Citizenship awards certain formal, legal rights to new members of society — such as full access to public benefits, voting rights, protection from deportation, and the right to run for public office. But it also has an important symbolic function. Citizenship helps create and cement a sense of belonging to one's adopted country, and in this way can be an important tool for immigrant integration.
Because citizenship is the most important marker of an immigrant's full and equal membership in a national society, countries have typically set requirements deliberately high for acquiring it. In recent years, these requirements have been getting even tougher, with lengthy in-country waiting periods, higher fees and standards, and a widespread adoption of citizenship tests. Many countries see redesign of their citizenship policies and practices as a way to improve the integration of society's newest members, the rationale being that more rigorous requirements ensure that new members of society have the tools needed to succeed.
At the same time, unintended effects can arise when would-be citizens are required to clear higher hurdles as part of the naturalization process. When the requirements to achieve citizenship are set too high (for example, a test demanding knowledge so detailed of the host country that even well-educated natives might fail), the citizenship process can become counterproductive, interfering with the very integration it seeks to promote. Conversely, if the conditions are too lenient, the process may not properly "signal" the importance of integration, and offers little incentive for newcomers to adapt. There is thus a tradeoff between imbuing the naturalization process with meaning by asking applicants to show evidence of their commitment to their country of settlement and erecting barriers that are so high that would-be citizens are turned away. In amending their citizenship policies, governments strike a tricky balance between providing positive incentives for immigrants to acquire the knowledge deemed most important (such as the host-country language) and enacting punitive measures (such as withdrawing benefits) to those who fail to meet certain benchmarks.
This article examines recent trends in citizenship policies and practices, and explores whether raising the difficulty of naturalization contributes to more loyal or better integrated citizens. Greater language skills, for one, have been proven a critical stepping stone to success, contributing to better educational and labor market outcomes. But there is little evidence that other measures— such as requiring deeper knowledge of history or civics, or trying to ensure country loyalty by restricting dual citizenship — have similar benefits.
The Benefits of Citizenship
National citizenship is a significant milestone for immigrants: a "rite of passage" to signal that newcomers take their rights and responsibilities seriously, and are to be recognized as full members of the community. On a practical level, providing a path to citizenship also levels the playing field, giving immigrants and their children access to the same opportunities as their native counterparts (though this of course does not guarantee equal outcomes).
Given these benefits, why don't countries simply award citizenship to everyone who meets a set of basic criteria? There is some logic to the various requirements would-be citizens are asked to fulfill. First, there are practical considerations: individuals need to be vetted thoroughly to ensure they meet certain standards and are not a security threat before being granted permanent access to a country. Also, governments want to be confident that newcomers acquire the tools needed to integrate quickly and efficiently, which has fueled the rise of language and civics tests (often accompanied by government-supported training programs).
Next are the emotional considerations. Citizenship is meant to symbolize a greater level of belonging to society: new citizens and their families will be able to shape the laws and norms in their communities for generations to come, thus policymakers establish guidelines to be certain of their character and commitment to the country.
Naturalization Requirements: A Trend toward Greater Restrictions
Countries approach naturalization in different ways, depending on their history, socioeconomic characteristics, and the political climate toward immigration, among other factors.
In the United States, the naturalization rate (about 50 percent of legal permanent residents in 2007) is considerably lower than countries such as Canada (89 percent), Sweden (82 percent), the Netherlands (78 percent), and Norway (70 percent). On the other hand, Luxembourg (12 percent), Switzerland (35 percent), and Germany (37 percent) have even lower naturalization rates. Some differences can be explained by the fact that certain countries actively promote the acquisition of citizenship. Canada is considered to have one of the friendliest systems for citizenship acquisition: the legal and administrative processes are easier to navigate, and communities as well as government institutions reinforce the message that citizenship is beneficial, accessible, and welcomed by society at large.
In some cases, anxiety that national identity is being eroded by newcomers is thought to have placed pressure on policymakers to enact greater restrictions. These have various permutations. Certain countries have increased the difficulty of naturalization requirements, some have restricted the categories of migrants eligible to access citizenship, and others have sought to restrict the behavior of immigrants during the naturalization process itself.
Citizenship Tests and Fees
Citizenship tests have long been a requirement for naturalization in most traditional immigrant-receiving countries, but have become mainstream only in the past decade. The overall trend throughout Europe has been a move toward wider adoption of tests, increasing the difficulty of the tests already in place, and standardizing the assessment process. Nor are these tests just for citizenship; some of them have now seeped into broader immigration policy, becoming requirements for permanent residence, and in some cases, for admission into a country.
While language testing is now widespread throughout Europe (in 26 out of 33 countries), assessment of country knowledge through a civics test is less common (17 out of 33 countries). All but six countries (Belgium, Cyprus, Ireland, Italy, Poland, and Sweden) have a language requirement for citizenship. The price of these tests ranges from zero (France), to nominal fees (Sweden, Canada), to what some describe as prohibitively high costs (the United States, the Netherlands, and most notably the United Kingdom). (See Table 1.)
Countries such as Denmark, France, and Luxembourg have recently increased the difficulty of their language and country-knowledge requirements. A round of reforms in France (which took effect January 1, 2012) not only revised the country's language test (formerly one of the easiest to pass) but also placed a greater emphasis on immigrants adhering to the symbols and values of the French Republic, requiring them to sign a charter outlining their rights and responsibilities vis a vis the state. In July 2012, change seemed to be imminent again. The newly appointed Interior Minister criticized the previous administration's "random and discriminatory" immigration policies and vowed to scrap the culture and history test. One of the principal complaints is the devolution of power to the local level: since 2009, naturalization decisions have been been in the hands of local prefectures, exposing what should be an objective process to a certain amount of ambiguity and arbitrariness.
Across Europe, efforts to standardize the language and civics assessment processes are resulting in a shift from interviews that give government examiners wide discretion in naturalization decisions to formal standardized written tests, which may be more difficult but are also more transparent.
Some countries have increased the amount of time immigrants must dedicate to the naturalization process. For example, in Luxembourg applicants are required to take three, two-hour civics courses.
Research on the increasing emphasis on civics has considered whether greater efforts to test immigrants' knowledge of host-country history and practices have been successful. On both sides of the Atlantic, there is evidence that native-born citizens would do worse on these tests than immigrants — or even fail. A 2011 nationwide survey in Canada showed that immigrants to Canada claim a stronger knowledge of the country's history than the native born.
The same concerns are applied to language tests, which can be both instruments of inclusion and exclusion. In 2008, the Finnish Minister of Migration and European Affairs raised a commonly voiced concern about the level of language proficiency required to ensure success in society, stating that in Finland, applicants could fail the official language proficiency test while having sufficient command of Finnish to succeed in their everyday lives.
Similarly, the United Kingdom's July 2012 proposal to overhaul its citizenship test is based on emphasizing traditional British history rather than teaching the practical details of British life (for example, requiring knowledge of the Duke of Wellington instead of information on how to read the gas meter). Critics say this is simply a coercive move designed to limit access to the United Kingdom, though the UK Home Office has defended its proposal, noting that integration is best served by putting culture and history at the heart of the citizenship test.
Another consideration is whether naturalization requirements impact different groups differently. For instance, family members in charge of child care (typically women) may have a much harder time qualifying for citizenship because of limited contact with native-language speakers and lack of access to language classes. While some technical requirements are waived for certain categories of migrants (the elderly or refugees, for instance), questions of discrimination likely could arise.
Canada, which prides itself on having one of the world's most liberal immigration systems, banned women from wearing veils while taking the oath of citizenship in 2011. This has both pragmatic motives (the necessity to be able to identify individuals during official events and to verify they are reciting the citizenship oath) as well as symbolic ones. The Canadian Minister of Citizenship, Immigration, and Multiculturalism emphasized the moral rather than practical argument, saying: "It is a matter of deep principle that goes to the heart of our identity and our values of openness and equality."
Though it has long been accepted to test knowledge of host-country norms and values (provided those tests are applied uniformly to all applicants), demands that newcomers adopt new values are more controversial.
Ancestry versus Residency Requirements
The length of residency required to become a citizen varies widely, from three years in Canada and Belgium, to ten years in Italy and Spain, and 12 years in Switzerland. Countries with traditionally liberal citizenship policies tend to have short residence requirements (France, the Netherlands, and the United Kingdom), while traditionally more restrictive regimes (Germany, Denmark, and Austria) and traditional emigration countries or new immigrant-receiving countries (Greece, Italy, and Spain) have longer requirements. Most countries now converge around the five- to eight-year residency requirement; however, there is little evidence on whether longer periods of required residency lead to a greater commitment to one's adopted country.
In some countries (such as Italy, Spain, and Greece), descendants of citizens are given an easier path to citizenship than permanent residents. Critics say long-term residents may actually have a deeper connection to a country than individuals with distant blood connections — who in some cases may simply be seeking European Union (EU) citizenship for practical reasons and have no intention of becoming a permanent part of the national community. Recently, several countries have changed their residency requirements. While Portugal, a new receiving and late democratizing state, lowered its requirement from ten to six years in 2006, Luxembourg raised its requirement from five to seven years in 2008. Some countries raise the stakes further by requiring largely uninterrupted or "continuous" residence for the specified period prior to applying for citizenship, such as the United States, Denmark, and France.
Some countries shorten the residency requirement if applicants can demonstrate through other means that they are actively trying to integrate, for instance by adopting host country norms, values, and language. In Finland, the residency requirement is lower for those who show they are "better qualified to live in Finnish society" (former Finnish citizens and Nordic citizens). In 2011, the residency requirement was also shortened (to four years) for applicants who meet the language skills requirement — an explicit acknowledgement that naturalization can be a means to support the integration of immigrants into society. Similarly, in France, the residency requirement can be reduced from five to two years if the applicant can show they received a diploma from a French university.
Vetting Prospective Citizens' Identity, Character, and Finances
Every country has a policy regarding an applicant's criminal record to ensure new citizens will not be a threat to national security. Austria and the United States have particularly strict policies, denying citizenship to those with criminal convictions or pending court proceedings. At the other end of the spectrum, Italy does not explicitly require a clean criminal record, and the assessment is more subjective. Some governments even use criminal convictions as reasons for withdrawing citizenship from individuals. In a much protested 2010 proposal, French President Nicolas Sarkozy tried to strip French nationality from immigrants who killed police or public officials, and the Netherlands recently proposed a new law to make it easier to revoke Dutch nationality for members of the Dutch diaspora should they acquire a second citizenship while abroad (other countries do this as well, though it is typically difficult to monitor the acquisition or renunciation of the second citizenship).
While some countries, such as the United States, use administrative procedures to strip citizenship acquired through naturalization for those found to have obtained it fraudulently, others have taken issue with this approach. A 1994 Committee of Inquiry in Sweden considered a provision that would have made it possible to revoke citizenship from people who had given false identifying information on their application. The committee held that doing so would create two different classes of citizenship: irrevocable citizenship by birth; and revocable citizenship by naturalization, and would not be consistent with the committee's sense of the principle of equality before the law.
Most countries also require that applicants for citizenship demonstrate stable financial conditions through evidence of income and absence of public debts. (In the United States, applicants for legal permanent residence — the step required before naturalization — can be denied if there is evidence they may become a public charge.) Additionally, countries such as Austria, Denmark, Hungary, and Ireland require evidence of independence from welfare or social benefits. Only a handful of countries do not require that applicants be financially independent; these include Belgium, the Netherlands, Norway, and Portugal.
Finally, some countries (such as Finland, Greece, Norway, and Sweden) require immigrants to provide proof of identity at the time of naturalization, in addition to what might have been required at the time of immigration. While exceptions are made for vulnerable groups (such as refugees), some countries still impose administrative hurdles beyond those required for permanent residency. The identity requirement in Norway's 2006 citizenship law, for example, is thought to have contributed to an increase in rejected naturalization applications among Iraqi residents, who may have had trouble confirming their identity. When there is a time lapse between entry and naturalization, some extra "membership requirements" may be necessary for security reasons, but can make the path to citizenship unduly long or burdensome for some immigrants.
Does Citizenship Boost Economic Integration?
The Organization for Economic Cooperation and Development (OECD) in a 2011 report found that naturalized immigrants tend to have better labor market outcomes than those who do not naturalize. However, the picture is more complex than it first appears. The relevant variable may not be citizenship per se, but the amount of time immigrants have resided lawfully in the country. The more time spent as a permanent resident (with all the rights this status implies), the more familiar individuals tend to be with the host-country labor market.
In addition, immigrants who are ¬already more likely to be successful (because they are highly motivated or well-educated) are more likely to naturalize in the first place. In essence, the OECD data point to a selection bias: the success of naturalized citizens can mostly be explained by their concrete differences, rather than the effect of citizenship itself. The OECD report showed significant differences between countries. For example, naturalization was found to have a positive effect on the labor market outcomes of migrants in the United States and Germany but not in Norway. There are several explanations for this discrepancy.
Generally, naturalization can have a positive effect because naturalized citizens are more likely to be hired and more likely to invest in integration (such as language learning) on their own. Employers tend to see naturalized citizens as better integrated (having already proven some language skills and shown motivation in the process of becoming citizens), and more likely to stay in the country for the long term. Employers may also opt for citizens to avoid administrative costs (having to verify work authorization for noncitizens). And some jobs, usually in the public sector, explicitly require citizenship status.
While citizenship may facilitate immigrants' complete access to the host country's labor market, other elements of integration policy — most notably employment and education policies — are arguably more central to success in society.
The Dual Citizenship Debate
While an increasing number of European countries accept dual citizenship, many still prohibit or limit it. Some countries only permit a second nationality with specific countries; others (such as the Netherlands) ban it completely. And some are trending in this direction (France's newly minted 2012 law states that applicants will no longer be able to claim allegiance to another country while on French soil, yet stops short of banning dual citizenship outright).
The principle of single citizenship may no longer make sense in a world in which mobility — rather than permanent migration — is becoming the norm. Increasing numbers of immigrants have overlapping ties to two (or more) countries, and about two-thirds of all states now recognize some form of dual citizenship. Advocates for dual citizenship say the need to ensure exclusive allegiances to the state — though quite potent in an era of compulsory military service — has lost relevance in today's interconnected world. Also, they add that countries may gain from allowing dual citizenship, as it gives them a way to protect the rights of their nationals abroad.
Many governments that prohibit dual citizenship on paper allow multiple exceptions in practice (typically when it comes to individuals who can prove ethnic or ancestral ties). For example, children born in Germany to foreign parents must choose between their German nationality and foreign citizenship by age 23. If they fail to renounce their other nationality, they lose German citizenship. Yet a child with German ancestry (i.e., at least one German parent) is able to keep multiple citizenships.
Finally, there is little evidence that transnational ties automatically detract from what immigrants can contribute to their adopted country, or that national identities are being weakened by the existence (or expression) of strong ethnic subcultures in advanced industrial societies. Some researchers have pointed out that forcing people to choose only one nationality may have negative consequences, such as deterring would-be-citizens from naturalizing or driving them even further from the host culture.
Empirical studies in Canada, France, and the Netherlands show that strong ethnic ties and national pride are not mutually exclusive. In the 2008 Trajectories and Origins survey (TeO) of France's National Institute for Statistics and Economic Studies (INSEE), 47 percent of immigrants to France reported they "feel French," despite maintaining ties (and even citizenship) to their country of origin. The desire to have dual citizenship may be a practical consideration (the ability to continue to own property in the country of origin, for instance) rather than evidence of split loyalties. The same study found that 90 percent of those found to have a "minority identity" (who said their ethnicity is an important feature of their identity) said they "feel at home in France," pointing to a robust new generation with "hyphenated" identities.
In such cases, banning dual citizenship produces the opposite of the intended effect, as some evidence shows that otherwise symbolic ethnic ties can become more salient precisely because they are restricted.
Striking the Right Balance
The challenge for governments is to strike a balance between policies that are robust enough to ensure immigrants acquire the tools they need to succeed, yet accommodating enough that the citizenship process does not impede the very integration it seeks to promote.
There is a fundamental tension between the different ways citizenship is used. On one hand, it can be used as a "reward," acting as an incentive for immigrants to integrate swiftly and effectively. On the other hand, it can be used in a punitive way, by withholding or restricting certain benefits to those who do not fulfill all the criteria. In both cases, the signaling effect is powerful. The existence of a path to citizenship is an important symbol of an immigrant's acceptance as a full member of society; restricting it can be seen as a coercive means of barring entry to certain migrants.
In order to be an effective integration tool, governments are turning to smart, tailored citizenship requirements as a means to genuinely narrow the gap between newcomers and natives, rather than a means to exclude certain individuals from accessing the full benefits of society. But in an era of unprecedented diversity in which citizenship policy can play a crucial role in promoting social cohesion, countries are increasingly rethinking what they can reasonably ask and expect from newcomers, and what is gained from each requirement.
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