 Robert Schuman Centre for Advanced Studies
Maarten Vink
naturalisation (A08), citizenship acquisition by a person born in the country to a parent who is
a citizen of that country (A01a) and reacquisition of citizenship (A16).
Figure 1. Number of modes of acquisition of citizenship per country
Source: GLOBALCIT Citizenship Law Dataset, v1.0
By using the iso3 identiers included in the Dataset, it is now also easy to merge GLOBALCIT
data with data from other sources, such as the Varieties of Democracy project (Coppedge et
al., 2021)9 and explore patterns of citizenship law regulation by, for example, regime type.
Figure 2 shows a density plot (i.e. the smoothed distribution) for the number of acquisition and
loss modes by country, by political regime. The main conclusion from this exploration is that,
on average, democracies have more applicable modes of acquisition of citizenship, but fewer
applicable modes of loss of citizenship.
9 For the 19 micro-states not covered by V-Dem, I have relied here on scores from Freedom House, scoring those free or partly
free countries with a Global Freedom score of higher than 55 as democratic. Source: https://freedomhouse.org/countries/
freedom-world/scores.
European University Institute 19
Making Citizenship Regimes (More) Comparable Globally
Figure 2. Number of modes of acquisition and loss of citizenship per country, by politi-
cal regime: density plot
Sources: GLOBALCIT Citizenship Law Dataset, v1.0 | VDEM, Freedom House
Frequencies II: conditions by mode
Besides the number of modes, the new Dataset also facilitates identifying the relevant type
of conditions for the acquisition or loss of citizenship, where respective modes are applicable.
These frequencies of relevant conditions can be explored by individual acquisition or loss
modes, or – in those cases where the relevant categories are comparable (see Codebook,
Vink et al., 2021b) – explored between multiple modes. Figure 3 visualises the distribution of
applicable conditions for the descent-based acquisition of citizenship by persons born in the
country (A01a, left-hand plot) or abroad (A01b, right-hand plot).
The distribution of relevant conditions for descent-based acquisition of citizenship visualised
in Figure 3 shows that in most countries a father or mother who is a citizen suces to acquire
the citizenship of that country: ius sanguinis is generally applicable in 65% of countries if
the child is born in the country, and in 54% of countries in case the child is born abroad
(cf. Honohan and Rougier, 2018, Figure 1 for a broadly comparable picture, but with some
dierences due to other coding methodology). Besides gender or wedlock restrictions, or
group-based discrimination, countries also apply dual citizenship restrictions or what is termed
in the Dataset as a generational transmission restriction, where the acquisition of citizenship is
dependent on the birthplace or place of residence of the child or parent.
20 Robert Schuman Centre for Advanced Studies
Maarten Vink
Figure 3. Birthright citizenship by descent: type of provisions around the world
Source: GLOBALCIT Citizenship Law Dataset, v1.0
Figure 4 visualises the distribution of the nominal years of residence required for residence-
based acquisition of citizenship, based on a new variable A06a_yrs included in the Dataset that
records the precise number listed in the citizenship legislation. As mentioned in the Codebook
(Vink et al., 2021b: 25), additional conditions related to residence are not coded, even if these
can signicantly impact the scope of the residence condition. Hence the information provided
by this variable should be interpreted with care, i.e. as representing variation in the nominal
years listed in the law, not as eective residence requirement. With this caveat, we nd that
the most frequent nominal residence-requirement is ve years (in 77 countries) and that most
countries (161) have a residence requirement of maximum ten years. Fourteen countries have
a higher residence requirement, up to thirty years in the United Arab Emirates or even forty
years in Equatorial Guinea. In fteen countries, no residence-based acquisition provision could
be identied.10
10 Provisions restricted to a specic group of persons based on existing citizenship, race, religion, language or ethnic charac-
teristics, are coded under A18 (citizens of specic countries) or A19 (cultural anity-based acquisition). Residence-based
acquisition (A06) also excludes acquisition based on marriage (A08/A13), or provisions for acquisition by refugees (A22) or
stateless persons (A23). Provisions based on special achievements or nancial assets or investments are coded under A24
or A26.
European University Institute 21
Making Citizenship Regimes (More) Comparable Globally
Figure 4. Residence-based acquisition of citizenship: years of residence in country
required*
*refers to nominal number of years listed in citizenship legislation; eective residence
requirement may vary in practice
Source: GLOBALCIT Citizenship Law Dataset, v1.0
Aggregation I: combining modes of acquisition/loss into categorical variables
The new categorical coding scheme implemented in the Dataset facilitates also descriptive
analysis beyond individual modes of acquisition, by generating new categorical variables
combining associated modes. I present two examples here.
Figure 5 visualises the distribution of countries for a territorial birth-based acquisition
of citizenship variable, combining information from modes A02a (ius soli for the ‘second
generation’) and A02b (ius soli for the ‘third generation’, sometimes termed ‘double ius soli’).
For simplicity’s sake, I leave aside additional related variables, such as those for foundlings
(A03a), children who would otherwise be stateless (A03b) or those who are born on territory
and can acquire citizenship at a later age (A05). With that caveat, we see that unconditional
ius soli, such as mostly present in the Americas, may be exceptional, but is still present in up
to 19% of countries globally. Moreover, a form of conditional ius soli is present in another 18%
of countries, where children born on the territory only acquire the citizenship of that country,
irrespective of the parental citizenship, if a parent is born her/himself on the territory or fulls a
certain residence requirement. In thirteen countries, gender or group restrictions apply.
22 Robert Schuman Centre for Advanced Studies
Maarten Vink
Figure 5. Citizenship by birth in country
Source: GLOBALCIT Citizenship Law Dataset, v1.0, variables: A02a_cat, A02b_cat. Excluding provisions
aimed at protecting against statelessness and those that only grant citizenship later in life.
In Figure 6, the distribution of countries is visualised based on a combination of one ‘acquisition’
and one ‘loss’ mode, which jointly reect a country’s broad approach to dual citizenship
acceptance at naturalisation. Whereas mode A06b records whether a country requires
applicants for naturalisation to renounce their previous citizenship (dual citizenship acceptance
for ‘incoming’ naturalisations), mode L05 records whether a citizen loses her or his citizenship
if she/he voluntarily acquires another citizenship (dual citizenship acceptance for ‘outgoing’
naturalisations). In 2020, half of all countries around the world fully accept dual citizenship,
whereas only 22% of countries consistently restrict dual citizenship at naturalisation. Almost a
third of countries only accept dual citizenship for immigrants (12%, incoming naturalisation) or
for emigrants (17%, outgoing naturalisations).
European University Institute 23
Making Citizenship Regimes (More) Comparable Globally
Figure 6. Dual citizenship acceptance for immigrants and emigrants
Source: GLOBALCIT Citizenship Law Dataset, v1.0, variable: dualcit_comb. Immigrant dual citizenship
acceptance if residence-based naturalisation and no eective renunciation requirement (A06b); Emigrant
dual citizenship acceptance if native citizens can naturalise abroad without losing citizenship (L05).
Aggregation II: combining modes of acquisition/loss into count or continuous variables
Finally, the categorical coding scheme implemented in the Dataset can be employed to
generate count or continuous variables combining scores on associated modes. I present two
examples here.
First, I give an example of a discrete variable that counts the number of provisions on
acquisition or loss of citizenship that can be considered at odds with what I would see as
generally accepted standards on non-discrimination and individual choice. In particular, I count
the presence of provisions that make arbitrary distinctions based on gender or belonging to a
particular group (e.g. ethnicity, race or religion); the absence of residence-based acquisition
within fteen years11; and the possibility to voluntarily renounce one’s citizenship. The point
here is not about what precisely makes up ‘liberal’ or ‘illiberal’ norms in citizenship law (see
e.g. De Groot and Vonk, 2016, esp. pp. 3-82 for an introduction to international standards on
nationality law; on gender discrimination, see eg Stratton, 1992) and I do not pretend that this
list of criteria is either exhaustive or uncontroversial. What matters here is to illustrate how the
categorical coding scheme of the data on modes of acquisition and loss of citizenship facilitates
descriptive or explanatory analyses of cross-national variation in adherence to international
standards on non-discrimination and minimal individual choice in citizenship law, in the sense
of Article 15(2) of the Universal Declaration of Human Rights, which proclaims that no one can
be ‘denied the right to change his nationality’.
Figure 7 visualises a count of the presence of such ‘illiberal’ provisions in ten selected
modes of acquisition or loss of citizenship, focusing on birthright-based citizenship acquisition,
residence-based naturalisation, marriage-based naturalisation and voluntary renunciation (see
list of respective modes at bottom of the plot). Users of the Dataset can generate variations
of this plot, selecting dierent modes of acquisition/loss or focusing on dierent types of
11 I purposively use a long time period here, in order to distinguish between those countries where naturalisation, generally
speaking, is accessible within some foreseeable time frame, and those countries where that is not the case, i.e. singling out
the 23 countries identied in Figure 4 where naturalisation is not possible within 15 years.
24 Robert Schuman Centre for Advanced Studies
Maarten Vink
categorical distinctions covered by the Dataset (see Codebook for details). Within this selection
of modes and conditions, in one-third of 190 countries (35%) at least one or more provisions
in the citizenship law include arbitrary discrimination or do not provide for individual choice.
In countries such as Brunei, Liberia and Sierra Leone, up to 6 modes with illiberal provisions
in citizenship law are counted (see e.g. Khan, 2021, for the GLOBALCIT country report on
citizenship law in Sierra Leone).
Figure 7. Illiberal provisions* in selected modes of acquisition or loss of citizenship
*Arbitrary discrimination based on gender or group restrictions; no residence-based acquisition
within 15 years; no/restricted voluntary renunciation (10 selected modes)
Source: GLOBALCIT Citizenship Law Dataset, v1.0, variables: A01a, A01b, A02a, A02b, A03a, A05, A06,
A06a, A08, L01
Second, the new Dataset allows combining modes of acquisition/loss into continuous variables,
for example for the purpose of developing policy indices on the inclusiveness of citizenship
law for immigrants and their descendants (see Schmid, this volume; for discussions of policy
indices on immigration and integration policy, eg Bjerre et al., 2015; Goodman, 2019). Here
I illustrate how Samuel Schmid’s Citizenship Regime Inclusiveness Index (CITRIX) can be
extended geographically beyond the 23 OECD countries used in Schmid (2021), by applying
his aggregation formula12 to the information from the global Dataset. To limit the risk of violating
the validity of the respective indicators as functional equivalents across a wide variety of
contexts (e.g. where rule of law is not guaranteed, or where there are large segments of the
population without formal legal identity), I restrict my analysis to a set of 68 countries a) with
democratic regimes (either electoral or liberal democracy); b) where birth registration rates are
higher than 90%; and c) residence-based naturalisation is available within max. 15 years of
taking up residence.
12 CITRIX Global = (2*jussoli2 + jussoli3)/3 + residur + dualcit + (langtest + cittest + ecoreq + crimreq)/4)/4. The equivalent
indicators used in the analysis are, respectively: A02a_cat, A02b_cat, A06a_yrs, A06b_cat, A06c_cat, A06d_cat, A06f_cat,
A06e_cat. Replication code available here.
European University Institute 25
Making Citizenship Regimes (More) Comparable Globally
I assess the validity of the CITRIX Global measure by analysing its correlation with Schmid’s
CITRIX (v2) score, for those 23 countries that are covered by both datasets (see Figure 8, left-
hand plot). Overall, there is a very strong correlation and signicant between both measures (r
= .88, p < 0.001). I also look at the correlation with another comparable measure, the scores
from the ‘Access to Nationality’ strand of the Migrant Integration Policy Index (MIPEX) (Solano
and Huddleston, 2020), which has 44 cases in common with CITRIX Global, and nd a slightly
weaker, but still high and signicant correlation (Figure 8, right-hand plot, r = .81, p < 0.001).
These ndings, based on a rst exploratory cut of the new GLOBALCIT data, suggest that
these data can be used as a basis for index construction a la CITRIX or MIPEX, and oer the
potential to substantially enlarge the geographical scope of those measures.
Figure 8. Correlation CITRIX Global, Citrix v2 and MIPEX Access to Nationality
Source: GLOBALCIT Citizenship Law Dataset, Schmid 2021, MIPEX (2020)
Subsequently, Figure 9 plots the CITRIX Global scores for the 68 selected countries. Scores
range from 92 for Argentina, representing the country with the most inclusive citizenship law
for immigrants and their descendants, to Liechtenstein with a score 4, representing the lease
inclusive country. As is clear from the CITRIX aggregation formula, ius soli weighs heavily
(25%) in the CITRIX Global score and hence, unsurprisingly, countries from the Americas
dominate the top of the list. The highest-ranked European country is Portugal with a CITRIX
Global score of 77, reecting conditional ius soli for the 2nd generation and automatic access
to citizenship for the third generation, plus an overall highly accessible residence-based
naturalisation procedure. In addition to the weight of ius soli, due to normalisation of the
variable that counts the years of residence required for naturalisation (based on A06a_yrs)
and a number of countries in the Americas requiring only 3 or 4 years of residence, even a
country such as Sweden that is one of the countries with the most inclusive citizenship laws
in the European contexts (with a residence-requirement of 5 years for naturalisation), falls
back to the middle of the pack in global perspective. Again, these CITRIX Global score are not
presented here as a denite pitch on how best to measure accessibility of citizenship laws for
immigrants and their descendants from a global perspective, but rather to illustrate how the
new GLOBALCIT data lend themselves for exercises that aim to explore how combined scores
on various indicators of the accessibility of citizenship can be represented in policy indices.
26 Robert Schuman Centre for Advanced Studies
Maarten Vink
Figure 9. CITRIX Global
Source: GLOBALCIT Citizenship Law Dataset, v1, calculation based on aggregation formula from Schmid
(2021), N = 68, 2020
3. Where to go from here?
In my contribution to the discussion in this Working Paper I aimed to highlight how the
possibilities for global comparison are greatly facilitated by the new structure of the GLOBALCIT
Citizenship Law Dataset. I provided various examples of how the newly structured data on
modes of acquisition and loss of citizenship lend itself more easily for descriptive analyses,
albeit ‘big picture’ analyses of the density of citizenship laws in terms of number of modes of
acquisition and loss of citizenship or analyses of cross-national variation in the regulation of
specic modes. I also highlighted ways in which the data can now be used to aggregate scores
across modes based on specic types of conditions to aggregate types of conditions across
various modes into a count variable or a policy index.
European University Institute 27
Making Citizenship Regimes (More) Comparable Globally
Where to go from here? First of all, I would emphasise that the current Dataset is explicitly
seen as a version 1.00, i.e. a Dataset that we aim to continuously update in order to provide
up-to-date information on citizenship laws. A next update is foreseen for 2023, where we
update the data to the situation on 1 January 2022. Second, apart from updating, we also
plan -and have started- to back-code the data, in order to provide longitudinal information on
citizenship law development. We will initially do so for selected indicators, eg on birthright or
dual citizenship (expanding e.g. the data from Vink et al., 2015 to cover not just automatic loss
provisions, but also data on renunciation requirements for residence-based naturalisation).
From there, the ambition is to gradually expand the longitudinal coverage to all relevant modes
of acquisition and loss of citizenship. Third, I hope that providing more user-friendly data on
citizenship law in a transparent and accessible manner will enhance the research agenda on
comparing citizenship regimes (cf. Vink, 2017). I look forward to all those new studies using
these data for descriptive purposes, eg on how existing citizenship regime typologies can be
extended globally (cf. Vink and Bauböck, 2013) or for explanatory purposes on e.g. the political,
demographic or economic determinants and implications of citizenship regime variation.
28 Robert Schuman Centre for Advanced Studies
Maarten Vink
References
Bjerre, L., Helbling, M., Römer, F., & Zobel, M. (2015). ‘Conceptualizing and measuring
immigration policies: A comparative perspective’. International Migration Review, 49(3):
555-600.
Coppedge, M., J. Gerring, C. H. Knutsen, et al. (2021). V-Dem [Country–Year/Country–Date]
Dataset v11.1. Varieties of Democracy Project. Available at: https://doi.org/10.23696/
vdemds21
De Groot, G.R. and Vonk, O.W. (2016). International standards on nationality law: texts, cases
and materials. Wolf Legal Publishers.
Dziedzic, A. (2020). Comparative regional report on citizenship law: Oceania. Global Citizenship
Observatory, Comparative Reports, 2020/01. Available at: http://hdl.handle.net/1814/66229
Jeers, K., Honohan, I., and Bauböck, R. (2017). How to measure the purposes of citizenship
laws: explanatory report for the CITLAW indicators, Version 3.0. Global Citizenship
Observatory. Available at: https://globalcit.eu/wp-content/uploads/2018/02/CITLAW_3.0.pdf
Goodman, S. W. (2019). ‘Indexing immigration and integration policy: Lessons from
Europe’. Policy Studies Journal, 47(3): 572-604.
Honohan, I., and Rougier, N. (2018). ‘Global birthright citizenship laws: how inclusive?’ Netherlands
International Law Review, 65(3): 337-357.
Khan, A. W. (2021). Report on citizenship law: Sierra Leone. Global Citizenship Observatory.
Available at: https://hdl.handle.net/1814/71023
Schmid, S. D. (2021). ‘Stagnated Liberalization, Long‐term Convergence, and Index
Methodology: Three Lessons from the CITRIX Citizenship Policy Dataset’. Global
Policy, 12(3), 338-349.
Schmid, S. D. (2020). ‘The architecture of national boundary regimes: mapping immigration and
citizenship policies in 23 democracies 1980–2010’. Comparative migration studies, 8(1):
1-20.
Solano, G., and Huddleston, T. (2020). Migrant integration policy index. Migration Policy Group.
Stratton, L. C. (1992). ‘The Right to Have Rights: Gender Discrimination in Nationality
Laws’. Minn. L. Rev., 77: 195-239.
Van der Baaren, L. and Vink, M. (2022). Modes of acquisition and loss of citizenship around
the world: Comparative typology and main patterns in 2020. GLOBALCIT Working Paper.
Available at: https://hdl.handle.net/1814/73267
Vink, M., L. van der Baaren, R. Bauböck, I. Honohan and B. Manby (2021a). GLOBALCIT
Citizenship Law Dataset, v1.0. Global Citizenship Observatory. Available at: https://hdl.
handle.net/1814/73190.
Vink, M., L. van der Baaren, R. Bauböck, I. Honohan and B. Manby (2021b). GLOBALCIT
Citizenship Law Dataset, v1.0, Codebook. Global Citizenship Observatory. Available at:
https://hdl.handle.net/1814/73190.
European University Institute 29
Making Citizenship Regimes (More) Comparable Globally
Vink, M.; De Groot, G.-R.; Luk, N.C. (2015). MACIMIDE Global Expatriate Dual Citizenship
Dataset. Harvard Dataverse, V5. Available at: https://doi.org/10.7910/DVN/TTMZ08
Vink, M. and Vonk, O. (2021), Global Databases on Modes of Acquisition and Loss of
Citizenship (2013-2016 data). Global Citizenship Observatory. Available at: https://hdl.
handle.net/1814/72998.
Vink, M. (2017). ‘Comparing Citizenship Regimes’. In: Shachar, A., R. Bauböck, I. Bloemraad
and M. Vink (Eds.), 221-244. Oxford Handbook of Citizenship. Oxford University Press.
Vink, M.P. & R. Bauböck (2013). ‘Citizenship Congurations: Analysing the Multiple Purposes
of Citizenship Regimes in Europe’. Comparative European Politics, 11(5): 621-648.
Waldrauch, H. (2006). ‘Methodology for comparing acquisition and loss of nationality’. In
Waldrauch H., Bauböck R., Ersbøll E., and Groenendijk K. (Eds.), Acquisition and Loss
of Nationality, Volume 1: Comparative Analyses: Policies and Trends in 15 European
Countries, 105-120. Amsterdam University Press.
30 Robert Schuman Centre for Advanced Studies
Samuel D. Schmid
Towards a Valid Global Citizenship Policy Index: Three Existing
Approaches and a New Hybrid Approach
Samuel D. Schmid*
In this contribution, I sketch the contours of a new hybrid approach to measure citizenship
laws across the globe. I start by discussing the issue of validity and the related problem of
cross-national equivalence when developing indicators that capture legal realities, that is,
laws on the books. I then present three existing approaches to index building as applied to
citizenship policies: the “classical xed indicators approach” using three-level concepts, the
“policy change approach”, and the “exible single indicator approach.” My hope is that the new
hybrid approach maximizes the advantages of each existing approach, while minimizing their
disadvantages. It may help us pave the way for a valid global citizenship policy index.
To move towards such a valid global index, I think we need to go back to the basics of
measurement validity. The seminal piece by Adcock and Collier (2001) is useful here.
They argue that to construct valid concepts and measures, we should move from concept
specication and operationalization to concrete data and back in an iterative way. This is
especially true for global indices, as new cases and available data might create the need to
adjust concepts and operationalizations. We must be aware further that the notion of validity is
bound to specic cases and settings, and that a global approach needs to be sensitive to these
contexts. We should be on the lookout especially for functional equivalents as we search for
varying instances of concepts across space and time.
The “classical xed indicators approach” to citizenship policy measurement is not sensitive
to context. Figure 1 shows the concept tree of the Citizenship Regime Inclusiveness Index
(CITRIX; Schmid, 2021). It aims to capture the inclusiveness of the access to citizenship for
immigrants and their children. This approach uses a three-level approach to concept formation
(Goertz, 2006; 2020). On the basic level there is the overarching concept or policy idea. Here
the aim is to have a systematic idea of what it is we are measuring. On the second level
there are the constitutive components or dimensions of the concept. Here, the aim is to cover
all relevant aspects and to nd a balance between minimalism and maximalism (Munck and
Verkuilen, 2002). Based on the literature and other indices, CITRIX does so by covering
conditions regarding birthright, residence, renunciation, and integration. It therefore focuses
on the ordinary naturalization of ordinary immigrants and their children. Only on the third level
do we nd the indicators that operationalize the components. Note that classical statistical
approaches usually drop the second level and often apply some form of latent variable modeling
to all individual indicators to create an aggregate measure. I omit the issue of aggregation in
this contribution (for details see Schmid, 2021).
* University of Lucerne.
European University Institute 31
Towards a Valid Global Citizenship Policy Index
Figure 1. The concept tree of the Citizenship Regime Inclusiveness Index (CITRIX)
Source: Schmid (2021)
This classical approach has the advantage that it operates with indicators that capture specic
aspects and therefore each indicator can be directly compared across space and time. This
may seem obvious – but as we will see, this classical approach is not the only game in town.
In addition, there is direct information about both relative and absolute levels of inclusiveness.
And there is indirect information about policy changes and their magnitude.
The disadvantage of this classical approach is that we super-impose a concept across
potentially diverse contexts. Thich is why internal validity in terms of dimensionality is so
important (Schmid, 2021). Conceptual dimensions must be shown to exist also empirically in
statistical terms, so that the theoretical super-imposition is valid. Another disadvantage of the
classical approach is that, by dening xed indicators and content, it assumes homogeneity or
equivalence across space and time. This may be the main problem that this approach faces
for “going global.”
The second existing approach focuses on “policy changes” as the unit of analysis. In the
eld of migration and citizenship, this approach has been championed by the DEMIG database
(de Haas et al., 2015). This approach allows us to consider any change. We can assess the
direction of change in terms of restrictiveness, and we can code the magnitude of change
with an ordinal scheme. This allows for a high applicability across space and time. But for this
we of course still need a concept that tells us when we see what we are looking for. Another
challenge is how to dene and code the magnitude of changes, which poses potential issues
for validity and reliability. The disadvantage is that here we have no information about relative
or absolute levels of restrictiveness. Also, if we do not code content, for instance if a change
is about residence or about integration conditions, we cannot compare more specic changes
across space and time.
The third approach is what I call the “exible single indicator approach.” This has been
applied by Peters (2017) to build indicators for a broader immigration policy index. Figure 2
32 Robert Schuman Centre for Advanced Studies
Samuel D. Schmid
shows the single composite scale for citizenship policy. Lower values stand for a more dicult
naturalization process. The maximum value stands for an easy process. These levels mix
various aspects, for instance language testing, residence, and they also incorporate jus soli.
The aim is to translate policy congurations directly into a composite quasi-numeric score. This
approach allows us to consider any change and assess the direction and magnitude of change.
We also have information about absolute and relative levels, and it is more applicable across
contexts because it allows for cross-national equivalence of similar policy congurations.
Figure 2. A exible single indicator for citizenship laws
Source: Peters (2017)
This is where the new hybrid approach comes in. It applies a three-level concept structure
with xed components on the second level and exible indicators on the third level (see Figure
3). When going global, we should rst reconsider the basic concept that we are measuring.
Inclusiveness can be seen as a normative notion based on liberal democratic theory. This
concept does not necessarily suggest that more inclusion is more democratic, which is an
even more normative adjective. Yet, it is still anchored in Western thought. For the moment,
let’s simply say we apply the notion of inclusion in the sense that more inclusion means less
restrictive citizenship laws.
European University Institute 33
Towards a Valid Global Citizenship Policy Index
Figure 3. The new hybrid approach
Source: Original illustration.
On the second level of the concept, then, we can follow the “classical approach” and clearly
identify the relevant constitutive policy components. This level therefore follows the classic
approach to identify in advance our potential suspects. It is therefore less open-ended than
a single exible indicator for all dimensions. Instead, each of these components can then
be used as a exible single indicator to be operationalized further on the third level. On this
third level we can dene categories that are more generic and exible than in the classical
approach, following instead the approach by Peters (2017). This may allow us to identify
potential functional equivalents such as informal rules, and other context-dependent or more
contingent dierences, but only as they apply to pre-dened policy components. With the
generic coding scheme for each policy component, we can consider any relevant change,
we can assess direction and magnitude of changes, and we have information about levels.
DEMIG, a database that records changes also in access to citizenship, could be used as a
starting point both in terms of data and measurement of magnitude of changes (de Haas et
al., 2015).
As the concluding Table 1 shows, this hybrid approach holds the promise of combining all
advantageous features of existing policy index approaches. Of course, however, it cannot do
away with the fundamental challenges of index building: conceptualization, measurement, and
aggregation (Munck and Verkuilen, 2002). Particularly, it cannot evade the special and hard
challenges involved in the exible indicator approach, namely the determination of starting
points and the assignment of valid numerical values for each policy change. Also, the hybrid
approach I outlined serves the purpose of comparing policy components and index values in
terms of ordinal or quasi-numeric levels across space and time.
34 Robert Schuman Centre for Advanced Studies
Samuel D. Schmid
Table 1. Summary of advantageous features of index building approaches
Classical Policy change Flexible Hybrid
Three-level
concept X X
Captures levels X X X
Captures
changes X X X X
Context-
sensitivity XXX
If the goal is to provide a global toolbox, then this hybrid approach is already one step further
than the groundwork of identifying relevant policy components, nominal variation, and policy
changes in the rst place. The new GLOBALCIT approach presented by Vink (this collection)
has laid some of this groundwork already. As the global version of CITRIX based on GLOBALCIT
data shows (Vink, this collection), the classical approach has the potential to reach wide. But
a hybrid approach may still be needed to accommodate more cases, especially as we go
longitudinal. Whether it can successfully translate cross-systemic variation into valid scores
on a single scale still needs to be tested. To do so, we will need to apply Adcock and Collier’s
(2001) strategy of moving from concept specication and operationalization to concrete data
and back in an iterative way until we have a workable index.
European University Institute 35
Towards a Valid Global Citizenship Policy Index
References
Adcock, R. & D. Collier (2001). ‘Measurement Validity: A Shared Standard for Qualitative and
Quantitative Research’, American Political Science Review, 95:3, 529–46.
Goertz, G. (2006). Social Science Concepts. A User’s Guide. New Jersey: Princeton University
Press.
Goertz, G. (2020). Social science concepts and measurement. Princeton: Princeton University
Press.
De Haas, H., K. Natter & S. Vezzoli (2015). ‘Conceptualizing and measuring migration policy
change’, Comparative migration studies, 3:1, 15.
Munck, G. L. & J. Verkuilen (2002). ‘Conceptualizing and Measuring Democracy’, Comparative
Political Studies, 35:1, 5–34.
Peters, M. E. (2017). Trading barriers. Immigration and the remaking of globalization. Princeton:
Princeton University Press.
Schmid, S. D. (2021). ‘Stagnated Liberalization, Long‐term Convergence, and Index
Methodology: Three Lessons from the CITRIX Citizenship Policy Dataset’, Global Policy,
12:3, 338–49.
36 Robert Schuman Centre for Advanced Studies
Rainer Bauböck
Global Comparison of Citizenship Laws: Promises and Pitfalls
Rainer Bauböck*
Imagine there were a reliable dataset comparing rules for acquisition and loss of citizenship in all
countries around the world since the 1960s. It would involve a big eort to build it. GLOBALCIT
is currently trying to do so by expanding its existing datasets on rules of acquisition and loss
of citizenship in space and time and coding them freshly. Is this worth doing? What limitations
need to be kept in mind and which pitfalls should be avoided when working with such data?
1. Promises: Why should we compare citizenship laws across countries and
time?
The most basic reason why we need global comparison is that citizenship laws do not just
determine who enjoys what kind of rights within a particular state. If citizenship were a purely
internal status regulated by domestic law, it might still be interesting to compare what rights
dierent countries attach to it and how they regulate access to it, but the status could also
mean very dierent things in each country and explaining the laws governing it would require
examining only domestic constitutional traditions and politics rather than also international
legal and political dynamics.
However, by turning people into citizens, or excluding them from citizenship, states shape
the status and opportunities of individuals in the international state system. Their citizenship
determines which states have to readmit them or grant them diplomatic protection and
consular assistance when they are abroad. More fundamentally, from a global perspective,
citizenship is a ling system attributing individuals to states (Brubaker, 1989) and determining
state responsibilities towards these persons vis-à-vis other states. Although it is a core element
of state sovereignty that they can determine their citizens under their own national laws, there
is thus also a growing body of international legal norms that aim to constrain state discretion in
this respect, e.g. by committing states to avoid generating statelessness.
A second and related reason is that citizenship laws do not operate in isolation from each
other but interact in important ways. The research eld of citizenship and immigration in the
social sciences as well as in normative political theory has been nearly exclusively preoccupied
with the rights of immigrants in receiving states of the global North and their access to formal
citizenship status. What this literature has largely ignored is that the foreign denizens of
these countries are at the same time nationals of their countries of origin. Their rights and
opportunities are thus co-determined by the laws of two states rather than one. This conclusion
is even more obvious for dual citizenship, a status that comes about only through an interplay
of rules for acquisition and loss of citizenship determined independently by two states.
Citizenship laws interact with each other not merely in determining the positions of individuals
with links to several states but do so also at the macro level of policy making when the laws
in one state are inuenced by those adopted in another one. A longitudinal comparison of
citizenship rules can reveal patterns of diusion with policies originating in a specic national
context becoming a model for lawmakers elsewhere. This is how ius sanguinis spread
throughout continental Europe after 1800 through the Code Napoléon (Weil, 2001) and how
ius soli became dominant in the Americas through the separate sources of English common
* Robert Schuman Centre for Advanced Studies, European University Institute..
European University Institute 37
Global Comparison of Citizenship Laws: Promises and Pitfalls
law and the 1812 Spanish constitution of Cádiz (Acosta, 2018). At independence, most former
African colonies initially adopted the birthright rules of their European colonizers (Manby, 2018).
More recently, a “civic turn” in immigrant integration policies pioneered by the Netherlands in
the early 2000s in reaction to fears about Islamist terrorism and “parallel societies” of Muslim
immigrants triggered the introduction of language, civic knowledge and value tests in many
Western European states (Goodman, 2014).
A second pattern of interactive law-making occurs when states do not imitate other countries’
laws but put up resistance against them. When Turkey started accepting dual citizenship for
its nationals in the 1990s, this move hardened attitudes against toleration of dual citizenship
for third country nationals in the Netherlands, Germany and Austria. When Hungary oered
dual citizenship to its co-ethnic “diaspora” in neighbouring countries in 2010, Slovakia reacted
with a law that turned voluntary acquisition of a foreign nationality into a reason for automatic
deprivation of the Slovak one (Bauböck, 2010a). Russia’s handing out of passports in Abkhazia,
South Ossetia, Transnistria and Eastern Ukraine has similarly chilled attitudes towards dual
citizenship in Georgia, Ukraine and the Baltic states.
In short, we need international comparison across countries and time in order to analyse
citizenship constellations (Bauböck, 2010b) that generate the statuses and rights of individuals
with cross-border ties as well as to grasp the macro-level dynamics of norm-setting in international
law, of policy diusion across states linked by a shared history or geographical proximity, and
of reactive law-making through which states aim to shield their citizenship regimes against
policies adopted by other states. Often, such research will require contextual comparative
analyses of small numbers of states. However, for analysing changing state practices and
norms in the international system (e.g. with regard to gender equality, statelessness and
multiple citizenship) we will need standardised global datasets.
2. Pitfalls: Perspectival and methodological biases in the comparison of
citizenship laws
On the one hand, every comparison in the social sciences involves a loss of detail and contextual
knowledge that some scholars will regard as essential for the purpose of interpretation. On the
other hand, systematic comparison that controls for similarities and dissimilarities and selects
cases and indicators well promises to contribute to explanatory theories. The divide between
qualitative small-N research aiming at interpretation and quantitative large-N research aiming
at explanation is also present in the eld of citizenship studies. Occasionally, the two sides
have engaged in methodology skirmishes, which all too often degenerate into turf wars over
the control of academic departments and associations. More often, they have just ignored each
other, robbing themselves thereby of critical feedback on their respective limits and biases.
I want to reect here briey on ve traps and biases that loom in the international comparison
of citizenship regimes. In my view, none of these critiques justies abandoning the endeavour
to build global datasets and engage in large-N comparisons, since each of these pitfalls can
be avoided when one remains alert and looks out for them.
The rst of these is known as “methodological nationalism” (Wimmer & Glick Schiller, 2002).
It consists in regarding citizenship laws only from the internal perspective of nation-states,
which are thereby treated as closed containers. As I have already explained above, this entails
a decient understanding of the operation and dynamics of citizenship in the international
state system. Because acquisition and loss of citizenship is regulated by national laws, we
need to start from collecting, interpreting and coding these laws so that we can compare
38 Robert Schuman Centre for Advanced Studies
Rainer Bauböck
them systematically. The trap of methodological nationalism does not lie in doing so, but in
interpreting the results in a manner that ignores how national citizenship laws respond to
international migration, to border disputes with neighbouring states, to policy innovations
introduced in other states or to normative developments in international law.
The second and closely related trap is that of “holism” in studying citizenship regimes. It
consists in an implicit assumption that the rules for acquisition and loss of citizenship status
hang together to form a coherent whole that can be understood as a “national model”. The
task of comparative analysis is to work out the dierences between such national models
and to explain their genealogy, which is mostly associated with a history of nation-building
and is assumed to persist over time through institutional path-dependency. Rogers Brubaker’s
comparison of France and Germany (1992) pioneered the national model approach in
citizenship studies, which has been widely criticised in recent decades (Joppke, 2007; Bertossi
& Duyvendak, 2012). Holistic assumptions can also be reproduced subconsciously in large-N
comparisons based on standardised indicators through methodological premises guiding their
selection and aggregation. For example, the access to nationality strand of MIPEX (Huddleston
& Solano, 2020) selects a number of indicators that all measure the inclusiveness of national
citizenship laws for ordinary immigrants and aggregates these into a single country score.
This is perfectly legitimate as long as users remain aware of what has to be left out in order to
enable such country rankings. For example, preferential access to citizenship for spouses of
citizens, for co-ethnic immigrants or extraterritorial “diasporas” remain excluded, even if these
are the main pathways to citizenship in many countries. If we want to understand instead the
shape of citizenship regimes, understood as the ensemble of rules for acquisition and loss of
nationality, then we need a much more comprehensive typology of all modes of acquisition and
loss that are recurrently used around the globe. When then analyzing patterns and trends in
the evolution of these citizenship regimes across countries we have to abandon the idea that
they are driven by a single purpose, such as selecting and integrating immigrants as members
of the polity. The rules of citizenship laws are instead shaped by multiple purposes of public
policy (Vink & Bauböck, 2013) and drivers of change include domestic as well as international
forces.
A third problem in comparative studies of citizenship regimes is generalisation from limited
samples that consist mostly of wealthy and democratic countries of immigration in the global
North. In the past this was partly due to a lack of available data on countries in the global
South, but the overwhelming focus on immigration and widespread ignorance of corresponding
emigration contexts also has to do with public debates and available funding for research
privileging domestic concerns and perspectives in countries with strong academic institutions.
There is nothing wrong with studying how “Western democracies” have adapted their citizenship
regimes to immigration from the global South, as long as one keeps in mind that this is a
particular context and does not lose sight of how “Western citizenship” is embedded in an
international state system and interacts with other states. Shifting the focus to the global South
and collecting data about it will, on the one hand, challenge assumptions about citizenship
that have been hidden or taken-for-granted in the global North. Consider the meaning of ius
sanguinis and ius soli in states where large numbers of children are not registered at birth,
or the meaning of naturalisation where it is an exceptional privilege granted by high-level
executive authorities rather than an option for immigrants who can become citizens if they meet
a certain set of conditions. Recent comparative studies of non-Western citizenship regimes
in South America (Acosta, 2018), Africa (Manby, 2018) and East Asia (Chung, 2020) have
provided genuinely new insights into the operation of citizenship that have yet to be digested
by mainstream theories derived from research on the global North.
European University Institute 39
Global Comparison of Citizenship Laws: Promises and Pitfalls
A fourth trap consists in confusing law in the books with law in action. This risk lurks
everywhere but is especially dangerous when interpreting citizenship regimes of countries
where the rule of law is weak. Unlike lawyers who are very conscious of the dierence between
legal norms and their implementation and eects, comparative social scientists often treat
citizenship laws simply as data that indicate how open and inclusive a political regime is towards
immigrants and diaspora populations. Instead, we need to be aware that comparing the rules
contained in citizenship laws in principle only allows to test hypotheses about variation of legal
norms across time and countries. This is an important research agenda in itself. Studying, for
example, regional patterns and trends regarding explicit gender discrimination in ius sanguinis
and naturalisation provisions is a relevant research question quite independently of how these
rules are implemented. It is linked to a human rights agenda and can be addressed through
collecting and coding legal rules in nationality laws on a global scale. Yet, especially with
regard to rules where the discretion of authorities has been traditionally wide, such as ordinary
naturalisation or citizenship deprivation, we need to know about implementation before
we can say anything about how eective these rules really are. Comparing administrative
implementation is, however, much more dicult than comparing legal rules, because the
former can only be captured through internal administrative documents or even observation
of individual cases. First steps have been made towards the goal of comparatively analysing
naturalisation procedures in European countries (Huddleston & Falcke, 2020). But a global
and longitudinal dataset on administrative implementation of citizenship rules remains beyond
reach. In this respect, in-depth qualitative comparative studies of selected cases are the best
we can hope for.
A nal trap that I want to highlight is that of letting our research questions be driven by the
available data. As mentioned above, in the 1990s and early 2000s the scarcity of standardised
comparative data generated a Northern and immigration-centric bias in theories about the
evolution of citizenship that often postulated a universal trend of liberal convergence. In the
future, thanks to eorts by GLOBALCIT to build open access global datasets, we may face
instead a problem of abundance. Once reliable global data are available, researchers will be
tempted to ask (only) those questions that they believe these data can answer. In a global
dataset the size and representativeness of country samples is no longer a statistical problem.
Researchers may then start to look for patterns of correlation and interpret even weak ones
as indicating some causal relation that calls for ad hoc explanatory hypotheses. We should
never forget that the most important task of social science is not to chase the holy grail of
causal relations between variables but to build coherent and evidence-based theories that help
societies to better understand the social and political institutions that they themselves have
created. This applies also to the institution of citizenship and for that endeavour we need to
keep large-scale comparisons open for big ideas even if these cannot yet be tested.
40 Robert Schuman Centre for Advanced Studies
Rainer Bauböck
References
Acosta, D. A. (2018). The National Versus the Foreigner in South America. 200 Years of
Migration and Citizenship Law. Cambridge, UK: Cambridge University Press.
Bauböck, R. ed. (2010a). Dual Citizenship for Transborder Minorities? How to Respond to
the Hungarian-Slovak Tit-for-Tat. 75 vols, RSCAS Working Paper. Florence: European
University Institute.
Bauböck, R. (2010b). “Studying Citizenship Constellations.” Journal of Ethnic and Migration
Studies 36 (5): 847 — 859.
Bertossi, C. & J. W. Duyvendak (2012). “National models of immigrant integration: The costs
for comparative research.” Comparative European Politics 10 (3): 237–247.
Brubaker, R. W. (ed. 1989). Immigration and the Politics of Citizenship in Europe and North
America. Lanham and London: University Press of America.
Brubaker, R. W. (1992). Citizenship and Nationhood in France and Germany. Cambridge, Ma:
Harvard University Press.
Chung, E. A. (2020). Immigrant Incorporation in East Asian Democracies (Cambridge University
Press, 2020). Cambridge: Cambridge University Press.
Goodman, S. W. (2014). Immigration and Membership Policies in Western Europe. Cambridge,
UK: Cambridge University Press.
Huddleston, T. & S. Falcke (2020). “Naturalisation in context: how nationality laws and
procedures shape immigrants’ interest and ability to acquire nationality in six European
countries.” International Migration 58 (2): 255-271.
Huddleston, T. & G. Solano (2020). Migrant Integration Policy Index (MIPEX) 2020. edited by
Migration Policy Group. Brussels.
Joppke, C. (2007). “ Beyond National Models? Civic Integration Policies for Immigrants in
Western Europe.” West European Politics 30 (1): 1-22.
Manby, B. (2018). Citizenship in Africa. The Law of Belonging. Oxford: Hart Publishing.
Vink, M. P. & R. Bauböck (2013). “Citizenship Congurations: analysing the multiple purposes
of citizenship regimes in Europe.” Contemporary European Studies, 11 (5): 621-648.
Weil, P. (2001). “Access to Citizenship: A Comparison of Twenty-Five Nationality Laws.” In
Citizenship Today: Global Perspectives and Practices, edited by Aleiniko and Klusmeyer.
Washington, DC: Carnegie Endowment for International Peace.
Wimmer, A., & N. Glick Schiller (2002). “Methodological nationalism and beyond: nation-
building, migration, and the social sciences.” Global Networks 2 (4): 301-334.
European University Institute 41
Without the South, It’s Not Global
Without the South, It’s Not Global: Creating Knowledge about
Naturalization Jointly
Luicy Pedroza* & Pau Palop-García**
In 2019, we wrote a research note for the APSA Newsletter on Migration and Citizenship
titled “How do we move migration policy datasets and indices further? A proposal to address
persisting lacunae and major research imperatives”. In that piece, we made proposals on
how to increase the geographic and temporal coverage, as well as the level of specicity and
detail of migration policy indices. We also argued that we should amplify the scope of our
measurements to incorporate dimensions of migration policy other than immigration policies.
The goal of that piece was to make a non-exhaustive stocktaking exercise, yet enough to
make the point that a more rigorous knowledge expansion requires reassessing our goals and
redirecting our eorts to cover areas that are still under-researched. A further important point
that we made is the need to conduct our forthcoming research according to common standards
of transparency and access to data.
In our contribution to this symposium, we want to pick up where we left in that research note
and go a step further by proposing clear pathways to solve some persisting blind spots and
biases that our policy measurements have – in this case especially regarding naturalization.
1. Addressing three remaining blind spots in migration policy indices
1.1. The focus on the global North
One of the clearest weaknesses of our measurements is their focus on the Global North.
Although some important eorts have been deployed to tackle this issue (GLOBALCIT being
the clearest example), Asia, Africa and Latin America remain under-researched. We suspect
that this bias has to do with data availability. For these regions, we still lack reliable data
that can be cross-checked and cross validated with other readily available datasets. Another
reason why we have focused on Western countries might be the easier access to primary
sources, with the background of a stronger rule of law: easily accessible systems that order
legal and policy primary sources and make them public.
Our proposal: There is no easy x for this, but with proper investments and planning, much
can be improved. The geographic concentration on the Global North keeps reproducing
because the investments in better data and reliable experts are kept in already wealthy
regions. We should promote and expand our networks to other regions so that we can
empower scholars working in those regions.
A factor that plays a role in keeping most of the datasets and indices geographically concentrated
is less obvious than data availability: our research questions. We tend to try to bend the rest
of the world to t the measurements developed for the questions that have been made in
the West. The kind of questions we ask, the frames we use for our research puzzles and
how we divide the world into relevant cases and irrelevant cases all play a role in continuing
biases. We have argued elsewhere against the simplistic dierentiation between “countries of
immigration” and “countries of emigration” for research design purposes because, as much as
* El Colegio de México.
** Willy Brandt School of Public Policy (University of Erfurt)..
42 Robert Schuman Centre for Advanced Studies
Luicy Pedroza & Pau Palop-García
this dierentiation resonates, it can be misleading. We think that there is much to be gained
from developing a more accurate sense of the range of variation of migration policies rst (in
this case, of naturalization regulations all over the world), and make our research questions
more sensitive to the variations observed.
Our proposal: A way to become sensitive to this bias (and to raise our sensibility for the
original interests and new potential questions that researchers in other regions could
have on citizenship and nationality issues) is to work together with scholars from those
regions. In a small scale, we can achieve this by entering common research projects and
particularly by aiming to publish together with authors from other regions. Institutionally,
we need our long-term funding schemes to move towards promoting sustainable cross-
regional academic cooperation.
1.2. The level of analysis
A second blind spot in migration and citizenship policy measurements is caused by a top-
down abstraction process. Sometimes we work with categories that are perfectly plausible
as theoretical and analytical constructs but that have no correlate in reality. Reality would
require us to become much more specic in our denitions. In the APSA Newsletter piece we
exemplied this with categories such as “high-skilled” migrants (which in reality might refer to
specic groups or professions) or “humanitarian migration” (which in reality tend to boil down
to the existence of a specic regulation for refuge or asylum, but do not exhaust humanitarian
categories).
Our proposal: we need to stop portraying policies as general and unitary when they are
not. We should start adjusting the level of analysis towards more specicity. This point is
relevant for the implementation of naturalization, for instance. We could experiment with
bottom-up approaches that focus on lower levels rst instead of imposing categories that
emanate from migration policies of the Global North. That is, we propose to collect data on
the categories that exist and, later, see if they add up analytically or not (i.e., if they require
creating a dierent category), to allow for comparisons across countries and regions.
1.3. The impact of new technologies on citizenship
A third blind spot that we want to mention relates to the digitalization processes happening
around migration and citizenship policies. Social credit systems based on big data, e-citizenship,
matching algorithms to select naturalization candidates or cloud communities are examples of
how new technologies might play a key role on the attribution and governance of citizenship in
the next decades. Our current indices do not capture these new realities.
Our proposal: We need to start reecting how we can measure the impact of new technologies
on migration and citizenship policies through new indicators or even completely new
dimensions for our current concepts. Studying countries that are early adopters of these
technologies would be a rst step.
2. Seeing through the prism of emigrant policies: dierent degrees and
qualities of citizenship
When analyzing the kinds of citizenship that are available to the naturalized there is much to
be gained from considering the emigrant side of migration policy. Studies on Latin America and
the Caribbean have given us some important lessons:
European University Institute 43
Without the South, It’s Not Global
The rights of dual nationals can be quite dierent from the rights of mono-nationals and of
nationals by origin, which suggests that many countries still attribute to immigrants the very
fears that they are supposed to have overcome for their own nationals (see Hoyo, 2015).
What we have observed is that states restrict key rights of citizenship such as protection
abroad and return for those who naturalized. While this may appear insignicant because
of the relatively few numbers of persons who naturalize and move abroad or acquire yet
another nationality, it illustrates gradations of cross-national membership and qualications
to the ideal of equal citizenship. Having clarity about these dierentiations is important
because they point to (other) multiple purposes of citizenship laws and regulations. The
regulations across Latin America and the Caribbean to dampen, condition or delay the
exercise of some citizen rights by naturalized citizens reect a skepticism that the links to
the community of membership, despite having complied with a standard process, will ever
amount to the same kind of membership of nationals by origin. Although our studies of
these dierentiations in other regions are incipient, some evidence from East Asian cases
(Pedroza, Palop-García & Chang, 2022a; 2022b) suggests that this is not an exclusive
practice of Latin American and Caribbean states.
We should not overlook that some states distinguish between ‘nationality’ and ‘citizenship’.
While the term nationality is used to refer to the condition and privileges derived from
having a certain passport (e.g. the right to return to a state, diplomatic protection of that
state abroad), citizenship is used to capture the condition to exercise a full set of rights
and duties (e.g. especially political rights) between a state and individuals (Pedroza &
Palop-García, 2017: 589). This legal distinction enables several of the above-mentioned
gradations: dierentiations between immigrants and emigrants, between those who are
nationals exclusively or dual/multiple- nationals, and between those nationals by origin and
nationals by naturalization. Scholars in Europe have deemed this dierentiation unworthy
of attention because it plays no role in European law traditions. Again, we have found
this dierentiation has relevance in other regions beyond Latin America --in Asia dierent
residence regulations (right of abode, household registration) serve to dierentiate one
from the other.
Thanks to these lessons learned we have added in our analyses ve new indicators to those
that GLOBALCIT has for naturalization:
(1) Distinction between citizenship and nationality,
(2) Emigrant dual nationality for immigrants who naturalized,
(3) Restrictions on citizenship for naturalized immigrants,
(4) Loss or suspension of citizenship for immigrants who naturalized and take residence
abroad, and
(5) Restrictions on citizenship for naturalized immigrants who are dual nationals.
3. Making more sustainable investments to expand datasets globally
We need more investments to support a global expansion of datasets and a further renement
of our measurements so that our indices reect the breadth of naturalization practices across
regions and countries.
Our main proposal here is to include the voices of scholars from the global South in this
process. Our scholarly community has relied a lot on two approaches: a) nd some experts
44 Robert Schuman Centre for Advanced Studies
Luicy Pedroza & Pau Palop-García
from abroad and have them ll out our questionnaires or b) train ourselves in their laws and
collect information “from here”. These strategies are ne and valid as a starting point, but we
can aim for more, not only because it is sometimes dicult to nd an expert to answer our
questionnaires, but also because of the eects that we are producing and, at the same time,
other eects we are not producing enough. With vastly better resources, projects directed from
the global North often engage scholars in the South in parts of the data collection – sometimes
even distracting them from their main tasks. Yet those scholars still rarely appear as authors
of the top-level publications produced with the data they helped collect. Even if it is true that
such participation still counts, tends to be remunerated, and gives them exposure, this is not
always acknowledged and duly quoted. We see a great potential in developing a culture of
jointly created and shared knowledge whereby scholars from the North train scholars from the
South in their regions, but also take a chance to learn from the latter and to hear their research
questions and interests. This not only makes it more likely that scholars from the South will be
included in top publications, but also enlarges our community of scholarship to other regions,
which potentially has a multiplier eect for the research produced by this scholarly community.
A rst step in this direction can be taken through training workshops (not only dissemination
workshops) with legal scholars, political scientists, and historians from/in these regions. This
proposal has an element of internationalization of knowledge production. In a post-pandemic
world, these trainings and workshops can and should keep taking place in Europe, but hopefully
can also take place in other regions, and have a hybrid and mixed format with some remote
components and some components of intense and joint learning in person. While no online
workshop or training so far allows the kind of in-depth exchanges that live workshops allow, it is
obvious that including some online modules expands the potential to socialize knowledge and
training and makes it more accessible nancially and more environmentally sensible.
Nourishing this kind of scholarship is a long-term endeavor, but one that could pay o for
everyone. It could widen our circle of readers and interlocutors, increasing the potential impact
of our research beyond data collection because it will be potentially understood and used
by more people and towards more purposes. It will make collaborations and co-authorships
across hemispheres more likely. Over time, it will also enhance cross-national comparability
as perhaps the intense North-South dialogues will lead to some convergence over common
indicators, measurements, and goals thereof, and it will enrich our research landscape with
fascinating new questions.
European University Institute 45
Without the South, It’s Not Global
References
Hoyo, H. (2015). “Apertura externa, exclusión interna: El nacionalismo revolucionario
y los derechos de digrantes, mexicanos por naturalización, y dobles nacionales en
México.” DesiguALdades.Net Working Paper, no. 87. http://edocs.fu-berlin.de/docs/
servlets/MCRFileNodeServlet/FUDOCS_derivate_000000005720/WP-87-Hoyo-Online.
pdf;jsessionid=852129AF36E3321DC86DC30A5EFEE281?hosts=.
Palop-García, P. & L. Pedroza (2019). “How Do We Move Migration Policy Datasets and Indices
Further? A Proposal to Address Persisting Lacunae and Major Research Imperatives.”
Newsletter of the American Political Science Association’s Organized Section on Migration
and Citizenship 7 (1): 37–52.
Pedroza, L. & P. Palop-García (2017). “The Grey Area between Nationality and Citizenship: An
Analysis of External Citizenship Policies in Latin America and the Caribbean.” Citizenship
Studies 21 (5): 587–605. https://doi.org/10.1080/13621025.2017.1316701.
Pedroza, L., P. Palop-García & S. Y. Chang (2022a), Migration Policies in Taiwan 2017-2019,
IMISEM Case Report, GIGA, https://doi.org/10.57671/imisem-22030, (accessed May 30th
2022).
Pedroza, L., P. Palop-García & S. Y. Chang (2022b). Migration Policies in South Korea 2017-
2019, IMISEM Case Report, GIGA, https://doi.org/10.57671/imisem-22028URL and DOI
forthcoming), (accessed May 30th 2022).
46 Robert Schuman Centre for Advanced Studies
Jelena Džankić
Avoiding Measure for a Measure’s Sake: Limits and Value Added of
Citizenship Law Indicators
Jelena Džankić*
Citizenship is commonly dened as a relationship between an individual and the state. At its
heart, the notion of citizenship has a legal component (nationality in international law), but also
the related political dimension composed of the rights, duties and actions of citizenship, as
well as the ascriptive or identitarian one. The interdisciplinary eld of citizenship studies has
evolved to unpack and examine each of these dimensions through dierent epistemological and
methodological lenses (Bauböck, 2013; Isin & Turner, 2002; Joppke, 2007). While recognizing
the variety of meanings that the notion of ‘citizenship’ has across the disciplines of social
science – including legal scholarship, sociology, economics, anthropology and demography
– comparative scholarship on citizenship and immigration has focused on measuring policy
variation in the domains of nationality acquisition and loss.
These measurements have taken place through the development of at least nine policy
indices that seek to systematically capture and compare the attribution of citizenship by
birthright and naturalization (Howard, 2009; Janoski, 2010; Koopmans et al., 2012; Koopmans
& Michalowski, 2017; Huddleston et al., 2015; Solano & Huddleston, 2020; Jeers et al., 2017;
Graeber, 2020; Schmid, 2021). All of these indices cover the European Union countries, and
all but Howard (2009) and Graeber (2020), include other European states. North American
countries, Asia and Oceania are included in ve of these indices, while some of the states in
South America are covered only in GLOBALCIT’s 2017 CITLAW indicators and Koopmans
and Michalowski’s 2017 version of ICRI, the latter being the only indicator that includes African
countries. In other words, most of these indicators have been developed to study immigrant
integration in the Global North rather than the overall direction of citizenship policies. This can
also be seen in the coverage of the dierent elements of citizenship policies included in the
respective indicators. All of them measure the degree of ‘inclusiveness’ or ‘exclusiveness’ of
birthright citizenship through ius soli and ius sanguinis, and what is broadly understood as
‘residence-based naturalisation’. Howard (2009), Janoski (2010), Huddleston et al. (2015),
Jeers et al. (2017) and Graeber (2020) also include systematic information on specic modes
of citizenship acquisition, including those based on marriage, or international human rights
norms.
Even though these indicators have certainly systematized our knowledge on the regulation
of membership, each of them has its shortcomings. Some of these have been noted in the
scholarship on citizenship, but also acknowledged in the codebooks explaining in which ways
the systematization of legal provisions and their translation into measurements has been
done. Even so, there are two key problematic aspects of measuring citizenship policies,
which scholarship has insuciently addressed so far. The rst one is something I would call
‘conceptual imposition’, or the presumption that terms and concepts that have been developed
to study and measure policies in Western democratic states will have the same meaning across
the world. The second is the vision of citizenship policies as qubits, or binaries, which prevents
scholarship from identifying where legal provisions are used to promote specic and often
conicting interests, such as those of expatriate and immigrant populations. In other words,
none of the indices so far adequately capture and enable scholars to study the complexities
and contestations that lie in the very heart of citizenship policies. In what follows, I explain why,
and nally argue that developing a new citizenship index would make a distinct intellectual and
* Robert Schuman Centre for Advanced Studies, European University Institute...
European University Institute 47
Avoiding Measure for a Measure’s Sake
scholarly contribution only if it suciently addresses the issues of conceptual imposition and
binarization. Developing a measure for measure’s sake makes little value-added to the current
state-of-the-art.
1. Conceptual imposition: the need to recognise the observer eect in social
science
The French Revolution was a turning point for what we understand to be the substance of
citizenship (Brubaker, 1992). It brought about the Declaration of the Rights of Man and the
Citizen, the basic charter of human rights, based on the freedom and equality of all men. It
solidied the conception of citizenship around the idea of an equitable distribution of socio-
political entitlements and obligations. Furthermore, the French citizenship model based on
territorial rather than blood connections, became most widely associated with the ius soli
principle for citizenship attribution.
Yet, the 1789 Revolution introduced another radical change, one that we frequently overlook
in the social sciences. It brought about the standardized units of measurement of length and
weight. Previously, each French region had used dierent measures, which made trade
and commerce between the dierent regions of France quite dicult. So, in August 1793,
the National Convention adopted a decree bill that imposed the ‘metric system’ in France.
The bill was enacted in April 1795, and by that time the ‘mètre étalon’ was installed around
the main marketplaces in Paris. These units of measurement spread around Europe during
Napoleon’s conquests and in 1875 the Treaty of the Metre aorded international recognition to
the predecessor of what is known today as ‘the metric system’.
This interesting anecdote aside, it is beyond doubt that measuring length and weight in
a standardized way has made all our lives far simpler; it also aided progress in science,
establishing units that colleagues around the world can use to compare lengths, distances,
temperatures or weight. Nonetheless, we should not forget two things. One, the system was
spread through imperial conquest in the rst place. Two, we need to wonder whether we can
measure ‘things’ in the social world in the same ways in which we measure those in the physical
one. To discuss this, I go back to the notion of ‘conceptual imposition’.
As social scientists, we often develop ‘new’ concepts, and even more so take pride in doing
that – as I did just now. We develop them from our own perspective, based on the facts,
events or dynamics that we can observe. We use them to study social relationships in our own
context, and compare these relationships with those in other corners of the world, using our
own units of observation. In so doing hardly ever do we question whether the concepts we use,
and the tools we deploy to compare societies, are adequate for understanding dynamics and
interactions that are conicting and incompatible with or contested beyond what we have based
our original observation upon. Is the substance of the notions of ‘citizenship’, ‘equality’, and
‘democracy’ the same in Brazil, China, Italy, Jordan, North Korea, Sierra Leone, Singapore?
Is it the same across scientic disciplines or social/economic classes; across culturally and
historically distinct communities?
The ‘observation eect’ in physics posits that some systems may be altered or disturbed by
the act of observation and that measurements may have lasting eects on those systems. By
analogy, recognising that we need to account for our own viewpoint and bias when constructing
measurements of social realities would perhaps also change the way in which we think about
indices and what they are used to measure, compare and study. This can be illustrated with
an example of a binary citizenship index. Let us imagine that an index measures whether it is
48 Robert Schuman Centre for Advanced Studies
Jelena Džankić
possible (or not) to acquire citizenship (i.e., the legal status of nationality under international
law) on the basis of marriage to a citizen of a given country. This index can take dierent
forms – it can measure only what is considered ‘marriage’ under national law (commonly a
legally recognised monogamous union between a man and a woman); it can include unions
recognised as equivalent to marriage, such as civil partnerships (commonly a legally recognised
monogamous union between the same or dierent genders); it can perhaps also account for
plural or temporary marriage, accepted in some cultures. In each of these cases, and perhaps
in those unaccounted for here, the results of observation will dier, and in some – they may
have normative implications (e.g., if a cultural norm is viewed negatively due to our observation
standards).
Avoiding this ‘conceptual imposition’ and the ‘observer eect’ that results from it is impossible.
It does not, however, mean that we should stop studying, measuring and comparing the
workings of our societies; after all – a meter and a foot both measure length. It means that we
need to acknowledge the drawbacks of and biases in our research from the very moment we
conceive of it.
2. Citizenship qubits: limitations of binary approaches
So far, most of the citizenship indices have classied countries by viewing their citizenship
policies either as single or bi-dimensional units. They would aggregate dierent elements of
citizenship laws and look at whether the overall policy is ‘inclusive’ or ‘exclusive’, or whether
naturalization seeks to foster admission of immigrants or to shun them away. The core
weakness of such binary approaches is that – while they do oer some broad insights in the
direction of policy – they frequently overlook the main character of citizenship legislation, and
its purposes and outcomes along dierent dimensions. For example, measuring whether a law
is ‘inclusive’ by – for instance – looking at the dierent naturalization conditions (e.g., years of
residence, language, income, character, etc.) may be misleading if a country has a rather open
citizenship policy, but substantive hurdles in the immigration law regulating the entry and stay
of foreigners. It could equally be misleading if naturalisation of foreigners (or even expatriate
populations) is reasonably straightforward, while indigenous populations or minority groups
are unrecognised or excluded from citizenry.
One way of overcoming this binary approach to ‘measuring’ the policy direction of citizenship
legislation would be a multi-dimensional model. In this vein, the empirical study of citizenship
policies in the EU and its neighbourhood by Vink and Bauböck (2013) is a two-dimensional
model based on aggregate policy indicators. This model posits ‘four idealtypic citizenship
regimes’ on the basis of the purpose of citizenship laws (Vink & Bauböck, 2013: 628). It divides
them into: 1) ethnoculturally selective; 2) ethnoculturally expansive; 3) territorially selective and
4) territorially expansive. While this model certainly resolves some of issues of the citizenship
qubit by looking at dierent types of selection and inclusion, it is still rooted in the traditional
ethno-territorial conception of citizenship and assesses the overall policy direction. A further
step forward would be a more stratied approach, which would better account for those aspects
of citizenship policies – such as merit, contribution, or humanitarian grounds – whose purpose
goes beyond ethnic or territorial principles. The key challenge for empiricists would be nding
the right tools to apply it across the board.
European University Institute 49
Avoiding Measure for a Measure’s Sake
3. A lookout: avenues for value-added measurements
Systematic studies of citizenship regulation are of key signicance not only for immigrant
integration across the world, but also for understanding the very essence of membership.
Immigrants account for merely four per cent of the global population (IOM, 2020), and mostly
consist of refugees in the Global South. Even so, the study of their integration has predominantly
concerned the scholarship on Western democratic states, thus often overlooking socio-political
realities of membership beyond Europe and Northern America. As a result, to have real value
added, any new index systematically comparing citizenship policies, would need to adequately
address the realities of immigration in Africa, Asia, Latin America and the Caribbean, and in
Oceania, rather than adding a range of countries from these regions to a model designed to
study immigrant integration through citizenship in the Global North. In other words, everyone
in the world is aected by the regulation of nationality in the territory where they are located.
Therefore, a new index could provide a true intellectual contribution only if designed to address
the real challenges of regulating membership in the contemporary world.
One way to do this, could possibly be to look at the implementation of dierent aspects
of citizenship policies and how they impact on who is recognised as a citizen. A step in this
direction has been made at GLOBALCIT with the Global Birthright Indicators (2019), which look
at the regulation of ius soli and ius sanguinis worldwide. While oering an excellent comparison
of the regulation of transmission of citizenship at birth, GLOBALCIT’s indicators unfortunately
do not capture implementation. Issues surrounding birth registration have frequently been the
cause of statelessness or undetermined status across African states (Manby, 2018) as well as
in the MENA region (Fischer, 2015; van Waas, 2014).
Implementation has, however, been granted substantial attention in the study of naturalisation
requirements (again, mostly in the Western democratic states). MIPEX (Solano & Huddleston,
2020) and CITIMP (Huddleston, 2013) have placed a substantial emphasis on the dierent
procedural requirements for naturalization, including conditions related to residence, language
knowledge, steps of the procedure. Stadlmair (2018) zoomed in on the eects economic
conditions for naturalisation, in particular; Goodman (2011), and, more recently, Jensen et
al. (2019) discussed how language requirements may impact on naturalisation rates. These
studies have shown the signicance of the dierent administrative and procedural requirements
in the process of citizenship acquisition. Even though they oer a substantive contribution to
our understanding of naturalisation, their application is limited to well-regulated administrative
systems. Again, such approaches exclude from systematic comparison those countries where
naturalisation is highly discretionary. The key challenge, and possibly an almost insurmountable
one, would be to devise systems for measuring the degree of discretion and its eect on
naturalisation.
A further avenue where a groundbreaking contribution to scholarship on citizenship could be
made is a methodical approach to the loss of citizenship. In recent years, indices of statelessness
(ISI, 2020) have become well established in both the academic literature and the policy world.
However, formulae for comparing the various aspects of citizenship loss, denaturalization (loss
of citizenship acquired by naturalisation) and denationalization (loss of citizenship attributed at
birth) have received far less scholarly attention. This is rather surprising given the incredible
variety of modes of citizenship loss (GLOBALCIT, 2017), and procedures through which they
are implemented. It comes as an even greater surprise given the salience of the issue in the
context in which human rights concerns clearly collide with issues such as the ght against
terrorism (e.g., Shamima Begum case in the UK; Ghoumid and others in France), result from
territorial rescaling (e.g., UK’s exit from the EU; dismantlement of post-communist federations)
50 Robert Schuman Centre for Advanced Studies
Jelena Džankić
or a state’s overall approach to citizenship (e.g., ex lege loss upon voluntary naturalisation;
loss due to long-term residence abroad).
In sum, developing ways to compare citizenship policies is by no means an easy task; and
doing so just for the sake of the measure makes scarcely any contribution to what scholars
have achieved so far. Perhaps scholars will never be able to develop a model ne-grained
enough to capture all the idiosyncrasies of all the citizenship laws in all the world. Yet, should
they be bold enough to go in this direction, their approach would need to be a) stratied – thus
accounting for the various layers of citizenship; b) internally and externally consistent – to
ensure broad applicability and avoid ‘conceptual imposition’; and c) honest – in that it will
highlight its potential and equally recognise its limitations.
European University Institute 51
Avoiding Measure for a Measure’s Sake
References
Bauböck, R. (2013). ‘Studying citizenship constellations’. In Migration and Citizenship
Attribution (pp. 143-156). Routledge.
Bauböck, R., I. Honohan & K. Jeers (2017). Citizenship Law indicators (CITLAW), EUI
Research Data, Robert Schuman Centre for Advanced Studies, European Union Democracy
Observatory (EUDO), Migration Policy Group. Retrieved from Cadmus, European University
Institute Research Repository, at: http://hdl.handle.net/1814/64595
Brubaker, R. (1992). Citizenship and nationhood in France and Germany. London: Harvard
University Press.
Fisher, B. (2015). ‘Why Non-marital Children in the MENA Region Face a Risk of
Statelessness’. Harvard Human Rights Journal, 31.
GLOBALCIT (2019). Global Birthright Indicators. San Domenico di Fiesole: European University
Institute.
Goodman, S.W. (2011). ‘Controlling immigration through language and country knowledge
requirements’. West European Politics 34(2): 235-255.
Goodman, S.W. (2015). ‘Conceptualizing and measuring citizenship and integration policy:
Past lessons and new approaches’. Comparative Political Studies 48(14): 1905-1941.
Graeber, J. D. (2020). ‘Quo vadis, Citizenship?’. Journal of Contemporary European Studies
77(1): 1–21.
Howard, M. M. (2009). The Politics of Citizenship in Europe. Cambridge: Cambridge University
Press.
Huddleston, T. (2013). Citizenship Implementation indicators (CITIMP), EUI Research Data,
Robert Schuman Centre for Advanced Studies, European Union Democracy Observatory
(EUDO), Migration Policy Group. Retrieved from Cadmus, European University Institute
Research Repository, at: http://hdl.handle.net/1814/64592
Huddleston, T., Ö. Bilgili, A.-L. Joki & Z. Vankova (2015). Migrant Integration Policy Index 2015.
Brussels: Migration Policy Group.
Isin, E. F. & B. S. Turner, eds. (2002). Handbook of Citizenship Studies. Sage.
Janoski, T. (2010). The Ironies of Citizenship: Naturalization and Integration in Industrialized
Countries. Cambridge: Cambridge University Press.
Jeers, K., R. Bauböck & I. Honohan (2017). How to Measure the Purposes of Citizenship
Laws: Explanatory Report for the CITLAW Indicators. Florence: GLOBALCIT.
Jensen, K.K., P. Mouritsen, E. C. Bech & and T. V. Olsen (2019). ‘Roadblocks to citizenship:
selection eects of restrictive naturalisation rules’. Journal of Ethnic and Migration Studies
47(5): 1-19.
Joppke, C. (2007). ‘Transformation of citizenship: status, rights, identity’. Citizenship
studies 11(1): 37-48.
Koopmans, R., I. Michalowski & S. Waibel (2012). ‘Citizenship Rights for Immigrants’. American
Journal of Sociology 117 (4): 1202–1245.
52 Robert Schuman Centre for Advanced Studies
Jelena Džankić
Koopmans, R. & I. Michalowski (2017). ‘Why Do States Extend Rights to Immigrants?
Institutional Settings and Historical Legacies Across 44 Countries Worldwide’. Comparative
Political Studies 50(1): 41–74.
Manby, B. (2018). Citizenship in Africa: The Law of Belonging. London: Hart Publishing.
Schmid, S. D. (2021). ‘Stagnated liberalization, long-term convergence, and index methodology:
Three lessons from the CITRIX citizenship policy dataset’. Global Policy 12(3): 338-349.
Solano, G. & T. Huddleston (2020). Migrant Integration Policy Index 2020. Brussels: Migration
Policy Group.
Stadlmair, J. (2018). ‘Earning citizenship. Economic criteria for naturalisation in nine EU
countries’. Journal of Contemporary European Studies 26(1): 42-63.
Van Waas, L. (2014). ‘A comparative analysis of nationality laws in the MENA region’. Available
at SSRN 2493718.
Vink, M. P. & R. Bauböck (2013). ‘Citizenship congurations: Analysing the multiple purposes
of citizenship regimes in Europe’. Comparative European Politics 11(5): 621-648.
European University Institute 53
Concepts in New Contexts
Concepts in New Contexts
Ashley Mantha-Hollands*
The development and use of concepts in social and political sciences is a key aspect to both
theory and inferences (Gerring, 1999). Concepts provide researchers with a framework for
what social, political, and economic phenomena are ‘out there’. They are both a language for
communicating what we are trying to explain and part of the frameworks we use to explain it
(Berenskoetter, 2017). In other words, concepts are analytical categories as well as the tools
scholars use to build theories.
As part of the production of knowledge in academia, there is a strong demand for cross-
country comparative research. One temptation in this regard is to use and test the same
concepts in other contexts. The goal of this cross-contextual comparison is to test conceptual
theories to see how they might play out in dierent settings. When broadening the scope of the
research on naturalisation and citizenship from the ‘usual suspects’ in Europe, North America,
and Oceania one common example of this is the binary of ‘inclusion/exclusion’ of the laws and
policies governing citizenship acquisition and loss. However, one must keep in mind that how
researchers describe, and label experiences will inevitably reveal biases in their research;
and therefore, there is a concern for the acontextual application of euro-centric membership
concepts when attempting to explain them across new contexts. With this short reection, I
consider: i) how to assess the value of a concept in a new context (historical, theoretical, or
political); ii) how to improve its structure; and, iii) how to develop conceptual alternatives.
1. Applicability
Concepts are often developed by observing a phenomenon at a contextual moment. Shifting
research to a new context (historical, theoretical, or political) may change both the meaning and
scope of a particular concept. It is therefore important to ask whether a concept can apply to a new
contextual site. As dierent aspects of the context change so will the applicability of the concept.
An old but poignant example is with the study of the concept of the ‘family’ where researchers
have had a euro-centric bias towards an individualistic orientation. This would be, for instance,
using the ‘nuclear family’ as a universal concept which in much of the world, would miss the bigger
picture. For example, Getrude Dadirai Gwenzi has recently shown how the meaning of ‘family’
in Zimbabwe is constructed and dened by care leavers – nding a more complex set of social
relationships (Gwenzi, 2020). John Gerring (1999) denes four criteria for conceptualisation in
comparative research: the term, its attributes, its indicators, and its phenomenon. When the
number of cases is expanded, researchers should consider all four aspects of the concept and
how it then might need to be adjusted. Thus, scholars should maintain exibility and be open to
expanding a concept denition as they broaden the scope of their research.
One intriguing example in the comparative study of citizenship research is with the concept
of ‘naturalisation’. Liav Orgad (2017) describes three functions to the concept of ‘naturalisation’:
i) a contract between the state and its prospective citizen; ii) as a political test for entry into
the bounded community; and, iii) as part of the process of nation-building. But the practice of
naturalising newcomers is not limited to the liberal democracies of Europe and thus, employing
this functional denition in non-European contexts may misinterpret reality. As Bronwen Manby
(2021) has recently shown in the context of some of the states in Africa, naturalisation has
an additional function of being “performative” – meaning that its restrictive nature acts as a
* Robert Schuman Centre for Advanced Studies, European University Institute...
54 Robert Schuman Centre for Advanced Studies
Ashley Mantha-Hollands
signal “that the non-African minorities privileged during colonial rule will not be allowed to
continue to dominate the political economy”. Or furthermore, looking to Noora Lori’s research
in the Gulf States, naturalisation is seen by the state as a mechanism for ensuring national
security (Loori, 2019). In the work on investor citizenship in small island states another function
could be to support the economy and means of production (Van Fossen, 2007; 2017). Thus
looking at the concept of naturalisation solely through the prism of liberal democracies would
limit its explanatory power. As these examples have shown, rather than thinking about how a
concept works in a new context, a better approach is to explore how a new context changes
the meaning of a concept. That is to say, scholars should make room to allow the new context
to challenge their conceptual assumptions rather than letting their ‘conceptual glasses’ fog
what they discover in new contexts.
2. Interpretation
The second challenge to studying concepts in new contexts is the depth of local knowledge
that is required to both label the concept and precisely measure the phenomenon in question.
This becomes increasingly dicult when comparative research involves a large N sample
as researchers may have asymmetric knowledge about their cases. One possible result is
‘conceptual confusion’ i.e., that researchers will label dierent phenomena with the same name
(Sartori, 1970). This issue is especially acute in the study of naturalisation and citizenship;
researchers should thus, be aware of two aspects of ‘interpretation’ in their empirical use of
concepts across dierent contexts.
The rst aspect of this is knowledge of the language of the membership community in which
research is being conducted as dierences in language can have empirical dierences in
results (Koselleck, 2004). Gerring (1999: 362) points out that “semantic complications multiply
when a concept’s meaning is considered historically, in dierent languages, in dierent
language regions of the same language, in dierent grammatical forms…, and in dierent
speech acts.” Therefore, using digital translation services to look at laws and policies may
shape the ndings of the study. It is further complicated in multi-lingual communities where the
governing language may be dierent from indigenous/local languages. Even within one state a
concept can have many meanings for dierent groups and can change over time.
The second aspect is that researchers’ own ‘positionality’ may aect their empirical application
of a concept (Manohar et al., 2017). As Edward Said wrote back in 1978, “no one has ever
devised a method for detaching the scholar from the circumstances of life, from the fact of his
involvement (conscious or unconscious) with a class, a set of beliefs, a social position, or from
the mere activity of being a member of society” (Said, 1978: 10). In other words, ‘who one is’
will shape ‘how one interprets’ and consequently, the proceeding explanations. Positionality
can be made up with aspects of the researcher that are xed (race or ethnicity) whereas others
can be subjective (personal lived experiences).
This is to say that scholars must not only keep in mind that their own research training and
methodological strategies will shape results but also how their positionality in research may
inuence the questions they ask, concepts they use, and interpretations. While this kind of
reection seems to be taking place in other disciplines (specically with post-colonial feminist
theorists), there is little in the case of citizenship studies. Citizenship itself is an essentially
contested concept with multiple meanings across scholarship. It also cannot be decoupled
from its colonial history. Therefore, those themselves with a ‘rst class’ passport may be biased
in how they view and employ the concept from the very beginning. This needs to be both
acknowledged and discussed.
European University Institute 55
Concepts in New Contexts
3. A local viewpoint
The question of ‘interpretation’ inevitably leads to what can be seen as a recommendation
but comes with its own set of challenges. Researchers in Europe and North America will face
diculties in their academic pursuits unless local scholars are included at every stage of their
research design. This expert knowledge for the concept under inquiry is the most important
aspect of a comparative conceptual study. Local scholars will have the best lenses to describe
and understand the related social, political, and economic phenomena. As Giovanni Sartori’s
guiding phrase suggests: ‘meaning before measurement’ (Sartori, 1970) which will help decide
if and how a particular concept can be applied and avoid conceptual confusion in interpretation.
On a logistical level, this means actively dissolving the barriers and burdens imposed on
researchers and practitioners from the global South. Digitalisation and online conferences have
facilitated this to an extent. This is because discussion and debate can move onto digital spaces
instead of in-person. In-person conferences may require researchers to bare the burdens of
travel costs or to go through expensive and bureaucratically onerous visa applications. But it
also means using and citing research from local scholars. This may seem obvious however, it
is not always something that is facilitated by university libraries which may only have licenses
to particular types of journals where scholars from the global South are underrepresented.13
Conclusion
Much of the current research on naturalisation and citizenship uses euro-centric lenses,
concepts, and methods and expands them broadly to other contexts. While the goal of a
concept is to establish equivalence across contexts, this practice will only lead researchers
to present an opaque picture of the specic contextual reality. With this reection, I have
presented several challenges to using concepts across contexts namely, i) considering the
applicability of a concept by not assuming universalism; ii) keeping in mind one’s own ‘glasses
of interpretation’; and iii) that local scholars will have the best knowledge of cases however,
inclusion requires researchers to take an active role in breaking down barriers. Considering
these issues will hopefully allow researchers interested in comparative research to open doors
for formulating concepts that are contextually aware.
Research is a mode of scientic production and “any comparison is a construction in the
sense that it discerns which elements or segments of social reality are to be related to one
another and along what dimensions” (Azarian, 2011: 123). It is important to keep in mind how
knowledge is produced. How concepts are used in research will give meaning to empirical
phenomena and can thus be a mechanism for exercising or reproducing existing power
dynamics.
All that being said, there is much to gain by expanding the scope of research on citizenship
and naturalisation. However, if conducted with the assumption of universalism and without
acknowledging how one’s own position might inuence ndings there will be practical
implications like compounding academic inequalities and reproducing ‘blindspots’.14
13 ‘Global South scholars are missing from European and US journals. What can be done about it,’ The Conversation 29 July
2018. https://theconversation.com/global-south-scholars-are-missing-from-european-and-us-journals-what-can-be-done-
about-it-99570.
14 See Luicy Pedroza’s intervention in the workshop for this symposium: https://www.youtube.com/watch?v=OkKZY1XD9aU.
56 Robert Schuman Centre for Advanced Studies
Ashley Mantha-Hollands
References
Azarian, R. (2011). ‘Potentials and limitations of comparative method in social science’.
International Journal of Humanities and Social Science 1 (4): 113-125.
Berenskoetter, F. (2017). ‘Approaches to concept analysis’. Journal of International Studies 45
(2): 151-173.
Gerring, J. (1999). ‘What makes a concept good? A critical framework for understanding
concept formation in the social sciences’. Polity 31 (3): 357-393.
Gwenzi, G.D. (2020). ‘Constructing the Meaning of ‘Family’ in the Context of Out-of-Home
Care: An exploratory study on residential care leavers in Harare, Zimbabwe’. Emerging
Adulthood 8(1): 54-63.
Koselleck, R. (2004). Futures past: On the semantics of historical time. Columbia University
Press.
Lori, N. (2019), Oshore citizens: permanent “temporary” status in the Gulf. Cambridge
University Press.
Manby, B. (2021). ‘Naturalisation in African states: its past and potential future’. Citizenship
Studies 25(4): 514-542.
Manohar, N., P. Liamputtong, S. Bhole & A. Arora (2017). ‘Researcher positionality in cross-
cultural and sensitive research’. In P. Liamputtong (ed.) Handbook of Research Methods in
Health Social Sciences. Singapore: Springer. 1-15.
Orgad, L. (2017). ‘Naturalisation’, in A. Shachar, R. Baubock, I. Bloemraad & M. Vink (eds.),
The Oxford Handbook on Citizenship, Oxford University Press. 337-357.
Said, E. (1978). Orientalism. Routledge & Kegan Paul ltd.
Sartori, G. (1970). ‘Concept Misformation in Comparative Politics’. The American Political
Science Review 64 (12): 1033-1053.
Van Fossen, A. (2007). ‘Citizenship for sale: passports of convenience from Pacic Island Tax
Havens,’ Commonwealth & Comparative Politics 45 (2): 138-163.
Van Fossen, A. (2017). ‘Passport sales: how island microstates use strategic management
to organise the new economic citizenship industry’. Island Studies Journal 13(1): 285-300.
European University Institute 57
Going Global
Author contacts
Émilien Fargues
Research Associate, Centre for Political Research (CEVIPOF),
Sciences Po / Research Fellow, Collaborative Institute on Migration (ICM)
Collège de France
1,Place St Thomas d’Aquin
75007 Paris
Giacomo Solano & Thomas Huddleston
Migration Policy Group
205 Rue Belliard, Box 1
1040 Brussels, Belgium
Email: mipex@migpolgroup.com
Maarten Vink
Robert Schuman Centre for Advanced Studies,
European University Institute
Villa Schifanoia
Via Boccaccio 121
I-50133 Florence
Samuel D. Schmid
University of Lucerne
Frohburgstrasse 3,
6002 Luzern, Switzerland
Rainer Bauböck
Robert Schuman Centre for Advanced Studies,
European University Institute
Villa Schifanoia
Via Boccaccio 121
I-50133 Florence
Luicy Pedroza
El Colegio de México
Carretera Picacho Ajusco 20 Ampliación,
Fuentes del Pedregal,
14110 Tlalpan, CDMX, Mexico
58 Robert Schuman Centre for Advanced Studies
Fargues, Solano & Huddleston, Vink, Schmid, Bauböck, Pedroza & Palop-García, Džankić, Mantha-Hollands
Pau Palop-García
Willy Brandt School of Public Policy
University of Erfurt
Nordhäuser Str. 63
99089 Erfurt
Jelena Džankić
Robert Schuman Centre for Advanced Studies,
European University Institute
Villa Schifanoia
Via Boccaccio 121
I-50133 Florence
Ashley Mantha-Hollands
WZB Social Science Center /
Robert Schuman Centre for Advanced Studies,
European University Institute
Villa Schifanoia
Via Boccaccio 121
I-50133 Florence
