From Aliens to Citizens: A Comparative Analysis of Rules of Transition

Abstract: Recently, the link between immigration, citizenship and national identity has emerged as a major political issue in Western Europe. During the last decade important changes have been implemented in the legislation concerning the attribution and acquisition of citizenship in several Western European countries. A trend of convergence, oberservable since the mid-1907s, was accelerated after 1990. Previously liberal regulations tended to become more restrictive, whereas traditionally restrictive regulations became more liberal. This article deals with the question whether these developments are due to the harmonization of widely diverging national approaches in the field of immigration and citizenship policies in Western Europe. The first part of the paper is concerned with the legal rules which regulate the naturalisation of immigrants and the intergenerational transmission of citizenship in Austria, Belgium, France, Germany, Italy, the Netherlands, Sweden, Switzerland and in Australia, Canada, the United States of America. The second part delivers an overview of the long-term effects of different patterns of citizenship policies on the inclusion of immigrant populations as citizens. It will be argued that since the beginning of the 1990s one can observe a certain convergence of legal rules which regulate the transition from aliens to citizens. However, major differences in national approaches to immigrants' inclusion as citizens are likely to remain across Western Europe as well as between European and non-European countries immigration.;