Citizenship, particularly how to acquire it, is a deeply sensitive issue for the European Union, and Member States hold dear their sovereign right to determine who should become a national. Whether, and how, a non-national is allowed to join the national club has also been much debated within national polities. However, there has been strong resistance by Member States towards any discussion of citizenship acquisition at the EU level, despite some outré national policy changes in recent years. A recent decision by Malta’s government to sell 1,800 passports (initially for 650,000 euros and later upped to 1.15 million euros in cash and investments) has caused unusual levels of furor in the tiny Mediterranean country, a resolution in the European Parliament, and a move by European Commissioner Viviane Reding to seek legal advice as to whether she has the power to prevent the programme. It would seem that this scheme has become the straw that breaks the camel’s back. And if so, why, and is it the price, or the value, of citizenship that is in question?
Citizenship policies vary widely across the European Union. While some Member States set high barriers to acquisition, others have more relaxed approaches. Across Europe, waiting times vary from three to ten years, and some, but by no means all, countries test would-be citizens on their language and civic knowledge. These policies can be paradoxical, and are deeply political. In Italy, a resident immigrant must wait a decade before being able to apply for citizenship. However, descendants of Italian emigrants, with few or no ties, can apply for citizenship without ever needing to set foot in the country. This dichotomy reflects a strong mistrust of immigration to Italy, at odds with the country’s proud history of emigration.
At the EU level, citizenship is mostly relevant only as far as it offers a right of free movement and residence across Europe, and EU law is clear that Member States are free to make their own rules as to who is eligible. The rights of free movement have been bitterly debated over the past months, particularly with respect to access to benefits, but the concept of citizenship itself has been left to one side. In 2011, a new Hungarian citizenship law stated that any ethnic Hungarians (descendants of Hungarians who were citizens before 1920), may apply for citizenship, in effect offering citizenship to large numbers of neighbouring state populations, including Moldova, Ukraine, Serbia, Slovakia, and Romania. The new rules reflected the nationalist approach of the ruling government; while they caused a political furor in neighbouring Slovakia, little was said in Brussels.
Responding to criticism, the Maltese government has been at pains to demonstrate its scheme is not unique (and even handed out lists of similar programmes to journalists at a 15 January Parliamentary hearing where the issue was discussed). Indeed, a plethora of investor visa programmes exist in Europe, which offer permanent residence to those willing to deposit large sums of money into property or government bonds, or even a simple bank account. In Latvia, for example, permanent residence could be obtained in 2013 through the purchase of (rural) property to the value of just 72,000 euros, a far lower price than that of the Maltese (the Latvian threshold has now doubled, in part due to public concerns). Whilst only visas and permanent residence are on offer in Latvia, it is implicitly understood that this is also a fast track to citizenship, security, and free movement.
But why has the direct valuation of citizenship and its benefits become so repulsive to other policymakers? The number of places on offer is negligible, and will not affect free movement flows to any great degree. Presumably, individuals capable of buying their citizenship will not be accessing welfare systems in Malta or elsewhere, and security and criminal checks have been put in place to keep out undesirables. And arguably, the ease with which distant descendants of European emigrés can access citizenship is equally distasteful: allowing those with no links, no term of residence, and no language knowledge to acquire citizenship just as easily, and more cheaply.
Is the issue one of wealth, and the blunt method in which the Maltese government has distinguished migrants according to their finances? Some have criticised Malta for detaining migrants arriving by boat from North Africa, whilst welcoming those with attractive bank statements. But this too is nothing new. Most countries across the EU apply ‘selective’ immigration policies, preferring those with university degrees and skills, and allowing family migration only when it is clear that the sponsoring individual can support family members financially. Immigration systems across the industrialised world categorise migrants according to desirability and, in the case of asylum seekers and refugees, need. Those with human and financial resources tend to be the most desirable.
In fact, the issue may be deeper, and the Maltese initiative has thrown into relief the nature and value of citizenship in a mobile world. The idea that citizenship is a prize, to be valued and respected, is reflected in the tests immigrants are willing to undergo to qualify, and the ceremonies that many enjoy when citizenship is bestowed. Some rules are needed to ensure that citizenship remains meaningful to those who hold it, even those who have dual- and triple-citizenship. Whilst some may acquire citizenship for the passport (and ensuing visa-free travel), others may be seeking access to secure residence in stable prosperous economies with greater rule of law and less capricious governance. But citizenship is more than immigration policy, and should not be viewed in terms of access alone. Citizenship also creates a contract with the national policy and society, and bestows responsibilities such as political participation, and social contribution. This bond cannot be financially assessed.
The mere fact of placing a price on citizenship can paradoxically devalue it. Investor visas—though requiring money—are intended to draw new residents in, with the hope that they will contribute to the future growth of the country. In the United States, Canada, Australia, and the United Kingdom, consideration has been given to the type of investment, and the multiplier effects of that investment on the local community and national well-being. But citizenship sales require nothing of the recipient beyond cash, whilst offering the most precious thing a country has to give, its identity. An uneven bargain.
Elizabeth Collett is Director of the Migration Policy Institute Europe and is Senior Advisor to MPI's Transatlantic Council on Migration. She is based in Brussels, and her work focuses in particular on European migration and immigrant integration policy.