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date: 17 February 2018

Comparative Immigration Policy

Summary and Keywords

The research on comparative immigration policy is relatively recent, with the earliest dealing with significant immigrant inflows into Western Europe after World War II. Because of the difficulties in finding empirically grounded measures of immigration policy, the literature has grown primarily by adding to the theoretical literature. In terms of the immigration control literature, nativism (anti-immigrant preferences) has been complemented by approaches that include attention to the economic consequences of immigration, focus on how societal preferences are channeled, and focus on state national interest and state security. In terms of the immigrant integration literature, there has been a tendency to classify the immigrant reception environment of states according to historical nation building features of the state and to types of “immigration regimes.” More recently, in recognition of the static nature of these models of policy making, scholars have disaggregated integration policy into its component parts and incorporated aspects of politics that change over time. The research arena is, in short, theoretically rich, though both dimensions of research on immigration policy suffer from two flaws. The first is the inability to compare effectively policies across countries. The second is the research focus on Western Europe and advanced industrial countries, to the neglect of the remaining countries in the world.

Keywords: comparative immigration policy, immigration, immigration policy, immigration control, immigrant integration, nativism, immigrant reception environment, nation building, immigration regimes


Comparative immigration policy is a broad topic with many different and important foci, addressed by scholars from many different disciplines. Given the rich research agenda, it is important to clarify the content of this essay. I provide an overview of the literature on state immigration policies toward voluntary migrants, that is, the choice of government policy to open or close the door to voluntary migrants, rather than the impact of those policies on migrants, or on the home and host communities. The determinants of migration itself and all reference to the literature on forced migration and policies covering asylum seekers and refugees are excluded as well.

Immigration policy has often been described as having two components, immigration control and immigrant integration, a distinction popularized by Tomas Hammar (1985; 1990). In this essay, I present the research on both dimensions. US scholarship on immigration policy has a rich and long history, consistent with the United States’ long history of immigration. The research on comparative immigration policy is more recent, with the impetus for scholarly research beginning with significant immigrant inflows into Western Europe after World War II. The comparative research has built on country analyses; the single country contributions are enormous and referred to only where they lend to theory building and theory testing in a comparative context.

Because of the difficulties in finding empirically grounded measures of immigration control and of integration, the literature has grown primarily by adding to the theoretical literature. In terms of the immigration control literature, the nativism (anti-immigrant preferences) referred to in Higham's (1955) work has been complemented by approaches that include attention to the economic consequences of immigration, both in the labor market and in social welfare policies, institutional approaches that focus on how societal preferences are channeled, and most recently, approaches that focus on state national interest and state security. In terms of the immigrant integration literature, there has been a tendency to classify the immigrant reception environment of states according to historical nation building features of the state and to types of “immigration regimes” that arose in the post–World War II period in countries that experienced immigrant inflows. More recently, in recognition of the static nature of these models of policy making, scholars have disaggregated integration policy into its component parts and incorporated aspects of politics that change over time, such as the composition of the governing coalition and the salience of the political debate.

The research arena is theoretically rich but, I argue, both dimensions of research on immigration policy suffer from two flaws. The first is the inability to compare effectively policies across countries. The absence of agreed measures to compare policies across countries prevents researchers from generating insights into generic political processes that drive immigration policy. The second is the research focus on Western Europe and advanced industrial countries, to the neglect of the remaining countries in the world. Given that more than half of all global migration takes place outside of the “developed” countries (Castles and Miller 2003), this is a serious oversight that constrains our ability as researchers to both generate and test theories purporting to explain government policies.

There are several review essays that are well worth while in obtaining a variety of lenses on the state of the research. Eytan Meyers’ (2000) contribution in International Migration Review provides a clear summary and evaluation of the theoretical approaches to immigration control. Erik Bleich's (2008) World Politics article outlines different types of intellectual contributions provided by researchers and points to the potential for broader contributions of political scientists. Gary Freeman's (2004) article provides a thorough overview of the theoretical literature on immigrant integration; Terri Givens’ (2007) article focuses on empirical research on that topic; Jeffrey Reitz (2002) discusses the research agenda and methodological issues. There are also numerous edited volumes that provide overviews of states’ immigration control and integration policies. For immigration control, see, among others, Böhning (1972), Kubat (1979), LeMay (1989), Thränhart (1992), Baldwin-Edwards and Schain (1994), Cornelius et al. (1994), Fassman and Munz (1994), Brochmann and Hammar (1999), Cornelius et al. (2004), and Triandafyllidou and Gropas (2007). For immigrant integration, see, among others, Hansen and Weil (2001; 2002), Aleinikoff and Klusmeyer (2002), and Bauböck et al. (2006).

State Admission and Control Policies

Immigration Control

The dominant trend in research is to look at domestic political factors as the central force driving the degree of state openness to immigration. In the United States, one of the seminal examinations of anti-immigrant sentiment was published by John Higham in 1955. Nativism is the driving force in his description of the public and political response to foreigners. That line of research has been extended specifically through analysis of public opinion and is evaluated in a separate contribution to this Compendium. Yet our knowledge of the public's attitudes toward immigration is only a starting point, as it is generally held as a latent opinion and, although it is generally negative, it is usually not the issue on which most citizens in democratic societies decide their vote. We need to know when the public becomes organized as a political actor, through political lobbies, social movements, citizens’ initiatives, or anti-immigrant political parties. And we need to know the institutional conditions under which these organized interests actually have an impact on the political outcome. And this is only one possible domestic political force. Thus, different lines of research have been pursued.

National Identity

Rather than focusing on public opinion per se, and differences in public opinion among nations and changes over time, analysts of immigration policy often consider “national identity” a primary determinant of immigration policy. No modern society permits open access to all comers. This closure reflects a widespread perception that “the central values and ethos that characterize one's society could be diluted by the entry of individuals and groups who do not share them” (Bhagwati 1984:681). Nonetheless, societies appear to have different levels of tolerance for foreigners, and “perhaps the most fundamental factor” in defining that level of tolerance “is how the country regards itself – its own national mythology” (Stalker 1994:138). Analysts who work in this tradition are generally country specialists; those who examine immigration control from a cross-national perspective tend to incorporate additional economic variables into the analysis. Nonetheless, the comparativists provide a good overview of the logic propounded by country experts.

Leitner (1995:262), for example, argues that “dominant racial and national ideologies, defining who belongs and who does not belong to a national community, also influence who is admitted.” In other words, nations have characteristics that make it more or less easy for the indigenous population to accept a resident alien population. National character or identity has been defined in a variety of ways. One method is to evaluate the homogeneity of the population, assuming that the more ethnically homogeneous the country, the more the citizens will be threatened by an influx of foreigners. According to Zolberg (1981:16), “given an equal challenge, the degree of tolerance of cultural diversity may vary as a function of the character of the receiving society. A highly […] ethnically undiversified nation with a dominant religion and which as a consequence of its insularity has experienced little immigration in the recent past, may have a lower threshold of tolerance than a more heterogeneous one, whose identity may have come to be founded on political rather than ethnic criteria.”

Alternatively, a distinction can be made on the basis of concepts of citizenship. Leitner (1995:262) states that “principles of citizenship, as laid down in nationality laws, are one expression of dominant national ideologies since they define what constitutes a nation and the relationship between state membership and nation membership.” Where citizenship is based on a common history and tradition, language, religion, or racial characteristics, there should be a low tolerance for immigrants. On the other hand, where citizenship is defined by political participation, tolerance of migrants should be greater (also see Meissner 1992).

Finally, identity may be historically rooted in a nation's colonial past, where national identity encompasses the larger colonial and postcolonial communities. Analysts suggest that nations with a colonial history have ties and commitments that tend to define a special relationship to former colonies and require them to accept greater levels of immigration than would otherwise be anticipated (Foot 1965; Hammar 1985; Layton-Henry 1985; Paul 1997). That is, “colonial experiences and ideologies shaped immigration decisions primarily, but not exclusively, by making these decisions more liberal than they would have been otherwise” (Freeman 1979:314).

Economic Interests

Theories that focus on national identity are complemented by theories that recognize that voluntary migrants are usually economic actors who may have distributional effects on other economic actors in the host country. Because migrants participate in the host economy, one group of analysts seeks the determinants of immigration control policy in the preferences of economic actors within the host society. Actors’ preferences are attributed to the differential economic impact of immigrants on groups in the host society. One line of analysis emerges from the Marxian tradition (Castles and Kosack 1973; Castells 1975; Petras 1981). From this perspective, migrants represent a surplus pool of labor that helps to discipline the indigenous working classes and to overcome crises in the capitalist system. But the demand for migrant labor is not constant, especially in welfare states where capitalists have maintained control via the quid pro quo of state-supported benefits in the indigenous labor force. Capitalists need a labor force that can be easily mobilized and just as easily disbanded when conditions warrant. Because “capital accumulation does not proceed at a steady and even pace, […] capital needs to have this [migrant] labor surplus to use, at its disposal, only to discard it when it is not required for production” (Petras 1981:48).

Another line of analysis focuses on the growing inflexibility of labor markets in advanced industrial countries as a result of union efforts to remove the native workforce from the vagaries of the market. Employers respond by hiring a second tier of workers, unprotected by work rules and union guarantees, thereby creating a segmented or dual labor market (Piore 1979). Immigrants are sought for this secondary labor market to provide the flexibility lost as a result of labor market regulation and to fill the jobs abandoned by the native workforce.

Of course, employers may not be the only political actors to organize. The question is: who is economically harmed by immigration? Leitner (1995:262) suggests that “labor unions might be opposed on the ground that this will harm workers’ wages and working conditions.” Shughart et al. (1986:30) also describe “the desire of organized interests groups to influence domestic wages.” Alternatively, labor is viewed as benefiting from immigration. If the dual labor market hypothesis is correct, immigrant labor tends to complement rather than compete with the indigenous workforce and enhances rather than detracts from the return to native workers. Gary Freeman (1995) reports that “the most significant organized counterpoint to [migration] has traditionally been labor unions but they have generally come to support immigration, resigning themselves to defensive rather than restrictive measures.” And Leah Haus (1995) and Julie Watts (2002) point out that unions may favor immigration as a method of maximizing their interests of increased union membership. Both in Europe and the United States, organized labor's opposition to immigration has shifted since the 1980s to one that focuses on organization of the immigrants themselves.

In summary, political economists focus on immigrants as economic actors who may have distributional effects on other economic actors in the host country. In general, employers are viewed as uniformly benefiting from immigrant labor, although their demand for immigrant labor may vary with labor market conditions. The position of workers appears to be more varied, ranging from opposition to neutrality to positive support for immigration.

Organizational and Institutional Filters

A small but growing cohort of political economists is attempting to incorporate the political process through which societal preferences are channeled (Ireland 1994; Soysal 1994; Freeman 1995). Freeman (1995) argues that immigration creates both concentrated benefits and diffuse costs. The recipients of concentrated benefits include employers, ethnic advocacy groups, and civil and human rights organizations. Because benefits are concentrated, these groups are more easily able to overcome the costs of collective action and organize to press government for openness to immigration. Diffuse costs are spread over the public as a whole, giving rise to anti-immigrant sentiments in popular opinion. But because the costs are diffuse, it is difficult for the public to organize and petition their representatives. Hence immigration policy is based on a clientelistic relationship wherein politicians respond to organized interests and ignore unorganized interests; immigration policy should therefore have a liberal bias.

An alternative explanation of a perceived liberal bias in immigration policy comes from James Hollifield (1992). Hollifield is one of a growing group of authors who emphasize the liberal nature of the state in advanced industrial societies and the concomitant extension of human rights to residents of these states, whether citizen or alien (Weil 1991; Cornelius et al. 1994; Soysal 1994). When market tendencies come in conflict with these human rights, the rights triumph. Hollifield (1992:216) argues that market forces accounted for the rise in immigration in the 1960s and early 1970s. When economic conditions turned sour following the 1973 oil shock, the “protection given to aliens in rights-based regimes” accounted for the persistence of immigration “in the face of economic crises, restrictionist policies, and nationalist (anti-immigrant) political movements.” In fact, the judicial branch of government may be the crucial policy making arena, constraining politicians’ ability to respond to domestic political interests.

Moving from the delineation of actors’ interests in the political arena, Money (1997; 1999) points out that actors’ interests are filtered through domestic political institutions. The argument is based on the geographic concentration of immigrants, which gives rise to geographically specific interests, who may organize, both to promote and to oppose immigration. Domestic political institutions are critical for understanding how national political coalitions are constructed. Only when local interests (pro- or anti-immigrant) are critical to constructing a national political coalition will these interests be turned into policy outcomes. Rosenblum (2003) also privileges state political institutions as an important component of the policy process.

The State, National Interest, and Security

The focus on domestic politics, domestic political actors, and political institutions has been contested by those who see the state as a central political actor and immigration as a national interest. Myron Weiner (1993) was one of the earliest scholars to connect immigration and security (also see Weiner and Russell 2001). A more systematic theoretical development of the connection between immigration and security is by Christopher Rudolph (2003; 2006). Rudolph broadens the definition of state interest to include three dimensions: military defense, economic productivity, and domestic stability or “societal security,” and he argues that states’ grand strategy is responsive to the threat environment. Specifically, Rudolph argues that high international threat causes states to prioritize the military dimension of security and the concomitant need for economic wealth; thus the migration policy complex is characterized by relative openness (also see Meyers 2004). As external threats decline, societal security rises on the state agenda, and grand strategy is modified to increase (at least the image of) border control and to facilitate immigrant integration into the nation (also see Alexseev 2006 on immigrants as an internal security risk). This proposition is labeled the “threat hypothesis.” It is complemented by the “rally hypothesis” that connects high external threat to enhanced group cohesion which facilitates the state's response to external threat. Rudolph also incorporates a constructivist frame, positing that ideas are important in the construction of grand strategy, and brings in feedback loops that link policy choices in prior periods to the policy environment in the current period.

Anthony Messina (2007) also privileges the state in his most recent contribution to the scholarly debate. He, too, points to the macroeconomic and political interests of the receiving countries, although rather than grand strategy, the state serves its interests by adjudicating the claims of various domestic actors. It is “political logic” of the state that is the dominant force defining policy choices.

More recent analyses evaluate the impact of the changing security climate on immigration policies, in light of the September 11 terrorist attacks in the United States, which echoes the focus on states’ national security as national interest. Givens et al. (2009) provide an edited volume that focuses specifically on the impact of September 11 on Western democracies. They conclude that, although rhetoric has changed, actual immigration policies have failed to change in any systematic way. In a second edited volume, Chebel d'Appollonia and Reich (2008) note the linkage between immigration and security in Western democracies, which they label the “securitization” of immigration. They argue that these public debates ignore the relationship to immigrant integration. Social exclusion of immigrants and their descendants suggests that security threats may be both domestic and international; policy prescriptions that focus only on international threats ignore an important area of public policy: immigrant integration. Moreover, the emphasis on security has often worsened, rather than ameliorated, the conditions of immigrants in the host states, working counterproductively to aggravate, rather than reduce, the security threat. This synthesis of immigration, security, and integration is important and is mostly overlooked in the research on immigrant integration addressed below.

International Pressures

Finally, Soysal (1994) is one of several authors who look to the international system as the source of change in immigration policy rather than to domestic politics. Human rights regimes to which states adhere force states to adopt immigration policies that may be at odds with domestic interests and/or actors. There is also a growing literature that examines the role of the European Union in both immigration control and immigrant integration in member states (see, among others, Geddes 2003; Guild 2004).

Disaggregating Immigration Flows

Researchers have also attempted to disaggregate strands of immigration streams and to argue that each type of migration access policy has a different political source. Gary Freeman (2006) has extended his cost/benefits model to include the full array of combinations of concentrated/diffuse benefits and costs and argues that each combination is reflected in the politics associated with different immigrant streams. Marc Rosenblum (2003) also bridges the economic/security divide in the literature, arguing that some immigrant streams are associated with the national interest and that these streams are governed by the executive branch rather than the legislative branch.

Empirical Evidence

The literature on immigration control thus has a number of competing and/or complementary hypotheses about the sources of domestic actor interests, the institutional constraints that these actors face, the role of the state protecting its own national interest, as well as the role of international forces. These are all plausible hypotheses and each of the researchers has brought to bear evidence consistent with the theoretical framework. However, the field has failed to sort among these theories to determine which provide the most explanatory weight, which provide idiosyncratic leverage in particular country cases, and which fail to provide any theoretical leverage at all. One central problem, alluded to in the Introduction, is the lack of agreement on empirical referents that can be compared across nations. Tellingly, there is still substantial debate among researchers in the field about whether the levels of immigration currently experienced by advanced industrial countries are large or small (Cornelius et al. 1994; Freeman 1995; Cornelius et al. 2004).

There are few cross-national quantitative analyses that attempt to sort among the various theories. Money (1999) and Rosenblum (2003) employ the annual per capita gross flow of legal resident aliens as a reflection of state policy for Western democracies. That choice of dependent variable has been controversial, but carefully defended by its proponents. Although the data are imperfect, they are a first step in evaluating the many competing hypotheses. The analyses suggest that domestic economic factors, in particular unemployment rates, are important, although the political processes through which the economic variable is translated into policy remain unclear. Political institutions may also be important but, thus far, cultural and international forces do not appear to play a role. The security hypotheses are not yet systematically tested and certainly warrant a new look with the available data. Moreover, before discarding the rich theoretical frames offered in the literature, we should think about alternative measures of immigration control policy and evaluate the robustness of the initial findings in light of alternative measures. Batalova et al. (2008) discuss some of the issues raised by comparative data collection.

A second problem with the immigration control research agenda as it currently stands is its focus on advanced industrial countries and, in particular, on Western Europe. Both quantitative analyses referred to above include only wealthy Organization for Economic Cooperation and Development (OECD) countries. It is important to theorize how developing countries and nondemocracies deal with immigration admissions and to test these theories with common empirical referents. By increasing the variation on the independent and dependent variables, we are able more effectively to develop robust accounts of the political forces driving immigration policy.

State Sovereignty and Contemporary Migration Flows

The comparative work described above focuses on state choices over migration flows rather than the ability of the state to implement those policy choices. However, there is an ongoing debate about whether or not states are actually able to implement their policy choices or whether states have lost control over their borders and state sovereignty is challenged. Cornelius et al. (1994) argue that states are unable to control immigration and offer the “gap” hypothesis, that is, the gap between the level of immigration states desire and what they are able to achieve. Their hypotheses are echoed by Sassen (1998), among others, who describes the transnationalization of immigration policy. On the other side of the debate, Freeman (1995) argues that continued state openness is a result of domestic political pressures for liberalization. Joppke (2003a) echoes and expands Freeman's analysis by describing “self-limited” sovereignty imposed both by domestic political actors and domestic political institutions, with particular emphasis on the role of the judiciary in expanding immigration flows. Anthony Messina (2007) also weighs in on this side of the argument in his most recent overview of immigration politics in postwar Europe.

The continued openness to immigration is visible in the efforts of most wealthy democratic states to attract high-skilled labor, an effort that has been described as a competition among Western democracies. Cornelius et al. (2001) describe the various flows, focusing primarily on the United States and the H1B program that permits workers with high education levels (college degree) to enter on a temporary basis. Their explanation of openness harks back to Freeman's (1995) interest based approach that focuses on employer demands associated with globalization and international competition. Adrian Favell and Michael Peter Smith (2006) also address this global phenomenon and the various dimensions of economic and social implications.

A second example of states’ interest in expanding immigration is for co-ethnics. One example is Israel but there are many less well known examples, including the United Kingdom and Germany. The research on return migration or ties between the host nation and its emigrants is still in its infancy. Joppke (2003b) proposes the term “re-ethnicization” to describe state policies that facilitate the return of emigrants/ethnic compatriots, even after generations abroad. He explains this phenomenon by reference to globalization and patterns of migration generated by globalization, both out-migration and in-migration. Most of the focus above has been on in-migration. Joppke rightly points out that emigration is the other side of the coin and that those countries that receive a large share of immigrants are also characterized by emigration. The second factor Joppke points to is the presence of a right or conservative party in government that, with its nationalist focus, seeks to expand these ties by making citizenship easier to retain or regain.

Skrentny et al. (2007) provide a comparison of such policies in Asia and Europe and argue that Asian states have an economic interest in retaining or renewing ties with co-ethnics abroad while European states do so to assist co-ethnics abroad.

The research on skilled migration and coethnics echoes the research agenda of both Rosenblum and Freeman who, as noted above, suggest that we need to disaggregate different migration streams to evaluate whether the policies governing those streams are driven by distinctive political forces. It might also help resolve the debate over state sovereignty. It could be that states remain sovereign in some areas but that sovereignty has been chipped away in other areas. Alternatively, as Massey (1999) suggests, based on the structure of domestic political institutions, state capacity, and hence state sovereignty, varies among states.

This is an arena that is fruitful for further research. It will take the focus off Europe and place it in the developing world, where outmigration is now widespread and, in some cases, supported by the state as part of a development strategy. Again, the variation among countries, of both the developed and developing world, will help researchers both generate and evaluate theories more effectively.

In summary, the research agenda on immigration admissions and control has been theoretically rich but hampered by the lack of agreed upon empirical referents to evaluate explanatory variables. Moreover, the overwhelming focus on Europe and advanced industrial states means that our understanding of immigration policy is limited to only half of the global immigration streams. It is certainly possible that policy development in nondemocracies and developing countries differs in systematic ways from policy development in advanced industrial countries. Although there are now a number of case studies of non-Western countries, the comparative analyses that exist are few and recent (see for example, Richards 1983; Findlay et al. 2000; Zlotnik 2003; Baldwin-Edwards 2005; 2006). Nonetheless, since half of global migratory streams end up in places other than Western democracies, we cannot claim to understand comparative immigration policy until we broaden our research lens.

Immigrant Integration


The integration literature starts with definitional issues, with a recognition that integration has two components, the policies of the state that govern the treatment of immigrants and the choices immigrants make in adapting to their host country. The largest part of the research on immigrant integration focuses on the degree to which immigrants come to resemble the population of the host state, with state policies governing integration taken as facilitators or barriers to integration. There is much less research on what determines those state policies. Because the focus of this essay is immigration policy, I focus on the research that examines the determinants of state policies toward migrants. I divide this literature into two categories, the burgeoning research on citizenship policy and on the broader set of state policies that govern treatment of immigrants relative to the citizen population.


Although there are some scholars who bemoan the devaluation of citizenship (Aleinikoff and Klusmeyer 2002), it is widely recognized that admission to citizenship is the measure of full membership in the polity that comes with access to all the benefits available to citizens, as well as protections, such as the protection against deportation. There are a number of useful compendiums, describing citizenship laws in advanced, industrial democracies (Brubaker 1989; Bauböck 1994; La Torre 1998; Schuck 1998; Castles and Davidson 2000; Hansen and Weil 2001; 2002; Kondo 2001; Aleinikoff and Klusmeyer 2002; Iredale et al. 2003; Koopmans et al. 2005; Vink 2005; Bauböck et al. 2006; Schierup et al. 2006; Tsuda 2006) as well as individual country studies, which are too numerous to cite. Each of these compendia offers country-specific accounts of the changes in citizenship policy but there is little by way of systematic comparative analysis. The comparative literature on the determinants of citizenship policy is remarkably thin.

The benchmark research that all subsequent scholars refer to is that of Rogers Brubaker (1990; 1992), who dichotomizes state treatment of immigrants into jus soli and jus sanguinis policies. Jus soli refers to the attribution of citizenship by birth on the territory of the state, with the United States being a prominent example of an unrestricted jus soli state. Jus sanguinis refers to the attribution of citizenship through blood lines, that is, through the citizenship of the parent.

Brubaker takes France and Germany as two ideal-typical cases of jus soli and jus sanguinis and traces the adoption of these distinctive policies, referring to the challenges of nation building during the nineteenth century. France, a state in search of a nation, developed a civic and political definition of citizenship that made citizens out of residents, using the homogenizing forces of military service and public education to construct the French citizen. Germany, a people in search of a state, developed an ethnic and cultural definition of citizenship that formed the basis of gathering the people into a territorially defined state. Nation building and the associated definitions of citizenship informed state policies that governed the access of foreigners to citizenship, whether they were immigrants themselves, or their offspring born in the host country. The restricted jus soli provisions of France granted citizenship to children of aliens born in France, upon reaching majority (given certain residence requirements). Children of aliens born in France to alien parents also born in France are French citizens at birth (double jus soli). Naturalization requirements are relatively modest. Germany, on the other hand, until the citizenship reforms of the 1990s, provided no form of jus soli, generating a large and growing population of second and third generation “aliens,” who could only be granted citizenship through onerous, discretionary naturalization procedures. By extension, other European states could be analyzed as falling closer to one type of nation building or the other (see also Favell 2001).

Brubaker had the fortune (or misfortune) of analyzing citizenship policies prior to the quite dramatic citizenship reforms in Germany during the 1990s, which brought prominence to the changes in citizenship law over time, in response to the growing immigrant population in Europe as well as the growing politicization of immigration as a public policy issue. The more recently published compendia cited above trace national changes in citizenship law. Christian Joppke has theorized about its determinants in several articles and books. The general theme of Joppke's (2003b) theoretical article points to the forces of globalization that generate increasing levels of both in-migration and out-migration, as well as the growth of human rights norms and liberal democratic values. These global forces are filtered through domestic political systems in advanced industrial democracies, with parties of the left promoting “de-ethnicization” and parties of the right promoting “re-ethnicization.” Left parties, with their egalitarian ideologies, promote reforms that make citizenship more easily available to foreigners. Right parties, with their nationalist ideologies, promote policies that strengthen ties with their compatriots abroad. Joppke reinterprets policy changes in both Germany and France in light of this theoretical framework, as well as extending the framework to deal with other European countries, including Italy and Spain. However important his examples are, though, there is no systematic analysis of all European countries, or all liberal democracies, leaving this to future research.

This is certainly Marc Howard’s starting point, in a 2007 article on comparative citizenship. Taking all 15 countries of the “old” European Union, Howard develops a quantitative measure of the degree of restrictiveness of citizenship policy for the 1980s and the 1990s. His research advances the agenda in two distinctive ways. First, Howard points out that the pressures for liberalization are not evenly felt by all countries, as some nations started the period with more liberal citizenship policies. States with a colonial history and an early experience with immigrants developed relatively liberal citizenship policies and therefore do not need to liberalize. States with restrictive laws are the ones to feel the pressures for liberalization. According to Howard, elites are predisposed to liberalize policies but cannot always do so. Active right-wing anti-immigrant parties or groups that politicize the immigration issue prevent elites from liberalizing policies. The presence or absence of policy change in most of the restrictive states in the EU-15 can be accounted for by the presence of significant right-wing parties and politicized immigration debates. Howard argues persuasively that the left–right distinction made by Joppke is less effective in elucidating change and stasis than right-wing party presence.

All three contributions move the research agenda forward but all three take the experience of the European states, or more broadly, advanced industrial democracies, as the starting point. Yet issues of citizenship are universal in the modern state system and migration is global in nature. This suggests that we need to be able to compare citizenship policies across all states and that we need to develop theories that are more generic than those generated by the European experience alone.

Three quantitative articles, all unpublished, move the research agenda in this direction. Money (2002) develops quantitative indicators for four types of citizenship rule: naturalization (of foreign adults), access to citizenship for children of nationals, access to citizenship for children of foreigners, and special rules for women. Two data sets are generated from global surveys of citizenship laws (Flournoy and Hudson 1929; United Nations 1954). The global, cross-national analysis of citizenship policies indicates that there is very modest correlation between the four dimensions of citizenship policy and that changes in the four dimensions appear to be driven by different factors, although Money does not propose a general theory of citizenship.

Graziella Bertocchi and Chiara Strozzi (2006) also generate a global database of citizenship policies at three periods in time: 1948, 1975, and 2001, although they propose a trichotomous variable rather than a scale reflecting the wide variation in policies that Money observes. They analyze a wide array of explanatory variables and find that jus sanguinis as the initial citizenship law reduces the likelihood of liberalization; that decolonization decreases the likelihood of liberalization; that jus sanguinis countries with a large migrant stock are more likely to liberalize; that demographically old countries are more likely to liberalize; and that democratic countries are more likely to liberalize. Moreover, they find that cultural variables do not affect citizenship policies. Their research is an important starting point but is hampered by a rather blunt measure of citizenship policy and does not theorize about the politics of citizenship policy – there are no political variables other than the level of political rights.

Jennifer Seely (2007) collects time-series cross-sectional data for all sub-Saharan African countries since independence, using Money's scale. This is an effort, like the global efforts above, to take citizenship policy and citizenship theory outside the context of the nation-states of Europe. She finds that the factors that account for the degree of restrictiveness in citizenship policy are different for children than for adults. For children, basic demographic factors indicating the scarcity of resources are prominent explanatory variables: population density is positively related to restrictiveness; annual rainfall and ethnic fragmentation are negatively related to restrictiveness. Democracy is also negatively associated with the degree of restrictiveness. For adult naturalization, population density is also associated with more restrictive naturalization laws; however, democracy works in the opposite direction, with greater levels of democracy associated with more restrictive policies (providing indirect support for Howard's hypotheses relating to politicization of immigration issues). Laws passed in the 1980s, Africa's “lost decade,” are, on average, more restrictive.

The research agenda is moving forward in a productive way. The references to two ideal types of citizenship policy, jus soli and jus sanguinis, are fading. There are at least three methods for comparing citizenship across states that reflect wider variation in citizenship policies (Money 2002; Bertocchi and Strozzi 2006; Howard 2007; also see Koopmans et al. 2005). Comparisons should be made to determine if these scales are highly correlated and whether the different dimensions of citizenship policy are usefully disaggregated. Yet the determinants of citizenship policy remain undertheorized. Theories that are generated by the European experience should be tested on a broader data set. New or extended theories should also be developed that focus on the incentives of politicians to expand or contract the citizen population.


Beyond full admission to the polity and equal treatment of immigrants as citizens, there is a wide variation in the degree to which immigrants are granted some of the rights of citizens. Denizenship is a term popularized by Hammar (1985; 1990) and indicates the type of reception immigrants receive upon arrival. There is a wide array of rights that non-citizens may have: rights to judicial system; access to the labor market; right to organize; right to represent workers; access to welfare provisions of the state; access to public goods such as education. Resident aliens also may be protected against discrimination through legislation or, more proactively, invited to retain their linguistic and cultural heritage. These rights and privileges vary across states and across time. Some states, such as Sweden, not only facilitate naturalization and recognize dual citizenship; they also provide most of the rights available to citizens to Swedish residents (jus domicile). Other states, such as some Gulf oil states, provide few rights to resident aliens.

An early description of the status of foreign minorities in Europe is contained in Glebe and O'Loughlin's (1987) edited volume. Barbara Schmitter Heisler surveys the generic issues generated by a resident alien population (1992), and Daniel Kubat's (1993) edited volume places issues of settlement and integration on the research agenda heretofore dominated by a focus on immigration control (see also Castles 1995; Miles and Thranhardt 1995).

Until recently, the main way of analyzing the variations in immigrant reception was via typology. Castles and Miller (2003) propose a trichotomous scheme: the differential exclusionary model, the assimilationist model, and the multicultural model. The differential exclusionary model represents a state policy that provides little labor market mobility, trapping immigrants in segments of the labor market that pay poorly and are often dirty and dangerous. State policy also tends to segregate immigrants residentially through social housing policies and to discriminate in the provision of social services. Finally, these states make acquisition of citizenship difficult both for the initial immigrants and for their children. Austria, Switzerland, and Germany, before its citizenship reforms, are often given as examples of differential exclusionary states.

The assimilationist state attempts to incorporate immigrants, but only if the immigrants are willing and able to adopt the linguistic and cultural traits of the nation. Although all immigrants experience labor market segmentation, the assimilationist model suggests that those immigrants that individually fulfill the requirements of assimilation will be able to move more freely in society. Social policies promote language learning and mainstreaming of immigrant children into the school system, so they can learn the social mores of the society. At the extreme, the ethnic status of individuals is not captured by any government statistics, making it impossible to determine if discrimination prevents assimilation. Children of immigrants usually have access to citizenship, either through modified jus soli (where the child born in the host society of foreign parents is granted citizenship at majority) or double jus soli (where the child born in the host society of foreign parent(s) also born in the host society is a citizen at birth). Naturalization requires demonstration of assimilation. France is usually cited as a case of an assimilationist state.

The final model, multiculturalism, is one where the state acknowledges that group/community formation for immigrants is a natural human process that ultimately facilitates incorporation. Group/ethnic communities are either tolerated or promoted, and immigrant communities are provided services to help ensure they have access to the tools they need to become successful members of the host society. Unconditional jus soli for the children of immigrants is often the rule and naturalization is relatively easy. In some cases, states permit dual citizenship, allowing immigrants to maintain citizenship in their country of origin while they also become full members of society in the host state. The “settler” states of Australia and Canada are usually cited as multicultural states, although the United States has many of the traits of a multicultural state, without the provision of state services.

These ideal-typical models of immigrant incorporation have been attributed to the “histories, ideologies and structures of the societies concerned” (Castles and Miller 2003:243). The historical experiences of states in the international system, the problems of nation building and the exercise of power through the formation of empires, the construction of the state as a civic or ethnic base of citizenship, all factor into the construction of both citizenship laws and the state policies that accommodate immigrants. The models may exhibit change over time, so, for example, multicultural states have moved away from the full recognition of the legitimacy of immigrant cultures. States may adopt different models over time as well – although Castles and Miller do not develop a full-fledged theory of change. They do argue that it is distinct state trajectories that determine immigrants’ chances of success in the host state. These chances are not based on the characteristics of the immigrants themselves but are based on the state policies that they confront upon arrival.

There are different classification schemes that provide additional models. Koopmans et al. (2005) construct a fourfold typology based on two policy dimensions – the ethnic/civic definitions of citizenship originally proposed by Brubaker and the cultural inclusiveness of the host state. And researchers have begun efforts to better calibrate the characteristics of the models by adding additional layers to the typology, such as the type of welfare state. Sainsbury (2006), for example, borrows from Castles and Miller their underlying dimension of inclusion and exclusion and overlays that on Gøsta Esping-Andersen's welfare regime typology, and she recognizes variation in reception regimes resulting from different entry categories (refugees vs. asylum seekers, for example). She is able to point out that social rights for immigrants are better developed in Germany and Sweden than in the United States, because they have more extensive welfare regimes. However, the difference in treatment of citizens and noncitizens is the crucial measure of immigrant reception. US citizens have fewer social rights than citizens of Germany and Sweden because of the “liberal” welfare state that relies primarily on means-tested social programs. The question is whether immigrants are treated similarly or dissimilarly to citizens. And that decision is not necessarily coincident with the welfare regime itself.

The broad typologies focus on an overall pattern of reception rather than specific dimensions of reception. Yet there is little understanding of the specific factors that produce the state policies and changes in the state policies that provide the reception environment that immigrants confront. We need to ask more specifically about the incentives politicians face to expand or contract the services that states provide to immigrants: how do politicians weigh the cost of the services to individuals against the potential backlash from the citizen population that is paying for these services and against the potential for societal unrest from a segment of the population that may be socioeconomically disadvantaged and discriminated against. These incentives may well vary from the incentives regarding labor market incorporation, where pressure from employers to segment immigrant workers may be offset by organized labor, the power of which varies substantially across countries.

Koopmans and Statham (2000) move the research agenda forward by incorporating a theory of political opportunity structure into analyses of change, one in which immigrants themselves become political actors rather than just objects of policies. In that same volume, Entzinger (2000) proposes a sixfold typology to classify policies, rather than countries. Gary Freeman (2004) also adopts the strategy of disaggregating integration policy into its component parts. Drawing on Entzinger, among others, he provides a “radically disaggregated perspective […] [of] regulatory frameworks in four domains – state, market, welfare, and culture.” He points out that only some of these domains are constructed specifically to deal with immigrants, and therefore incorporation frameworks are “not fully cohesive.”

These research efforts are helpful as they allow researchers to move beyond relatively static state-level typologies and to disaggregate integration policies into various dimensions. As with the different types of immigration streams and different dimensions of citizenship policy, there is an open question about the level of disaggregation necessary to understand the determinants of policy formation. However, the first step of disaggregation will most certainly be useful, as this will allow researchers to determine if the policy dimensions move in tandem or not. Here too, empirical referents of these dimensions are being developed: Geddes and Niessen (2005) provide cross-national measures of incorporation across five different domains for European countries.

The research on immigrant integration, as on citizenship more specifically, is expanding exponentially. The connection between immigrants and the welfare state was originally discussed by Freeman (1986) but issues of integration more broadly still have an important component associated with access to the welfare state. Bommes and Geddes (2000) survey the access of migrants to the welfare state in Europe. Joppke and Morwaska (2003) provide country analyses of the policies and practices of integration in the US and Europe. Soroka et al. (2006) evaluate the impact of immigration on political support for the welfare state in Western democracies. Anti-discrimination legislation is the focus of Bertossi's (2007) edited volume.


The connection between immigration control and immigrant integration has been obscured by the division of the research agenda into its component parts. This is understandable because researchers want to gain some empirical traction on these issues and disaggregation is one way to unpack and evaluate hypotheses. And, even within these two dimensions of immigration research, there has been a trend toward disaggregating policy dimensions. This makes for a complex picture of immigration policy, if various flows and various integration schemes are governed by different political forces. This is likely to be the way forward, at least in the medium term. Yet we should remain open to the connections among the various immigration flows and integration policies – either in common explanatory schemes or as inputs into the policy process. There is also the potential for endogeneity. Societal forces include immigrants themselves, organized extra-politically or within the political institutions of the country. Policies that govern access to citizenship may well have an impact on both immigration control and policies governing immigrant integration.

The research agenda on comparative immigration policy is both theoretically rich and politically important but the paucity of empirical referents prevents systematic testing of the explanatory value of the theories. The generation of data is a time-consuming task that we should attempt to undertake collectively, making the data collected more widely available. Below I provide links to multiple sites that provide data on immigration flows, stocks, countries of origin, naturalization rates, etc. But most sites provide only recent data. Therefore we should also encourage country experts to consult national bureaucracies to obtain older data and to post comparable data on a common website. We should also recognize that there may be no one silver bullet; rather, we need multiple measures of immigrant admissions and reception policies. This will help to develop robust notions of the policy dimensions and robust tests of theory.

The comparative scope of theory building is also narrow: it focuses primarily on Europe, with its unique history of nation-building, and on advanced industrial countries more broadly. Yet migration is a global phenomenon. We need to know whether the theories generated by research in advanced industrial countries provide insight into policy making elsewhere. Examining policy processes outside of the European context often provides greater variation on both independent and dependent variables. It can also highlight the generic nature of some processes and the idiosyncratic nature of other explanations.

The centrality of immigration to contemporary political debates suggests that research on comparative immigration policy can contribute fruitfully to our knowledge of political processes governing these policies and help policy makers develop policy solutions that help resolve societal conflicts that currently arise from global population movement.


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I wish to thank Gallya Lahav for asking me to contribute to the ISA's Compendium Project and Sarah Lockhart for providing research assistance.