Models of citizenship: Defining European identity and citizenship

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1 Citizenship Studies ISSN: (Print) (Online) Journal homepage: Models of citizenship: Defining European identity and citizenship Gerard Delanty To cite this article: Gerard Delanty (1997) Models of citizenship: Defining European identity and citizenship, Citizenship Studies, 1:3, , DOI: / To link to this article: Published online: 16 Nov Submit your article to this journal Article views: 1729 View related articles Citing articles: 26 View citing articles Full Terms & Conditions of access and use can be found at Download by: [Universita Studi la Sapienza] Date: 14 April 2016, At: 05:28

2 Citizenship Studies, Vol. 1, No. 3, 1997 Models of Citizenship: Defining European Identity and Citizenship GERARD DELANTY Citizenship implies membership of a political community and is internally defined by rights, duties, participation, and identity. It has traditionally been subordinate to nationality, which defines the territorial limits of citizenship. In order to theorize forms of citizenship that go beyond the spatial domain of nationality, citizenship must be seen as multilayered, operating on the regional, national and supranational levels. European citizenship as postnational citizenship is compatible with other forms of citizenship and could become an important dimension to the integration of European society in the twenty first century. At the moment, however, the tendency is to define European citizenship in terms of, on the one hand, a formal and derivative citizenship based on rights and which is mostly supplementary to national citizenship and, on the other hand, a European supranationality defined by reference to an exclusivist conception of European cultural identity. This conception of European identity and citizenship neglects other possibilities which European integration offers. Introduction A central theme in debates on citizenship in recent times has been the question of whether citizenship can have a substantive dimension. In modern advanced societies with multicultural value systems, a great variety of oppositional movements and complex societal institutions, the legitimation of the political order has mostly been conceived in procedural or formal terms. Since Weber it has become common place to remark that modern societies do not legitimate power by reference to substantial values or cultural traditions. The dominant characteristic of modern society is the formalistic nature of law-making which provides a framework in which disputes can be resolved. This applies to citizenship too: citizenship has been held to imply membership of a polity and is defined by the rights bestowed by the polity on the individual. In the most general terms, citizenship involves a constitutionally based relationship between the individual and the state. Gerard Delanty, Department of Sociology, The University of Liverpool, Eleanor Rathbone Building, Bedford Street South, Liverpool L69 7ZA, U.K. ( delanty@liv.ac.uk) /97/ Carfax Publishing Ltd 285

3 Gerard Delanty Critics of citizenship have traditionally accepted this idea of formal citizenship which could be said to be based on a rights model of citizenship. Rights are formal; they are not reducible to values and subject to negotiation. Thus, in one of the classic texts on citizenship, Marshall (1992) merely sought to supplement civil and political citizenship with social citizenship in the sense of social rights. His model has been extended to include a wider conception of rights, such as economic rights and the collective rights of community, encompassing, for instance, cultural rights in cases of deeply divided societies, for not only individuals but also cultural communities can be the bearer of rights. Though the latter would suggest a fundamentally different kind of rights, since they are addressed to the collective and not to the individual. In general, a rights model of citizenship in its civic, political, and social dimensions has prevailed in discussions on citizenship. The rights model, which presupposes a formal or procedural understanding of citizenship has been criticized on the grounds that it excludes the possibility of active citizenship. It is held that there is more to citizenship than rights. Other dimensions include responsibilities or duties, participation in a broader sense, and identity. These dimensions rights, duties or responsibilities, identity and participation altogether express the different aspects of what membership of a political community entails. More recent debates on citizenship have transformed the concept of citizenship by arguing that formal citizenship does not exhaust all levels of citizenship (Roche, 1992; Stewart, 1995; Turner, 1990). Thus feminists have argued for a substantive dimension of citizenship. Citizenship, it is argued, is not only about rights but is also about action, it is about involvement in the polity (Lister, 1998; Mouffe, 1992). Environmentalists have argued for the inclusion of a notion of collective responsibility, raising the question whether nature has rights, and the concept of responsibility cannot be exhausted by reference to the notion of duties to the state, for it is held we have duties to nature as well as to society (Steenbergen, 1994). Communitarians, such as Etzioni (1995), argue for greater citizenship involvment in the public domain and stress the importance of cultivating a sense of civic responsibility. A substantive dimension to citizenship therefore entails in a certain sense an active concept. To an extent the idea of social citizenship and cultural citizenship suggest something more concrete than rights, but in general these models, and in particular the former, tend not to extend into the more substantive dimensions of citizenship. While there is indeed a new discourse of human rights emerging that challenges the western idea, on the whole the rights discourse has existed in a formalistic framework. Human rights tend to refer to the universalistic rights of the individual, though they can be adapted to accommodate collective rights (Turner, 1993). Nevertheless, they are more concerned with protecting individuals against state violence than empowering them in the way that citizenship does. Morever, they refer to the minimal rights of personhood. What is noteworthy about much of the debate around alternatives to purely formal conceptions of citizenship is that the model of the nation-state is rarely questioned: citizenship is based on a territorial framework. A rights model seems to assume a spatial entity. This is a necessary consequence of the fact that citizenship in the rights discourse is primarily about the relationship between 286

4 Models of Citizenship the individual and the state and has reflected the tradition of state-building (Aron, 1974; Bendix, 1964) and some of the classical conceptions of law, such as those associated with Kelson and Hart (MacCormick, 1993). Today, however, the tradition of state-building has been replaced by processes of globalization which presents us with a new conception of citizenship. It is in this context that I would like to mention a second debate. A debate which has begun to emerge relates to the possibility of a transnational citizenship (de Burca, 1996; Delanty, 1996d; MacCormick, 1993, 1996; Pinder, 1995; Preuss, 1996a, 1996b, 1996c). In the context of European integration since the Maastricht Treaty, a new kind of citizenship is slowly emerging but it is very unclear as to whether it will be an alternative to national citizenship or merely a derivative of it (Meehan, 1993). Other debates have raised the question of a global cosmopolitan citizenship emerging beyond the nation-state (Bellamy, 1995; Held, 1996). In this debate there are two sets of questions. The first is whether a supra or transnational citizenship, such as that associated with European citizenship, is a genuinely postnational citizenship and therefore based on different criteria than those of national citizenship: instead of birth or blood, residence, for instance, being one such criteria. In more global terms, there is the possibility, that a kind of 'cosmopolitan citizenship' or 'world citizenship', could evolve based on human rights. Such a citizenship would not be territorially specific but based on the universal rights of personhood (Baubock, 1994; Soysal, 1994). The second is related to the balance between inclusion and exclusion. Citizenship involves both inclusion, in the sense of conferring rights on a group of people, and exclusion in that these rights apply only to a specified group. Strictly speaking, citizenship entails inclusion while nationality involves exclusion: citizenship defines the internal relationship of the individual to the state and nationality defines the external relationship between states with respect to their citizens: one is a British national as opposed to a French national, but one is a British citizenship because one has certain rights within the British polity. One of the problems, then, with global citizenship is that it neglects the dimension of exclusion which seems to be a necessary counterpart to participation: in global citizenship, the other dimensions of citizenship (responsibility, participation and identity) are reduced to a set of basic formal rights. Thus global citizenship maximizes inclusion at the cost of participation. This is perhaps why global citizenship can best be conceived as a citizenship of personhood, referring to a set of minimal rights which can be held to be universal. The central argument I shall be proposing in this article is that the concept of postnational citizenship associated with European integration is in danger of being a purely formal kind of citizenship and, moreover, that it will constitute a supranationality. As both a formal citizenship and a supranationality, European citizenship is thus in danger of incorporating the disadvantages of global citizenship (which is weak on participation) and nationality (which is weak on inclusion). Notwithstanding these problems, my contention is that European citizenship offers a challenge to institutionalize an active kind of citizenship which is not primarily based on exclusion. Precisely because of the extreme difficulties that 287

5 Gerard Delanty are being experienced with institutionalizing, what is in fact, a fairly meaningless form of European citizenship modelled on formal citizenship and an exclusivist supranationality, it may be more feasible to attach to European citizenship a substantive dimension which will not necessarily transcend nationality but will go beyond it in the articulation of a new kind of reflexive identity. But in order to begin to conceive citizenship in this way, we shall have to see citizenship as multi-levelled, and therefore postnational citizenship will have to be part of a more complex model which will include national citizenship. In this article I shall (1) outline some models of citizenship (2) suggest some criticisms of these models in order to arrive at a more complete conceptualization of citizenship and (3) apply this more complete concept of citizenship to European citizenship. Four Models of Citizenship Citizenship has been discussed from a variety of perspectives which reflect the different kinds of citizenship. One way of conceiving the different forms of citizenship is to contrast civic citizenship with ethnic or cultural constructions, with France and the United States as paradigmatic examples of the former and Germany of the latter (Brubaker, 1992). If citizenship is centrally concerned with defining the relationship between the individual and the state, immigrants, it may be suggested, as new comers to a polity, are the test case of citizenship (Brubaker, 1989; Cesarani and Fulbrook, 1996; Rex, 1996). The case of immigrants indicates that citizenship in the western world, while being primarily based on nationality, involves both civic and cultural dimensions (Kymlicka, 1995). In countries such as Germany, where the jus sanguinis prevails, the cultural dimension is stronger, while in France and the United States the civic tradition of the jus soli is stronger. However, it is clear that the civic and cultural are frequently to be found together as in Britain, where there has been a stronger tradition of social citizenship. In other words, in order to understand the discourse of citizenship we need to go beyond the historical and legal framework by which citizenship is seen merely in terms of the formal rights of nationality: we need to see how citizenship is also an oppositional concept and is articulated in a variety of different forms. An important caveat must be mentioned. While immigrants maybe the test case of citizenship, the problem of citizenship is far greater than the problem of integrating immigrants: if immigrants were to be enfranchised and be granted the full rights of citizenship as it is currently codified, citizenship would be a problem in so far as it pertains to something more than mere formal rights. I wish to argue that citizenship can be seen in terms of four models which emphasize different dimensions of what membership of a political community entails: rights, duties, participation and identity. Each of these models corresponds closely to the respective theoretical and ideological traditions of: liberalism, conservatism, democratic radicalism and communitarianism. I do not wish to suggest that this is a complete characterization of citizenship, but I believe these ideal-typical models sum up much of how citizenship has been conceived. 288

6 Models of Citizenship The Rights Model Rights is a dimension to citizenship which is mostly stressed by liberals and refers to the rights citizens hold against the state. Typical rights are those outlined by T. H. Marshall, who of course was not himself a liberal in the conventional sense of the term: civic rights, political rights and social rights. Reduced to a formula, Marshall (1992) argued that civil rights (the right to free speech, assembly and the right to enter into contract) became established in the eighteenth century with the expansion of law; political rights (the extension of sufferage) became established in the nineteenth century with the development of democracy; and in the twentieth century with the rise of the welfare state, social citizenship (the right to social goods such as health, education and social security) completed the historical process of the institutionalization of citizenship. While earlier forms of citizenship, in particular civil rights, were a protection against state violence and emerged in the context of the bourgeois emancipation revolts against the absolute state, social citizenship, in Marshall's view, was a protection against market forces and social inequality. A citizen is a person who is the bearer of rights which are held against the state. The state is obliged to protect those rights which are properties of individuals. The most basic kind of rights are the rights of humankind which are held to be inviolable and not subject to fundamental change by particular states. The rights framework is often contrasted with a justice framework. For instance, much of the debate on European citizenship is conducted on the level of social citizenship understood in terms of enhancing the rights of Europeans to welfare and education. The liberal conception of citizenship could then be distinguished from the social democratic model with its emphasis more on social justice than on civic rights. A liberal understanding of citizenship emphasizes the rights individuals hold while social democrats, such as Marshall, emphasize social justice. However, it is now being increasingly argued that these rights and their conceptions of social justice are primarily formal and say very little about the other dimensions of citizenship conceived in terms of a stronger notion of agency. In other words, social justice in the social democratic ideology is not, in fact, really an alternative to the liberal tradition for its advocation of social justice as opposed to merely civic and political citizenship has been largely based on a formalistic conception of such rights as: health, education, social security and the provision of public communications and transport. These social rights are therefore merely formal entitlements and have little to say on membership of the political community. In general, Marshall was more concerned about equality than participation (Hindess, 1993; Mann, 1986). For this reason, while mindful of the distinction between liberal individualism and social democracy, I am including the justice model as an extension of the rights model. The first model, then, equates citizenship with formally held rights and has traditionally been an expression of liberalism but is now an accepted part of social democracy. 289

7 Gerard Delanty The Conservative Model While the discourse of rights has been primarily a liberal idea and the related discourse of justice a social democratic idea, the notion of duties and responsibilities has been primarily characteristic of conservative theories of citizenship. Instead of stressing what rights citizens hold against the state, conservatives tend on the whole to emphasize the duties of citizens to the state (Selbourne, 1994). The classic duties of citizens to the state are: taxation, military service and education. The dutiful citizen is an obedient and responsible citizen who does not ask what the state can do for him/her but what he/she can do for the state. This kind of citizenship has a strong mooring in social Christianity and is the ideology of charitable societies, but is also related to the tradition of civic responsibility which is itself an older tradition than conservatism. The conservative model of citizenship reduces citizenship to something both active and passive; active in that it implies that citizens must actually do something as opposed to being recipients of the state's services; and passive in that citizens are not supposed to engage in critical discourse. In general the conservative idea of duties has been incorporated into the rights and justice framework: while citizens hold rights against the state, they have in turn to perform certain duties. It is to be noted that these duties are primarily formal, though they can take a substantive form. The Participatory Model It was observed that characteristic of the liberal model of citizenship is its formal nature, while the conservative model opposed a purely formal model of citizenship with a quasi-substantive model involving the idea of duty. Radical conceptions of citizenship oppose the restrictions of citizenship associated with both liberal and conservative ideas. Against the liberal idea, the participatory or radical model stresses the active dimension of citizenship; and against the conservative model of duty, radicals emphasize the socially critical aspect of citizenship. The radical idea of citizenship stresses participation as an active process and something which cannot be reduced to duty. Participation differs from dutifulness in that it emphasizes agency while the conservative notions of duty suggests passivity and obedience. The dutiful citizen does not fundamentally question the status quo while for radicals the active citizen is involved in politically motivated action. In the participatory model citizenship is to a large extent an oppositional concept. The participatory model is closely associated with neo-republican thought which emphasizes the involvement of citizens in the building of society. Thus the basis of neo-republicanism is the idea of civil society: the self-legislating political community. In the classical tradition of neo-republicanism from Aristotle to Rousseau and Kant to Arendt, the civic community is rooted in virtues which tend to equate citizenship with public roles. The private world is excluded from the political and there is generally an emphasis on the value systems of a culturally dominant group. However, the participatory model is, of course, far wider than the neo-republican version, which is peculiar to North American 290

8 Models of Citizenship political philosophy, and includes direct demoracy. Neo-republicanism is in fact closer to communitarianism. The Communitarian Model A fourth dimension to citizenship is the question of identity. For communitarians, citizenship is more than rights and duties but also involves issues of identification. Communitarian ideas of citizenship are similar to neo-republican conceptions, and in many cases indistinguishable, in that they are very much concerned with the substantive dimension to citizenship. Both of these ideas of citizenship such as the positions associated with the writings of Taylor, Walzer, Sander and Etzioni can be contrasted to the liberal theory of citizenship which is seen as being purely formal. Citizenship for communitarians is closely linked to culture and in particular to national identity. Citizenship in communitarian discourse is ultimately reducible to nationality which gives citizenship a sense of cultural cohesiveness. It should be remarked that communitarian thinking tends to lie somewhere between the conservative emphasis on cultural particularness and duties and neo-republican conceptions of participatory democracy. However, there is a difference between the conservative ideology, as represented by Maclntyre, for instance, and communitarianism in that the latter has mostly been reconciled to the liberal critique, and, properly speaking, tends to take the form of liberal communitarianism. A distinguishing feature of communitarianism is its conception of the polity of citizens as a national community. The political community for communitarians is not an open one; it is defined by membership of a cultural community in the first instance. The community is defined by its cultural ties and historical traditions which exist prior to the state. The state is merely the expression of a cultural community. As a political community the body of citizens who comprise civil society can maintain strict rules on who belongs to the polity and therefore who is entitled to its privileges. In contrast, neo-republicans, as a stronger version of communitarianism, see the community as a pre-eminently political community. A New Model: Postnational Citizenship The four models of citizenship can be seen as variations on the theme of substantive versus formal citizenship, with the liberal and conservative models representing the formal tradition of citizenship and participatory and communitarian models a concern with the substantive critique of citizenship. Both of these kinds of citizenship can also be seen in terms of the historical forms of civic (in the broader sense of the term) or ethnic conceptions of citizenship: the traditions of the demos and ethnos. Civic citizenship, in general, is based on a strong sense of the rights of citizenship and also entails a degree of participation by citizens in the polity. It therefore includes both a formal and a substantive dimension. The ethnic conception of citizenship is based more on an emphasis of identity and duties, and therefore involves both a formal and a substantive 291

9 Gerard Delanty ^^^Type of citizenship Historical form "^"-^^^^ Civic citizenship Ethnic citizenship Formal Rights Duties Substantive 1 Participation Identity Figure 1. The core components of citizenship dimension. This framework is summarized in Figure 1. It is to be emphasized that, in practice, citizenship as an institutionalized discourse and as an oppositional discourse incorporates many different dimensions. Returning to the second debate I mentioned at the outset, the question of whether citizenship can transcend the nation-state in its self-understanding and jurisdiction, I would now like to discuss the idea of postnational citizenship with respect to these models of citizenship. I wish to propose that an adequate model of citizenship must involve all four dimensions: the formal dimension of rights and duties, on the one side, and on the other the more strongly pronounced substantive dimension of participation and identity. However, the way in which I believe we must theorize these models should go beyond the nation-state as the normative reference point. In all of the examples I have given the nation-state is generally seen as the space in which citizenship is actualized. In both the formal and substantive conceptions of citizenship associated with the liberal, conservative, participatory or communitarian models, citizenship is generally equated with nationality. In the participatory model this is less pronounced, but in general the advocates of participatory democracy have not questioned the nation-state as the territorial unit of citizenship. The emphasis on nationality is particularly pronounced in the liberal and conservative models and in the communitarian model there is a taken-forgranted assumption that citizenship is based on a cultural community united in a common national tradition. These conceptions of citizenship can be said to be underpinned by a spatial dimension. In so far as they take the nation-state for granted as the geo-political framework for citizenship, they entail a degree of exclusion. Exclusion has always been central to the definition of citizenship from the Athenian polis to the Enlightenment republic. Max Weber traced this back to the rise of the city in western Europe at the beginning of the medieval period when cities developed with their own civic traditions based on the corporate professions. The idea of the republic later came to symbolize the idea of citizenship as it was constituted in the free associations of European cities. By the nineteenth century, the city ideal was transformed into the nation-state. Both cities and states are spatial entities and the kind of citizenship they created has been underpinned by a territorial referent. This was an inevitable consequence of the fact that citizenship became linked with democracy and thus ceased to be an abstract universalistic idea but began to take on an institutional form. 292

10 Models of Citizenship I think the historical tie between citizenship and democracy is important to stress as there is a tendency in the recent literature on postnational citizenship to dismiss national citizenship on the grounds that it entails exclusion (Hindess, 1998). It must be recognized that there is nothing inherently undesirable with the fact that citizenship entails exclusion, for it is a necessary and inevitable part of all group and identity definition that the 'we' is defined by reference to a 'they'. What matters, of course, is the balance between negative and positive identification: negative identification or recognition of the 'other'. In the present context the problem is that citizenship emerged in modern times as an extension of nationality to which it was subordinate. Nationality entailed a restrictive view of citizenship as the rights pertaining to the citizens of a particular geopolitical territory and the evolution of democratic structures. The price for a measure of democratization was exclusion, for the historical experience has been that citizenship requires a degree of exclusion in order to maximise inclusion. In my view any debate on postnational citizenship that does not recognize this historical reality will be condemned to futile utopianism. However, all is not lost: there are changes for a meaningful kind of postnational citizenship. When we shift the context to complex and transnational polities such as the European Union, the reduction of citizenship to a spatially delimited nationality cannot be taken as a self-evident model for the Union. Undoubtedly the equation of citizenship with nationality has to varying degrees functioned to enhance democracy in the context of national societies, but this may not be the case for the Union (for the very reason that it is still more of a union of states than a state in itself). Let me clarify why the Union cannot reproduce the national model of citizenship. One of the arguments against abandoning the spatial reduction of citizenship is that it would compromise the socio-economic basis of western multicultural and social democracy: the welfare state. Western societies have managed to institutionalize a degree of multicultural citizenship in the political culture of the political domain, an achievement facilitated by the relative prosperity of the post-second World War era which made possible the creation of an inclusive welfare state. In fact, economic prosperity made the creation of many different kinds of welfare states, ranging from the British to the German to the Scandinavian. The post-cold War era is different: the welfare state is under considerable attack by neo-liberal political agendas and right-wing neo-nationalist movements who are anxious to restrict prosperity to nationals. Under the conditions of economic post-fordism and political neo-liberalism it would also appear that western capitalism can sustain continued growth without full employment, which was presupposed by the social democratic model of social citizenship and multiculturalism. The welfare state, then, has been the spatial or territorial basis of a good deal of western citizenship in the last four decades (Delanty, 1996d). Unless the European Union can reproduce the welfare state on a supranational level a very unlikely prospect there is little point in making pleas for a meaningful kind of European citizenship. Such expectations are unrealistic, given that the national welfare state, however much under attack it may be, is far from at an end and we may confidently suppose that there will continue to be a variety of fairly resilient welfare states in western Europe for the near future 293

11 Gerard Delanty (Hirst and Thompson, 1996; Pierson, 1992). In other words, to the extent to which social democracy is not a spent force, there is little point in holding out for the arrival of a European welfare state. Yet, in order to arrive at a more complete idea of citizenship, the prospect of a European postnational citizenship offers a major challenge (Touraine, 1994). It forces us to rethink certain assumptions about nationality and opens up the possibility if institutionalizing a new kind of citizenship which may be unrealistic to bring about at the level of the nation-state at the present time. Before considering some of the problems associated with European citizenship, I would like to indicate how I think we can theoretically conceive of a more complete model of citizenship. Drawing from the four models of citizenship discussed above, it may be argued that citizenship is a multilevelled concept involving four dimensions: rights, responsibilities, participation and identity. The rights of citizenship must be seen as extending to include transnational rights. We can no longer operate with a purely national constitution. Yasemin Soysal (1994, 1996) has argued how universal rights of personhood are coming to provide an alternative basis for transnational citizenship. This is particularly apparent in the case of immigrants in Europe who can challenge nationality as an exclusive reference point. She argues this is leading towards a model of citizenship based on deterritorialized rights, a model indicative of a new postnational order which in the global and post-cold War era. However, her model is largely based on human rights: the rights of individuals, previously codified in national constitutions, are increasingly been deterritorialized and the resulting globalized discourses of rights is moving in the direction of a postnational order of the rights of personhood. The upshot of this is that the distinction between citizenship, as the domain of particular rights, and human rights, as the domain of universal rights, is increasingly blurred. Concerning the second issue, the duties and responsibilities of citizenship, it may also be argued that these are now extending to matters beyond the nationstate and which cannot be reduced to the level of the state. For instance, we have duties to other social groups as well as to the environment. Thus the conservative dominance of the discourse of responsibility is today being challenged by the new social movements who have been able to mobilize public opinion critical of what Beck (1992,1995) has called 'organized irresponsibility'. Bart van Steenbergen (1994) argues that citizenship is once again becoming a revolutionary concept, this time as ecological citizenship which entails responsibility for nature. The idea of collective responsibility is becoming a new theme in much of contemporary social theory. It suggests a model of collective action as opposed to individual action. In other words, the idea of responsibility is being decoupled from the idea of duty and is becoming a key theme in the reinvention of politics today: social movement activists as well as the wider public have a sense of being responsible for nature and towards the future (Apel, 1991, 1992; Melucci, 1996). This understanding of responsibility goes beyond the conservative discourse of duty and its focus on duty to the state. The new discourse of collective responsibility refers to social problems; it is not merely the expression of social problems. We may say that under the conditions of 294

12 Models of Citizenship ideological fragmentation, the discourse of responsibility has been released from the conservative ideology and is being taken over by new social actors. With respect to the other substantive dimensions of participation and identity, participation refers to attempts made to democratize society. But the simple and romantic model of the polis can no longer be a realistic model for a participatory democracy on the scale of the European Union. Active participation must be conceived in new ways. It is possible that the idea of responsibility is becoming the basis of a notion of citizenship as participation. In order to see how this is taking on a concrete form it is particularly instructive to look at new social movements and the kind of citizenship they imply. Roche (1995, pp ) argues that the sociology of citizenship has much in common with the sociology of social movements which could be said to address the problems of politics in a postnational era. Finally, the question of identity is also an important cultural resource in a complete model of citizenship and cannot be reduced to nationality. In this latter context what is becoming important today is multicultural identity and alternative possibilities for identity in a political community. An important dimension to citizenship has always been identity, but it has mostly been reducible to national identity. Thus citizens do not identify with their citizenship but with their nationality. In so far as nationally delimited citizenship has been confined to the model of formal civic nationality, it is not surprising that citizenship itself has not been a source of identity. A tendency is becoming apparent today that is pointing towards the separation of identity from the traditional definition of citizenship as rights. This development can be described as the uncoupling of nation and state: nationality is increasingly becoming a discourse mobilized against the state, as is witnessed by new nationalist movements all over the world. In other words, nationality is more likely to be deployed against the state than by the state (Delanty, 1996d). It is becoming a free-floating discourse of domination which can be used by social actors seeking to institutionalize their identity projects. This development is undoubtedly connected with the overall fragmentation of ideology liberalism, conservatism, socialism, nationalism as result of globalization. That is to say, these ideologies are breaking up but are not disappearing: they are being recombined in new ways by many different social agents as a result of becoming free-floating discourses. This is also the fate of citizenship. Citizenship is no longer a coherent discourse fixed in a particular framework. In short, it has suffered the fate of the other 'meta-narratives' and is consequently open to new definitions: its core components rights, duties, participation and identity have become disjointed. The current situation of citizenship in Europe is faced with the challenge of reconstituting citizenship in a new key. Essential to that task will be the recombination of the substantive and the formal dimensions of citizenship. A concern with participation and multi-identification as the substantive content of citizenship expresses the core of the idea of postnational citizenship. It captures the sense in which new forms of citizenship are emerging today which challenge the traditional model of nationality and the reduction of citizenship to formal rights. A crucial challenge for European citizenship will be whether it will 295

13 Gerard Delanty attempt to reproduce national citizenship on the supranational level or seek to find ways to institutionalize an active citizenship of participation in a political community and which could also be the basis of a non-exclusivist European identity. In the following section I would like to relate some of these ideas to the formation of European citizenship. European Citizenship and Postnational Identity Since Maastricht, European integration has moved beyond its older emphasis on purely administrative and economic regulation to encompass the social and cultural dimensions. This concern with social integration is reflected in growing interest in the possibility of European citizenship, on the one hand, and on the other with European cultural identity. Two models of European citizenship are emerging today: a formal citizenship and a substantive citizenship of European nationality. The former is based on a postnational understanding of citizenship while the second is based on a new communitarian ideology of European cultural identity, and is becoming the basis of a European nationality. I believe that both of these conceptions of European citizenship are inadequate. In the final section I shall outline an alternative model. Postnational European Citizenship The first conception of European citizenship as a postnational citizenship is primarily a formal citizenship. The Maastricht Treaty makes clear that citizenship in a future European constitution can only be based on the existing constitutions of the member states. To qualify for European citizenship one must be first of all a citizen of one of the member states. In this sense, then, it is clear that European citizenship as it is currently conceived in the legal framework of the European Union is a supplementary kind of citizenship. While the exclusive sovereignty of national citizenship may be undermined, European citizenship is not an alternative citizenship. It is derivative of nationality and can only be a second-order citizenship. In general, European citizenship adds to existing national citizenship. It is primarily codified around the right to free movement and the right to stand and vote at municipal elections within member states as well as for the European Parliament. With these additional rights, European citizenship points the way forward to a concept of citizenship based more on residence than on birth. However, at the moment there is no indication that the right to vote at local elections will be extended to national elections in any one of the member states. The problem with European citizenship in the context of the earlier discussion is that it does not recognise the extent to which formal citizenship has been challenged by a whole range of social forces in recent decades and which cannot be reduced to a rights model. Instead of enhancing possibilities for participation and the resolution of contentious action, European citizenship is in danger of becoming an even more formalized kind of citizenship than national citizenship 296

14 Models of Citizenship currently is and, moreover, is pointing in the direction of becoming an exclusionary supranationality defining Europe by reference to the non-european. The result is that the new dimension of the postnational is reduced to a supranationality whose substantive content is very limited. This is one of the problems with Soysal's (1994) important study on postnational citizenship in the world today. For her postnational citizenship is coming to be based on the rights of personhood, which are held to universal and therefore a contrast to national forms of citizenship. To this we can also add the question of new kinds of rights that are arising with the idea of a constitution of the media on the agenda. What is significant about these kinds of rights is that they transcend the nation-state in their application and refer to global problems. While I would not disagree with the basic line of argument that deterritorialized discourses of human rights are increasingly coming to prevail in the post-cold War era, I feel that this theoretical position reduces the idea of a postnational citizenship too much to a purely formal kind of citizenship and neglects the possibility of a more active kind of citizenship based on identity with a political community. It is a simple fact that by reducing exclusion, participation is also reduced. In other words, the greater the sphere of inclusion the weaker will be the degree of participation. A global citizenship can therefore only be a minimal citizenship of the rights of personhood. But citizenship, as I have tried to argue, also entails a relation to democracy and therefore must address the question of participation as an active, as opposed to a formal, process. To overcome the trade-off between inclusion and participation is the principal challenge facing postnational citizenship. An alternative postnational model is suggested by David Held's (1996) idea of cosmopolitan citizenship. Lying at the centre of his theory, which is almost entirely normative, is the notion of the 'principle of autonomy' which captures the sense in which citizenship on the global level must go beyond a purely formal level and encompass an active citizenship of participation. Though Held does not explicity use the term, I wish to propose that his analysis points the way for a recognition of collective citizens, for his model grants a central place to social movements, NGOs, citizen groups who could represent specific interests and thereby present an alternative to representation by states. I shall return to this shortly. European Cultural Identity While European citizenship is predominantly conceived as being based on a minimal set of formal norms which are supplementary if not derivative of nationality, European cultural identity is seen in more substantive terms. One is ultimately a European not by virtue of whatever rights European citizenship entails, but by virtue of being culturally a European, a member of the community of nationalities which make up Europe. I have written elsewhere on the formation of European cultural identity (Delanty, 1995a, 1995c, 1995d, 1996a, 1996d, 1996e, 1997a) so it will suffice here to remark that one of the current tendencies is the construction of European identity around an essentialistic understanding of culture. European are defined not by reference to the citizenship in the sense of the members of civil society, but by reference to a cultural discourse whose 297

15 Gerard Delanty reference points are: the geopolitical framework of the European continent, the cultural heritage of Europe, and a strong sense of the uniqueness of Europe. Who is a European is largely a matter of exclusion, and in the dichotomy of self and other which constitutes the discourse of European identity, Europeanness is constructed in opposition with the non-european, in particular Islam. This sense of the uniqueness of the European is today emerging as a basis for a kind of supranational identity and citizenship which European integration does not have. Thus rather than rely on the cultural resources of the nation-state, the European Union is now about to enter into a phase in which it can generate its own political culture, though it is unlikely that this will be a challenge to national cultures. At this point the relationship between the two models of citizenship is apparent. European citizenship as a postnational and formal kind of citizenship is being supplemented by a new kind of citizenship focused less on rights and participation than on identity. This new kind of cultural citizenship is becoming, in fact, the basis of European nationality. Nationality, it may be suggested, is an 'exterior' or external kind of nationality: it defines citizenship by reference to other polities; citizenship itself, though frequently equated with nationality, is primarily an 'internal' matter, defining the rights and identity of citizens with respect to the state. I am suggesting, then, that European citizenship as an inclusive citizenship is taking the form of postnational formal citizenship while a sense of European nationality as an exclusive citizenship is emerging around the idea of European identity. The idea of European nationality, as already mentioned, is also, of course, present in the codification of citizenship in the Maastricht Treaty, which confines citizenship to citizens of the member states, While immigrants may now vote in municipal elections of the member states they cannot vote in national or European elections. This situation suggests, then, that European citizenship is more influenced by an aspiration towards supranationality and therefore towards exclusion rather than inclusion. The model of citizenship that is emerging is based on a narrow cultural communitarianism: European citizenship is ultimately moving towards cultural definitions of belonging the idea of nationality than on a complete kind of citizenship. With European citizenship confined to a minimal set of formal rights (which happen to be conductive to labour mobility), citizenship in the inclusive sense is seen as residing in the existing constitutions of the members states. Along side this development, a new political culture of European nationality is shifting on the supranational which defines the internal face of citizenship. Conclusion: Towards a Reflexive Model of European Identity European citizenship is an ambivalent development. The EU is no longer a community or union of states (intergovermentalism) but neither is it a federation (whereby sovereignty resides in a federal constitution). Today the nation-state is by no means at an end: what is happening is that many of its functions, in particular those which states manage less well, are being taken over by supranational agencies, with the paradoxical result that the nation-state is in fact 298

16 Models of Citizenship reinforced in certain key domains (Delanty, 1997b; Dunn, 1995). There is no doubt that European integration has involved a shift away from national citizenship, which is no longer the only model for citizenship, but a federal constitution has not yet emerged in so far as this has been able to usurp national sovereignty. Indeed, many of the member states, such as Germany and Belgium, are themselves highly federalized. It would appear that sovereignty is being transferred downwards as well as upwards, It is evident, then, that European citizenship has opened the way for a conception of citizenship based more on residence than on birth or blood. Therefore it cannot be seen merely as an extension of the older and more territorial notions of civic citizenship or ethnic cultural citizenship which have to various degrees characterized much of citizenship in the modern world. However, on the other hand,' European citizenship as it is currently codified is still very much limited by national models of citizenship. In other words, we can say that European citizenship is an open agenda at the moment. A realistic assessment of the situation is that European citizenship and the various kinds of national citizenship will continue to exist and something like a multilevelled framework of citizenship will emerge, incorporating the subnational, the national and the supranational. This will involve linking citizenship with federalism (Majone, 1990; Marquand, 1994; Smith, 1995). The aim of this article is to suggest that European citizenship faces three options of which only the third is desirable if we want a genuinely postnational citizenship. The first is that European citizenship will be merely an extension of the formal citizenship which currently exists on the level of the national constitutions. European citizenship in this model will not be an alternative as such but a supplementary kind of citizenship and reflection of the growing complexity of the European polity in its national and supranational levels. The second model, which is compatible with the first, is that European citizenship will be codified around a notion of the cultural specificity of Europe and will therefore become a kind of supranationality, more concerned with the relationship between a mega Fortress Europe and the non-european. The third model is that European citizenship will seek to institutionalize a substantive citizenship of participation which will be based on residence. If residence is more fully established as the basis of European citizenship, the dimension of inclusion can be enhanced. European citizenship could then become not merely relevant to the some 5 million citizens of the member states living in other states of the Union, but also to the some 10 to 15 million immigrants. However, if European citizenship is to encompass a more complete kind of citizenship it will have to maximize participation. This is perhaps the greatest difficulty, given the complex nature of European society and its diverse political structures. I would like to suggest that the most important dimension to this will not consist in strengthening the ties between individual citizens and the institutions of the European Union, such as the European Parliament. Of greater importance will be the institutionalization of links between the regional authorities of the member states and the Union, on the one hand, and on the other the opening of the Union to social movements. At the moment in many countries the regions 299