Crossing the Divide Building and Breaking Down Borders through Discourse on Citizenship and Naturalisation Policy in Germany and the UK, 2000-2010

The past decade has been a period of upheaval for citizenship and naturalisation policy (CNP) in the UK and Germany, with elite discursive shifts reflecting accompanying evolutions in their respective national identities. Germany has gone from insisting that it was not a country of immigration in the 1990s to widespread recognition of its long-resident foreign population and the pressing need to increase integration. The UK, on the other hand, has shifted from elite discursive acceptance of immigration – even, at times, despite public opposition – to increasingly open hostility and continual changes to requirements for naturalisation. This article examines the shift in perspectives on integration in the UK and Germany and the resulting implications for national identity. Throughout the changes in both countries, there is evidence of conscious construction and alteration of the national narrative that has led to a re-conceptualisation of the borders between “insiders” and “outsiders.” The result has been greater inclusion in Germany and greater exclusion in the UK. This article, though drawn from theory-driven research, focuses on describing the changes to CNP in the UK and Germany over the past ten years, examining elite discursive shifts that indicate changing national identities in the face of long-term migration. It ultimately argues that, despite the popularity of convergence literature, the empirical data supports a growing body of literature indicating continued divergence of British and German CNP. This article briefly defines key terms used throughout before presenting the United Kingdom and Germany, respectively, as case studies before offering analysis and conclusions about the lack of apparent convergence. The terms “citizenship” and “nationality” are frequently used interchangeably, though they are separate concepts. When used precisely, citizenship describes not just one’s nationality but also the rights and duties accompanying the legal status. In Germany, politicians consistently employ the term ‘nationality’, but in the UK, usage is far more mixed, due in part to its complicated colonial history and the resulting six main forms of British nationality, including British citizenship. One could argue that more recent discussions in both countries revolve more around citizenship than nationality, as recent legislation seeks to codify rights and obligations as well as possession of a passport. However, this article’s use of the terms reflects the usage in the respective countries. Discourse in this article is very broadly defined, encompassing the use of written and spoken language, including diction and repetition. Discursive shifts occur when there are changes to popular phrases; previously unacceptable ideas become mainstream; or the words used to frame a debate on contentious issues are modified, causing a change in the focus of the debate. After a long history of formally unrestrictive policies, recent UK immigration and nationality policies reveal a growing conservative trend, with restrictive changes made to nearly every criterion for naturalisation since 2000 in the UK. This research does not argue that restrictive discursive shifts have not happened before in the UK: They have occurred several times in post-war British immigration policy, most notably in the aftermath of Enoch Powell’s infamous “Rivers of Blood” speech in 1968, which pushed Heath to a more conservative policy. Such a shift in discourse is again evident in the period in question. After a few decades of carefully constructed scripts and elite shunning of anti-immigrant rhetoric, the discursive shifts between the 2002 and 2009 immigration bills indicate a growing number of mainstream politicians expressing worries about “thresholds,” “limits,” and lack of integration. This section analyses the identity discourse evident in responses to external pressures, debates surrounding limits on immigration, the imposition of language requirements, and the Knowledge of Life in the UK Test. Each of …