Calling for the Super Citizen: Naturalisation Procedures in the United Kingdom and Germany (Palgrave Politics of Identity and Citizenship Series) [1st ed. 2023] 9783031342592, 9783031342608, 3031342593

Table of contents :
Acknowledgements
Praise for Calling for the Super Citizen
Contents
About the Author
1: Naturalisation as Subject-Formation and the Call for the Super Citizen
1.1 Synopsis of the Book
1.2 The Call for the Super Citizen: Naturalisation as Subject-Formation
Naturalisation Requirements in the Academic Debate
The Subject-Formation Framework
The Call for the Super Citizen
1.3 The Historical Emergence of Naturalisation in the UK and Germany
The UK Case
The German Case
Naturalisation Requirements in the UK and Germany Today
1.4 A Multi-sited State Ethnography of Naturalisation in the UK and Germany
1.5 Outline of the Book
References
2: Problematisations in Naturalisation Processes: Super Citizen or “Scrounger”
2.1 The Dependent Citizenship Applicant: Supposed Lack of Economic Integration
Benefit Receivers
Minors, Elderly, and Disabled People
Students
2.2 The Insincere Citizenship Applicant: Doubts About Cultural-Linguistic Integration Efforts
“War Criminals” and “Illegal Entrants”
Suspicious Sponsors: “Sham” Marriages and Solicitors
“Dodgy” Colleges and Medical Practitioners: Suspected Fraud in Relation to Language and Knowledge Tests
“Impersonators”: Suspected Identity Fraud
EU Nationals: Suspected of Claiming Welfare Without Making Contributions
2.3 The Indifferent Citizenship Applicant: Suspicious Political Loyalties
Frequent Fliers
Dual Nationals
Idealised Refugees Versus Saturated National-Borns: Maintaining Democracy Against the Far Right
2.4 Engrained Institutional Mistrust
References
3: Rationalities of Naturalisation: Citizenship as Award or Entitlement
3.1 Naturalisation as a Discretionary Award
“A Straightforward Process”
No Right to Appeal
No “Entry Ticket” or “Old Roll”
From “Knave” to “Knight”
The First Citizenship Test in Saxony
“Lecture About Rights and Duties”
3.2 Naturalisation as a Legal Entitlement
A Political and Economic Necessity or “Plus”
Enablement and Empowerment Rather Than “Social Imperialism”
Pro-naturalisation Campaigns in Hamburg: Volunteer “Guides” and Personal Letter by the Mayor
3.3 Naturalisation as Creating an Emotional Attachment
Turning a Bureaucratic Procedure into a Lived, Meaningful Experience
Inducing National and Local Self-identification
Humanising the State
Emotional Work
Apolitical, Too Political, Right or Left?
3.4 Naturalisation as a Commercial Commodity
Customer Service
Source of Profit: “Citizenship Pays for All the Other Applications.”
3.5 Comparison and Conclusion
References
4: Authorities in Naturalisation Procedures: Structurally Prescribed and Self-Perceived Roles of State Actors
4.1 Accessing Information and Forms: The Role of Legal Advisers
Structural Conditions: Regulation and Funding
Relationship with Citizenship Applicants
Relationship with State Departments
4.2 Educating “Good” Citizens: The Role of Citizenship Course Teachers
Structural Conditions: Guidelines, Accreditation, and Funding
Teachers’ Experiences with the “Citizenship Materials” and “Orientation Courses”
4.3 Presenting the Certificate: The Role of Registrars and Caseworkers
Structural Conditions: Guidelines, Competences, and Working Conditions
Self-Perception and Experiences
4.4 Addressing the “New” Citizens: The Role of Honorary Ceremony Speakers
Guidelines
Self-Perception
4.5 Discrepancies Between Structurally Prescribed and Self-Perceived Roles
References
5: Techniques of Subject-Formation: Citizenship Courses, Tests, and Ceremonies
5.1 Citizenship Courses and Tests
Presentation of the State
Suggested Self-Guidance
5.2 Citizenship Ceremonies
Presentation of the State
Suggested Self-Guidance
5.3 The Dialectics of Citizenship Courses, Tests and Ceremonies: Between National Nostalgia and Democratic Modernity
References
6: Responses to the Super Citizen: Migrants’ Lived Experiences of Naturalisation
6.1 Embrace
6.2 Contestation
6.3 Disaffection
6.4 Migrants’ Competition for State Recognition and New Hierarchies of Worthiness
6.5 The Ambivalent Effects of the Super Citizen
References
7: The Super Citizen and the Future of Naturalisation
7.1 Current Policy Developments in the UK and Germany
7.2 Recommendations for Future Policy-Making
De-Symbolise Naturalisation
Introduce a Conditional Entitlement to Naturalisation and a Right to Appeal (in the UK)
Reduce the Naturalisation Fee (in the UK)
Restore the ESOL with Citizenship Materials Course Route (in the UK)
Restore Public Funding for Legal Advice on Naturalisation (in the UK)
Allow Dual Nationality (in Germany)
Clearly Define “Outstanding Efforts at Integration” (in Germany)
Publish the Administrative Guidelines (in Germany)
Redefine the Economic Self-Sufficiency Requirement (in Germany)
References
Index

Citation preview

PALGRAVE POLITICS OF IDENTITY AND CITIZENSHIP SERIES

Calling for the Super Citizen Naturalisation Procedures in the United Kingdom and Germany Elisabeth Badenhoop

Palgrave Politics of Identity and Citizenship Series

Series Editors Varun Uberoi Brunel University London London, UK Nasar Meer University of Edinburgh Edinburgh, UK Tariq Modood University of Bristol Bristol, UK

The politics of identity and citizenship has assumed increasing importance as our polities have become significantly more culturally, ethnically and religiously diverse. Different types of scholars, including philosophers, sociologists, political scientists and historians make contributions to this field and this series showcases a variety of innovative contributions to it. Focusing on a range of different countries, and utilizing the insights of different disciplines, the series helps to illuminate an increasingly controversial area of research and titles in it will be of interest to a number of audiences including scholars, students and other interested individuals.

Elisabeth Badenhoop

Calling for the Super Citizen Naturalisation Procedures in the United Kingdom and Germany

Elisabeth Badenhoop University of Wuppertal Wuppertal, Germany

ISSN 2947-6100     ISSN 2947-6119 (electronic) Palgrave Politics of Identity and Citizenship Series ISBN 978-3-031-34259-2    ISBN 978-3-031-34260-8 (eBook) https://doi.org/10.1007/978-3-031-34260-8 © The Editor(s) (if applicable) and The Author(s), under exclusive licence to Springer Nature Switzerland AG 2023 This work is subject to copyright. All rights are solely and exclusively licensed by the Publisher, whether the whole or part of the material is concerned, specifically the rights of translation, reprinting, reuse of illustrations, recitation, broadcasting, reproduction on microfilms or in any other physical way, and transmission or information storage and retrieval, electronic adaptation, computer software, or by similar or dissimilar methodology now known or hereafter developed. The use of general descriptive names, registered names, trademarks, service marks, etc. in this publication does not imply, even in the absence of a specific statement, that such names are exempt from the relevant protective laws and regulations and therefore free for general use. The publisher, the authors, and the editors are safe to assume that the advice and information in this book are believed to be true and accurate at the date of publication. Neither the publisher nor the authors or the editors give a warranty, expressed or implied, with respect to the material contained herein or for any errors or omissions that may have been made. The publisher remains neutral with regard to jurisdictional claims in published maps and institutional affiliations. This Palgrave Macmillan imprint is published by the registered company Springer Nature Switzerland AG. The registered company address is: Gewerbestrasse 11, 6330 Cham, Switzerland

Acknowledgements

This book has its origin in a research project that I conducted at the University of Glasgow in fulfilment of the requirements for the PhD degree in Sociology (award date: 29 June 2018). For their extraordinary supervisory support and encouragement during the Glasgow years, I would like to thank Satnam Virdee and Robert Gibb. I am also indebted to Bridget Byrne and Andy Smith for their careful examination of my PhD thesis and for their helpful feedback which I incorporated into the book manuscript. I would also like to thank the many anonymous research participants who shared their insights and experiences with me and who helped me gain access to research sites and interview partners. I am most grateful for the generous funding which I received for this research project from the UK Economic and Social Research Council (award number ES/J500136/1), the German Academic Scholarship Foundation (Studienstiftung des deutschen Volkes), the University of Glasgow’s School of Social and Political Sciences, and the Ethics, Law and Politics Department at the Max Planck Institute for the Study of Religious and Ethnic Diversity, Göttingen. From the beginning of my PhD until the completion of this book project, I have been privileged to work at a number of excellent and stimulating research institutions in the UK and in Germany: the University of Glasgow, the University of Edinburgh, the Max Planck Institute for the Study of Religious and Ethnic Diversity, the Max Planck v

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Institute for Social Anthropology, and the Martin Luther University Halle-Wittenberg. In all these places, I have received helpful feedback and support by many colleagues and friends, including (but not limited to) Stephen Ashe, Seumas Bates, Rainer Bauböck, Anna Beesley, Petra Bendel, Christina Boswell, Benjamin Boudou, Richard Brunner, Claire Bynner, Frances Cairney, Sara Casella-Colombeau, Emile Chabal, Andria Christofidou, Derek Denman, Petra Dobner, Janet and Nigel Fabb, Andreas Fahrmeir, Thomas Faist, Katie Farell, Marie-Claire Foblets, Jelka Günther, Lisa Harms, Sabine Hess, Alex Hudson, Mo Hume, Rebecca Kay, Matthias Koenig, Kelly Kollman, Christine Lang, Minna Liinnpää, Gail Lythgoe, Zuleykha Mailzada, Brendan McGeever, Ines Michalowski, Liav Orgad, Mengxi Pang, Alison Phipps, Mareike Riedel, Carin Runciman, Dora Sampaio, Stefan Schlegel, Jan Schneider, Karen Schönwälder, Liza Schuster, Ayelet Shachar, Sven Siefken, Karen Siegel, Mike Slaven, Jenny Speirs, Anna-Kaisa Terje, Lito Tsitsou, Martijn van den Brink, Steve Vertovec, Larissa Vetters, Matthew Waites, Amy Watson, Nick Watson, Shadi Whitburn, and Alan White. For their interest in and their support of my work, I thank the editors of the “Politics of Identity and Citizenship Series” at Palgrave Macmillan, especially Nasar Meer, as well as the production editors Sarah Hills, Liam Inscoe-Jones, and Sharla Plant. I am indebted to my parents and the extended Badenhoop, Rahe, and Wolfsteller families for their unlimited support throughout these years. Finally, I thank René Wolfsteller for everything.

Praise for Calling for the Super Citizen “This book proposes a bold new interpretation of naturalisation requirements and procedures. Transcending debates about the liberal character or exclusionary effects of naturalisation tests, courses and ceremonies, Badenhoop regards them as state efforts to produce “Super Citizens”, who contribute to the economy and cultural diversity, demonstrate sincere effort and show loyalty and gratitude. A meticulous comparative analysis of naturalisation practices in the UK and Germany reveals how such policies reinforce hierarchies between nativeborn and naturalised citizens and non-national migrants. A must-read for scholars, policy-makers and others interested in citizenship.” —Rainer Bauböck, Robert Schuman Centre for Advanced Studies, European University Institute, Florence, Italy “Elisabeth Badenhoop’s book, drawing on a clear conceptual framework and a wealth of empirical data, provides important insights into the character of naturalisation processes in modern states, viewed both from the perspectives of the states themselves and those who are naturalising. The figure of the “Super Citizen” is a powerful metaphor for the ways in which states use the naturalisation processes to place heavy demands on migrants.” —Jo Shaw, Head of School, Edinburgh Law School, UK “The myriad expectations placed on immigrants are enormous if not daunting. Naturalisation and citizenship are offered to them as a kind of reward or endgame only after the successful completion of an obstacle course of rules, procedures, and state bureaucracies. Through multi-sited research and multiple perspectives, Badenhoop takes an indepth look at the regulations and experiences of naturalisation in Germany and the UK. It is a powerful and revealing, indeed breakthrough study that will shape citizenship research for years to come.” —Steven Vertovec, Director, Max Planck Institute for the Study of Religious and Ethnic Diversity, Göttingen, Germany

Contents

1 Naturalisation  as Subject-Formation and the Call for the Super Citizen  1 1.1 Synopsis of the Book   3 1.2 The Call for the Super Citizen: Naturalisation as Subject-Formation  7 Naturalisation Requirements in the Academic Debate    7 The Subject-Formation Framework   10 The Call for the Super Citizen   12 1.3 The Historical Emergence of Naturalisation in the UK and Germany  15 The UK Case   16 The German Case   18 Naturalisation Requirements in the UK and Germany Today  21 1.4 A Multi-sited State Ethnography of Naturalisation in the UK and Germany  23 1.5 Outline of the Book  26 References 29

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2 Problematisations  in Naturalisation Processes: Super Citizen or “Scrounger” 35 2.1 The Dependent Citizenship Applicant: Supposed Lack of Economic Integration  37 Benefit Receivers  37 Minors, Elderly, and Disabled People   40 Students  41 2.2 The Insincere Citizenship Applicant: Doubts About Cultural-Linguistic Integration Efforts  43 “War Criminals” and “Illegal Entrants”   43 Suspicious Sponsors: “Sham” Marriages and Solicitors   45 “Dodgy” Colleges and Medical Practitioners: Suspected Fraud in Relation to Language and Knowledge Tests   48 “Impersonators”: Suspected Identity Fraud   49 EU Nationals: Suspected of Claiming Welfare Without Making Contributions   51 2.3 The Indifferent Citizenship Applicant: Suspicious Political Loyalties  55 Frequent Fliers  55 Dual Nationals  57 Idealised Refugees Versus Saturated National-Borns: Maintaining Democracy Against the Far Right   58 2.4 Engrained Institutional Mistrust  59 References 62 3 Rationalities  of Naturalisation: Citizenship as Award or Entitlement 65 3.1 Naturalisation as a Discretionary Award  66 “A Straightforward Process”   67 No Right to Appeal   68 No “Entry Ticket” or “Old Roll”   69 From “Knave” to “Knight”   70 The First Citizenship Test in Saxony   71 “Lecture About Rights and Duties”   72 3.2 Naturalisation as a Legal Entitlement  74 A Political and Economic Necessity or “Plus”   74

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Enablement and Empowerment Rather Than “Social Imperialism”  76 Pro-naturalisation Campaigns in Hamburg: Volunteer “Guides” and Personal Letter by the Mayor   77 3.3 Naturalisation as Creating an Emotional Attachment  82 Turning a Bureaucratic Procedure into a Lived, Meaningful Experience  83 Inducing National and Local Self-identification   84 Humanising the State   85 Emotional Work  86 Apolitical, Too Political, Right or Left?   88 3.4 Naturalisation as a Commercial Commodity  90 Customer Service  90 Source of Profit: “Citizenship Pays for All the Other Applications.”  92 3.5 Comparison and Conclusion  96 References100 4 Authorities  in Naturalisation Procedures: Structurally Prescribed and Self-Perceived Roles of State Actors103 4.1 Accessing Information and Forms: The Role of Legal Advisers 105 Structural Conditions: Regulation and Funding  105 Relationship with Citizenship Applicants  107 Relationship with State Departments  111 4.2 Educating “Good” Citizens: The Role of Citizenship Course Teachers 114 Structural Conditions: Guidelines, Accreditation, and Funding  114 Teachers’ Experiences with the “Citizenship Materials” and “Orientation Courses”  116 4.3 Presenting the Certificate: The Role of Registrars and Caseworkers 121 Structural Conditions: Guidelines, Competences, and Working Conditions  122 Self-Perception and Experiences  123

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4.4 Addressing the “New” Citizens: The Role of Honorary Ceremony Speakers 127 Guidelines 127 Self-Perception 130 4.5 Discrepancies Between Structurally Prescribed and Self-Perceived Roles 133 References137 5 Techniques  of Subject-Formation: Citizenship Courses, Tests, and Ceremonies141 5.1 Citizenship Courses and Tests 143 Presentation of the State  146 Suggested Self-Guidance  154 5.2 Citizenship Ceremonies 161 Presentation of the State  161 Suggested Self-Guidance  170 5.3 The Dialectics of Citizenship Courses, Tests and Ceremonies: Between National Nostalgia and Democratic Modernity 175 References179 6 Responses  to the Super Citizen: Migrants’ Lived Experiences of Naturalisation183 6.1 Embrace 184 6.2 Contestation 186 6.3 Disaffection 189 6.4 Migrants’ Competition for State Recognition and New Hierarchies of Worthiness 192 6.5 The Ambivalent Effects of the Super Citizen 198 References203 7 The  Super Citizen and the Future of Naturalisation205 7.1 Current Policy Developments in the UK and Germany 208 7.2 Recommendations for Future Policy-Making 213 De-Symbolise Naturalisation  213

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Introduce a Conditional Entitlement to Naturalisation and a Right to Appeal (in the UK)  215 Reduce the Naturalisation Fee (in the UK)  215 Restore the ESOL with Citizenship Materials Course Route (in the UK)  216 Restore Public Funding for Legal Advice on Naturalisation (in the UK)  217 Allow Dual Nationality (in Germany)  217 Clearly Define “Outstanding Efforts at Integration” (in Germany)  218 Publish the Administrative Guidelines (in Germany)  219 Redefine the Economic Self-Sufficiency Requirement (in Germany)  220 References221 I ndex225

About the Author

Elisabeth Badenhoop is Assistant Professor of Sociology at the University of Wuppertal. She is the guest editor of “Citizenship Matters: Assessing the History, Regulation and Lived Experiences of Naturalization from a Global Perspective” (Citizenship Studies, 2021). Her research has been published in leading journals, including Governance, Regulation & Governance, and Comparative Political Studies, and has been cited by the UK House of Lords Justice and Home Affairs Committee.

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1 Naturalisation as Subject-Formation and the Call for the Super Citizen

One morning in October 2012, around forty candidates and guests gathered in the local Council Chamber of the London Borough of Brent to receive their certificates of naturalisation as British citizens, listening to the head registrar as he concluded his “welcome speech”: We want you to respect being British, […] to respect the values of this country—as I’m sure you do—but also to retain your own cultural identities because that’s also incredibly important, that’s what makes Britain incredibly special and we want to celebrate that. […] And at some point, you could actually be sitting on one of these seats, actually helping your community and being an elected representative of your community. And that’s part of why we hold the ceremonies here, too, to ensure you know this isn’t just a scary place, it’s somewhere you can aspire to. (observation BrPres7, 09/10/2012)1  Given the diversity and volume of the data, I cite observations of events and interviews with research participants using a system of codes that indicate the research location (Brent, Burnley, Dresden, and Hamburg) and participant group (citizenship applicants, administrators, teachers, legal advisers, politicians, and ceremony guest contributors) or event type (citizenship class session, citizenship ceremony, and submission of application). Here, “observation BrPres7, 09/10/12” means that this was the seventh presentation of certificates (citizenship ceremony) I observed in Brent on 9 October 2012. 1

© The Author(s), under exclusive license to Springer Nature Switzerland AG 2023 E. Badenhoop, Calling for the Super Citizen, Palgrave Politics of Identity and Citizenship Series, https://doi.org/10.1007/978-3-031-34260-8_1

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At a similar event in Dresden, Germany, in August 2013, a gathering of several hundred naturalised citizens and their guests assembled in the plenary hall of the Saxon parliament in Dresden for the state’s annual citizenship ceremony. The Saxon Foreigner Commissioner addressed them in the following way: Please do become aware of the strengths and weaknesses of your different cultures. […] Our country needs such people capable of building bridges (Brückenbauer) as you. You will have already recognised many of the strengths of your new diversity. Utilise this knowledge and invest it into our society and politics! You now possess the highest privilege of our society. You may vote and, just as important, you may stand for election—do it! Help our politics and our political parties to recognise, value and utilise the opportunities of cultural diversity and of building bridges. Do become members of a democratic party. (observation DrPres3, 31/08/2013)2

These two extracts from speeches held at citizenship ceremonies in the UK and Germany, respectively, point to the crucial insight of this research study. So-called naturalisation procedures do not simply select and include (or exclude) migrant citizens by granting (or declining) full membership. They also call upon migrants to optimise themselves in the nation-state’s alleged political, economic, and cultural interests. In other words, citizenship admission procedures can be conceived as a regime of subject-formation producing a specific type of subjectivity which I conceptualise in this book as the “Super Citizen”. At the above-cited ceremonies, the speakers envisaged a particular role for the newly naturalised citizens. The British speaker encouraged naturalised citizens to “aspire” to taking a Council seat, while the German speaker suggested that they become “bridge builders”. The subjectivity of the Super Citizen expresses this idealised figure of the naturalised citizen who, in the eyes of the state (as performed by officials and implied by regulations and guidelines), has the potential to become an asset to the liberal state’s democratic self-­ representation, to its flourishing economy and cultural diversity.  Throughout the book, all translations from German into English are made by the author, unless otherwise specified. 2

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1.1 Synopsis of the Book In this book, I focus on citizenship as formal state membership; hence, I concentrate on the aspect of status rather than rights or identity (cf. Joppke 2010, 28–30).3 Unlike scholars’ idealisation of post-national, de-­ national, and transnational citizenship following the end of the Cold War (cf. Soysal 1994; Sassen 2002; Faist 2000), this book starts from the assumption that the importance of holding national citizenship status should not be underestimated, for two reasons. First, citizenship continues to offer the most secure status to immigrants from a global and interdisciplinary perspective (Badenhoop 2021a). In the immigration-hostile climate which continues to shape large parts of Europe and the USA, naturalisation “protects immigrants against deportation” (Aptekar 2015, 3). As studies on statelessness have demonstrated, citizenship remains the precondition to accessing basic human rights such as residence (Blitz and Lynch 2011; Butler and Spivak 2007). Second, not just any nationality will do to provide access to rights. From a perspective of global justice, the distribution mechanism of citizenship at birth is similar to a “birthright lottery” as that membership “has a significant impact on our identity, security, well-being, and on the range of opportunities realistically available to us” and yet its allocation by the two main legal principles of birthright (ius soli and ius sanguinis) is completely “arbitrary” (Shachar 2009, 5, 7). In other words, naturalisation offers a means of agency for individual migrants to reject a poor result from, and evade that, global lottery by applying for membership of a relatively wealthy, stable nation-state, for example, Germany or the United Kingdom. As European states increasingly securitise and control citizenship at their borders and within their territories, it becomes vital for non-national residents to obtain citizenship of a European nation-­ state so that they are able to pass identity checks (cf. Anderson 2013; Walters 2009).  Although these three aspects are closely linked and mutually reinforce each other, for example, the prospect of gaining the right to vote or the feeling of belonging to Germany or the UK, respectively (or the city or region), may motivate someone to apply for naturalisation; likewise, the experience of naturalisation offers new rights and may reinforce a sense of belonging to Germany or the UK, but it may also alienate some applicants who previously felt well integrated (see Chap. 6). 3

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The widespread adoption of citizenship tests, courses, and ceremonies since the 2000s in most European states profoundly changed the naturalisation process in these countries, including those with significant migrant influx, such as Germany and the United Kingdom. Previously, naturalisation used to be a largely impersonal bureaucratic process dealt with on paper behind closed doors. The tests and courses introduced a new standardised assessment of civic knowledge and language skills based on multiple-choice questions and centralised course curricula while the local ceremonies created new platforms of self-representation of the state as well as encounters between migrant citizenship applicants and state actors. How are these new naturalisation regimes implemented in practice and how are they experienced by migrants who are subjects of it? Existing accounts in political science and law tend to justify the new citizenship requirements as more or less liberal measures of civic integration and inclusion (cf. Joppke 2010; Goodman 2014), whereas critical naturalisation studies in sociology and anthropology rejected the tests, courses and ceremonies as further contributing to migrants’ exclusion in Western states (cf. Suvarierol and Kirk 2015; zur Nieden 2009; Tyler 2010). While these accounts have highlighted the important dynamics of inclusion and exclusion through naturalisation, they fail to explain the productive effects of naturalisation. That is, they fail to describe and explain the ways in which the course exercises, test questions or ceremony speeches produce meaning for, and provide guidance to, migrants for how to think of and conduct themselves, thereby defining and structuring the field of possible actions. In other words, we still know little about the local implementation and lived experiences of the new naturalisation regimes. By investigating their intended as well as unintended consequences, the aim of this book is to understand the empirical efficacy of naturalisation policies, thereby allowing citizenship studies to move beyond the normative divide between the paradigm of civic integration and critical naturalisation scholarship that has dominated the field over the past decades. Rather than simply assuming the efficacy of naturalisation policies for normative reasons (legitimising or rejecting citizenship requirements), this book treats the policy effects and consequences as open empirical questions. In so doing, my analysis considers the perspectives

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of a variety of actors involved, from the state officials who design and implement the naturalisation regime to the migrants who are subjects of it. The book’s core argument is that the current naturalisation requirements and procedures in Germany and the UK constitute a particular subject-formation regime which suggests to migrants to constantly optimise themselves in the state’s interests towards a specific subjectivity that I critically term the Super Citizen. This subjectivity is the product of the naturalisation laws, regulations, practices, test questions, course exercises and ceremony speech acts all together, and it requires citizenship applicants to assess and model themselves to become a political, economic, and cultural asset to the liberal-democratic, capitalist nation-state. The subjectivity of the Super Citizen expects migrants to save the economy by providing their highly skilled labour as well as unpaid labour through extensive volunteering, from the local nursery to the fire brigade; it suggests to migrants that they should be culturally different (but not too different) to maintain the public self-image of diversity, for example, by maintaining multiple language skills to facilitate intercultural dialogue; and it demands naturalised citizens to revive the political democratic system and set an example for fellow citizens by casting their vote and standing for public office. In short, the Super Citizen subjectivity holds migrants responsible to behave like role model citizens and even to fight off the racism they encounter in an increasingly immigration-hostile climate. The concept of the Super Citizen allows us to highlight and criticise the state’s double-standards and overburdening expectations towards citizens by application as opposed to citizens by birth. Moreover, it shows that the new naturalisation regimes facilitate a self-presentation of the British and the German states as inclusive, liberal, and meritocratic polities which are in stark contrast to migrants’ lived experiences of the naturalisation process and their interactions with discretionary state authorities. Based on that argument, this book makes three significant contributions to citizenship and migration studies. First, it uniquely demonstrates that naturalisation is a powerful regime of subject-formation that produces highly ambivalent (equalising and differentiating) social effects, facilitating new hierarchies and a continuous competition for recognition

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among migrant and national-born citizens. This insight challenges the conventional wisdom of citizenship and migration theories that naturalisation is the final moment of state recognition offering full legal and symbolic membership status for migrants. The comparative analysis of this book reveals that the Super Citizen is a transnational subjectivity found in all four research locations in Germany and the UK which suggests that the naturalisation procedures of other immigration countries might be underpinned by similar subject-formation regimes as well. Second, employing constructivist theories of governance and power, I define four categories of analysis—problematisations, rationalities, authorities, and techniques—to flesh out the mechanisms through which the Super Citizen subjectivity is created. This analytical focus on the policy implementation generates insights into local practices of naturalisation that legal and political science accounts fail to capture. Third, the methodological framework of a multi-sited state ethnography enables the analysis of this book to trace naturalisation processes for the first time from the pre-application to the final stages in two different national and four different local contexts, covering the perspectives of both state and migrant actors based on the analysis of qualitative interviews, ethnographic observations, and official documents. The combination of multiple methods and multiple actors’ perspectives in multiple research locations enables a comprehensive, fine-grained and nuanced analysis at the macro, meso, and micro levels of the processes through which migrants obtain full membership. In offering a robust empirical analysis of both the design and implementation of naturalisation policies at local and central levels, this book makes a unique contribution to the existing literature. These empirical, theoretical and methodological innovations allow the book to move beyond the existing narrow focus on written policies on the one hand, and on single elements (e.g. tests or ceremonies) or actors (e.g. migrants) on the other hand, offering a truly holistic account of naturalisation processes in two major European immigration countries from an interdisciplinary social science perspective. In the remainder of this introduction, I examine how the new naturalisation regimes have been discussed in the academic debate before I present the subject-­ formation framework and the concept of the Super Citizen. I then

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present a brief analysis of the historical emergence of naturalisation in the UK and in Germany up to the current legal requirements in both countries today. Finally, I explain the comparative case study design and the methodological approach of a multi-sited state ethnography behind the analysis in this book, before I conclude by giving an outline of each chapter.

1.2 The Call for the Super Citizen: Naturalisation as Subject-Formation Naturalisation Requirements in the Academic Debate The existing research on citizenship tests, courses, and ceremonies can be grouped into roughly two different approaches. On the one hand, authors with a state-centred perspective (who tend to work within the disciplines of political theory, quantitative political science, and law) have focused on the structural-formal citizenship requirements on a macro-level, arguing that these are more or less legitimate and compatible with republican or liberal norms and values. On the other side of the debate, scholars often adopt a migrant-centred perspective (often within the disciplines of sociology, anthropology, and education), focusing on the micro-level practices and lived experiences of citizenship tests, courses, and ceremonies, and highlighting their excluding, racializing, and securitizing effects. However, both of these approaches tend to remain limited to the question of inclusion or exclusion and fail to grasp the productive effects of naturalisation as I will show in the following section. Citizenship tests first caught the attention of political scientists. To the extent that citizenship has traditionally been studied in the context of normative political theory, the predominant literature on citizenship tests has examined whether such tests can be regarded as “liberal”, “republican”, or “communitarian” policies, yet often struggling to reach clear conclusions (see, e.g., Etzioni 2007; Orgad 2010; Joppke 2010; Guild et al. 2009; Oers et al. 2010; Goodman 2010). Christian Joppke, for example, argued that language and knowledge tests represent an “‘illiberal social

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policy’ in a liberal state” (Joppke 2007, 14). Following this logic, tests are sometimes regarded as “liberal” overall because they pursue “liberal goals”, but since they are obligatory, they are also “repressive” (Michalowski 2011, 750). The distinction between “liberal” and “illiberal” in this debate refers to the tests’ terms (e.g. whether they are mandatory or voluntary), their content, and their social selectivity. For example, test questions or preparation books may convey a pluralistic, open imagination of the nation, or an ethno-culturally exclusive and homogenous one, implicitly or explicitly upholding a view of the superiority of Western liberal-democratic states. The questions may test an applicant’s practical knowledge of how to exercise citizenship rights and duties, for example, by voting, and/or they may reproduce historical myths about the birth and the achievements of the nation. The meaning of “liberal” and “illiberal” in those accounts can also refer to the social selectivity of tests as expressed in fees, pass rates, and how the questions are formulated, as this can make them easily comprehensible or deliberately misleading (on the social selectivity of citizenship tests, see also Bauböck and Joppke 2010). However, this state-centred approach suffers from an epistemological and a methodological limitation. First, the criticism that certain tests are “illiberal” implies the justification of other tests as liberal. In other words, this literature risks legitimising rather than critically analysing citizenship tests. For example, Ricky van Oers concluded that the German citizenship test is more “liberal” than the British one (Oers 2014, 144), whereas Ines Michalowski disagreed, arguing that both the German and the British test contents can be described as “liberal” (Michalowski 2011, 765). This raises the question of how meaningful labels such as “liberal” really are. Second, while this body of literature has examined an impressive range of countries and helped reconstruct policy shifts at the macro-­ level, it has tended to approach naturalisation as a policy written on paper and drawn conclusions based on laws, regulations, and government papers. In other words, the explanatory power of the distinction between “liberal” and “illiberal” is very limited regarding the practical effects of such policies because its authors have tended to neglect the real-life implementation of citizenship tests.

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Addressing this shortcoming, a growing number of sociological and anthropological studies have provided empirical insights from ceremony halls and classrooms that can be categorised into three distinct critiques of the tests, courses, and ceremonies as (1) neoliberal, (2) postcolonial-­ racist, and (3) dialectical naturalisation requirements. According to the first critique, the new citizenship requirements represent a shift of responsibility from the state onto migrants, who should take responsibility for their own settlement and integration processes without expecting public support (Suvarierol and Kirk 2015; Turner 2014). The neoliberal outsourcing of state duties also extends the ongoing securitisation of migration (Huysmans 1995) into the policy area of naturalisation, as language teachers are expected to perform border guard-type duties in classrooms, such as checking migrants’ passports and identity documents before they may participate in a citizenship course (zur Nieden 2009). Secondly, it has been argued that the new citizenship requirements represent a form of state racism (Tyler 2010) and a “civilizing project” that inflict mandatory integration lessons delivered by a “predominantly white […] administration” onto “mainly People of Colour from the postcolonial states of Africa, Asia and Latin America, in fact especially Muslim communities with Turkish or Arabic backgrounds” (Hà 2010, 164). Thirdly, most studies in this area have emphasised that the modern citizenship requirements represent a new level of state selection through a highly ambivalent process of simultaneous inclusion and exclusion of migrants aspiring full membership whereby migrants are considered both as a potential national source of pride and of scorn. The ceremonies, for example, provide a welcome that comes too late for many migrants, and an offer of inclusion to be doubted; they mainly serve to reassure public anxieties about migrants (Fortier 2013; Byrne 2014; Aptekar 2015; Damsholt 2008). Finally, this approach has also considered the perspectives of migrants on naturalisation and on citizenship tests and ceremonies (Prümm 2004; Wunderlich 2005; Street 2014; Çelik 2015; Witte 2018; Byrne 2014, 2017; Bassel et al. 2018; Monforte et al. 2019; Sredanovic 2022a, 2022b). While these analyses provide important critiques and insights, most of them have tended to focus on one requirement and a single country, thus neglecting that the test (or ceremony or course) is just one element of the naturalisation process, and that these new requirements are part of a transnational trend.

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The Subject-Formation Framework Both the state-centred and the migrant-centred perspectives revolve around attitudes to inclusion/exclusion. However, in order to understand the productive effects of naturalisation processes, a new conceptual approach is needed; one that moves beyond the dialectic of inclusion and exclusion which has dominated citizenship and migration studies for too long. The subject-formation framework shifts the focus of analysis onto all the attempts through which states suggest to individuals that they should model themselves to reflect a specific subjectivity, shaping and optimising their self-conduct and self-understanding according to that ideal (Badenhoop 2017, 412). Originating in post-structuralist theories of power, specifically governmentality studies (Foucault 1983; Dean 2003; Lemke 2002), this framework assumes that “power […] also can act positively to produce and to define” (Bevir 1999, 349). Subject-­ formation, or subjectification, refers to all instances where “human beings shall be made subjects and transform themselves into subjects” (Bröckling 2007, 121; cf. 2012, 131). The subject or subjectivity is defined here not as a homogenous, bounded, natural entity as it is conceived in the Kantian philosophical tradition. Rather, for the purpose of the analysis in this book subjectivity is understood as a “focal point for all the efforts to define and control [the individual] from without and within” (Bröckling 2016, 3). A particular subjectivity such as “an entrepreneur” is not something we are, or can ever attain, but is, rather, “something we are supposed to become” (ibid., ix). This definition of subject-formation has three important features. First, it is performative, since the subject is not “pre-existent and waiting to be discovered but it has to be produced” (nicht vorfindbar, sondern hervorzubringend) (Bröckling 2012, 132). Subject-formation requires constant self-modelling, and the focal point for all those efforts can never be reached. Second, the subject is both socially shaped and self-shaped. On the one hand, it is constituted by external forces as it is being called upon (“hailed”) by others. In this context, the post-structuralist term “hailing” refers to social interactions where an individual faces discursive calls, that is, suggestions or expectations regarding his or her behaviour (what to do/not do) and self-understanding (how to think of her/himself ) that

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aim at influencing potential future actions. On the other hand, the hailed individual is not purely passive, reacting to external calls according to his or her pre-conditioned self; they also actively participate in processes of subject-formation as they are also “a hailer of others” and of themselves (Bröckling 2016, 6). Subject-formation thus involves both external forces as well as individual self-conduct: a “troika of shaping, being shaped and self-shaping” (ibid., 8). Third, because of this formative aspect, subject-­ formation is considered highly efficacious and powerful. The constant conditioning and modelling mean that individuals internalise the expected conduct which contributes to “structuring and shaping the field of possible action of subjects” (Lemke 2002, 52). Applying the subject-formation framework to the study of citizenship admission procedures has the advantage of creating analytical distance to the inclusion/exclusion logic of nation-state policies. While the subject-­ formation approach conceptualises naturalisation as a practice that divides citizens by birth from citizens by application, a practice originally invented because non-citizens have “come to be seen as problematic” (Rose 1999, xi) in the global order of nation-states, it further examines which subjectivity naturalisation produces, and how it does so. Adapting some of the elements proposed by Rose (1998, 25–27; 1999, xi) to the case of naturalisation, the subject-formation framework allows us to shift the research focus onto four specific categories of analysis each of which will be explored in depth in the following chapters: 1. problematisations, such as statutory requirements that render certain features of a citizenship applicant problematic, for example, holding dual nationality or not being of “good character” (see Chap. 2); 2. rationalities, that is, concepts and ways of thinking about citizenship that justify a specific design of naturalisation procedures, for instance, naturalisation as a privilege versus entitlement (see Chap. 3); 3. authorities, that is, the state actors in charge of implementing naturalisation procedures, including caseworkers, ceremony organisers, teachers and test administrators, among others (see Chap. 4); and 4. techniques for citizenship applicants to optimise themselves; for example, by undergoing citizenship courses, tests and/or ceremonies (see Chap. 5).

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The subject-formation approach has been systematically applied in the fields of mental health (Rose 1998, 1999; Miller and Rose 2008), economics, and welfare state policy (Bröckling 2016; Cruikshank 1999). This literature has tended to concentrate on the various calls, that is, the attempts of subject-formation, thereby neglecting the responses that are the effects of subject-formation. For example, in his study of the “entrepreneurial self ”, a subjectivity he found in economic theories, management literature, and welfare state policies, Bröckling concluded that “[t]he interpellations of the entrepreneurial self are totalitarian” (Bröckling 2016, 196). Consequently, he saw little room for resistance, let alone agency. However, adhering to the assumption of the somewhat automatic efficacy of policies and regulations risks overemphasising the effectiveness of subject-formation in practice. Existing analyses of subject-formation are prone to structural determinism as long as their focus remains limited to how “the social world makes the subject, not the ways in which the subject makes the social world” (Bevir 1999, 357). From the point of view of political sociology, analyses of subject-formation must consider the role of individual agency. While it is important to understand the techniques and authorities of a specific call of subject-formation, it is equally important to understand how this call is received and answered by those being called upon. Migrants’ lived experiences of naturalisation procedures and their responses to the Super Citizen subjectivity will therefore be examined in detail in Chap. 6.

The Call for the Super Citizen In many ways, naturalisation is an example of subject-formation par excellence. Citizenship is a significant tool of social closure through which nation-states include their own nationals and exclude non-nationals and migrants (Brubaker 1992). However, naturalisation not only selectively includes migrants; it also attempts to activate and optimise citizenship candidates. Naturalisation illustrates the ambivalent attitude of the liberal-­democratic nation-state towards immigrants who are welcomed as “givers”, for example, by providing their labour, or rejected as “takers”,

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for example, by accessing welfare benefits (Honig 2001). By applying for naturalisation, migrants can resolve their problematised “foreignness”, yet their request for citizenship still troubles the ideology of nation-states, which are defined not as voluntary associations but as communities formed primarily through involuntary birthright membership. While the outcome of the naturalisation process legally eradicates migrants’ difference (by giving them equal status with “national-born” citizens), the existence and practice of naturalisation in many states re-enact the distinction between nationals who automatically obtain membership at birth on the one hand, and non-nationals, on the other, who have to apply for, and be tested to attain, citizenship status (on this distinction cf. Brubaker 1989). Moreover, by directing institutionalised appeals at citizenship applicants through tests, courses, and ceremonies, naturalisation procedures express the state’s expectations and create the subjectivity of the Super Citizen (Badenhoop 2017, 2021b). This subjectivity is visible both in Germany and the UK, and there are indications that it may, in fact, play an important role across the Western hemisphere because the Super Citizen is a subjectivity of a role model member of a liberal-democratic, capitalist, modern nation-state. The Super Citizen suggests to migrants aspiring to citizenship that they should become ideal citizens and combined political, economic, and cultural assets to the state. They should exercise their newly gained right to vote, thus helping to maintain the democratic political system, and should strengthen the capitalist market economy by providing paid and unpaid labour. And with their supposed multiple language skills and multicultural lifestyles and cuisines, they should enhance the ethnic and cultural diversity of the modern liberal society. As such, the Super Citizen forms an instrumental part of maintaining a specific self-image of the nation-state as an open and diverse society based on a competitive market economy and liberal democracy. The call for the Super Citizen is found throughout the naturalisation procedure, expressed by various actors and in different settings, ranging from standardised test questions, exercises used in local citizenship courses, speeches delivered regularly at citizenship ceremonies, to the spontaneous interactions with caseworkers in naturalisation offices. For example, migrants may find themselves being reminded before receiving their certificate of naturalisation that they now possess the right to vote

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and the right to stand for election, which they should use to set an example to national-born citizens who do not cast their vote (or who vote for far-right parties) (see Chap. 5 and Badenhoop 2017, 420–21). In a classroom exercise, migrants may be asked to list examples of voluntary work, and then apply the question “Are you a good citizen?” to themselves (see Chap. 5). The Super Citizen concept thus provides a critical tool for the analysis of contemporary naturalisation procedures, in three key ways. First, it highlights the extraordinary efforts and self-modification required from, and expected of, citizens by application—as opposed to citizens by birth. No person considered to be a “national” state member is asked to pass a citizenship test, or to demonstrate their loyalty in order to gain full membership status as citizenship is automatically assigned to them at birth. The formal threshold for migrants to obtain citizenship has been raised in recent years, and the state’s expectations as expressed in the Super Citizen subjectivity require constant efforts which go beyond the formal elements of the naturalisation process. The call for the Super Citizen brings to light these double-standards. Second, the Super Citizen points to the idealisation of naturalised migrants as citizens by choice (cf. Byrne 2014; Aptekar 2015). Migrants’ active decision to request a specific state membership is considered to be more compatible with liberal-democratic ideals than the passive, automatic granting of such membership to nationals at birth without their consent as individuals. Thus, migrants’ applications for citizenship mean they come to be seen as democratically ideal citizens. This idealisation explains the overload of expectations according to which migrants should constantly strive to become political, economic, and cultural assets for the nation-state. Third, the Super Citizen subjectivity also has significant neoliberal and neonational dimensions. It is supposed to activate migrants and hold them responsible for becoming role model citizens in order to convince anti-immigrant citizens by birth that migrants are “givers”, not “takers”. Migrants are expected to adopt a new, moderate nationalism that should serve as an antidote to new populism and the far right (Badenhoop 2017). By staging citizenship ceremonies and courses as symbolic politics which celebrate these new members’ diversity, states present themselves as inclusive, multicultural, and

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modern, yet without committing themselves to combat the structural inequalities and racism faced by migrants.

1.3 The Historical Emergence of Naturalisation in the UK and Germany The UK and Germany are particularly instructive cases to explore the emergence, implementation and lived experiences of naturalisation because they represent similar-but-different case studies: the British and German citizenship models were historically different but have converged and, to some extent, reversed today. Specifically, the comparative analysis of the UK and Germany helps to shed light on how two factors shape the implementation of similar naturalisation policies (tests, courses, ceremonies): first, different citizenship traditions (expansive vs. restrictive) and second, different state structures (centralised vs. decentralised). Britain and Germany are both established immigration countries in Europe and introduced similar naturalisation reforms since the early 2000s including citizenship tests, courses and ceremonies. However, the two countries are characterised by historically different models of “civic” versus “ethnic” citizenship as Britain expanded membership across its empire when adopting the legal principle of ius soli (membership by right of birthplace) in 1914, while the 1913 German Nationality Act affirmed ius sanguinis, thus restricting membership of the German state to Germans by family descent. Today, by contrast, German nationality law provides a relatively secure path to naturalisation through entitlement while the grant of British citizenship remains a privilege at the ultimate discretion of the UK Home Secretary, as discussed in the following section. Moreover, the administration of naturalisation is shaped by different state structures. In the centralised system of the UK, the processing of citizenship applications is concentrated within one department of the Home Office (the Nationality Group based in Liverpool) and the grant (or rejection) of naturalisation is at the ultimate discretion of the Home Secretary. In the German federal state system, the decision work is carried out by several hundred local Foreigner Authorities according to the

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federal citizenship act and the state-specific administrative regulations. Unlike the administrative regulations issued by the Federal Ministry of the Interior,4 the administrative regulations of the sixteen states are binding and not published in every state, for example, in Saxony. This federal structure means that naturalisation practices vary significantly within Germany, between different states and different local authorities. In the context of these different state structures, the process of naturalisation has been practised long before the modern concept of citizenship was known or codified in law. However, in feudal states, naturalisation conferred membership (“subjecthood”) and social status in terms of ancestry and land property within highly stratified societies. Reforms introduced during the nineteenth century in Britain and Germany gave naturalisation its contemporary administrative form: a standardised written application procedure conferring citizenship rights and duties. Since the beginning of the twentieth century, the British case shifted from expansive towards restrictive policies in the area of immigration and naturalisation, while naturalisation in Germany moved from a highly restrictive towards an expansive policy approach.

The UK Case In the UK, evidence of first acts of naturalisation goes back as early as 1295; however, such grants remained rare as individuals had to approach the King or Parliament through the “slow, cumbersome and expensive” private Bill procedure (Dummett and Nicol 1990, 72) and were thus dependent on the ultimate discretion of the monarch who chaired Parliament (Parry 1957, 34–35). This period saw the origin of the first requirement for naturalisation still valid today in amended form, an oath of loyalty, and an early form of citizenship ceremony. In 1066, William the Conqueror bound all lords through a “contract” of rights and   Vorläufige Anwendungshinweise des Bundesministeriums des Innern zum Staatsangehörigkeitsgesetz (StAG) in der Fassung des Zweiten Gesetzes zur Änderung des Staatsangehörigkeitsgesetzes vom 13. November 2014 (VAH-StAG Stand: 1. Juni 2015), https:// www.bmi.bund.de/SharedDocs/downloads/DE/veroeffentlichungen/themen/verfassung/stag-­ anwendungshinweise-­06-15.html (accessed 3 September 2022). 4

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obligations which was concluded by swearing an “oath of homage […] in a solemn church ceremony” (Dummett and Nicol 1990, 23). During the nineteenth century, the House of Commons considered “immigration […] highly beneficial” to the national economy (ibid., 84) and facilitated access to naturalisation with the 1844 and 1870 Naturalization Acts towards a mass application procedure concluded by a certificate requiring a written form, a fee, residence in the UK or Crown Service. However, these Acts retained the purely discretionary nature of naturalisation giving the Home Secretary instead of the monarch the power to make (or refuse) new “subjects” or, as they later came to be called, “citizens” of the United Kingdom without giving reason and without a right to appeal. This entirely discretionary definition of naturalisation continues to characterise the British case today and represents a key contrast to the German case. The 1914 British Nationality and Status of Aliens Act (s 1 (1) a) adopted the most expansive membership definition with the legal principle of ius soli and thus conferred entry and residence rights in Britain to any person born within a territory ruled by the British monarch—eventually “perhaps a third of the population of the world” (Harris 2004, 78). However, the 1914 Act (s 2 (1) b) also added new naturalisation requirements so that applicants had to demonstrate “good character and […] adequate knowledge of the English language” which at that time effectively prevented Jewish refugees from Russia and Germany naturalising in the UK (Kimber 2010, 31). After the Second World War, British state companies such as British Rail, London Transport, and the National Health Service actively recruited workers from colonies in the Caribbean, India, and Pakistan who as citizens of colonies or Commonwealth countries still enjoyed the right of abode in the UK under the 1948 British Nationality Act. This changed with a series of Immigration Acts in 1962, 1968, and 1971 which limited the right to enter and live in the United Kingdom to those whose passport had been issued in the UK or who could demonstrate British ancestors (“patrials”) (Clayton et al. 2016, 77–78). The crucial consequences of these legislative changes on colonial citizens’ lives were perhaps most dramatically highlighted in the case of East African Asians who had served for generations in the British civil service in Kenya,

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Tanzania, and Uganda, and who decided after those countries’ declarations of independence to keep their “citizenship of the United Kingdom and Colonies” but found that the UK borders were suddenly closed to them (ibid., 77). The European Commission on Human Rights found that the 1968 Act was “racially discriminatory” because the UK government deprived its “coloured” citizens of their right to enter and live in the country of their citizenship (ibid., 78). Nonetheless, the 1981 British Nationality Act (BNA) formalised the exclusionary practices that were effectively in place since 1971. The Act created the privileged status of “British citizenship” and formally withdrew the right of abode from the other five categories it created for people who had once been colonised (ibid., 79). Moreover, the 1981 Act abolished unconditional ius soli (ibid.) by reserving British citizenship for persons born in Britain to British parents. Following violent clashes between Asian and white British youth in Northern English towns, the 2002 Nationality, Immigration and Asylum Act significantly amended and formalised the existing language and oath requirements for naturalisation. By the end of the twentieth century, the oath of allegiance to the monarch was usually administered in private by a magistrate or solicitor and sufficient English skills were “assumed unless there was evidence to the contrary” (Clayton et al. 2016, 92). The 2002 Act specified that the oath and an additional pledge are to be made at a local “citizenship ceremony” (sch 1 [1]). The Act also added that applicants must demonstrate “sufficient knowledge of life in the UK” (s 1 [1]) to the existing language requirement. Subsequently, mandatory citizenship ceremonies came into force on 1 January 2004 and the “Life in the United Kingdom test” alongside language with citizenship courses have been run across Britain since 1 November 2005 (Fransman 2011, 409).

The German Case In Germany, naturalisation used to be a common local practice that became centralised and highly restrictive during nineteenth- and twentieth-­century German state formation processes and has been facilitated again since the 1990s.

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In the forty-one different states of the German Confederation (Deutscher Bund, 1815–1866), state membership was based on residence (ius domicilii) whereby emigration over ten years automatically led to de-­naturalisation, while ten years’ settlement usually led to “implicit” naturalisation (Fahrmeir 2000, 24). Municipalities were in a powerful position as local membership conferred membership of the respective state, which in turn granted membership of the Confederation (ibid., 64). Prussia was the first state to disempower local authorities with the 1842 Prussian Subjecthood Act which centralised the decision power in the hands of the Prussian police forces and Minister of the Interior with wide discretion (s 5) and abolished automatic naturalisation through settlement (s 13). Instead, it defined high socio-economic requirements for naturalisation including contractual capability, absence of a criminal record, accommodation, and self-subsistence (s 7). Moreover, the Act set descent as the main acquisition mode for state membership (s 1) and thus established the long tradition of ius sanguinis in Germany. Above all, this Act served as a template for subsequent naturalisation acts at the federal level, including the 1913 Empire and Nationality Act (Reichs- und Staatsangehörigkeitsgesetz, RuStAG) which remains in place today in amended form, known as Nationality Act (Staatsangehörigkeitsgesetz, StAG). Early forms of citizenship ceremonies existed in some German states similar to the UK. For example, the acquisition of citizenship status in Bavaria from 1812 onwards required taking a “citizenship oath” to obey the constitution, the laws and the monarch in a “dignified” manner, including an “instructive reminder” (belehrende Erinnerung) (Gosewinkel 2001, 48). This suggests that in a feudal state order, the introduction of citizenship ceremonies served as a tool for the monarch to discipline and subjugate the aristocracy (ibid. 45–48). In the German Empire (1871–1918) and Weimar Republic (1918–1933) the practice of naturalisation became increasingly standardised and restrictive. The socio-economic criteria of self-subsistence and accommodation particularly excluded poor Eastern European and Russian applicants (Gosewinkel 2001, 250) and thus had the same effect as the first introduction of an English language requirement in Britain in 1914. While a German language test was only introduced in 1997 for German immigrants (Spätaussiedler) to determine their German

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ethnicity (Volkszugehörigkeit) (Michalowski 2010, 185), “linguistic and cultural affinity” became unofficial requirements for membership as German emigrants returning from the USA or Russia and other Western European applicants achieved higher naturalisation rates than Eastern European, Russian or Jewish applicants (Gosewinkel 1998, 131; 2001, 243). The Nazi regime accelerated the trend of centralising and racializing the regulation and practice of naturalisation by systematically denaturalising Jews and forcibly naturalising Eastern Europeans deemed as belonging to the German “Volk” (Ehmann and Stark 2008, 24–36). After 1945, both German states actively recruited foreign labourers (although the German Democratic Republic (GDR) only sought them from socialist countries and did so on a much lower scale). Yet, neither East nor West Germany defined themselves as countries of immigration, and the return of migrant workers to their countries of origin was encouraged, particularly after the oil crisis in the 1970s. Consequently, naturalisation was “an exception, not the rule” (Green 2001, 31) to be granted only if “in the public interest” at a high fee of 5000 German Marks according to the 1977 West German naturalisation guidelines (Einbürgerungsrichtlinien) (cited in: ibid., 30, 33). Unlike labour migrants, ethnic German immigrants were entitled to citizenship under article 116 of the 1949 Basic Law (Grundgesetz) as well as free German language courses under the 1953 Federal Expellees Act (Bundesvertriebenengesetz, BVFG s 9 [1]). After the fall of the Berlin Wall, the arrival of German immigrants from the former GDR and the USSR coincided with an increased number of refugees from Kurdistan/Turkey, Yugoslavia, Iraq, Iran, Afghanistan, Vietnam, Sri Lanka, and elsewhere (Hoerder 2010, 112; Kurthen 2006, 185–86). Public opinion in unified Germany turned against alleged “asylum fraud”, asylum seeker accommodations were put on fire and migrants were murdered in several East and West German cities in 1992 and 1993 (Hoerder 2010, 111–12; Palmowski 2008, 555). At the same time, the 1990 Foreigner Act (Ausländergesetz) introduced a “legally enforceable right to naturalisation” (Anspruchseinbürgerung) on the conditions that applicants renounced their previous nationality, could demonstrate a minimum of fifteen years’ residence (eight years for young adults aged 16–23), could provide for themselves without receiving public benefits, and were without a criminal record, at a reduced fee of 500 German

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Marks for discretionary naturalisation and 100 German Marks for the entitlement route (AuslG s 85–86 cf. Green 2001, 32–34). In 1993, the unconditional right to asylum codified in article 16 of the Basic Law was significantly restricted while access to citizenship ought to be further facilitated in a cross-party compromise on immigration (Green 2001, 40). With the major reform of the Nationality Act (StAG) which came into effect in 2000, the Social Democrat and Green coalition government for the first time publicly affirmed that Germany is an immigration country and introduced a conditional ius soli for children born in Germany to foreign parents who had been legally resident for 8 years, and it reduced the residence requirement from 15 to 8 years for naturalisation by entitlement (Green 2012, 175). However, it also specified a German language requirement for naturalisation and introduced a new declaration of loyalty to the “free democratic constitution” (freiheitliche demokratische Grundordnung) (ibid., 176–177). Following the recommendations of the Süssmuth commission, the 2004 Immigration Act (Zuwanderungsgesetz) for the first time introduced a state-subsidised language course for all migrants (not just ethnic German ones). This “integration course” consists of a six-month-long language course followed by a one-month-long “orientation course” with citizenship materials, to be concluded by the standardised multiple-choice test “Life in Germany” which substitutes the naturalisation test (see below). The 2007 reform set the German language requirement at level B1 of the Common European Reference Framework, introduced a standardised naturalisation test (Einbürgerungstest) and required that the written declaration of loyalty also be made orally when the certificate is presented (Green 2012, 178). At the same time, municipalities increasingly began to organise local citizenship ceremonies with the intention that they would be a “positive conclusion to the process of naturalisation” (ibid., 177).

 aturalisation Requirements in the UK N and Germany Today The legal requirements for naturalisation in Britain and Germany have converged and are today largely similar, with a few significant exceptions.

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Both states require that applicants can demonstrate a permanent immigration status (usually “Indefinite Leave to Remain” in the UK and settlement permit, i.e. “Niederlassungserlaubnis” in Germany), legal capacity as well as freedom of criminal or debt record (in the UK, this is called the “good character” requirement which is highly opaque and creates numerous problems for citizenship applicants, as discussed in Chaps. 2 and 4). The UK and Germany also demand certified language skills (at level B1 of the Common European Reference Framework for Languages) and civic knowledge as certified through passing the “Life in the United Kingdom” or “Life in Germany” tests (henceforth referred to as British or German citizenship tests). And both states require proof of the applicant’s loyalty. In the UK, applicants must speak an oath of allegiance to the Monarch as well as a citizenship pledge at a mandatory local citizenship ceremony which concludes the naturalisation process. In Germany, applicants must sign a declaration and pledge to the liberal-democratic constitution on the application form and orally repeat the words at the final office appointment (although the modalities may vary, e.g. some local authorities insist that the declaration is rehearsed and spoken freely, see Chaps. 2, 3, and 6). Local or regional citizenship ceremonies in Germany are voluntary and take place after the applicants successfully completed their naturalisation procedures. Five important differences remain. First, the main difference between naturalisation in Britain and Germany today is its legal nature. British citizenship admission remains completely discretionary (1981 BNA s 6), whereas German citizenship law contains a statutory entitlement for migrants to obtain citizenship (StAG s 10). The discretionary definition in the UK has significant consequences for migrants because they have no right to appeal and the application fee will not be refunded if their application is refused. Second, while both states require a minimum length of lawful and documented residence in the country, German law requires eight years compared to just five years in the UK (although the current coalition government in Germany plans to reduce the required residence to five years which would further align the two countries’ naturalisation requirements, see Chap. 7). Moreover, British nationality law requests actual physical residence in the UK since day one of the qualifying period (a maximum of 450 days of absence is tolerated over the five years’

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residence period and no more than 90 days each year), and it requires that applicants intend to stay in the UK. Third, candidates in Germany must demonstrate that they can support themselves and their family members without recourse to social benefits unless this is “due to conditions beyond their control”5 (StAG s 10 (1) 3). While this criterion is not explicitly included in the list of statutory requirements in the UK, financial soundness is part of the British “good character” requirement. Fourth, Germany requests that new members renounce their previous nationality as German nationality law still adheres to the principle of avoiding dual nationality even though there are more and more exceptions to this rule and the current coalition government plans to allow multiple nationalities (see Chap. 7). While the UK does not prohibit dual nationality, this also facilitates the withdrawal of British citizenship of dual nationals under certain circumstances, a trend that has accelerated as discussed in Chap. 7. Finally, the current fee for naturalisation significantly differs between the two countries: an application for naturalisation costs 1330 GBP (including the 80 GBP citizenship ceremony fee) in the UK compared to 255 Euro in Germany.

1.4 A Multi-sited State Ethnography of Naturalisation in the UK and Germany This book analyses naturalisation policies and processes based on the qualitative empirical research approach of a “multi-sited state ethnography” (Badenhoop 2017; cf. Pates and Schmidt 2009; Falzon 2009). This strategy has two significant analytical advantages for the study of state policies. First, applying ethnographic research methods to the context of government and policy-making offers the possibility to examine the actual implementation and interpretation of policies, moving beyond the law on the books. This approach shifts the focus on the agency and perspectives of the multiple actors involved in the policy-making process at both local and central levels of government and administration, paying  Translation by the Federal Ministry of the Interior (https://www.gesetze-im-internet.de/englisch_ stag/englisch_stag.html, accessed 25 April 2023). 5

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attention to the crucial role of “street-level bureaucrats” in shaping policy outcomes (Lipsky 1980; Latour 2010). While ethnographic research designs have been associated with the study of postcolonial and authoritarian states (Sharma and Gupta 2006; Scott 1998), they have lately been successfully applied to Western democracies in the area of migration, for example, to examine the administration of asylum policies in Glasgow (Farrell 2012) and Vienna (Dahlvik 2018). Second, assuming a “spatial de-centredness” (Falzon 2009, 2) and a “polycentric” state order (Pates and Schmidt 2009, 215) where national law is enforced locally, this methodology enables us to shift the research focus to multiple locations and compare practices within as well as between different states, thereby avoiding the pitfalls of methodological nationalism. Research for this project was conducted in four distinct locations. For the British case study I conducted fieldwork in the London Borough of Brent and in the Northern English town of Burnley; for the German case study I focused on the East German city of Dresden and the Northern city-state of Hamburg. These four locations were not chosen to be equivalent matches, but rather because of their individual significance to represent socio-economic, political, and ethnic differences within the two states. Hamburg and Brent are both thriving urban hubs. A long-standing migrant presence has created super-diverse populations and given these places a metropolitan character, attracting new waves of highly qualified migrants. Hamburg and Brent can also be described as pioneering pro-­ active policies towards migrants becoming citizens, each within their remits. Given the relative autonomy afforded by its status as a city-state, Hamburg has launched several naturalisation campaigns since 2006, and Brent Council hosted the first British citizenship ceremony in 2004. In both places, the local government adopted migration, or the ethnic diversity resulting from it, as part of the state’s self-understanding. Burnley and Dresden, on the other hand, are situated in socio-­ economically deprived areas, in de-industrialised North England and post-socialist East Germany respectively. Both locations have experienced a political far-right presence which has been expressed, for example, through important electoral successes for the British National Party

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(which gained its first County Council Seat in Burnley in 2009) and for the German National Democratic Party (NPD) before Pegida and the Alternative for Germany (AfD) established themselves. A comparatively limited experience with migration has created predominantly white populations and both places have a history of racist attacks and murders. The analysis in this book draws on three main types of sources (interviews, observations, documents) gathered over the course of twelve months’ ethnographic fieldwork from 2012 to 2013 in four research locations: First, I conducted ninety-two semi-structured interviews, as well as one hundred ethnographic conversations with a range of state and migrant actors. The largest group of respondents were migrants applying for citizenship. The sample of these citizenship applicants was as diverse as possible including women and men with thirty different nationalities from Europe, Africa, Asia, Russia, and the Americas, aged between 19 and 106 years. These research participants had taken various immigration routes to the UK and Germany (work, study, family reunification, documented or undocumented entry for asylum, or they had been born in the country as non-nationals) and were at different stages of the naturalisation process at the time of the research. The other main groups of respondents included state officials and politicians, legal advisers, teachers of citizenship courses as well as honorary guest speakers at citizenship ceremonies, including David Blunkett who as then UK Home Secretary first introduced citizenship tests and ceremonies in Britain and Olaf Scholz who as then Mayor of Hamburg adopted extensive pro-naturalisation campaigns and citizenship ceremonies. Second, I conducted seventy-seven participant observations of local citizenship ceremonies, citizenship courses and naturalisation office appointments. The appointments I observed in Germany took place in municipal Foreigners Authorities where naturalisation applications are dealt with by local caseworkers. In the UK, applications are processed by a central department of the Home Office located in Liverpool which I visited, in addition to attending “Nationality Checking Service” (NCS) appointments at a local registry and a training workshop organised by the Home Office for local registrars who offer such NCS screening appointments.

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Third, I analysed official documents such as nationality laws and regulations, caseworker instructions, application forms, information materials, written correspondence, invitation letters, manuscripts of ceremony speeches, course curricula and materials used in classrooms as well as test questions and textbooks that were publicly accessible or shared with me by research participants in addition to my own audio-­recordings and photographs taken during observations. Research participants and sites were accessed primarily through local migrant support groups, adult education colleges and snowball sampling.

1.5 Outline of the Book Following this chapter’s introduction to the book’s argument, analytical framework, and case studies, the next chapter analyses the problematisations which are constructed and deployed in contemporary naturalisation procedures in the UK and Germany. Defined as the categorisations and vocabularies that are mobilised in policy discourses and legal regulations to stigmatise certain people, ways of conduct and attitudes among citizenship applicants, problematisations separate desired from undesired membership candidates from the state’s perspective. In so doing, they reveal an underlying regulative ideal of the desired migrant candidate— the Super Citizen—who is characterised by three sets of features: economic self-sufficiency and cultural-linguistic competence; transparent and credible efforts and motivation to gain citizenship status; as well as loyalty, commitment, and gratitude towards the naturalising state. This regulative ideal of the Super Citizen is constructed against the three deviant figures of the “dependent”, the “insincere”, and the “indifferent” citizenship candidate. While these deviant subjectivities are often based on misrepresentations of migrant groups, their social construction by statutory requirements and administrative practice is highly powerful insofar as citizenship applicants are regularly required to dissociate themselves from them through credible performance. Chapter 3 examines the rationalities of naturalisation. As concepts or ways of thinking about citizenship that justify the specific design of naturalisation procedures, rationalities fulfil a key function within this

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subject-formation regime by rendering plausible its other core elements, such as authorities and techniques. My analysis shows that naturalisation in the UK and Germany is structured by four main rationalities which are expressed in different elements of the regime: citizenship as award, as entitlement, as emotional attachment, and as commodity. The rationality of citizenship as an award to be merited is particularly salient in the British definition of naturalisation as a grant at the discretion of the Home Secretary, placing migrants in a subordinate position with little agency. Although less significant in German law, it demonstrably played an important role in the justification of the introduction of citizenship tests in both countries. The rationality of citizenship as a right to which migrants are entitled, on the other hand, underpins the German legal definition of naturalisation. The conceptualisation of naturalisation as an instrument to create a sense of emotional attachment to the naturalising state was a pivotal argument for the introduction of citizenship ceremonies. Following this rationality, the act of naturalisation is seen as a mutual exchange of loyalty and devotion between the state and its new members. Finally, the conception of naturalisation as a commodity for purchase, as a good with high market value, played a crucial role in the extraordinary increase of the British naturalisation fee since 2004. In Chap. 4, I turn to the authorities of subject-formation, defined as the actors who enact naturalisation processes on behalf of the state. I identify four main authorities of subject-formation that shape and facilitate the Super Citizen subjectivity before, during, and after the application process: legal advisers translating citizenship laws, teachers tasked with educating “good” and “democratic” citizens, caseworkers granting or rejecting applications, and honorary guests speaking at citizenship ceremonies. These authorities operate under different structural conditions: While the British case is centralised, less regulated, and less funded, naturalisation in Germany is decentralised, more regulated, and better funded. Discrepancies emerged between structurally prescribed and self-perceived roles. Ceremony guest speakers, for example, have the purely symbolic role to welcome the “new” citizens, yet some speakers assume the role of informally testing citizenship applicants’ language skills or reminding them of their duties.

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Chapter 5 focuses on the implementation of citizenship courses, tests, and ceremonies as techniques of subject-formation. As “political technologies”, techniques of subject-formation suggest to citizenship applicants a specific collective self-representation of the (nation-)state as an imagined national, regional, and local community, as well as a specific individual self-understanding for citizenship applicants as new members. Moreover, as “technologies of the self ”, courses, tests, and ceremonies suggest a specific self-guidance regarding the recommended conduct of aspiring new state members. The analysis shows that both in Germany and in the UK, the presentation of the state oscillates between images of traditional, ethno-culturally homogenous nationhood and modern, culturally diverse statehood. The courses, tests, and ceremonies thus reflect the dialectical tension inherent to citizenship which offers democratic and supposedly equal membership status while that membership is defined as belonging to a nation which excludes non-nationals and migrants. At the very moment when they try to resolve their “foreignness”, migrants are thus repeatedly reminded that they present a problem to the ideology of the nation-state and that they are expected to resolve this tension and compensate for deficits among national-born citizens by following the code of conduct of an ideal citizen—the Super Citizen. This culminates in the suggestion that naturalised citizens should develop a new, “moderate” nationalism. Chapter 6 examines the effects and effectiveness of the Super Citizen subjectivity by studying the lived experiences of naturalisation. Based on the analysis of interviews and conversations with migrants at various stages of their application procedures, I argue that the Super Citizen subjectivity is a powerful call which is heard by migrants throughout the naturalisation process. Yet, the analysis shows that the subject-formation regime does not produce a uniform answer. In fact, I identify three types of perceptions and responses to the call for the Super Citizen, ranging from embrace to ignorance and contestation. While some citizenship applicants welcomed the Super Citizen subjectivity by showing how well they match the state’s expectations, others felt unaffected or expressed criticisms and alienation. Hence, my analysis shows how naturalisation as the process of migrants’ full legal inclusion as equal state members may, in fact, produce adverse effects by creating rejection, competition, and

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new social hierarchies among non-national, naturalised, and national-­ born citizens. Chapter 7 concludes this book with a critical reflection on my findings and argument in the context of recent developments in citizenship and naturalisation policies in the UK and Germany. While this study demonstrated that the British and German naturalisation regimes have converged towards the transnational subjectivity of the Super Citizen, further convergence after Brexit seems increasingly unlikely. In the UK, there is no indication of the immigration and naturalisation system becoming more accessible; rather, we see the continuation and potential intensification of the “hostile environment” approach that has dominated British immigration policy for the last decade. In Germany, on the other hand, the new coalition government led by the Social Democrats has committed itself to the liberalisation of immigration policies, including the naturalisation regime. I finish the book with key lessons for future policy-making and recommend a number of reforms which would significantly improve the accessibility of naturalisation in both countries, including the introduction of a conditional entitlement to naturalisation and a right to appeal a negative decision in the UK, and the allowance and recognition of dual nationality in Germany.

References Anderson, Bridget. 2013. Us and Them? The Dangerous Politics of Immigration Control. Oxford: Oxford University Press. Aptekar, Sofya. 2015. The Road to Citizenship: What Naturalization Means for Immigrants and the United States. New Brunswick: Rutgers University Press. Badenhoop, Elisabeth. 2017. Calling for the Super Citizen: Citizenship Ceremonies in the UK and Germany as Techniques of Subject-Formation. Migration Studies 5 (3): 409–427. ———. 2021a. Citizenship Matters: Towards an Interdisciplinary and Global Perspective on Naturalization. Citizenship Studies 25 (4): 445–455. ———. 2021b. Responding to the Call for the Super Citizen: Migrants’ Ambivalent Experiences of Naturalization in Germany and the United Kingdom. Citizenship Studies 25 (4): 564–582.

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Bassel, Leah, Pierre Monforte, and Kamran Khan. 2018. Making Political Citizens? Migrants’ Narratives of Naturalization in the United Kingdom. Citizenship Studies 22 (3): 225–242. Bauböck, Rainer, and Christian Joppke, eds. 2010. How Liberal Are Citizenship Tests? EUI Working Paper RSCAS 2010/41. European University Institute, Robert Schuman Centre for Advanced Studies. Bevir, Mark. 1999. Foucault, Power, and Institutions. Political Studies XLVII: 345–359. Blitz, Brad K., and Maureen Lynch, eds. 2011. Statelessness and Citizenship: A Comparative Study on the Benefits of Nationality. Northampton: Edward Elgar. Bröckling, Ulrich. 2007. Regime des Selbst—Ein Forschungsprogramm. In Kulturen der Moderne. Soziologische Perspektiven der Gegenwart, edited by Thomas Bonacker and Andreas Reckwitz, 119–139. Frankfurt a. M.: Campus. ———. 2012. Der Ruf des Polizisten. Die Regierung des Selbst und ihre Widerstände. In Diskurs—Macht—Subjekt. Theorie und Empirie von Subjektivierung in der Diskursforschung, edited by Reiner Keller, Werner Schneider, and Willy Viehöver, 131–144. Wiesbaden: Verlag für Sozialwissenschaften. ———. 2016. The Entrepreneurial Self: Fabricating a New Type of Subject. London: SAGE. Brubaker, Rogers. 1989. Citizenship and Naturalization: Policies and Politics. In Immigration and the Politics of Citizenship in Europe and North America, edited by Rogers Brubaker, 99–127. Lanham: University Press of America. ———. 1992. Citizenship and Nationhood in France and Germany. Cambridge, MA: Harvard University Press. Butler, Judith, and Gayatri Chakravorty Spivak. 2007. Who Sings the Nation-­ State? Language, Politics, Belonging. London: Seagull. Byrne, Bridget. 2014. Making Citizens. Public Rituals and Personal Journeys to Citizenship. Basingstoke: Palgrave Macmillan. ———. 2017. Testing Times: The Place of the Citizenship Test in the UK Immigration Regime and New Citizens’ Responses to It. Sociology 51 (2): 323–338. Çelik, Çetin. 2015. ‘Having a German Passport Will Not Make Me German’: Reactive Ethnicity and Oppositional Identity among Disadvantaged Male Turkish Second-Generation Youth in Germany. Ethnic and Racial Studies 38 (9): 1646–1662. Clayton, Gina, Caroline Sawyer, Rowena Moffatt, Georgina Firth, and Helena Wray. 2016. Textbook on Immigration and Asylum Law. 7th ed. Oxford: Oxford University Press.

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Cruikshank, Barbara. 1999. The Will to Empower: Democratic Citizens and Other Subjects. Ithaca: Cornell University Press. Dahlvik, Julia. 2018. Inside Asylum Bureaucracy: Organizing Refugee Status Determination in Austria. Cham: Springer. Damsholt, Tine. 2008. Making Citizens. On the Genealogy of Citizenship Ceremonies. In Constituting Communities: Political Solutions to Cultural Conflict, edited by Per Mouritsen and Knud Erik Jørgensen, 53–72. New York: Palgrave Macmillan. Dean, Mitchell. 2003. Governmentality: Power and Rule in Modern Society. 2nd ed. London: SAGE. Dummett, Ann, and Andrew Nicol. 1990. Subjects, Citizens, Aliens and Others: Nationality and Immigration Law. London: Weidenfeld and Nicholson. Ehmann, Eugen, and Heinz Stark. 2008. Deutsches Staatsangehörigkeitsrecht: Vorschriftensammlung mit erläuternder Einführung. Heidelberg: Jehle. Etzioni, Amitai. 2007. Citizenship Tests: A Comparative, Communitarian Perspective. The Political Quarterly 78 (3): 353–363. Fahrmeir, Andreas. 2000. Citizens and Aliens: Foreigners and the Law in Britain and the German States, 1789–1870. New York: Berghahn. Faist, Thomas. 2000. Transnationalization in International Migration: Implications for the Study of Citizenship and Culture. Ethnic and Racial Studies 23 (2): 189–222. Falzon, Mark-Anthony. 2009. Introduction: Multi-Sited Ethnography: Theory, Praxis and Locality in Contemporary Research. In Multi-Sited Ethnography: Theory, Praxis and Locality in Contemporary Research, edited by Mark-Anthony Falzon, 1–24. Aldershot: Ashgate. Farrell, Catherine. 2012. Asylum Narratives and Credibility Assessments: an Ethnographic Study of the Asylum Appeal Process in Scotland. PhD Thesis, University of Glasgow, Glasgow. Fortier, Anne-Marie. 2013. What’s the Big Deal? Naturalisation and the Politics of Desire. Citizenship Studies 17 (6–7, 697): –711. Foucault, Michel. 1983. The Subject and Power. In Michel Foucault: Beyond Structuralism and Hermeneutics, edited by Hubert L. Dreyfus and Paul Rabinow, 2nd ed., 208–228. Chicago: The University of Chicago Press. Fransman, Laurie. 2011. British Nationality Law. 3rd ed. London: Butterworths. Goodman, Sara Wallace. 2010. Integration Requirements for Integration’s Sake? Identifying, Categorising and Comparing Civic Integration Policies. Journal of Ethnic and Migration Studies 36 (5): 753–772. ———. 2014. Immigration and Membership Politics in Western Europe. Cambridge: Cambridge University Press.

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Germany, edited by Ruth A. Starkman, 181–197. New York: Palgrave Macmillan. Latour, Bruno. 2010. The Making of Law: An Ethnography of the Conseil d’Etat. Cambridge: Polity. Lemke, Thomas. 2002. Foucault, Governmentality, and Critique. Rethinking Marxism 14 (3): 49–64. Lipsky, Michael. 1980. Street-Level Bureaucracy: Dilemmas of the Individual in Public Services. New York: Russell Sage. Michalowski, Ines. 2010. Integration Tests in Germany. A Communitarian Approach? In A Re-Definition of Belonging? Language and Integration Tests in Europe, edited by Ricky van Oers, Eva Ersbøll, and Dora Kostakopoulou, 185–210. Boston: Martinus Nijhoff. ———. 2011. Required to Assimilate? The Content of Citizenship Tests in Five Countries. Citizenship Studies 15 (6–7): 749–768. Miller, Peter, and Nikolas Rose. 2008. Governing the Present: Administering Economic, Social and Personal Life. Cambridge: Polity. Monforte, Pierre, Leah Bassel, and Kamran Khan. 2019. Deserving Citizenship? Exploring Migrants Experiences of the ‘Citizenship Test’ Process in the United Kingdom. The British Journal of Sociology 70 (1): 24–43. zur Nieden, Birgit. 2009. ‘… und deutsch ist wichtig für die Sicherheit!’ Eine kleine Genealogie des Spracherwerbs Deutsch in der BRD. In No integration?! Kulturwissenschaftliche Beiträge zur Integrationsdebatte in Europa, edited by Sabine Hess, Jana Binder, and Johannes Moser, 123–136. Bielefeld: Transcript. van Oers, Ricky, Eva Ersbøll, and Dora Kostakopoulou, eds. 2010. A Re-Definition of Belonging? Language and Integration Tests in Europe. Boston: Martinus Nijhoff. van Oers, Ricky. 2014. Deserving Citizenship: Citizenship Tests in Germany, the Netherlands and the United Kingdom. Leiden: Martinus Nijhoff. Orgad, Liav. 2010. Illiberal Liberalism. Cultural Restrictions on Migration and Access to Citizenship in Europe. The American Journal of Comparative Law 58 (1): 53–106. Palmowski, Jan. 2008. In Search of the German Nation: Citizenship and the Challenge of Integration. Citizenship Studies 12 (6): 547–563. Parry, Clive. 1957. Nationality and Citizenship Laws of the Commonwealth and of the Republic of Ireland, Volume 1. London: Stevens & Sons. Pates, Rebecca, and Daniel Schmidt. 2009. Die Verwaltung der Prostitution: eine vergleichende Studie am Beispiel deutscher, polnischer und tschechischer Kommunen. Bielefeld: Transcript.

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2 Problematisations in Naturalisation Processes: Super Citizen or “Scrounger”

As the previous chapter discussed, subject-formation regimes have at least four elements, each of which is considered in turn by the following empirical chapters. These four elements are “problematisations”, “rationalities”, “authorities”, and “techniques” (Rose 1999, xi–xii; Bröckling 2016). This chapter focuses on the first aspect by reconstructing the problematisations. The term “problematisation” here refers to the categorisations and “vocabularies” that define and separate “undesirable” people, practices, and ways of thinking from those considered “desirable” from the perspective of the state (Rose 1998, 25, 26, 28). The analysis of problematisations extracts the “criteria in relation to which certain persons, things, or forms of conduct come to be seen as problematic … [and] the dividing practices involved”; for example, the distinctions of “sickness from health” or “normality from pathology” (Rose 1999, xi). Thus, the process of reconstructing the problematisations in the current citizenship admission procedures also reveals the corresponding idealisations, that is, the features of the Super Citizen. Naturalisation itself is a “dividing practice” because it separates those who are considered immigrants or members of a foreign state from national state members based on nationality criteria. The persistent

© The Author(s), under exclusive license to Springer Nature Switzerland AG 2023 E. Badenhoop, Calling for the Super Citizen, Palgrave Politics of Identity and Citizenship Series, https://doi.org/10.1007/978-3-031-34260-8_2

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existence of naturalisation laws and procedures around the world (Badenhoop 2021) reveals the distinction states make between members by right of birth and members by discretionary application. As Chap. 1 argued, naturalisation is the procedure through which states select and admit “aliens” to citizenship status (or previously subjecthood) based on criteria not expected or tested from citizens by right of birth. The list of these legal requirements has become longer and more formalised over time. Nowadays, it includes capability, physical and legal residence on the territory, law obedience, economic self-reliance (only in Germany), knowledge of the national language and society, and loyalty to the state in both Britain and Germany. The current legal provisions suggest the idealised subjectivity of the Super Citizen, which is characterised by the expectation to make a political, economic, and cultural contribution to the liberal-democratic capitalist nation-state. Moreover, the statutory requirements also indicate who or what is being considered problematic, deviant, and therefore incompatible with national citizenship. This chapter reconstructs the problematisations in current British and German naturalisation procedures and discourses extracted from official documents, interviews with state officials and participant observations in naturalisation authorities. The analysis shows that the desired Super Citizen relies on three undesired figures, which I call “dependent”, “insincere”, and “indifferent” citizenship applicants. These three images or roles problematise numerous groups of people and ways of conduct including benefit receivers, spouses, EU nationals, and frequent fliers. They are socially constructed categories yet highly powerful as they are not mutually exclusive but overlap and reinforce each other, and they may be reproduced and sometimes exaggerated in spoken discourse. Moreover, the three deviant characters of the “dependent”, “insincere”, and “indifferent” citizenship applicant intersect and overlap with two other transnational trends in public policy insofar as the Super Citizen is a highly neoliberal and securitised subjectivity. The comparison between the UK and Germany reveals that the three figures were found in all four research locations. While the neoliberal character of the “dependent” is prevalent in both countries, for example, in the discourse of welfare benefit “scroungers”, the figure of the “insincere” and other effects of securitisation are more visible in the UK,

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especially in the superdiverse research location of Brent. The image of the “indifferent” was found in both Germany and the UK although it problematised different groups of people for supposedly not showing sufficient commitment to the state: the global business elite in the UK case and dual nationals in the German case. Above all, the three figures demonstrate an engrained institutional mistrust vis-à-vis migrants in contemporary naturalisation procedures in both countries according to which citizenship applicants are conceived as takers rather than givers (cf. Honig 2001).

2.1 The Dependent Citizenship Applicant: Supposed Lack of Economic Integration The deviant figure of the dependent refers to the undesirable citizenship candidate who is incapable of speaking the language, passing the knowledge test and being economically self-sufficient without relying on the support of the state. This figure corresponds to the economic and neoliberal aspect of the Super Citizen subjectivity as it expects citizenship applicants to be “hard-working” and to dissociate themselves from welfare benefit “scroungers”. In law, this figure is suggested by the requirements of full age and capacity, good knowledge of language and society, and economic self-sufficiency (in Germany). In discourse, this figure is attached to benefit receivers; minors, elderly, and disabled people; as well as students.

Benefit Receivers While the ideal of economic self-sufficiency is a non-negotiable, statutory requirement in Germany, it is nonetheless present in UK law and discourse, and may result in discouraging some migrants from submitting their application. German citizenship law requires applicants to be able to financially support themselves and their families without receiving welfare benefits, unless this is “due to conditions beyond their control” (Nationality Act s 10 ss (1) sent.1 no.3). British nationality law does not

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require this; indeed, “An application must not be refused simply because the person is reliant on public funds”, as explicitly stated in the caseworker instructions (Home Office 2020, 37). Only if there is evidence for fraud in relation to public funds, bankruptcy, liquidation, non-­ payment of debts, or taxes, the application will normally be refused (ibid., 35–38). This way, the Home Office examines applicants’ “financial soundness” to check whether their “financial affairs have not been in appropriate order” (ibid., 9), as part of the statutory “good character” requirement. While the central caseworker instructions mainly refer to cases of deliberate non-payment of debts or taxes vis-à-vis public authorities, the existence of the legal provision of “financial soundness” opens the door for different, more expansive interpretations as I observed during one Nationality Checking Service (NCS) appointment in Brent (observation BrSub05, 23/10/2012). The applicant had received no income for some time during which he had been supported by a family member, a fact which emerged during his appointment. The registrar informed him that he needed to provide detailed written proof of how he financially supported himself. An awkward situation emerged when the applicant was unable to sufficiently explain his circumstances to the registrar’s satisfaction who repeatedly asked the applicant: “Who paid for your food and clothes during these years?”. The handwritten letter by the applicant’s sister was not considered sufficient evidence and the registrar demanded additional proof, for example a letter written by the applicant’s medical doctor. In the end, this applicant was sent home to produce the proof requested and his application was deferred. It is unclear why in this instance the official suggested a letter by a medical professional as proof for financial soundness. This incident shows the inconsistency and discrepancy between the written, central nationality regulations and their local interpretation. Private debt is not necessarily a reason to refuse the application in the UK. Ironically, this discouragement was unnecessary as the Nationality Checking Service is an optional service with an additional fee. If the person had submitted his application straight to the Home Office, the issue of family support during a phase of unemployment might not have been considered a problem.

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Indeed, the importance of employment was emphasised by all the senior politicians who were interviewed in this study and involved in the design of local or national naturalisation policies regardless of their party affiliation. While left-leaning politicians tended to idealise citizenship applicants as hardworking, right-leaning politicians reversed this theme and problematised non-working national-born citizens. Olaf Scholz (Social Democrats, SPD), the then First Mayor of Hamburg clarified thus: “In my opinion, [a citizenship applicant] should work and make an effort.” He also characterised Hamburg as “a society which associates hardworking people” (HaPol2 interview 28/08/2013). Similarly, the Labour politician and former British Home Secretary David Blunkett who introduced citizenship tests and ceremonies in the UK described citizenship applicants as industrious people and defended them as morally superior immigrants and citizens: People who are seeking naturalisation are on the whole employed and highly committed to this country by the very nature of it and wish to stay here and make their life and grow their family. […] We’re not talking here about a bunch of never-do-wells wanting to scrounge off the system. We are talking about people who want to be committed to the country. (UKPol1 interview 05/09/2012)

Conservative politicians extended the problematisation of benefit receivers to national citizens. For the opposition leader of the Hamburg Christian Conservatives (CDU) and former Integration Senator, the real “integration problem” in terms of education, language, and labour market “exists independent of nationality because we have immigrant groups who are economically well integrated and who do not hold the German passport and on the other hand we have a German population that lives in hardened poverty on Hartz IV [social benefits] and shows all signs of disintegration but hold the German passport”. (HaPol1 interview 13/08/2013)

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Minors, Elderly, and Disabled People The strong emphasis on economic independence raises the question of how age and disability are considered in naturalisation procedures. Indeed, the law in both the British and German cases provides exemptions from the language and knowledge test requirements for minors, the elderly, and disabled people (1981 BNA sch 1 [2] e), StAG s 10 [6]). However, the empirical evidence of this study suggests that physical and mental impairments may still be considered problematic and it is very difficult to get such an exemption, especially from the loyalty requirement. For example, the application of a disabled child in Dresden was rejected twice because the candidate could not speak and was therefore unable to meet the language and loyalty requirements, as his mother reported (DrCA2, interview 09/04/2013). The Dresden authorities normally insist that the applicant not only signs but also speaks the declaration and they eventually granted an exemption in this case, yet only after the mother sought help from a private lawyer who took the case to the court and convinced the authorities to apply the exemption foreseen by the law. This example demonstrates that it requires financial resources, professional support and personal self-confidence to actually obtain an exemption. It also points to a wider problem of discrepancy between the law on the books and its application in practice. Even if applicants successfully make a case for an exemption from the language and civic knowledge requirements, they are expected to meet the loyalty requirement. In the UK, this requirement is considered as having been met when the willingness to attempt to speak it has been demonstrated. As a Home Office official explained: “As long as they attempt to speak it, it’s fine” (UKAdmin1, observation 17/01/2013). In practice this means that if candidates do not move their lips during the oath in the ceremony, then the registrars will take action: We will, we would stop this. We’ll let them go, we don’t want to embarrass them, [and] at the end, we’ll take the certificate off them. We want to be convinced that they can understand, they need to understand what it is that they are saying. Sometimes it is just that they are nervous, so then we can do a private ceremony here [in a smaller office]. They’ll have to be able

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to say the words in front of us and we’ll do the ceremony. And other times they’ve gone to centres to do their courses where they take cash and give them the certificate. And that we report to the Home Office who will investigate on that one. It’s very rare but it does happen. Or they’ll send somebody else to do the test for them, that happens as well. (BrAdmin2, interview 12/09/2012)

The registrar concedes that cases where applicants do not say the words of the oath may be due to nervousness, but she also indicates that this may be due to incapability or fraud involving factors such as unqualified ESOL centres or impersonation, as is discussed later in this chapter. The practice of private ceremonies is indeed enforced as I observed during one appointment for an elderly lady in Brent (BrPres11, 30/10/2012). Even though she was supported by a translator as she was unable to speak or understand English, she had to repeat the words herself one by one. This inconsistency between the oath in theory and practice, whether it is sufficient to just move one’s lips or repeat the words or understand “what it is that they are saying”, raises the question of how meaningful the administration of the loyalty requirement actually is. In Germany, the above-mentioned restrictive interpretation that the declaration of loyalty must not only be signed in writing but also be spoken is a decision of the local authority. The Dresden authorities go even further by handing out a printed copy of the declaration and requesting that applicants learn the words of the declaration by heart prior to their ceremony appointment, as the Head of the Naturalisation Unit told me (DrAdmin1, interview 14/05/2014).

Students The expectation of economic independence problematises citizenship applicants who receive support from the welfare state, but also those who do not contribute by paying taxes for the welfare system, that is, those who are not in full-time employment, such as students. In the UK, some people’s actual residence does not legally count towards the minimum time of residence required; for example, those on temporary admission

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such as students but also people in detention (Clayton et al. 2016, 91). Similarly, in Germany, student residence permits are not accepted in all states as “legal and regular residence” because students do not stay indefinitely, as a legal adviser in Dresden explained the Saxon authorities’ reasoning to me (DrLA6, conversation 28/03/2013). In the UK, students are considered “tax dodgers” as they supposedly do not pay sufficient taxes and thus burden the welfare system, as a senior official from the Home Office explained to local registrars at a training workshop on how to carry out the Nationality Checking Service (NCS) (observation 17/01/2013). This is why students who wish to apply for British citizenship must demonstrate that they do not rely on the state-­ funded National Health Service; to do so, they need to show evidence of private medical insurance in order to qualify for naturalisation. In Germany, students are regarded as focussing on their studies and thus not being fully involved in society. For example, the Head of the Naturalisation Unit in Dresden referred to a hypothetical engineering student to illustrate what the German state expects from its citizenship applicants: Assuming a student had come here to study and he studied engineering for eight years, very intensively. In his final year, he falls in love and would like to stay after all. So, then he has been here for eight years but because of his studies he never bothered about German society. He only ever went to the cash machine, to the university canteen and that was it. I am exaggerating but where did the integration take place in his case? If he only came to study? At this point you naturally have to ask, what kind of integration took place here, what knowledge do you have of this societal order (Gesellschaftsordnung) that you now want to be part of? (interview DrAdmin1, 14/05/2013)

For this senior official, if an applicant is a full-time student, s/he cannot simultaneously participate or engage in local society. Moreover, even entering a romantic relationship in that location is not credited as “integration” as it does not count towards the applicants’ suitability, which is assessed primarily in terms of the individual’s efforts to contribute to, and show knowledge of, the local society. The above statement points to the

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crucial requirement of knowledge of social norms and hierarchies as a further aspect of this deviant character, which aligns the figure of the dependent with the figure of the illiterate.

2.2 The Insincere Citizenship Applicant: Doubts About Cultural-Linguistic Integration Efforts The deviant image of the insincere refers to the applicant who is suspected of fraud and of making an incredible application. The applicant’s efforts to meet the requirements appear insufficient to the state because they are deemed inauthentic. The ideal citizenship applicants should always be willing to reveal any personal information and to make a credible performance of their motivation to naturalise when examined by the state. In this regard, the Super Citizen resembles another neoliberal subjectivity, the figure of the “indebted man” (Lazzarato 2012) who is constantly required “to make [him]self transparent, open up [his] books and make a convincing show of being able to pay back [his] credit” (Bröckling 2016, ix). By implication, any sign of unwillingness to disclose information gives rise to concern. The public suspicion of fraud was particularly apparent in relation to migrants’ personal relationships and their cultural-­ linguistic integration efforts which links this second deviant figure to the cultural aspect of the Super Citizen subjectivity. In law, this figure is primarily constructed through the “good character” requirement (in the UK); while in discourse, it was particularly attached to persons with criminal convictions, in “sham” relationships, those who had taken “dodgy” language courses, and to EU citizens (mainly in the UK).

“War Criminals” and “Illegal Entrants” Underlying the current UK and German naturalisation procedures is the general assumption that citizenship applicants and those associated with them may withhold information, creating a general suspicion of attempted deception. This suspicion is expressed, for example, in the penalty

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provisions in both countries for providing false information. In Germany, achieving naturalisation by “intentionally providing wrong or incomplete information” may lead to the revocation of citizenship up to ten years after naturalisation (StAG s 35). Similarly, the UK Home Secretary reserves the right to deprive a person of British citizenship status if this was obtained through “fraud, false representation or concealment” (1981 BNA s 40) (see also the discussion of recent developments of citizenship withdrawal in Chap. 7). More specifically, this suspicion is found in the British “good character” requirement. It is not fully transparent who or what exactly the Home Office considers to be not of “good character”, because the caseworker instructions on nationality in relation to this particular requirement are restricted for internal Home Office use and only partially published; for example, information on “international crimes” and “terrorism” has been removed from the publicly available version (Home Office 2020). As reported by lawyers interviewed in this study, however, it is clear that the Home Office’s interpretation of the “good character” requirement has become stricter and less transparent (BrLA4, 24/10/2012; BrLA8, 29/11/2012). For example, caseworkers in the Home Office use a list of countries which the Home Office deems “war torn”. However, this list is not published. When I visited the Nationality Group in Liverpool, individual caseworkers wanted to show me this document when explaining their work on two occasions, but in both cases their supervisors intervened saying “put that away, you are not supposed to show that” (observation 15/11/2012). This list has the effect that applicants from a listed country undergo additional checks, amongst others by the “Deprivation Screening Team” (DST). As a senior Home Office caseworker told me, this unit was initially set up to detect former Waffen SS members after the Second World War and prevent them from being granted British citizenship (UKAdmin1, conversation 14/11/2012). Because from the perspective of the Home Office it is difficult to revoke British nationality once granted, “we try to make it as hard as possible, have as many checks as possible, before we give nationality” (ibid.). The Home Office is aware that in the period following the Second World War, many migrants came to Britain from Eastern Europe, including non-German “Nazi criminals” who were considered even more violent

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than the Germans as they had to prove themselves during the war (ibid., conversation 17/01/2013). These applicants would not be flagged up by computer checks, as the databases do not go back far enough in time. Therefore, all applications from Poland, Latvia, and other Eastern European countries from a person born before 1930 are categorically checked for involvement with Nazi war crimes and cases of suspicion are referred to the Home Secretary (ibid.). To identify a Nazi criminal, the Home Office uses various methods including the reports and lists produced by the Simon Wiesenthal Centre (ibid.). Any criminal conviction gives rise to suspicion, including that of child applicants, because “we want the good ones, not the bad ones”, as the civil servant explained to local registrars during their training workshop (UKAdmin1, observation 17/01/2013). Since 2014, the Home Office also considers any breach of immigration law as evidence of not meeting the “good character” requirement which leads to a ten-year ban from naturalisation (Yeo 2018a). This applies, for example, to refused asylum seekers (“overstayers”), “illegal entrants”, “absconders”, and “illegal workers” (Home Office 2020, 46–48). This group of migrants is disadvantaged because their residency does not count towards the “qualifying period” and they must wait another ten years before they can make an application. Employers found to have hired “illegal workers” are barred from naturalisation indefinitely (ibid., p. 48).

Suspicious Sponsors: “Sham” Marriages and Solicitors In Britain, it was assumed that if an applicant’s spouse was British, then s/he would have taught them English, while for single applicants a letter issued by a solicitor sufficed to demonstrate knowledge of English (observation 17/01/2013). However, as an official explained, “solicitors aren’t always straight”, and the Citizenship Ceremony Liaison Group was set up to “eliminate that, to separate the ones who could speak from those who couldn’t speak” (ibid.). Thus, the British state signalled that it no longer trusted spouses and solicitors to train or assess a candidate’s language skills, and abandoned this informal, deregulated arrangement,

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instead handing the competence to certify a candidate’s language skills to education providers such as colleges. The caseworker instructions on the “good character” requirement problematise applicants entering “sham” marriages or civil partnerships as well as those “of convenience”, who are considered as breaching immigration laws (Home Office 2020, 43). It is made clear that their applications “will normally” be refused. These relationships are considered not “genuine” if the documents are “invalid”, “fictitious” or “forge[d]”; or if the relationship was entered for the specific “purpose of circumventing UK immigration control” (ibid.). These applicants are thus regarded as dishonest and as having prioritised personal advantage over obedience to the law. They would be considered a case of “deception” by the Home Office, which bars them from naturalisation for ten years after the “sham” relationship is “discovered or admitted” (ibid.), similar to the group of “illegal migrants” discussed above. This problematisation was not only found in legal documents but was also reflected in the discourse of the registrars who officiate at marriage and citizenship ceremonies. The theme of “sham” or “bogus” marriages was particularly prevalent in Brent, as I discovered while being escorted to the building’s exit after my first visit. A senior registrar showed me the week’s schedule of marriage ceremonies as we were walking past it, and remarked: It used to be the French, British, Germans, now it is the new European countries which are popular. It is usually Bulgarian and Ukrainian women who are offered a lot of money to marry someone from India, Burundi, Bangladesh. This way, they can claim benefits as EU spouses—with UK spouses you would have to wait for two years after marriage to be able to claim benefits. (BrAdmin1, conversation 13/06/12)

This quote demonstrates that the problematisations of benefit receivers, “bogus” marriage, and EU nationals (see below) intersect with one another. The registrar then pointed to the nationalities indicated on the schedule and concluded that “Ukraine and Pakistan seem to be the model of the week” (ibid.). The unprompted statement set out above was not an isolated observation, but was confirmed during an interview with the Head Registrar in Brent:

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We probably do 1600 weddings a year in the office in Brent and I would say minimum 600 of those are probably out of immigration avoidance. And it’s always with a foreign national whose visa is about to or has already expired so they’re here illegally marrying a national of another EU country, not the UK. So that’s the benefit here, if you marry a British national, you are subject to more checks than if you marry a German or a Dutch or a Portuguese person. Eastern Europe is the problem at the moment; the one of the year at the moment is Pakistani marrying Lithuanians. And sometimes they can’t even speak a shared language, they can’t communicate in any way at all and you think, this is definitely not a love marriage. It’s just nonsense. You get very frustrated with that particular aspect of what we do. […] I mean you can spot them a mile off. It sounds very sexist, I know, but very often the Eastern European girls are probably victims as well, sometimes they are trafficked into the UK for the sex industry, they are used and abused and they are used for bogus marriage. Sometimes you have a young Pakistani male who is quite plainly from a good family marrying a girl who looks like she is probably on the game. Now you just know that that wouldn’t happen but we’ve got to do the marriage. And it’s so frustrating. So, we are now trying to work with the UKBA [United Kingdom Border Agency, now UK Visas and Immigration, Immigration Enforcement and Border Agency] trying to combat that issue. (BrAdmin4, interview 1, 20/09/2012)

These two extracts indicate that registrars regard the issue of “bogus” marriage as a growing trend when they refer to this development as “popular”, and note “models” of the week or year. As they attribute this trend to specific (white) Eastern European and (brown) South Asian nationalities, the theme of “bogus” marriage has a significant racial element. This theme also has a gender dimension, as it is made clear that the EU nationals involved are usually women and that the South Asians are men. As it is acknowledged that the women may not always enter the relationship consensually, the dishonest intentions to avoid immigration control and claim benefits are mainly attributed to the Asian men. The Brent registrars identify such a “bogus” marriage mainly through language and habitus, noting instances when a couple cannot communicate in a shared language and/or when stark differences in class backgrounds are revealed through their appearance.

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“ Dodgy” Colleges and Medical Practitioners: Suspected Fraud in Relation to Language and Knowledge Tests Dishonesty is also anticipated in relation to the language and knowledge requirements. The British application guide notifies applicants that “any attempts at cheating or pressure to provide false results […] through bribery, physical threats or emotional blackmail” applied to staff members at a Life in the UK test centre will be prosecuted and the application refused (Home Office 2022, 31). This issue was also addressed by the Head Registrar in Brent. Having brought up the theme of “dodgy course centres”, he gave the following information: BrAdmin4:

EB: BrAdmin4:

“We get people in ceremonies, how do you get through an ESOL course or the Life in the UK test without being even able to say your name seems to me rather odd, and we report those cases to the UKBA but very rarely are they investigated.” “How many times would that happen over the year?” “Across the country. We have national conferences which I chair and we get feedback from across the country that this is happening across the country, in every ceremony, in every local authority every week at a year, so I think it’s a big issue. Primarily through the colleges, some of the classes only last a day and you think, hang on a minute, these poor people pay three hundred, four hundred pounds for one or two days to get them from one level to the other. I think that’s a huge area of concern, or should be, for the Home Office, because the whole idea of this is to assist integration so we can have people who come in to the UK who can contribute to society, they can contribute, they can get a job so therefore they need to be able to have some level of English even to get by.” (BrAdmin4, interview1, 20/09/2012)

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The expectation is therefore that applicants should have sufficient English skills “to get by”, to find employment, and to “contribute to society”. The end of the statement demonstrates that the imperative to work is linked to the imperative to speak the language, so knowledge of the language is thought to facilitate participation in the labour market, in turn generating tax revenue for the state. The discourse which problematises applicants with insufficient language skills was also found in Germany, albeit in a somewhat more cautious formulation. In Hamburg, a legal adviser explained that some applicants misuse the medical exemption, treating it as a legal “loophole” (Hintertürchen) to avoid learning the German language (HaLA10/CA12, interview 26/08/2013). This adviser had herself come to Germany from Bulgaria and naturalised and for her, the ability to speak German was a crucial precondition for “integration” (ibid.). She explained, however, that a handful of medical practitioners in Hamburg issue medical certificates stating that an applicant is unable to pass the language and citizenship test (ibid.). She was critical of GPs issuing such letters, commenting that applicants “pass around their names” and are unwilling to learn German, and she also noted that the authorities have not taken notice of this phenomenon or acted against it.

“Impersonators”: Suspected Identity Fraud At the time of the research, the UK Home Office clarified in its guide to applicants that if an applicant during the ceremony is unable to repeat the words of the oath or pledge “unsupported”, the registrar may report “doubts about how you satisfied the language requirement” to the Home Office, which will then investigate (Home Office 2015, 21). If it finds that this was a case of “deception by getting someone else to impersonate you at the test or ceremony”, then the applicant and the “impostor” will both be liable for prosecution, which may lead to deportation (ibid.). While the current guide for applicants (Home Office 2022) no longer mentions these details, it still ensures applicants are aware of the consequences of deception.

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The issue of “impersonation” was brought up by British civil servants at the Local Authority level as well as the Home Office. The Head of Brent Registration and Nationality Services mentioned that “impersonation” is more of an issue at test centres than it is at citizenship ceremonies (BrAdmin4, interview1, 20/09/2012). A senior Home Office caseworker also explained that impersonation has become less frequent since the introduction of additional checks (UKAdmin1, conversation 15/11/2012 and 17/01/2013) which require local test centres to check photo identity documentation, compare signatures, and employ an additional second invigilator to reduce the risk of bribery (ibid.). Nonetheless, the training workshop which the caseworker runs for local registrars on how to do Nationality Checking Service (NCS) includes an exercise which trains them to detect “impersonation” (observation 17/01/2013). During this “Impostor Detection Program” which I attended we were shown a PowerPoint presentation of passport-type photographs. Each slide presented two photographs that appeared very similar. The registrars’ task was to determine within three seconds whether the two pictures were of the same person, or were instead of two different people. The official explained that the use of official identity documents by another person has become the most common practice of identity fraud, and is most difficult to detect since border guards have little time to check and decide. He concluded by clarifying why he had asked the assembled local officials to participate in this exercise: “What I expect from you is to check that the person applying is the one on the picture [in the application form].” (UKAdmin1, observation 17/01/2013) Thus, this NCS workshop not only trained local registrars to check whether the application form had been filled out completely, but also to carry out a task usually performed by border guard officials. This exercise also had a significant racial and gender dimension since most of the pictures shown were of black and brown men (and most of the registrars in the room were white women).

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 U Nationals: Suspected of Claiming Welfare Without E Making Contributions In the UK, EU nationals wanting to apply for British citizenship face two particular challenges. The first difficulty is to stay informed about the fast-changing rules before and after Brexit. The second difficulty is to prove they meet the residency requirement, even when they are long-­ term residents. Already at the time of the empirical fieldwork in 2012 and 2013, it was difficult for EU nationals to produce sufficient evidence that they had been exercising the European Economic Area (EEA) Treaty Rights in the UK for five continuous years. Exercising these Treaty Rights means showing economic activity through work, job seeking, study or self-sufficiency. This is a problem for stay-at-home carers, low or cash paid, or women on maternity leave to mention but a few, which shows that the figure of the insincere overlaps with the figure of the dependent citizenship applicant discussed above. Even for those in full-time employment, it remains a challenge to produce five continuous years of pay slips. Rather than producing such detailed and large piles of evidence, the Home Office recommended that EU nationals apply for a permanent residence card as this was a convenient and effective way for a caseworker to quickly assess whether an EU national met the residency requirement. From the perspective of EU nationals, applying for a permanent residence card was unnecessary (since they held the right to permanent residence anyway, the application was just to obtain written confirmation), it required paying another immigration application fee and filling in the eighty-five pages long application form without making a mistake, and it further delayed the application for naturalisation. With the introduction of the British Nationality (General) (Amendment No. 3) Regulations in November 2015, the Home Office changed this policy and from then on required EU applicants to show a permanent residence certificate which had until then been optional. However, many EU nationals were unaware of this change and lost their fee when their application for naturalisation was refused, as lawyers reported (BrLA2, conversation2, 31/10/2012). After Brexit, the situation for EU nationals in the UK further aggravated due to the uncertainty about their legal status and the fast-changing

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rules. The permanent residence card or certificate was accepted only until 31 December 2020 and became invalid after 30 June 2021 when the “grace” period came to an end, and was replaced by the EU Settlement Scheme (EUSS) (Halliday 2021). It emerged that the Home Office demanded additional but often legally unnecessary documents from EU nationals (Yeo 2018a). Children of EU nationals were particularly disadvantaged; if their parents could not prove they were settled then children of EU nationals born in the UK lost their entitlement to British citizenship (ibid.). These children therefore experience the same UK-made problem as the Windrush generation (discussed in Chap. 7) as both groups “came to the UK lawfully, they remained lawfully, they were entitled to status” and yet they risk losing their entitlement to British citizenship because they cannot provide the proof required by the Home Office (ibid.). From the point of view of the Home Office, EU nationals are problematic migrants because they are “takers” rather than “givers”, especially regarding the provision of welfare, for example, the National Health Service (NHS). In this way, EU nationals, particularly EU students, were considered problematic because they could access the welfare state without paying sufficient tax contributions (since they were not in full-time employment). As a senior official explained: “The idea is that we don’t want people who are not paying into the system, for example, if they are in the NHS.” (UKAdmin1, observation 17/01/2013) In the UK, the NHS in principle offers healthcare to everyone, it is a tax-funded universal provision rather than an insurance system as in Germany or France (Slaven et al. 2021). However, since 2015, in the increasingly immigration-­ hostile environment (see Chap. 7), all non-EU nationals have been required to pay an annual “health surcharge” in order to access the NHS (which has risen from initially 200 to 624 GBP in 2020). The paradoxical situation for EU nationals who were students, self-sufficient, or family members was that they were entitled to use the NHS, but for their application for naturalisation, since 2011 they had to demonstrate that they have Comprehensive Sickness Insurance (CSI) or alternatively buy private health insurance or show proof of health insurance in their country of nationality, for example, through a European Health Insurance Card (Yeo 2018b). Again, many affected people were unaware of this CSI

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requirement, as legal advisers reported (BrLA2, conversation2, 31/10/2012); moreover, the European Commission considers the CSI requirement a breach of EU law (Yeo 2018b). Since Brexit, EU nationals in the UK are at risk of being considered to be not of “good character”, in breach of immigration law. Even before they were problematised in law, EU nationals were already problematised in official discourse at the time of the research. As discussed above, EU nationals in the UK were suspicious to the state because when they married a non-EU national they could pass over the residence and social rights they held as EU citizens to their non-EU spouse, as a senior official from the Home Office explained: “European applications are most abused because they can marry, for example, a Lithuanian married a Pakistani fellow” (UKAdmin1, observation 17/01/2013). In using the example of a Lithuanian-Pakistani couple, the official reproduced the theme of “sham” marriages voiced by the Brent registrars (see above). The idea that EU nationals are suspicious was not only found in the discourse of the research participants who are directly employed by the state, such as Local Authority registrars or Home Office caseworkers; it also emerged in the discourse of ESOL course teachers in Brent. Among their students, they noticed a group of course participants who had acquired the nationality of a European state in addition to their initial birthright citizenship, for example, Latin Americans who had acquired a Spanish passport through ancestry (BrT3 interview 21/11/2012), or Somalis who had gained Swedish or Dutch passports through naturalisation (BrT4+5 interview 23/11/2012). This group of persons with multiple passports particularly attracted the attention of two teachers during a joint interview in Brent (BrT4+5, interview 23/11/2012). These teachers were “very curious” because if someone had “already gained EU citizenship from another country”, then “why do they come here from countries that are safe?” (ibid.). At this centre, the teachers’ job is not only to teach language courses but also to secure and sustain course funding. Their curiosity at multiple passport holders turned into suspicion, because the students’ multiple nationalities put them in a situation where they could strategically choose which passport to show to identify themselves to their best advantage in a given situation. For example, showing a Swedish or Dutch passport at the UK border would allow them entry and residence as an EU

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citizen, while showing a non-European passport to the course centre meant that they were eligible for a free ESOL course there. The teachers also suspected that the students use their multiple nationalities strategically to “claim benefits”: BrT5: “[There are] certain elements of fraud involved in terms of setting residence up in several places, moving children around, claiming benefits, have one property in Sweden, rent a property here, move your children around to claim benefits. […] It is like, someone said ‘Which passport do you want?’ and they rummage around in their handbag and you are like, oh my god, how many have you got in there? […] If you’ve got an Italian passport but you are actually Brazilian, they have to work out which passport to use where they get more benefits. […]” BrT4: “The [course funding] criteria are fundamentally flawed because they are supposed to promote integration and it seems that if someone got an EU passport they are integrated but if you look at Eastern European countries or Romania for example, those cultures and British culture are not necessarily the same, people coming here from countries like Romania etc. they may need to be better integrated, need more help for integration. […]” BrT5: “They’ve got these passports but they’ve never actually been to Europe, they arrive from Brazil with an Italian passport and yet they know nothing of Europe. [It’s a] massive group [who] rush to get those passports, digging up certificates from their grannies.” (BrT4+5 interview 23/11/2012)

The above quote presents EU citizens who have become citizens through naturalisation or ancestry as somehow inauthentic Europeans, and as rapacious individuals who are concerned with maximising their own benefits. Additionally, and in a similar vein to the Brent registrars cited above, these teachers essentialised migrants from Eastern Europe when referring to them as from a different “culture” who “need to be better integrated.” In this research, the theme of the problematisation of EU nationals as a particularly fraudulent group among citizenship applicants only

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emerged in the UK, and particularly in the London research location. While registrars were concerned that EU citizens facilitated other immigrants’ access to the welfare state through marriage, teachers expressed concern about migrants who had acquired an additional EU nationality either through ancestry or naturalisation, and were thus able to move freely between different EU countries, allegedly accumulating benefits from different national welfare states.

2.3 The Indifferent Citizenship Applicant: Suspicious Political Loyalties The Super Citizen subjectivity expects migrant citizenship applicants to be loyal, committed and grateful to the state whose membership they seek. The third deviant figure is that of the indifferent citizenship applicant: an individual who is unwilling to contribute and commit to the state or unconcerned with doing so. In law, loyalty and commitment are required through physical presence (in the UK) or the renunciation of a previous nationality (in Germany). In discourse, people who were regarded as not committed enough were frequent fliers, those who do not make the effort to move the lips or learn the words of the oath by heart, and those who do not care about the rise of the far right and/or anti-­ immigration sentiments. By implication, this figure particularly welcomed political refugees for their supposed democratic commitment and therefore emphasised the political aspect of the Super Citizen subjectivity.

Frequent Fliers Commitment is interpreted in different ways. In the UK, loyalty is demonstrated through settlement on the state’s territory. The physical presence of the candidate is examined throughout the required residence period, from the first day of that period. Thus, if someone happened to be out of the country on that day five years ago then their application may be refused, as a legal adviser reported in London (BrLA2, first

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conversation 10/10/2012). This is because in Britain, “an application is ‘made’ when it is received [by the Home Office], not when it is posted [by the applicant]” (BNA 1981, s 50 (8), cf. Fransman 2011, 709). The Home Office requires that applicants count every day they have been absent from the UK during this period, and stipulate that the absent days should not exceed 450 days in total, as outlined in the previous chapter. This poses a problem for the international business elite, so-called “frequent travellers” (Calhoun 2002). The Home Office “normally disregard[s]” longer absences if an applicant has met all other requirements and has established “a substantial part of your estate” in the UK (Home Office 2022, 10). Capital investment thus excuses absence from the country, and frequent fliers are tolerated provided they keep their money in the country (see Chap. 3 on the commodification of citizenship and investor visa). Furthermore, the Home Office requires applicants to state the country in which they intend to make their principal home, as discussed in the previous chapter. This requirement does not, however, apply to the spouses or civil partners of British citizens. Being in a relationship with a British citizen is apparently sufficient evidence for the Home Office that newly admitted citizens will not leave the country again, or will stay committed to the country when staying with their British partner abroad. Similarly, in the discourse of civil servants, frequent fliers or highly skilled migrants are problematised as potentially not committed enough. For example, the Citizenship Ceremonies Officer in Burnley explained that she tries to “encourage” successful candidates to attend a group ceremony instead of a private ceremony, a recommendation agreed upon by the Head Registrar in Brent and the senior Home Office caseworker (BuAdmin1, interview 27/02/2013). However, “if someone insists, generally doctors, they are very impatient people”, then she arranges an individual ceremony for those citizenship applicants who cannot wait for the next available place in a collective ceremony (ibid.). In Germany, the federal administrative guidelines suggest that the application should still be considered if the applicant has spent at least half of the required time period in Germany, including several stays abroad of up to six months (Bundesministerium des Innern 2015, 38). Thus, frequent fliers are also (though to a lesser extent than in the UK)

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problematised in Germany. The SPD politician Olaf Scholz used them as an example to illustrate his vision of how immigrants in Germany should have a right to naturalisation from their first entry into the country: We need to change our approach [to naturalisation] so that whoever immigrates into our country, should have the prospect to gain citizenship, unless he comes as an academic who from the start just wants to work somewhere on a two-year appointment. (HaPol2, interview 28/08/2013)

According to Scholz’ statement, highly skilled migrants such as researchers do not fall into the category of desired citizenship applicants because of their likely limited period of residence and the international career prospects that might induce them to emigrate again. However, the current coalition government led by Olaf Scholz now plans to introduce such a “prospect” as we shall see in Chap. 7.

Dual Nationals In Germany, applicants’ exclusive loyalty to the German state is primarily established not through actual or intended residence but through the prevailing single nationality norm. As the previous chapter discussed, German citizenship law still requires German citizenship applicants to renounce their previous nationalities, although the current coalition government plans to allow dual nationality (see Chap. 7). Indeed, more and more exceptions are made to this rule. The Citizenship Act provides exemptions from this requirement for EU citizens, in cases where the “foreign state” has no legal provision to “release” citizens or “regularly refuses” to do so; or where it would impose “unreasonable” conditions resulting in economic or inheritance right “disadvantages” for the applicant (StAG s 12). The Federal Ministry of the Interior specifies that many Southern American states, such as Argentina, Bolivia, Costa Rica, Ecuador, Guatemala, Honduras, Mexico, Nicaragua, Panama, Uruguay, Brazil, and the Dominican Republic, do not release their citizens de jure, while other states, for example, Afghanistan, Algeria, Angola, Eritrea, Iran, Cuba, Lebanon, the Maldives, Morocco, Nigeria, Syria, Thailand,

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and Tunisia, do not release their citizens de facto (Bundesministerium des Innern 2015, 32–33). These recommendations are, however, not binding. Consequently, their implementation varies within Germany, and the interpretation of this requirement indicates a political commitment or reluctance to facilitate naturalisation at the Länder level. For example, Hamburg exempts Russian Jewish quota refugees (Kontingentflüchtlinge) from the requirement to de-naturalise, thus automatically recognising their dual Russian-­ German nationality (HaAdmin1, conversation 30/05/2012). In Dresden, in order to retain their previous nationality, citizenship applicants must first demonstrate that they made an effort to renounce their nationality but that their state was unwilling to release them or did not cooperate with their request. The Head of the Naturalisation Unit illustrated this with the example of Kosovars who also hold Serbian nationality (DrAdmin1, interview 14/05/2013). In their case, while the Kosovan nationality is released relatively quickly, most applicants “insist” that they cannot renounce their Serbian nationality (ibid.). The Dresden official expects these candidates to first apply for de-naturalisation before their dual nationality application can even be considered (ibid.). Following this civil servant, since the German law prescribes the avoidance of multiple nationalities, the issue of nationality renunciation sometimes becomes a question of “supporting” applicants in their endeavours “to be released” from their previous state membership to a point when the caseworker “bends and gives in” (ibid.). The applicants’ requests to tolerate their dual nationality are thus perceived as an unreasonable demand by German state officials.

Idealised Refugees Versus Saturated National-Borns: Maintaining Democracy Against the Far Right The criterion of commitment also refers to democratic political engagement. In this respect, political refugees are idealised as maintaining the democratic political order. The Head of the Dresden Naturalisation Unit always asks citizenship applicants what they contribute to society before he presents them their certificate, and he reported to be amused when:

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Some then try to sell themselves saying ‘I offer this and that’ while others say ‘I have nothing to offer’. And then I say, but we want you nevertheless because you have something [to offer] that you perhaps don’t recognise yourself and that is an experience usually made by refugees. They know what it is like when you cannot participate in a democracy. And that is exactly what we need to be reminded of because we are so saturated that we no longer see that. (DrAdmin1, 14/05/2013)

The figure of the refugee persecuted by an authoritarian state and seeking asylum in a democratic society is mobilised as a necessary corrective in advanced liberal democracies. Thus, citizens persecuted by their state of attribution who seek naturalisation in another state are idealised as living reminders of the democratic rights and freedoms guaranteed to citizens by birthright who are saturated with prosperity and show signs of a declining appreciation of political rights. This conceptualisation also indicates that the Super Citizen subjectivity is constructed not only against other migrants, but also against the national population. In this sense, national-born citizens are problematised as indifferent and in need of new role-model citizens, such as citizens by application.

2.4 Engrained Institutional Mistrust This chapter has argued that the idealised subjectivity of the Super Citizen in contemporary British and German naturalisation procedures is constructed against the background of three undesired counter-figures that I describe as “dependent”, “insincere”, and “indifferent” citizenship applicants, each of which problematises numerous persons, activities, and lifestyles. First, the figure of the “dependent” problematises citizenship applicants who are considered not working full time and not contributing sufficient tax payments, such as benefit receivers or students. It also views those applicants as problematic who are unable to meet the language and loyalty requirements because of age or disability reasons. This figure thus devalues migrants for their supposed lack of economic and or cultural-linguistic integration. Second, the figure of the “insincere” includes different groups of people, such as EU nationals, unauthorised

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entrants, and convicted war criminals, as well as migrants’ sponsors such as spouses, medics, teachers, or solicitors. This figure is based on the suspicion that citizenship applicants deceive and betray the state authorities to gain citizenship status through fraudulent, not credible efforts. Third, the figure of the “indifferent” refers to the global business elite as well as dual nationals who are suspected of insufficient political loyalty to the state where they gain naturalisation as their economic capital or multiple passports allow them to quickly move on to another country at their convenience. Of the three deviant characters, the figure of the “insincere” citizenship applicant was most pronounced in Brent. While this figure is inscribed into British nationality law through the “good character” requirement and is therefore characteristic of the British context, it was also a recurrent theme in the discourse of registrars and teachers in Brent, while being conspicuously absent in Burnley. This may reflect the wider political context of the increasing criminalisation of immigrants in the UK and in London, where the Home Office trialled recent anti-immigration policies such as the “Go Home” vans (see Chap. 7). The deviant figure of the “indifferent”, on the other hand, was stronger in Germany, where citizenship applicants were expected not only to vote but also to challenge racist national-born citizens both in Dresden and in Hamburg. The three deviant roles analysed in this chapter are not mutually exclusive but they overlap and are highly inconsistent. For example, the mobility and physical absence of the global business elite is problematised yet their financial investment is welcomed, as we shall see in Chap. 3. Moreover, the “dependent”, “insincere”, and “indifferent” do not correspond to social reality; rather, they are socially constructed categories based on stereotypical misrepresentations. For example, many of the student applicants interviewed for this research were in part-time employment to fund their studies, and thus participated in the labour market and contributed tax payments, contrary to what the figure of the “dependent” implies. And yet, the three figures are highly influential because they require migrant applicants to dissociate themselves from these negative “regulatory ideals” (Rose 1998, 23), as Chap. 6 discusses. The combined analysis

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of the different data gathered in this research, including official documents, interviews, and participant observations, demonstrates that these deviant characters are not only purported by written paper and statute books; they are also reproduced and reinforced through spoken discourse by a range of politicians and civil servants. This was especially the case where the three problematised figures intersect and overlap with other powerful subject-formation regimes in the area of welfare, securitisation, and inequalities. The figure of the “dependent” which problematised applicants who are not in full-time employment draws on the widespread demonisation of “benefit scroungers” both in the UK and in Germany. The intersection with the welfare regime also points to the political-economic logic underlying naturalisation whereby states facilitate access to citizenship for desired workers and restrict access for those considered to be a burden on the welfare state. Similarly, the figure of the “insincere” indicates that naturalisation is not unaffected by the recent “securitizing” trend in migration and citizenship policies (cf. Nyers 2009). As this chapter has demonstrated, the formalisation of the language and knowledge requirement was the result of increased political anxiety and distrust of migrants’ linguistic integration efforts which reflect a broader development (Byrne 2013). This was particularly prevalent in the UK, where the language testing was still “not rigorous enough” according to the former Home Secretary David Blunkett (interview 05/09/2012). Although this theme was less prevalent in Germany, medical practitioners were suspected of bribery in providing letters for exemption from the language and knowledge requirement. These developments appear to be a redistribution in the outsourcing of migration control duties whereby competences were formally or informally withdrawn from non-state or private actors, such as solicitors and spouses, and handed over to new local state or private actors, such as registrars and teachers. The figure of the “insincere” also had a gendered and racialised dimension as perhaps best demonstrated by the “bogus” marriage theme which in the narrative and everyday experience of the Brent registrars in the UK tended to involve brown Asian men and white Eastern European women. The fact that the most explicit racist discourse,

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the narratives of “bogus” marriages and naturalisation “scroungers”, was found in the most ethnically diverse research location suggests that the link between superdiversity and racism requires further investigation. In sum, the three figures of the “dependent”, “insincere”, and “indifferent” citizenship applicants suggest an engrained institutional mistrust which we would not expect in the area of naturalisation considered as the final inclusion of long-term settled migrants. The analysis showed that both in Germany and the UK the presentation of migrant applicants oscillates between victims of, for example, the supposedly money-hungry language industry on the one hand, and the image of the perpetrator conjured by the naturalisation “scrounger” or “impostor” clauses, on the other. This revitalises the much-discussed normative dilemma that migration poses for liberal democracies and political thought according to which migrants are perceived as givers or takers (cf. Honig 2001). The empirical findings of this study suggest that this dilemma remains unresolved. In theory, migrants resolve their problematised foreignness through an act of naturalisation and are even idealised as role-model democratic citizens. However, as long as the state’s suspicion remains so strong as visible in the three problematisations analysed here, all efforts by citizenship applicants may never be enough to provide that reassurance and achieve full societal recognition.

References Badenhoop, Elisabeth. 2021. Citizenship Matters: Towards an Interdisciplinary and Global Perspective on Naturalization. Citizenship Studies 25 (4): 445–455. Bröckling, Ulrich. 2016. The Entrepreneurial Self: Fabricating a New Type of Subject. London: SAGE. Bundesministerium des Innern. 2015. Vorläufige Anwendungshinweise des Bundesministeriums des Innern vom 1.6.2015 zum Staatsangehörigkeitsgesetz in der Fassung des Gesetzes zur Änderung des Staatsangehörigkeitsgesetzes vom 13. November 2014 (Stand: 1. Juni 2015). Accessed 9 March 2023. https://www.bmi.bund.de/SharedDocs/downloads/DE/veroeffentlichungen/themen/verfassung/stag-­anwendungshinweise-­06-­15.html.

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Byrne, Bridget. 2013. Neurotic Britishness: Why Are We Threatened by the Multi-Lingual Home? OpenDemocracy. Accessed 9 March 2023. https:// www.opendemocracy.net/en/opendemocracyuk/neurotic-­britishness-­why­are-­we-­threatened-­by-­multi-­lingual-­home/. Calhoun, Craig. 2002. The Class Consciousness of Frequent Travelers: Toward a Critique of Actually Existing Cosmopolitanism. South Atlantic Quarterly 101 (4): 869–897. Clayton, Gina, Caroline Sawyer, Rowena Moffatt, Georgina Firth, and Helena Wray. 2016. Textbook on Immigration and Asylum Law. 7th ed. Oxford: Oxford University Press. Fransman, Laurie. 2011. British Nationality Law. 3rd ed. London: Butterworths. Halliday, Iain. 2021. The Pathway to British Citizenship for European Nationals in the UK. Free Movement (blog). 18 February 2021. Accessed 9 March 2023. https://freemovement.org.uk/british-­c itizenship-­e uropean-­c itizens-­i n-­ the-­uk/. Home Office. 2015. Guide AN: Naturalisation as a British Citizen—A Guide for Applicants. To Be Read in Conjunction with Booklet AN (October 2015). Accessed 7 March 2017. https://www.gov.uk/government/publications/form-­an-­guidance. ———. 2020. Good Character: Nationality Policy Guidance. GOV.UK. 30 September 2020. Accessed 9 March 2023. https://www.gov.uk/government/ publications/good-­character-­nationality-­policy-­guidance. ———. 2022. Guide AN. Naturalisation Booklet. The Requirements and The Process. GOV.UK. 28 June 2022. Accessed 9 March 2023. https://www.gov. uk/government/publications/form-­an-­guidance. Honig, Bonnie. 2001. Democracy and the Foreigner. Princeton, NJ: Princeton University Press. Lazzarato, Maurizio. 2012. The Making of the Indebted Man: An Essay on the Neoliberal Condition. Los Angeles: Semiotext(e). Nyers, Peter, ed. 2009. Securitizations of Citizenship. London; New  York: Routledge. Rose, Nikolas. 1998. Inventing Our Selves: Psychology, Power and Personhood. Cambridge: Cambridge University Press. ———. 1999. Governing the Soul: The Shaping of the Private Self. London: Free Association Books. Slaven, Mike, Sara Casella Colombeau, and Elisabeth Badenhoop. 2021. What Drives the Immigration-Welfare Policy Link? Comparing Germany, France and the United Kingdom. Comparative Political Studies 54 (5): 855–888.

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Yeo, Colin. 2018a. Briefing: What Are the Barriers to British Citizenship for EU Nationals? Free Movement (blog). 14 June 2018. Accessed 9 March 2023. https://freemovement.org.uk/briefing-­w hat-­a re-­t he-­b arriers-­t o-­b ritish-­ citizenship-­for-­eu-­nationals/. ———. 2018b. Comprehensive Sickness Insurance: What Is It, and Who Needs It? Free Movement (blog). 13 December 2018. Accessed 9 March 2023. https://freemovement.org.uk/comprehensive-­s ickness-­i nsurance-­w hat­is-­it-­and-­who-­needs-­it/.

3 Rationalities of Naturalisation: Citizenship as Award or Entitlement

The previous chapter argued that the idealised subjectivity of the Super Citizen is constructed at the expense of three problematised figures: the “dependent”, the “insincere”, and the “indifferent” citizenship applicants. This chapter reconstructs the rationalities that correspond to these problematisations by examining how, that is, through which concepts, the features of the Super Citizen subjectivity are justified by those who design and implement the current naturalisation procedures. As defined in Chap. 1, rationalities are here understood as “explanations” and attempts at justification that render problematisations (and other features of subject-formation, such as authorities and techniques) plausible through “operative concepts” (Rose 1999, xi). Rationalities are the concepts that make a subject-formation regime appear “rational” (Lemke 2002, 55). This chapter reconstructs the rationalities in contemporary citizenship admission procedures in the UK and Germany extracted from official documents, interviews with state officials and politicians, as well as participant observations in naturalisation authorities. The analysis shows that naturalisation procedures are influenced by four main rationalities. First, naturalisation is thought of as an award that must be merited. Second, it is regarded as a right to which one is entitled. © The Author(s), under exclusive license to Springer Nature Switzerland AG 2023 E. Badenhoop, Calling for the Super Citizen, Palgrave Politics of Identity and Citizenship Series, https://doi.org/10.1007/978-3-031-34260-8_3

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Third, state officials envisaged naturalisation as creating an emotional relationship or attachment that they expect citizenship applicants ought to feel towards the state and society. Fourth, naturalisation is seen as a commodity for purchase. The international comparison demonstrates that these four rationalities were found both in Germany and in the UK but that the idea of naturalisation as a commodity and source of income was most advanced in the British case. The intranational comparison in the German case revealed significant differences between local authorities led by Conservatives and Social Democrats. Thus, Christian Democratic Union (CDU) politicians and administrations would primarily conceive of naturalisation as an award while Social Democrats (SPD) governments argued for an entitlement to naturalisation. In this regard, the city state of Hamburg stood out as the only research location in this study where the state made the biggest effort to promote naturalisation through various campaigns, personal letters, and a volunteering project.

3.1 Naturalisation as a Discretionary Award The first rationality conceptualises the act of naturalisation as a prestigious award that is granted at the discretion of the state; it is a privilege and favour that cannot be taken for granted but that must be merited. According to this rationality, the citizenship applicant must demonstrate his/her “worthiness”. This rationality was found especially in the UK data (the legal provisions) and in the German interview data with Conservative state officials. Both the UK and Germany have a long history of discretionary naturalisation, as discussed in Chap. 1. In the UK, since the thirteenth-­ century, naturalisation was always granted at the monarch’s will, and later, since the nineteenth century, it has been granted at the Home Secretary’s ultimate discretion. In Germany, naturalisation has been discretionary since 1871; however, automatic naturalisation through settlement was a common practice before then, and a statutory entitlement to naturalisation has recently been re-introduced through section 10 of the

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Nationality Act (StAG). Thus, the present situation is that naturalisation remains exclusively discretionary in the UK, while in Germany it can also be obtained through entitlement.

“A Straightforward Process” It is therefore unsurprising that the idea of naturalisation as an exclusive privilege was particularly prominent in the UK. The Home Office explains to applicants that: [N]aturalisation is not an entitlement. It is a matter of law as set out in the British Nationality Act 1981. The Home Secretary may exercise discretion to naturalise you only if you satisfy a number of statutory requirements. This guide helps you to understand them. It may be possible to grant your application even if you are not able to meet all of the requirements, but this cannot be done in all cases. The way that discretion is exercised is described throughout this booklet. (Home Office 2022, 3)

The UK Home Office regards naturalisation as a “grant” to be made at the “discretion” of the Home Secretary. The legal definition of naturalisation as a discretionary grant makes citizenship admission for “aliens” and “foreigners” an exceptional rather than automatic access route to citizenship. This also means that the Home Office is under no obligation to facilitate naturalisation. Indeed, in a previous version of its Guide to citizenship applicants, the Home Office stated that legal advice and support should not be necessary because: […] applying for naturalisation is a straightforward process which does not require the use of specialist agencies. You should be capable of applying successfully by following the guidance provided in this Guide and ensuring that you are able to satisfy the requirements detailed in the Booklet AN. (Home Office 2015, 4)1

 This passage has been removed from the current version of the Guide, and it has been replaced by a paragraph explaining how migrants can identify qualified immigration legal advice in the UK (Home Office 2022, 4). 1

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The rationality of a discretionary award also explains the withdrawal of Legal Aid funding for immigration advice, including naturalisation, as Chap. 4 discusses in more detail. Furthermore, the rationality of a discretionary grant justifies the lack of a right to appeal.

No Right to Appeal As Chap. 1 outlined, the UK Home Secretary was traditionally not required to justify a grant or rejection of a naturalisation application. The Mohammed al Fayed case in 1997 challenged this non-transparent practice and Jack Straw as the then Home Secretary in the Labour government announced that refusals would henceforth be justified (Clayton et  al. 2016, 97). Moreover, the 2002 Nationality, Immigration and Asylum Act repealed sections 44 (2) and (3) of the 1981 British Nationality Act which had provided that the Secretary of State should give no reason for their decisions (ibid.). However, there is still no right to appeal a decision made by the Home Office and the commitment to explain refusals is self-binding, not enforceable. The only option for a rejected applicant wishing to challenge a negative decision is to initiate a judicial review which “presents high hurdles of argument and expense” because they would need to prove the “Home Office error” (Clayton et al. 2016, 97; cf. Fransman 2011, 755–768). The responsibility is thus put on the individual applicants who depend on the goodwill and commitment of the Home Office to make its decision transparent. Applicants are extremely limited in their agency to challenge a Home Office decision. Apparently, the Home Office is committed to reducing the number of rejections, as a senior official explained to local registrars during a training workshop which I observed: “We want to refuse as few people as possible. We want to give citizenship to the people who merit it. The people who don’t, we don’t care about them” (UKAdmin1, observation 17/01/2013). Nevertheless, because naturalisation is considered an exceptional grant that is subject to prior careful examination, it is unthinkable—following this rationality—that a rejection could be mistaken. The Home Office, as the above statement confirms, “does not care” about the applicants who, in the eyes of the state, do not “merit” British citizenship. Consequently, the Home Secretary’s decisions cannot be appealed.

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No “Entry Ticket” or “Old Roll” As mentioned above, even though the present German citizenship law contains a legal entitlement for naturalisation, discretion was the only route to German citizenship for most of the twentieth century. Accordingly, the rationality of present-day awards was also expressed by research participants in Germany, notably around the themes of “integration” and applicants’ supposed “willingness to integrate”. This became apparent, for example, when the leader of the Hamburg Christian Democrats (CDU) and former Integration Senator brought up the term “integration” in an interview: “There is a lot of talk about people unwilling to integrate (Integrationsunwillige); but no one can integrate themselves if the majority of society does not want to integrate them.” (HaPol1, interview 13/08/2013) While distancing himself from the term “integration” and from those who use it, this politician pointed out that both “migrants” and the “host society” should show a “willingness to integrate” (ibid.). In doing so, he therefore did not reject the term “immigrants unwilling to integrate” (Integrationsunwillige) used in xenophobic debates, but instead extended it to all citizens, migrant and national-born alike. From this position, he explained his understanding of naturalisation as a reward rather than a condition for “integration”: What is citizenship after all? Is it an accomplishment and reward concluding a successful integration process or is it an entry ticket? I would rather take the view that it should be at the end because if we gave away citizenship unconditionally, no integration problem would be solved. (HaPol1, interview 13/08/2013)

This conservative politician regarded the passport as a reward for immigrants at the end of a successfully completed “integration” process, a view typical of his party, the Christian Democratic Union (CDU). A similar view was also expressed by senior state employees such as the Head of Naturalisation in Dresden. He explained that: “We don’t just want to give away [citizenship] for nothing, because you would not throw [citizenship] away like old rolls (alte Semmeln)” (DrAdmin1, interview 14/05/2013).

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The CDU politician and the Dresden official’s references to “entry tickets” and “old rolls” suggest that the state should not “give away” (verschenken) membership to migrants too easily. They agree that naturalisation should not be undersold and that it requires applicants to try and demonstrate their “willingness” to deserve the privileges of citizenship status. Naturalisation is thus thought of as a “sovereign act” (hoheitlicher Akt) (DrAdmin1, interview 14/05/2014) which is deployed to reward past efforts.

From “Knave” to “Knight” The above-mentioned conceptualisation of citizenship admission as a “sovereign act” by the Head of Naturalisation in Dresden also influences his everyday work. Since his appointment as the most senior caseworker in Dresden, he has been officiating at the presentation of all naturalisation certificates in the city (DrAdmin1, interview 14/05/2014). By contrast, in Hamburg, caseworkers who process an application also present the certificate at the end; however, the Head of the Dresden Naturalisation Unit did not entrust this task to his subordinate staff. Thus, any successful citizenship applicant in Dresden is invited to one of his “ceremony appointments” (Feierstunde). Up to five successful candidates gather in his small office on each of these occasions, during which he likes to “facilitate” a discussion using one of several “narratives” before handing over the naturalisation certificates (ibid.). One of the “narratives” for the group discussion preceding the conferral of citizenship in Dresden is the “image of the knight”, which proceeds as follows: when “knaves” wish to become “knights”, they must “accomplish tasks like rescuing princesses or other stuff to prove themselves” so that “the king confers the knighthood on them” with his “heavy sword”; and in order to “prevent the king from mistakenly cutting off their heads, the knights kneel down in front of him, which also demonstrates their submission” (DrAdmin1, interview 14/05/2014). This was one example of how this civil servant discursively framed the actual grants of naturalisation in his everyday work. In drawing upon this fairy tale motif, he presented the act of naturalisation as resembling an act of submission to

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a feudal sovereign. Furthermore, the imagery of the “knave” justifies the expectation from citizenship applicants to demonstrate their “worthiness” before a decision is made on whether to grant them citizenship.

The First Citizenship Test in Saxony In addition to the well-known examples of Baden-Württemberg and Hesse, Saxony is a lesser-known example of a German state which practiced its own form of citizenship test before the federal naturalisation test was introduced in Germany in 2008. This finding emerged unexpectedly during the interview with the Head of the Dresden Naturalisation Unit. According to him, because section 8 of the German Nationality Act states that naturalisation grants express “preferential treatment”, this rationality of privilege justified the introduction of an early form of testing at the local level: It was about checking whether people who are given the favour of naturalisation (bevorzugt eingebürgert), I mean with a discretionary naturalisation [section 8] you [citizenship applicants] always receive a preferential treatment so in return we expected that you know a bit about the system. (DrAdmin1, interview 14/05/2013)

The question then arises: how did the authorities ensure that applicants “know a bit about the system”? The Saxon Ministry of the Interior recommended a catalogue of fifty written multiple-choice test questions about “basic knowledge of the state order” which local offices administered by choosing twenty or twenty-two questions and requiring applicants to answer these in the local offices (DrAdmin1, interview 14/05/2013). According to his own account, the Head of the Naturalisation Unit in Dresden assisted the Ministry in drafting and disseminating the use of this questionnaire among local authorities in Saxony (ibid.). For their preparation and to act as a “book of answers” (Lösungsheft), applicants were given a copy of the Basic Law (Grundgesetz) (ibid.). This civil servant expressed disapproval that the current federal test questions are “a lot easier” than the previous questions used by the

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Saxon Interior Ministry (ibid.). Moreover, the initial test in Saxony allowed the caseworker to discuss the questions with the applicant in case they had not answered them all correctly (ibid.). He presented this as a more efficient way of learning, because they would be unlikely to forget the questions they got wrong (ibid.). In the past, the caseworker could decide to send away applicants who had not prepared because “their mind [was] set on their work or [they were] simply not interested”, and to offer them the opportunity to prepare again and “re-sit the examination just like it would be at school” (ibid.). The early test in Saxony thus gave caseworkers the authority to behave like exam invigilators and schoolteachers in their interactions with citizenship applicants.

“Lecture About Rights and Duties” The idea of naturalisation as a “preferential” rather than automatic treatment was important for the Head of Naturalisation in Dresden. He characterised the option of naturalisation as entitlement introduced through section 10 as a “mistake” in the following comment: So, if you get applicants who you have to naturalise because of the entitlement to naturalisation. And it is a mistake that we naturalise them but I am only the executive. But then at least they get a lecture about their rights and duties. (DrAdmin1, interview 14/05/2013)

The civil servant criticised the introduction of paragraph 10 for withdrawing discretionary powers from local caseworkers. In his view, his influence in selecting candidates worthy of naturalisation was now reduced to discursive or disciplinary power in giving them a “lecture” before handing over the certificate of naturalisation. Significantly, the presentation of certificates, and thus the legal transformation of migrants into citizens, ought to be administered by a German national, as he made explicit at the end of the interview: Now I do say it after all: In my opinion, this must be done by a German. What does it look like if, say, an Australian was standing here? […] If this work was carried out only by employees, then a Turk might come in and

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file a competitor lawsuit (Konkurrentenklage), and who knows, he might be successful? In my view, this is a sovereign task (hoheitliche Aufgabe) that requires a German to execute it. (DrAdmin1, interview 14/05/2014)

Admission to the German civil service normally requires German nationality, so foreign nationals are excluded. However, as this administrator explained during the interview, he was the last remaining civil servant in the department; all his colleagues who had joined the naturalisation unit after him were only given the status of regular employees due to “austerity measures” (DrAdmin1, interview 14/05/2014). He was thus afraid that these cuts had effectively made his job, a position capable of “making” new Germans, accessible to non-Germans. In his worst-case imagined scenario, “a Turk” might legally force his way into the department. The rationality of award and privilege thus facilitates nationalist thinking, because if naturalisation is considered an “act of national sovereignty” then only Germans should assess who is considered worthy of the state’s “favour”. To summarise, the rationality of naturalisation as a discretionary grant made it plausible that citizenship applicants in the UK should not need to use state-funded legal advice, and that they have no right to appeal. According to the logic of the Home Office, if British citizenship candidates cannot evidence their “worthiness” themselves, then there is no further case to be made about the matter. In the UK, the rationality of privilege is structurally determined by the legal definition of naturalisation, but in Germany the law defines naturalisation both as a discretionary award (StAG s 8) and as entitlement (StAG s 10). The examples given here from the CDU politician in Hamburg and the civil servant in Dresden show that section 10 in Germany is contested precisely because the rationality of award still prevails in the public imagination. Thus, the Hamburg conservative conceptualised naturalisation as a reward for successfully completed “integration” efforts, while Saxony practiced an early form of citizenship test that authorised local caseworkers to assess whether a candidate deserved the “preferential treatment” of naturalisation. The rationality of award and privilege corresponds to, and reinforces, the deviant figure of the “dependent” citizenship applicant discussed in the previous chapter, because it problematises citizenship applicants who

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lack the knowledge, self-confidence, and skills to enter and complete the application procedure on their own, in contrast to the rationality of entitlement which constructs citizenship applicants as needing information, encouragement, and support, as the following section demonstrates.

3.2 Naturalisation as a Legal Entitlement Contrary to the rationality of discretionary award, the second rationality conceptualises naturalisation as a legal entitlement. Following this rationality, the state should facilitate naturalisation and encourage long-term migrant residents to apply. The potential citizenship applicant is considered as a rights-holder who needs to be informed about their entitlement and empowered to help themselves. This rationality was expressed both in the UK and in Germany by centre-left politicians, and was most influential in the city state of Hamburg.

A Political and Economic Necessity or “Plus” The rationality of naturalisation as a legal entitlement is based on the recognition that the naturalisation of new citizens is necessary or even desirable for the state. The politicians interviewed for this research affirmed that naturalisation is a political necessity in any democratic state. This theme was particularly prevalent in Hamburg where it was expressed by members of both main German political parties, the Christian Democrats (CDU) and the Social Democrats (SPD). Thus, the then First Mayor of Hamburg, Olaf Scholz (SPD), declared: I consider it to be an important aim of the state (Staatsziel) that those who live with us for a long time may acquire citizenship. This is important for social cohesion (eine Gesellschaft, die zusammenhält). (HaPol2, interview 28/08/2013)

Similarly, the former Integration Senator (CDU) explained that the first pro-active naturalisation campaign in Hamburg was introduced

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among other reasons out of a democratic unease felt by the then CDU-­ led Hamburg government, that those who rule a democratic state should largely be congruent with those who are ruled: Of course, one reason behind this was that those who live in Hamburg permanently, who build up the city, shape and enrich it, should not be excluded from citizenship but should complete  their integration process including political integration. That was the designated aim […] that the constitutive people (Staatsvolk) should not deviate too much from the population of residents. It’s a large group. (HaPol1, interview 13/08/2013)

As this politician developed his idea of “integration” (discussed in the previous section of this chapter), naturalisation became part of a migrant’s “political integration”, and could thus be expected as a duty from long-­ term immigrants. In the UK, the view that naturalisation is unavoidable and even desirable was also expressed. The former British Home Secretary, David Blunkett (Labour), who introduced the citizenship test, courses, and ceremonies in the UK insisted that naturalised citizens are “valuable” and a “plus” for society rather than simply being rights-claimers and protesters, as the then Conservative and Liberal Democrat Coalition government had suggested: Now the present Coalition see naturalisation as something that should be resisted, they want to make it more difficult to become a naturalised citizen. They want people to be here much longer. I saw it as a plus, I thought someone wanting to become naturalised citizen in the UK was a valuable step in identifying and being part of our society and our future. (UKPol1, interview 05/09/2012)

The acknowledgement that the state relies on naturalisation is not only based on a political, democratic necessity, but is also linked to an economic, demographic necessity in ensuring the effective functioning of the welfare state in an ageing society. For example, a senior Home Office official mentioned that “They pay our pensions!” (UKAdmin1, conversation1 14/11/2012), thus acknowledging the important economic contribution migrant workers make to the British welfare state.

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 nablement and Empowerment Rather Than E “Social Imperialism” The rationality of entitlement and encouragement re-defines naturalisation requirements from being a means of separation and exclusion which is at the disposal of the state, to being important “equipment” for individual citizenship applicants that enables them to participate in society. The idea that migrants need to be “equipped” justifies the idea of education and empowerment with declared liberal intentions. Thus, the former Labour Home Secretary who introduced the Life in the UK test specifically clarified that he did not want to abuse the test to “impose” a specific royalist and imperial interpretation of British history on citizenship applicants: We never ruled out British history, we just wanted to see it in the context of the lives that people would be leading now rather than some sort of social imperialism where we felt that we had to impose our recollection and our particular version of our own history and that of our empire on other people and these are very controversial areas. You know, I am very interested in history, and economic and political history, whereas other people see history as being almost linear. […] They think that knowing which king followed which queen is history, whereas actually history is about the people of this country and their relationship with each other and with the world. That is much more profound than the kind of history that, for instance, Michael Gove or Theresa May would have you believe in. (UKPol1, interview 05/09/2012)

In making this comment, he distanced himself from the “social imperialism” of which he accused the then Secretary of State for Education, Michael Gove, and the then Home Secretary, Theresa May, both Conservative ministers in the then Coalition government, and which he saw as being exemplified in the third revised edition of the “Life in the UK” handbook. This edition significantly extended the chapter on British history both in text volume and in time covered while also, for example, reducing the section on the European Union, as Chap. 5 discusses.

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Similarly, the senior administrator responsible for organising the citizenship ceremonies in Hamburg emphasised that ceremony invitations are only sent to those applicants “who want to be invited” (HaAdmin1, interview2 17/07/2013). This statement carried the implication that no one is forced to attend. Rather, as the former British Home Secretary continued, the intention behind the introduction of the citizenship course and “Life in the UK” test was to enable citizenship applicants to become “active citizens”: It was intended originally for people to be able to live openly, comfortably, effectively and independently in the United Kingdom by being able to relate to their neighbours, to be able to obtain and hold a job, to be able to function as an active citizen because Bernard Crick and I put a lot of emphasis on active citizenship and I am still doing that now, I am still obsessed with the idea of engaging people in the civil society in volunteering and putting the glue into society. (UKPol1, interview 05/09/2012, original emphasis)

By “engaging” citizenship applicants in “civil society”, he hoped to foster social cohesion or “putting the glue into society” as he put it, similar to the Hamburg First Mayor’s reference to “Zusammenhalt”, mentioned above. The expectation that migrants become “active citizens” was found explicitly in some exercises of citizenship courses, as Chap. 5 discusses in depth. As this and the previous sub-section have demonstrated, the rationality of naturalisation as an entitlement and a means of inclusion was found in the participants’ discourse both in the UK and Germany. In Hamburg, this rationality was most consequential as it directly informed two highly effective government campaigns, as the following part of this section discusses.

 ro-naturalisation Campaigns in Hamburg: Volunteer P “Guides” and Personal Letter by the Mayor The context in Hamburg is characterised by two consecutive pro-­ naturalisation campaigns. The first campaign was initiated by the CDU-­ led government and was driven by the then Integration Senator who

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introduced citizenship ceremonies in 2006. It involved a poster campaign, a website2 and a telephone hotline in 2010 to advertise naturalisation. Featuring on the posters and representing a key element of this campaign were the volunteer “guides” who should help migrants to successfully submit their naturalisation applications (Einbürgerungslotsen), a network coordinated by the Turkish Community Hamburg (Türkische Gemeinde Hamburg und Umgebung e.V.) and commissioned and funded by the Hamburg government. The campaign assumed that some potential applicants are unaware of their eligibility to naturalise or are misinformed, as the former Integration Senator explained: We said, we won’t have that: a lot of people know too little or have reservations or believe that naturalisation causes them negative consequences in their country of origin. So, we wanted to actively do something against that and promote naturalisation. (HaPol1, interview 13/08/2013)

To this purpose, the Hamburg population statistics were specifically analysed to identify groups with a “high willingness to naturalise”, such as “Africans” and “Iranians”, compared to those who are “weak in naturalisation” (einbürgerungsschwach), for example Turkish residents, which was one reason why the funding for the support network was given to the Hamburg Turkish Community (HaPol1, interview 13/08/2013). The Hamburg approach to naturalisation became an issue of management where the state made the effort “to see which group has a high potential but where naturalisation has so far been rather unpopular so that we could then specifically target that group with the naturalisation guides project” (ibid.). Furthermore, the administrator in charge of the campaign consulted evaluations of existing attempts to make naturalisation more attractive: I read a lot of studies before the campaign. The existing appeal is not working; it is ineffective to simply put up posters. [It works] only through multipliers whom we saw in the “communities”. Opinion makers who really  http://einbuergerung.hamburg.de/ (accessed 24 February 2017).

2

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have something to say. If we manage to win over those people who in turn encourage others to also naturalise, take away their reservations (Scheu), impart the topic positively, then we may have a chance of  success. (HaAdmin1, interview2 17/07/2013)

The campaign was designed to be “output-driven”, and in this sense Hamburg was the only location examined in this research where the government had the explicit political aim to “sustainably increase the number of naturalisation grants” (HaPol1, interview 13/08/2013). Hamburg implemented an organised effort to make naturalisation more popular, within which the “naturalisation guides” were given the crucial role of setting a new trend: At the time, we looked at factors that hinder naturalisation: the lack of knowledge, sometimes lengthy procedures, and surely whether you see examples. Hence [we aimed at] reduction of length of procedures, giving a clear signal of being wanted, but also to actively promote through the guides. Based on the assumption that many perhaps toyed with the idea but never carried out the plan and if more migrants do this, the more it becomes fashionable and en vogue to say, “Gosh! Why don’t I do this, too?” when you have seen others do it. That was our idea, the more let themselves naturalise, the more will report back to their own “community” so that a self-reinforcing process can develop. But also clearly coupled with a political culture of welcome, to express that [naturalisation] is being wanted. (HaPol1, interview 13/08/2013)

As this interview extract demonstrates, the marketing aim was linked to a neoliberal aim. The former Integration Senator admitted that “the City would not have had the personnel capacities to do so”, which is why the Turkish community was given the task of “tapping other communities” (ibid.). By activating a few individuals representing different migrant “communities”, it was hoped that they would, in turn, nudge those around them. Then, in time this would turn into a chain reaction or a self-fulfilling effect, thus achieving a big outcome with little effort. The neoliberal idea of self-empowerment conceptualised migrant “communities” and their members as resources and skills that the state lacks, which can be mobilised and put to use in the state’s interests. As the “whole aim”

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of the campaign relies on the idea of “self-propulsion” (Eigenantrieb) (ibid.), the campaign should “help” the Turkish community and the other migrant communities in Hamburg to “help themselves”. The effectiveness of the “guides” was believed to lie in their roots in specific national or ethnic “communities”, and their potential to “utilise specific occasions as well as everyday situations”, as the commissioning administrator explained: Anybody can be a naturalisation guide, be it a volunteer at a Turkish football club who in his leisure time explains naturalisation to his team colleagues; or an employee of a trades union who informs his colleagues at his workplace; or a law student who reports about naturalisation at the university and assists fellow students; or in religious settings; for example, the African guide often takes her information materials to wedding ceremonies or church services which is very popular. These are large events and it is completely normal that she has her mobile information desk there at the side and informs people on the topic of naturalisation. (HaAdmin1, interview2 17/07/2013)

The promotion of naturalisation, that is, the formal bureaucratic procedure to apply for state membership, was deliberately taken into informal, personal, and private spheres because this was believed to be capable of producing more effective outcomes. The specific role of the volunteer “guides” in facilitating naturalisation will be further discussed in Chap. 4. The “naturalisation guides” project and the ceremonies were continued under the SPD, who were elected to Hamburg state government in 2011 after ten years of CDU rule. The SPD government led by Olaf Scholz started a second campaign which increased the number of caseworkers in the naturalisation authorities in order to reduce processing times, and which also introduced a letter. The government analysed the statistics again and identified all the local residents who fulfilled the eight years’ residence requirement. These migrant residents were then sent a personal letter from the First Mayor informing them about the possibility of naturalising, and inviting them to do so. The letter started with the recognition that the recipient had “already long since become a Hamburger”,

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and suggested that this assumed local self-identification could thus be formally recognised through an application for official naturalisation: I would like to explicitly encourage you to take up this opportunity. After completing naturalisation, you would not only continue to pay taxes like before. You could also have a say in how the state should spend your money. You would have full voting rights. You could cast your vote and stand for vote. You could have an influence on the direction of the city and the country.

On the back of the letter, the First Mayor listed the legal requirements but also drew attention to the “exemptions foreseen by law” and advised the potential applicant that they should “not be put off” by the long list, but should instead approach a caseworker to discuss this in person. The First Mayor decided to send these letters because he regards migrants as a potential for the state that needs to be “mobilised”, as he explained during the interview for this research: The big cities and many countries such as Germany are places of hope. Many people go there because they hope to find a better life for themselves and their families. And we need to mobilise this hope and utilise the forces that it produces. The prospect of naturalisation (Einbürgerungsperspektive) ultimately improves our living together. (HaPol2, interview 28/08/2013)

The idea of facilitating naturalisation through entitlement and encouragement is based on conceptualisations of the nation-state that acknowledge that immigration is a natural and irreversible given fact. Thus, Hamburg’s First Mayor affirmed that the city population has “grown through immigration, predominantly from within Germany” and emphasised that Hamburg is “open to the world” (weltoffen) due to its harbour (HaPol2, interview 28/08/2013). The former British Home Secretary similarly insisted that “Britain has always been a melting pot […] a mongrel nation” (UKPol1, interview 05/09/2012). Likewise, the CDU opposition leader in Hamburg affirmed that “There is no going back. We will not return to the nationally, ethnically, religiously closed societies. There is no way back, only a way forward” (HaPol1, interview 13/08/2013).

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In Hamburg, the rationality of entitlement was developed further as politicians and administrators agreed that the liberal state ought to be more welcoming, so the “guides” project was regarded ideally as a temporary policy measure to compensate for the authorities’ existing deficit in “intercultural competence”: “If the authorities were more intercultural and naturally included such things in their repertoire, then we would not need such an extra measure” (HaAdmin1, interview2 17/07/2013). To summarise, the rationality of entitlement conceptualises naturalisation as a right that long-term migrants automatically hold. Naturalisation then becomes a matter of personal choice for the migrant who may be willing or unwilling, or indeed unaware of how to apply. Following this rationality, the state should acknowledge and embrace the population’s ethnic diversity by actively supporting individual applicants to obtain naturalisation. This rationality was found in the UK and in Germany, but was most prominent in Hamburg where it informed two consecutive political campaigns, led by the CDU and SPD respectively. While the rationality of entitlement corresponds to the problematisation of the dependent citizenship applicant who needs to be (self-)empowered, it also relates to the indifferent citizenship applicant who needs to be “won over” (see the previous chapter). The following rationality relies on this figure of the indifferent more strongly.

3.3 Naturalisation as Creating an Emotional Attachment The third rationality identified in this study conceptualises citizenship as an emotional relationship between the individual and the state. According to this logic, naturalisation should facilitate a lasting attachment to the state. The citizenship applicant is seen as a recipient of the state’s affection, which should be valued and returned. This rationality has, above all, justified the introduction of citizenship ceremonies. While the ceremonies as a technique of subject-formation will be discussed in detail in Chap. 5, this section uses the discursive framing of their introduction as an example to illustrate the rationality of the emotional tie.

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 urning a Bureaucratic Procedure into a Lived, T Meaningful Experience Ceremonies were first introduced in an attempt to turn the paper-based application procedure into a lived, meaningful experience, or at least to complete the act of naturalisation in this way. The politicians interviewed for this research agreed that the previous handling of the application procedure was “too formulaic” (UKPol1, interview 05/09/2012), a “purely bureaucratic act” (HaPol1, interview 13/08/2013). Rather than sending out a newly naturalised citizen’s certificate via post or handing it over in “unfriendly and cold” offices (HaAdmin1, interview2 17/07/2013), the aim was to “celebrate” naturalisation since a “change of nationality” was regarded as “one of those significant life events”, like a “wedding” or “birthday” (BrAdmin4, interview1 20/09/2013). The idea was therefore to treat naturalised citizens with the highest symbolic respect by receiving them in special places, like special state guests. Thus, the ceremony in Hamburg is organised as “the highest possible event according to the protocol”, which means that naturalised citizens are invited as “guests of the First Mayor” into the ceremony hall of the Town Hall which is considered “Hamburg’s best parlour” (HaAdmin1, interview2 17/07/2013). Similarly, citizenship ceremonies in Dresden take place in the plenary room of the Saxon Parliament, the “best place of the state” (DrPres3, observation 31/08/2013), and are deliberately hosted by the Parliament’s President, the “highest-ranking person in Saxony” (DrPol1, conversation 18/06/2012). The format of the ceremonies was carefully chosen to express the (new) significance the state attributes to naturalisation and to make it a more social and emotional act. The administrative organiser of the Hamburg ceremonies emphasised that ceremony guests are seated; this is “not a standing reception”, and that they can bring their relatives to “mark this occasion not alone”. Indeed, they are given the opportunity to “socialise and exchange with others” during the “convivial” reception following the ceremony (HaAdmin1, interview2 17/07/2013). The politicians who initiated and hold ceremonies in Hamburg agreed that the ceremonies should create an “emotional tie and loyalty” (HaPol1, interview

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13/08/2013) to the state, and transform naturalisation into a mutual “devotion” (Hinwendung) and “affection” (Zuwendung) between applicants and society (HaPol2, interview 28/08/2013). Ironically, national-­ born members of that society are hardly present in citizenship ceremonies except as guests or speakers, as Chap. 5 discusses.

Inducing National and Local Self-identification Making citizenship applicants feel attached to the state was motivated by the aim of politicising new individual members of the state and making them aware of the public good. The former British Home Secretary David Blunkett formulated this idea when I asked him whether they had looked at any particular country or model of citizenship ceremonies in their planning: I think we’d all been sceptical about the all-singing, all-dancing, cheerleader approach of the United States because it can be very, in a colloquial expression naff. It can be seen as being just like you get it at baseball games (laughs) but we also recognised that demand of signing up to something bigger than just the individual concern about themselves and their family, something that said I am part of this nation, I am part of the wider family of the British people, I felt was really important. And if we could get a balance between the all-singing, all-dancing of the States and the almost indifference that we’d had in the UK, then we would be able to get it right. (UKPol1, interview 05/09/2012, original emphasis)

Compared to the United States, the British former approach to naturalisation was characterised as “indifferent”, and David Blunkett wanted to change this, to raise citizenship applicants’ concerns from their individual affairs to public matters, and for them to identify themselves as “part of this nation”. Similarly, the Head Registrar in Brent (who administrated the first British citizenship ceremony) explained that the ceremonies should make applicants “feel more British” (BrAdmin4, interview1 20/09/2012). In both the UK and Germany, the ceremony organisers mobilised local representations of the state (e.g. of the city or the region) in order to

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induce citizenship applicants’ national self-identification, for example, through speeches by invited local guest speakers or the use of flags, symbols and songs, as will be analysed in detail in Chap. 5.

Humanising the State In order to induce an emotional attachment to the state, it had to be made appear more approachable and likeable through actual physical contact with state representatives in state buildings. When I asked the Integration Senator who initiated citizenship ceremonies in Hamburg how he himself experienced the ceremonies, he replied that he enjoyed them as “a kind of friendly possession-taking (freundliche Inbesitznahme)” by people from all over the world in the building of the Town Hall, the seat of the Hamburg government and parliament (HaPol1, interview 13/08/2013). In the UK, a senior Home Office official outlined to local registrars the important function of the Nationality Checking Service as applicants get to see “a friendly face and can keep their documents” while “the benefit” for the local authority is that “you get to see the local community from an early point on” (UKAdmin1, observation 17/01/2013). Similarly, the Head Registrar outlined the purpose of the ceremony to the naturalising citizens and their guests in a ceremony speech in Brent by highlighting that the local authority is “not a scary place” (BrAdmin4 in BrPres7, observation 09/10/2012). Indeed, as he explained to me in an interview, he did not want to adopt the “military” style that “Britain is famous for”, because it might be “a bit scary” for refugees; rather, the ceremonies should feel like “a group hug”: What I wanted was it to be welcome so it shouldn’t be the usual sort of trumpets and very posh people talking very far back. It should be normal people celebrating what immigrants bring into the UK. For me, it was supposed to be a group hug. A formal occasion which you enjoyed yourself. So, it was not going to be […] some Local Authorities have the Lord Lieutenant in uniform, the mayor processes in, everybody has to stand. I tried to ensure we have a less formal field and people, a smiley event, want them to enjoy it, go away and feel uplifted rather than feeling a bit intimidated by it. (BrAdmin4, interview1 20/09/2012)

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The state was therefore presented here as an intimately related group, and metaphors of the family and romantic couple were often used. The former British Home Secretary referred to naturalisation as “becoming part of the wider British family” (UKPol1, interview 05/09/2012), a phrase which is also found in the UK ceremony script. In Dresden, the Saxon Foreigner Commissioner explained that the citizenship ceremonies he organised should be like a “family party” or “wedding”, and should be “meaningful” and “funny” events celebrating the fact that naturalised citizens are now “part of the family” (DrPol1, conversation 18/06/2012). One of the “narratives” in the “repertoire” of the Head of the Dresden Naturalisation Unit was that of a “couple”, comparing the act of naturalisation to a “couple freshly in love” who initially live in “concubinage” (wilde Ehe) until they get married (DrAdmin1, interview 14/05/2013). The act of naturalisation was thus likened to the act of marriage, and the citizenship applicant was seen as entering a quasi-­ romantic relationship with the state.

Emotional Work One logical consequence of this rationality of encouraging an emotional attachment is that in the administration of naturalisation, registrars and caseworkers are required to perform emotional work when presenting certificates. Indeed, the senior administrator in Dresden referred to the activity of handing over the certificate as “making [citizenship applicants] happy” (beglücken) (DrAdmin1, interview 14/05/2013). While this was perhaps said with some irony, he stressed that he asks every applicant to sign and speak the declaration individually, one by one, so that “they take something home” (ibid.). For this administrator, the way he officiated the declaration was also a final means to check if the successful applicants were rightly receiving German membership: So, if you want to make a declaration, you have to be somehow affected (betroffen) or actually believe in that which you declare. And I try to make that clear. I cannot make people believe in it but I can try to awaken what is in them already. So, when it comes to speaking the declaration some

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people get really nervous asking ‘Do I do this the right way, where do I need to put my hand?’ [he placed his hand on his heart and raised it for a vow, imitating citizenship applicants] And when they receive the certificate, they often break out in tears. Then I know for sure, these people now really belong to us. (DrAdmin1, interview 14/05/2013, original emphasis)

While signs of nervousness and tears might also indicate a general relief after a lengthy, difficult application procedure, this civil servant interpreted these signs as indicating that the newly naturalised citizens “know that they really belong” and that they remain “alert” citizens even outside election times; he then felt that “I have accomplished my task” (ibid.). This emotional aspect of his work is a part which he actually enjoyed, because if he were no longer allowed to present the certificates in the way he does it, then his job would be “no longer fun at all” (ibid.). This concern about how meaningful and lasting the oath before the certificate’s presentation really is was also expressed in the UK context. The Brent Head Registrar wondered how effective ceremonies are in the long run, and also drew on the same metaphor of a married couple, but one in which one partner was “having an affair”: How much more British do you feel? […] What’s more important, what’s the lasting effect of it? It’s a bit like you go to a wedding and the couple get married, I’m sure at that particular time they are all loved up and you know, the vows they make to each other are all very meaningful. Three years down the line, one of them might be having an affair, you know, you tend to forget those things that you said three years ago. Wouldn’t it be nice if we could do some sort of reaffirmation of those things that you were very proud of at the citizenship ceremony? Couldn’t we try and re-establish those in some ways? So, we keep contact, we effectively do the ceremony and then we say: ‘Welcome to Brent, really lovely to see you, fantastic group hug—on you [go], bye, never see you again.’ I think that’s a real shame, more frequent engagement would be good. […] send out cards on their first anniversary, something small, relatively cheap but something that might spur a little bit of a re-awakening of ‘Oh, that’s really nice!’ Something that I might pursue. (BrAdmin4, interview1 20/09/2012)

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More than eight years after the first British citizenship ceremony was held in Brent, the Head Registrar wondered: “Are we losing that welcome?” (BrAdmin4, interview1 20/09/2012). In order to address this concern, he developed new formats for the ceremony, for example, occasionally hosting the ceremony at new locations such as the Wembley stadium or a local school, and he also wrote a guide to “good practice” for local authorities in the UK.

Apolitical, Too Political, Right or Left? The question of whether citizenship ceremonies are political or not was debated by participants in the UK. On the one hand, it was made clear by some participants that the ceremonies are anything but political. For example, the Head Registrar in Brent wanted to hold a ceremony in a local shopping centre and imagined the sound of the whole atrium of Brent Cross being filled with people singing the national anthem (BrAdmin4 after BrPres5, observation 20/09/2012). This idea was, however, not realised, as: The management got cold feet and dropped out. They thought it’s political. But the citizenship ceremony is apolitical, it’s not a party event, it’s to welcome new citizens to the UK. (Ibid., original emphasis)

On the other hand, the citizenship ceremonies officer in Lancashire talked about the difficulties of introducing the ceremonies in Burnley because the national symbols involved, such as the UK flag and anthem, were considered “too political” (BuAdmin1, interview 27/02/2013). In the context of Burnley, carrying the British flag was associated at the time with the far right British National Party hence its display at citizenship ceremonies was not an easy decision: When I started, the Union Flag was seen as a symbol of the British National Party. It wasn’t perceived as a particular friendly symbol in East Lancashire, they got an MP, had a few councillors and a lot of anti-Muslim feelings in East Lancs. (BuAdmin1, interview 27/02/2013)

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This changed later with the more positive associations fostered by the London Olympics and the Queen’s Diamond Jubilee in 2012, the officer reported. After these events, she felt more confident that she could “put [the] Union Jack on paperwork, brochure and everything”, as she perceived that it had become more acceptable to use British symbols more frequently (ibid.). This official was aware of the particularly negative reputation East Lancashire had within Lancashire, so moving the citizenship ceremonies to Burnley was a symbolic move by the Lancashire County Council: “Some counties only do it in one place but we felt we need[ed] to move to East Lancashire also to be seen to be happy to come to East Lancashire.” (ibid.) The Home Office Citizenship Ceremony Liaison Group whose meetings this officer attended approved this move, agreeing that with the citizenship ceremonies: “We’re trying to reclaim the union flag and make it a more positive symbol, against fascism.” (ibid.) Whether singing the national anthem was seen as apolitical or the national flag considered too political, the UK ceremonies have been criticised by both the political left and right, as the Brent Head Registrar recalled the criticisms the first citizenship ceremony received as an “unduly patriotic” event which “make[s] people artificially pledge their allegiance to the country and the Queen”, while “others were like, we should be doing more of that, they should work even harder to get British citizenship” (BrAdmin4, interview1 20/09/2012). The public perception was different in Germany where citizenship ceremonies were supported by both the right and the left, a cross-party consensus transcending political boundaries without meeting significant opposition (HaPol1, interview 13/08/2013; HaAdmin1, interview2 17/07/2013). To summarise, this rationality conceptualises naturalisation as creating an emotional attachment that the citizenship applicant ought to develop towards the state. This rationality has been used to justify the introduction of citizenship ceremonies. It has attempted to induce citizenship applicants to identify themselves with the local town or region as well as the national state. Attempts were made to present the state not as “scary” but instead as having a human face, and metaphors were even employed which compared the state to a family or the intimate partner of the citizenship applicant. This humanisation of the state is achieved through civil servants who are effectively required to perform emotional work

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while also having to justify their work as political (or not). The fourth identified rationality turns to economic reasoning, and is now discussed in the next section.

3.4 Naturalisation as a Commercial Commodity The final rationality conceptualises citizenship as a commodity that can be purchased. In this perspective, naturalisation becomes a business for the state as well as for citizenship applicants, who are accordingly regarded as customers. This rationality was more prevalent in the two British sites than in the two German locations.

Customer Service The UK Home Office regards naturalisation as a service provision. This rationality was only adopted under the New Labour government (1997–2010). As stated in the 2002 white paper “Secure Borders, Safe Haven” (Home Office 2002, 31), the Home Office committed itself to “speeding up the process” with the aim of reducing the processing time for naturalisation applications from twenty months in 1999 to three months in 2004. Ten years afterwards, in an interview for this research, the former British Home Secretary Blunkett criticised the “engrained inefficiency” of what was then known as the Nationality and Immigration Directorate (at the time of the fieldwork its name was the UK Border Agency, UKBA, and since then it has been re-named again to UK Visas and Immigration) (UKPol1, interview 05/09/2012). The former Home Secretary aimed to professionalise the Home Office and make its work more effective by turning visa and naturalisation applications into a service provided for a fee: My imperative was, if you are charging people, if you are asking them to find a lot of money, you have to increase the efficiency and the delivery of what is a service. And that previously hadn’t been seen in that light. (UKPol1, interview 05/09/2012)

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He admitted that “we massively increased the fees (laughs), we charged people in a way that hadn’t been undertaken previously”, and that this was “part of the challenge” for the Home Office to become more efficient (ibid.). The Home Office official made a similar argument when he emphasised the following information to local registrars learning to do the Nationality Checking Service: “Remember that an application costs 851 pounds, if it is refused you only get 80 quid back, so it’s a lot of money, so make sure you get it right.” (UKAdmin1, observation 17/01/2013) At the time of the fieldwork, the fee for naturalisation in the UK was 851 GBP, this has increased to 1330 GBP in 2022 (see below). By increasing the application fee, the Home Office imposed on its staff the moral duty to perform fast and thorough casework. However, the effectiveness of this internal policy measure remains questionable (see Chap. 7 on recent problems of the Home Office). By contrast, the application fee for naturalisation in Germany is set by law to 255 Euro (StAG s 38 [2]). Indeed, the rationality of naturalisation as a commercial commodity is incompatible with the rationality of award and attachment, as the Head of the Dresden Naturalisation Unit argued when explaining the financial aspect of naturalisation from the authorities’ perspective: All our work is, of course, funded through tax payments. The applicants do not pay the market value for naturalisation, it’s simply a fee. Just like when you get a parking ticket, 15 Euro is not the market value for parking in the wrong spot, but merely a fee. So, for naturalisation, you pay a fee of 255 Euro regardless of whether you grant the application or whether it keeps you busy for several years. So, [naturalisation] is not a payment and service in return (Leistung und Gegenleistung), but it is […] a sovereign act (hoheitlicher Akt). (DrAdmin1, interview 14/05/2014)

With these words, the Dresden official maintains the rationality of award following which naturalisation is an “act of sovereignty” that does not have a “market value”. Accordingly, the naturalisation fee is only charged at the point when the authorities issue a notification (Bescheid), once the application is reviewed. If the application is approved, the normal fee of 255 Euro is charged, while if the application is rejected, a

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reduced fee of 195 Euro is charged (DrLA6, first conversation 28/03/2013). The UK Home Office, by contrast, regards any application that is not accompanied by the correct fee as “invalid” (cf. Fransman 2011, 697). This difference again demonstrates the different approaches to naturalisation in the UK and Germany according to which naturalisation is a customer service that is not even reviewed before the fee is paid (in the UK) as opposed to one where naturalisation is a sovereign act of the state, beyond the logic of market capitalism (in Germany). Despite these structural differences between Britain and Germany, the discourse of service provision was found in all four locations. One consequence of the conceptualisation of naturalisation as a service provision is that applicants are seen as customers, and indeed, administrators in all four sites used the word “customer” or “client” to refer to their citizenship applicants. The conceptualisation of citizenship applicants as customers also emerged in other discursive instances, for example when an administrator explained that their department regularly seeks and assesses “customer satisfaction feedback” to improve the service experience (BuAdmin1, interview 27/02/2013).

 ource of Profit: “Citizenship Pays for All the Other S Applications.” By increasing the UK naturalisation application fee, the Home Office not only attempted to self-discipline caseworkers and make them more efficient; it also had an increased source of income at its disposal. The financial transactions processed daily are “in the millions”, I was told when visiting the Nationality Group in Liverpool (observation 15/11/2012). When I asked about the rise of the fee, the officials said that the fee increases were justified to them based on business reasons. They explained that within the UKBA, the Nationality Group raises such significant income that it can effectively fund the other departments, as well as new border control technologies. This was confirmed by a senior official, who explained that since the government cannot charge for asylum applications as these are human rights cases: “Citizenship pays for all the other applications.” (UKAdmin1, conversation 15/11/2012) While most fees

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for UK immigration applications have increased over the past decade, the rise of the naturalisation fee is an extraordinary example of this trend. To give an idea of the scale of the phenomenon, a brief overview of the development of the fee for British naturalisation is helpful. Prior to 1951, the fee for naturalisation was 1 GBP, which had subsequently risen to 150 GBP by 1980 (British Government 2013). In 2004 naturalisation cost 218 GBP, including the new citizenship ceremony charge of 68 GBP (Fransman 2011, 698). Since the enactment of the 2004 Asylum and Immigration (Treatment of Claimants, etc.) Act, the Secretary of State may legally charge fees which are higher than necessary to cover the administrative costs arising (ibid., 698–699). Since then, the naturalisation fee has increased exponentially from 218 GBP in 2004 to 1330 GBP in 2022 over the course of eighteen years, the rate rises usually coinciding with the start of a new tax year in April (for details see Fransman 2011, 697–706), while the actual cost for processing an application is only 372 GBP (Yeo 2018). The Immigration and Nationality (Fees) Order of 2016 further increased the maximum amount that can be charged for naturalisation to 1600 GBP (1500 GBP for the application plus 100 GBP citizenship ceremony fee). Clearly, naturalisation has become an important and steady source of income for the Home Office. To be sure, naturalisation is not the most expensive immigration application in UK; for example, the fee for a permanent residence permit (Indefinite Leave to Remain, ILR) is 2404 GBP in 2022. Migrants in the UK will generally have paid several thousand pounds to the Home Office for their entry and settlement permits prior to naturalisation. Indeed, immigration application fees in the UK are set higher than the actual administrative costs arising which has been most criticised in cases of child registration (Yeo 2022). In this regard, the UK illustrates a transnational development of states seeking profit through investor visa or investor citizenship programmes which has been systematically analysed by Džankić (2019). Through such schemes, states offer residence or citizenship rights to wealthy foreigners in return for hefty financial transactions or investments, often reducing or waiving other requirements such as residence length or language skills, while simultaneously raising income barriers for other migrants (cf. Shachar 2021). In Europe, the European Commission recently launched infringement proceedings against Cyprus

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and Malta for selling EU citizenship (Iser 2020). Germany offers an investor residence scheme although the monetary amount required is not specified (Džankić 2019, 200) and the scale of the phenomenon is unclear. The United Kingdom introduced a tier 1 investor visa in 2008 which granted residence rights to individuals and their families who held two million GBP investment and a UK bank account. After it emerged that over 6000 of those “golden visa” (half of all those issued since 2008) were reviewed for “possible national security risks”, then Home Secretary Priti Patel abandoned this scheme on 17 February 2022 in the wake of the Russian invasion of Ukraine (Allegretti 2022), effectively closing this potential gateway to naturalisation in the UK for the meantime. Local Authorities benefit from the business of naturalisation, too, albeit on a smaller scale than the Home Office, through the fees they charge for citizenship ceremonies and for the Nationality Checking Service. As outlined above, the local authority claims 80 GBP from the Home Office for each applicant who has participated in a ceremony, once the ceremony is completed. The Brent Head Registrar mentioned the difficulty in determining the correct fee for the ceremony: “we had to make a guess […] ended up in 2004 at 68 quid” (BrAdmin4, interview1 20/09/2012). This is the price for a collective ceremony, while the fee for an individual ceremony may be set higher: “This is where you make the real money”, as private ceremonies were commented upon at the registrars’ training workshop (observation 17/01/2013). This means that individual ceremonies appear more attractive from a financial perspective; however, following the rationality of creating an emotional attachment, collective ceremonies are preferred by the ceremony organisers (BuAdmin1, interview 27/02/2013). The introduction of the Nationality Checking Service (NCS) to facilitate and speed up naturalisation applications was indirectly linked to the Home Office’s wish to combat “sham marriages”. The Brent Head Registrar claimed that the NCS was “my idea, nothing totally altruistic”, and further explained how the NCS came about (BrAdmin4, interview1 20/09/2012): through the citizenship ceremonies, local authorities hand over the naturalisation certificates and have thus become “trusted partners” of the Home Office. Representing the local authorities, the Brent Head Registrar was a member of the Citizenship Ceremonies Liaison

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Group and through this forum had regular contact with the Home Office. Through these meetings, he learned that the Home Office was experiencing backlogs which were mainly caused by incomplete applications, so caseworkers spent time with applicants on the phone to complete their applications rather than taking decisions. At the same time, the Local Authorities’ registration services experienced fewer marriage ceremonies, especially in areas of high ethnic diversity such as Brent: When [the] government introduced legislation to combat sham marriage in 2005, I knew that that would mean we would lose business on marriage. And don’t forget, although it’s not business you want, I estimated we would lose in marriage business about 60,000 pounds. That means two members of staff going down the road. So we [had] just recruited three [members of a] citizenship team and would lose two marriage team [members]. So I was desperately thinking how we could recoup that income. (BrAdmin4, interview1 20/09/2012)

Because of this situation, the Head of Brent Registration and Nationality Services made the Home Office an offer: “Why don’t we see your customers and send you an application all ready for a decision?” (ibid.) This led to the creation of the Nationality Checking Services (NCS) and turned out to be a “success all round”, as the Home Office is twice as effective and Brent and Barnet registration and nationality services make an annual income of “over a quarter of a million pounds” from NCS (ibid.). To summarise, the Nationality Checking Service was introduced, among other reasons, to compensate for an income stream that “sham marriages” had previously been producing. In recognition of his efforts in introducing the NCS, the Head of Brent Registration and Nationality Services (RNS) was awarded an Order of the British Empire by the Queen (ibid.). The Nationality Checking Service has created a new market that puts Local Authorities’ registration services in direct competition with each other. Usually, the service is used by local residents. However, Brent sometimes receives applicants from other London Boroughs or from places as far away as Brighton or Wales because the waiting list in Brent is not very long, they can sometimes offer a quicker appointment than the neighbouring local authority (BrAdmin5, interview 20/09/2012).

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Or, if a local authority does not offer this service, the next nearest one benefits from the situation, as the Burnley citizenship officer jokingly said about Blackburn: “We do poach from them” (BuAdmin1, interview 27/02/2013).

3.5 Comparison and Conclusion This chapter has discussed the rationalities underpinning the respective current naturalisation procedures in the UK and Germany, and that contribute to create the Super Citizen subjectivity. Rationalities in this research are defined as “concepts” (Rose 1999, xi) and ways of thinking about citizenship by application, which are used to justify the design and features of subject-formation regimes such as naturalisation. Based on the analysis of official documents and the discourses of politicians and senior officials in the interviews and observations carried out for the research, this chapter has identified four main conceptualisations that are mobilised to render citizenship admission plausible: naturalisation as a discretionary award; as a legal entitlement; as an emotional attachment; and as a commodity. These rationalities were found across the four research locations, albeit with varying emphases and significant nuances. The rationality of award was more prevalent in the UK documents, but was also found in some of the German interviews, while the idea of citizenship as a legal entitlement was almost exclusively expressed in the German data. The UK regulations placed the sole responsibility upon the citizenship applicants to prove their worthiness of naturalisation. The citizenship grant ultimately depends on the UK Home Secretary whose decision cannot be appealed. This structural set-up places the migrant in the subordinate position of a petitioner to the state. This perpetuates the feudal origin of subjecthood status in the UK, as discussed in Chap. 1. It is perhaps unsurprising that the rationality of award is more entrenched in the UK, which is still a constitutional monarchy, than in Germany, which has experienced significant state transformations in the past. In the German case, the rationality of award was found only among Conservative politicians or in CDU-governed states such as Saxony. In Dresden, the head caseworker wished that naturalisation was codified

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only as an award, rather than as an entitlement. By defining naturalisation as a “sovereign act”, and by using the narrative of the “knave to knight”, he implicitly imagined himself as a kind of King, able to bestow or withhold citizenship. Following this narrative, citizenship grants through entitlement (StAG s 10) are a “mistake” because this legal provision reduces the caseworker’s discretionary power to assess the candidate’s worthiness. Adopting a similar discourse, the Hamburg conservative politician argued that citizenship is not an “entry ticket” but, rather, an “award for past integration efforts”. However, this interpretation of the rationality of award obliged both the migrant and the host society to make an “integration effort”. This theme, that the state or those who are in power also have a responsibility vis-à-vis those who are ruled, was largely absent in the UK. While the former UK Home Secretary David Blunkett acknowledged the “positive contribution” migrants make, the idea that the democratic state has a responsibility to offer political membership to long-term migrants was only expressed in Germany. The rationality of award shifts the responsibility to integrate and naturalise onto migrants while the rationality of entitlement takes the liberal-democratic state up on its promise to offer full inclusion and membership to long-­ term settled migrants. The rationality of entitlement was most emphasised in Hamburg. Interestingly, the idea of mutual obligation—that if migrants make a commitment to the host society then the state should also be committed to them and facilitate their inclusion—was expressed by both the social-­ democratic and the Christian-conservative Hamburg politicians interviewed for this research. This finding questions the traditional significance attributed to party affiliation, according to which conservatives tend to think of naturalisation as an award, while liberals regard naturalisation as entitlement (cf. van Oers 2014). When examined more closely, the two Hamburg politicians desired migrants to maintain the city state’s self-­ imagination as a hub of superdiversity, while also embracing and utilising the “hope” and productive “forces” that migrants supposedly bring. A political economic logic was thus underlying this rationality of entitlement. By contrast, the UK Home Office made clear that naturalisation is not an entitlement.

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The rationality of commodity represented the most significant difference between the UK and Germany. While citizenship applicants were referred to as “customers” across the four research locations, the idea of citizenship as a “good” for purchase, and hence a source of income for both local and central authorities, has clearly been more prevalent in the UK. The neoliberal commodification of the passport is a recent and wider trend which has been observed across Western societies (Shachar 2017), but in the case of naturalisation it appears to be more advanced in the UK than in Germany. While the fee for British naturalisation had risen from 1 GBP before 1951 to 150 GBP in 1980, it was the New Labour government under Tony Blair which redefined naturalisation as a chargeable “service provision” beyond cost recovery in 2004. In an attempt to modernise the nationality and immigration administration, the then UK Home Secretary David Blunkett increased the fees to resolve the “engrained inefficiency” of the nationality group and to reduce the application backlog and lengthy processing times (which stood at twenty months in 1999), simultaneously increasing the pressure on caseworkers to “make sure you get it right”. In contrast, while the SPD/Green coalition government led by Gerhard Schröder (SPD) in Germany at the same time also adopted neoliberal reforms (Fördern und Fordern) in the policy areas of welfare (the so-called Agenda 2010) and, to a lesser extent, immigration (see, e.g., the discussion of integration courses in Chap. 5), naturalisation in Germany remains funded by the national and non-national taxpayers. The German naturalisation fee is set by law and does not cover the administrative costs involved; the naturalisation officers are instead funded by the local authorities. This is also part of the explanation for the discrepancy in naturalisation practices and staff numbers across different local authorities in Germany (Thränhardt 2017). As the funding of naturalisation administration depends on the local authorities’ wealth and political commitment, some local authorities such as Dresden invest less in the naturalisation administration than others, for example, Hamburg. The rationality of emotional attachment conceptualises naturalisation as a reciprocal gift exchange: if the state shows its appreciation of migrants, then it can expect those migrants’ loyalty and devotion in return. While

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in the UK, the former Home Secretary and local officials in Brent and Burnley tried to make the state look less “indifferent” and “scary” to potential citizenship applicants, the former Hamburg integration senator (CDU) went further by suggesting that through naturalisation, migrants ideally “take possession” of the state. Across the four research locations, politicians and officials variously referred to the act of naturalisation as a “group hug”, “family party”, “marriage”, or “love affair” between the state and its (carefully selected) migrant population. These references romanticise, informalize, and de-politicise naturalisation, echoing Sayad’s (2004) conceptualisation of naturalisation as a form of “gentle violence” and symbolic power. The four rationalities discussed in this chapter are highly ambivalent and contradictory. The rationality of award conceptualises the citizenship applicant as a petitioner with limited agency and restricts access to citizenship, the grant of which is considered to be a privilege or exception, not the rule. The rationality of entitlement, on the other hand, expands access to citizenship and conceptualises citizenship applicants as agents and rights holders. Similarly, the rationalities of emotional attachment and commodity are in tension with each other since the former regards citizenship applicants as the highest state guests, friends, or even lovers, whose affection is to be gained and maintained; in contrast, the latter reduces citizenship applicants to customers paying for a service provision. These contradictions do not undermine the four rationalities; on the contrary, they are highly productive and powerful because they legitimise other features, such as techniques of subject-formation. For example, the rationality of award was used to justify early forms of local citizenship tests in Saxony, while the idea of entitlement and empowerment led to the commission of the “naturalisation guides” and the letter campaign in Hamburg. The conceptualisation of naturalisation as an emotional tie was pivotal to the introduction and justification of citizenship ceremonies in both Britain and Germany, while citizenship as a customer service provision has been the justification for the increases to fees seen in the UK.

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References Allegretti, Aubrey. 2022. UK Axes “Golden Visa” Scheme After Fraud and Russia Concerns. The Guardian, 17 February. https://www.theguardian.com/ uk-­news/2022/feb/17/uk-­ministers-­plan-­to-­scrap-­golden-­visa-­scheme-­amid-­ russia-­concerns. Accessed 13 March 2023. British Government. 2013. British Nationality Regulations 1948–1982: Summary for Caseworkers. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/267909/britnatregulations.pdf. Accessed 18 May 2017, Archived 27 July 2017. Clayton, Gina, Caroline Sawyer, Rowena Moffatt, Georgina Firth, and Helena Wray. 2016. Textbook on Immigration and Asylum Law. 7th ed. Oxford: Oxford University Press. Džankić, Jelena. 2019. The Global Market for Investor Citizenship. Cham: Palgrave Macmillan. Fransman, Laurie. 2011. British Nationality Law. 3rd ed. London: Butterworths. Home Office. 2002. Secure Borders, Safe Haven: Integration with Diversity in Modern Britain. Norwich: The Stationary Office. ———. 2015. Guide AN: Naturalisation as a British Citizen—A Guide for Applicants. To Be Read in Conjunction with Booklet AN (October 2015). https://www.gov.uk/government/publications/form-­an-­guidance. Accessed 6 March 2017. ———. 2022. Guide AN. Naturalisation Booklet. The Requirements and The Process. GOV.UK, 28 June. https://www.gov.uk/government/publications/ form-­an-­guidance. Accessed 13 March 2023. Iser, Jurik Caspar. 2020. “Goldene Pässe”: EU leitet Verfahren gegen Zypern und Malta ein. Die Zeit, 20 October. https://www.zeit.de/politik/ ausland/2020-­10/goldene-­paesse-­zypern-­malta-­eu-­kommission-­verfahren-­ staatsbuergerschaft. Accessed 13 March 2023. Lemke, Thomas. 2002. Foucault, Governmentality, and Critique. Rethinking Marxism 14 (3): 49–64. Rose, Nikolas. 1999. Governing the Soul: The Shaping of the Private Self. London: Free Association Books. Sayad, Abdelmalek. 2004. The Suffering of the Immigrant. Cambridge: Polity. Shachar, Ayelet. 2017. Citizenship for Sale? In The Oxford Handbook of Citizenship, edited by Ayelet Shachar, Rainer Bauböck, Irene Bloemraad, and Maarten Vink, 789–816. Oxford: Oxford University Press.

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———. 2021. Unequal Access: Wealth as Barrier and Accelerator to Citizenship. Citizenship Studies 25 (4): 543–563. Thränhardt, Dietrich. 2017. Einbürgerung im Einwanderungsland Deutschland. Analysen und Empfehlungen. Friedrich Ebert Stiftung, November 2017. http://library.fes.de/pdf-­files/wiso/13590-­20170821.pdf. Accessed 13 March 2023. van Oers, Ricky. 2014. Deserving Citizenship: Citizenship Tests in Germany, the Netherlands and the United Kingdom. Leiden: Martinus Nijhoff. Yeo, Colin. 2018. Briefing: What Are the Barriers to British Citizenship for EU Nationals? Free Movement (blog), 14 June. https://freemovement.org.uk/ briefing-­w hat-­a re-­t he-­b arriers-­t o-­b ritish-­c itizenship-­f or-­e u-­n ationals/. Accessed 13 March 2023. ———. 2022. Immigration and Nationality Fees for 2022/23. Free Movement (blog), 7 April. https://freemovement.org.uk/immigration-­nationality-­ application-­fees-­2022-­23/. Accessed 13 March 2023.

4 Authorities in Naturalisation Procedures: Structurally Prescribed and Self-Perceived Roles of State Actors

This chapter explores the role of the various authorities which enact naturalisation procedures in the UK and in Germany and is based on an analysis of official documents, observations, and interviews. Authorities are defined here as “persons” who are “accorded or claim” a position of power vis-à-vis persons “who are subject to them” (Rose 1998, 26). The role of these authorities as “experts” and “stage directors of subject-­ formation” is crucial in implementing and shaping processes of subject-­ formation (Bröckling 2007, 133). However, authorities not only govern, but are also always “themselves governed” (Rose 1998, 26). Accordingly, this chapter aims to answer two questions: First, in the current British and German naturalisation procedures, who holds which formal competences, and how are these authorities themselves regulated—in other words, under which prescribed guidelines and working conditions do they operate? Secondly, how do these authorities perceive their own role, and what sort of relationship does this create between the authorities who implement naturalisation and the citizenship applicants who are subject to naturalisation? Proceeding along the main stages of the application procedure, the chapter argues that there are four main groups of authorities of © The Author(s), under exclusive license to Springer Nature Switzerland AG 2023 E. Badenhoop, Calling for the Super Citizen, Palgrave Politics of Identity and Citizenship Series, https://doi.org/10.1007/978-3-031-34260-8_4

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subject-formation, all of which contribute to suggesting the Super Citizen subjectivity, albeit to varying degrees and effects. First, legal advisers have a crucial role in accessing and translating the information about making an application even though they have no formal role in the naturalisation process and, according to the UK Home Office and some lawyers, should not even be involved. Second, while teachers of English or German as a foreign language have already in the past deployed elements of citizenship education in their everyday work, the new expectation in the British citizenship materials and German integration course curricula that they should educate “good” and “democratic” citizens produces tensions and ambivalent reactions. Third, registrars and caseworkers are the authorities with the most important formal power as they receive and assess the application and present the certificate. They appreciate the emotional reward of their task to make new citizens but also struggle with striking the right balance in the new ritual of citizenship ceremonies. This group of authorities also has significant discursive power as their encouragement or indeed discouragement of migrants to think of themselves as worthy of citizenship may persuade or deter migrants from submitting their naturalisation applications (see also Chaps. 2 and 6). Fourth, honorary guest speakers at citizenship ceremonies intervene at the latest stage in the naturalisation process, after the application has already been successfully granted, yet they exercise this role in very different ways, either welcoming or disciplining successful candidates. While this group of authorities has no legal power in the naturalisation process and is indeed the least regulated authority, ceremony speakers assume a key role in the subject-formation regime as they most explicitly spell out the Super Citizen subjectivity when addressing the successful candidates. The international comparative analysis shows that the British and German authorities often have similar self-understandings even though they operate under very different structural conditions. The British system is centralised, less regulated, and less funded compared to the decentralised, more regulated, and better funded German case. Moreover, the combined analysis of document and interview data reveals significant discrepancies between the structurally assigned and the self-assumed roles of some of these authorities. For example, guest speakers at citizenship ceremonies are assigned a purely symbolic role to welcome new citizens,

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and yet some of them assume the role of informally testing citizenship applicants’ language skills or reminding them of their “duties” even though their naturalisation grants have already been decided. This suggests that the least regulated and least powerful authorities in naturalisation procedures may voice the most explicit call for the Super Citizen.

4.1 Accessing Information and Forms: The Role of Legal Advisers Structural Conditions: Regulation and Funding The legal advisers interviewed for this research all found themselves in a mediating position between state authorities and citizenship applicants, but the nature of the governmental support for their work varied. At the time of the research, the British case was characterised by a withdrawal of funding and service while the German case was characterised by a provision of additional funding and service. In England and Wales, “Legal Aid” has provided state funded legal support for persons who cannot afford it since 1949. It became available for immigration issues in 1998 but was subsequently curtailed in the following years (Singh and Webber 2010). Naturalisation, for example, was taken off the list of funded services. At the time of the fieldwork, lawyers working in publicly-funded Law Centres or other non-profit advice agencies were only allowed to assist with naturalisation cases where the application had been rejected and legal advisers could assist in applying for judicial review (BrLA5, BrLA7). In April 2013, this competence was further withdrawn from the services covered under Legal Aid, alongside all other immigration related issues (except detention and asylum) (Howard 2014). Simultaneously, the Home Office appointed a new authority, the Office of the Immigration Services Commissioner (OISC), to standardise and professionalise the immigration legal advice industry, which regulated (by sanction) the level of advice which immigration advisers are allowed to provide (Office of the Immigration Services Commissioner 2012). For example, legal advisers certified at OISC level 1 may provide

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basic advice on naturalisation (ibid., 14), while those certified at OISC level 2 are permitted to negotiate exemptions, but are explicitly not permitted to assist in judicial review (ibid., 17–18), a role reserved for those at level 3. Thus, the current situation in the UK is that in effect, no qualified, publicly funded naturalisation advice is available (except where an individual lawyer works pro bono). This corresponds to the rationality of naturalisation as a discretionary privilege that the Home Office adheres to. The German case, by contrast, exemplifies the rationality of entitlement as the federal government has provided publicly funded “migration advice for adult immigrants” (Migrationsberatung für erwachsene Zuwanderer, MBE) since the coming into force of the Immigration Act on 1 January 2005 (ZuwandG s 45) (Bundesministerium des Innern 2010, 261). This basic social and legal support is delivered by local and national non-profit welfare organisations such as the Workers’ Welfare Association (Arbeiterwohlfahrt, AWO), Christian associations (e.g. the Catholic Caritas), and the Federation of German Expellees (Bund der Vertriebenen, BdV). These advisers are commissioned, regulated, and funded by the Federal Ministry of the Interior, which specifies in its funding guidelines that: The migration support shall purposefully initiate, guide and accompany immigrants’ integration process […] empower immigrants to act independently in all areas of everyday life. This shall also contribute to reduce immigrants’ dependence on social benefits to a necessary minimum. Immigrants shall […] be won over for a continuous, active cooperation in the integration process. (Bundesministerium des Innern 2010, 261)

The above statement demonstrates the neoliberal aspect of the rationality of entitlement: that migrants should be “empowered” to help themselves and not be a burden on the welfare state. The migration advice thus also relies on the problematised figure of the dependent citizenship applicant, as analysed in Chap. 2. In addition to these state-funded migration advice centres, naturalisation support is also provided by self-organised local migrant support groups as well as by special Commissioners appointed by local and regional state governments. These Commissioners have a political role in

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that they mediate between migrant residents and the state administration. For example, the Dresden “Integration and Foreigner Commissioner” and the Saxon “Foreigner Commissioner” hold the right to request information and file inspection directly from the Saxon Ministry of the Interior and from the foreigner authorities (SächsAuslBeauftrG s3 (1)) and may thus “control” the naturalisation authorities (Stadt Dresden n.d.). In Hamburg, citizenship applicants may turn to the government commissioned volunteer guides. The German case is thus characterised by the availability of a variety of support including state funded advice, whereas the British case has seen a withdrawal of funding and competences. These structural differences have affected the relationship between legal advisers and citizenship applicants, from having no relationship at all to acting as translators or even brokers, as the following section explores.

Relationship with Citizenship Applicants Some of the legal advisers interviewed had no relationship with citizenship applicants because they had to refer or reject them due to structural constraints. The withdrawal of Legal Aid funding for UK naturalisation had a direct impact on legal advisers’ everyday work in the British non-­ profit sector. In Brent, two of the seven legal advisers interviewed for this research faced redundancy due to cuts to Legal Aid and other funding (BrLA2 conversation1 10/10/2012; BrLA5 conversation 31/10/2012). Those whose posts were still Legal Aid funded at the time of the research, and who therefore were not allowed to advise on naturalisation, expressed different responses to these constraints. One adviser was attempting to continue to provide basic support by referring naturalisation requests to volunteers whom she supervised (BrLA5 conversation 31/10/2012). However, this advice by proxy was limited to general support such as obtaining and filling out forms. More specific and further requests concerning eligibility had to be forwarded to private lawyers (ibid.). Another legal adviser was instructed by her supervisor to “stay away from naturalisation”, as they would not be able to claim funding for this work (BrLA1, conversation 24/09/2012). While most of the legal advisers interviewed

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for this research agreed that certain applicants do require assistance, this adviser adopted the rationality of privilege and the problematisation of the dependent: [Naturalisation] is a mere exercise of form-filling and quite rightly so. People applying for citizenship should have the language capacities to apply on their own. If they cannot fill out the form by themselves then, really, they should not become citizens. There is no legal issue with naturalisation, no case to be made about it, no appeal to be made. (BrLA1, conversation 24/09/2012)

In Dresden, legal advisers’ work was also severely constrained by the state; however, this was not because of strict funding regulations but, rather, was due to a lack of knowledge: “The Saxon Minister of the Interior has been refusing to publish the administrative regulations on naturalisation for years. Consequently, this makes giving advice impossible because of the risk of possibly providing false information” (DrLA1, conversation 18/06/2012). As a result, legal advisers in non-profit centres merely assisted with obtaining and filling in the form and then signposted their clients towards private solicitors (e.g. DrLA3 conversation 19/03/2013). Despite these structural constraints, many legal advisers acted as translators because they helped migrants to access the application form and understand the requirements. Legal advisers in all research locations received queries by applicants seeking help in obtaining and completing the form and assessing their eligibility. In making legal information accessible, these legal advisers played the role of translators. In the UK, the Home Office only provides the application form for naturalisation online. This poses a problem for elderly and refugee applicants who may lack access to the internet or the skills to use it, as the legal advisers reported, so in order to assist, they download the form or create e-mail addresses on the applicant’s behalf (BrLA2, first conversation 10/10/2012, BrLA4 conversation 24/10/2012). Several advisers independently expressed the view that the Home Office homepage was difficult to navigate “even for caseworkers” (BrLA5, conversation 31/10/2012, cf. BrLA2, BuLA6). Moreover, the information provided by the state is exclusively written,

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which excludes illiterate applicants or those with limited knowledge of English, as an adviser reported in Burnley: “The biggest problem is a lack of English language skills but also literacy and numeracy; some clients cannot write their own name” (BuLA6, conversation 27/02/2013). In addition, the UK application form, guidelines, and regulations contain specific legal vocabulary which legal advisers found they had to translate into plain language. For example, a legal adviser in Brent reported a case where the application was refused because the applicant happened to be out of the country on day one of the qualifying period (BrLA2, first conversation 10/10/2012). The applicant was unaware that for the Home Office, “an application is ‘made’ when it is received” (1981 BNA s 50 (8)), so the Home Office starts counting the day they receive the application, not the day on which the applicant submitted the application by post. A more ambiguous term is the “good character” requirement. Barristers explicitly conceded that: “No one really knows what it means” (BrLA4, conversation 24/10/2012), and critically remarked that “the Home Office never had a clear policy on this” (BrLA8, conversation 29/11/2012). Several of the interviewed legal advisers independently expressed the suspicion that this ill-defined term gives too much discretion to the Home Office (BrLA3, conversation 18/10/2012; BrLA4, conversation 24/10/2012). Moreover, legal advisers in the UK found it challenging to translate what the legal nature of British naturalisation as a privilege means (BrLA2, first conversation 10/10/2012; BrLA3, conversation 18/10/2012). They noticed that some applicants struggled to comprehend that they do not hold the right to appeal the Home Office’s decision if it is negative; this was especially true for applicants who had been through the asylum procedure where there is a right to appeal (ibid.). However, understanding the discretionary nature of naturalisation in the UK is crucial, as a rejection bears significant material consequences, that is, the risk of losing the application fee. Some legal advisers also acted as brokers as they represented applicants vis-à-vis the naturalisation authorities or negotiated exemptions on their behalf. In Germany, advisers found it difficult to clarify the term “outstanding integration efforts” which, if demonstrated by an applicant, may reduce the required period of residence from eight to six years (DrPol2,

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interview 15/04/2013). In Dresden, this translation challenge was aggravated by the fact that the Saxon authorities refused to publish the administrative guidelines which contain a definition, resulting in significant negative impacts on individual applications. The Dresden Foreigner Commissioner acknowledged that she cannot provide legal advice; however, what she could offer to applicants was to arrange a personal appointment directly with the Head of the Naturalisation Department rather than with one of the lower-level caseworkers (DrAdmin2, conversation 27/05/2013). She could therefore act as a broker, as the support she provided was to assist applicants in reaching a higher level in the bureaucratic hierarchy and thus facilitate their access to the key administrator who reviews all decisions (ibid.). This service may, however, also be a disservice, as the independent legal advisers in Dresden agreed that the Head of the Naturalisation unit himself does not exactly facilitate naturalisation, as is discussed further below. In Hamburg, the volunteer guides assist in obtaining and completing the form, and they also accompany applicants at their individual appointments (HaLA1, first conversation 18/05/2012). The guides closely liaise with the caseworkers and can thereby act as gatekeepers for applicants. In both countries, advisers’ assistance was also called upon in negotiating exemptions, for example on medical grounds from the knowledge requirement (BrLA3, BrLA7). Advisers can then help to identify a specialist accepted by the UK Home Office as an expert rather than a General Practitioner, and to convey to the medical practitioner what the Home Office wanted to know, e.g., how concretely a candidate’s condition impacted on their ability to attend a course and test (ibid.). Advisers also assisted elderly or impaired applicants in filling in the form and submitting the application on their behalf (e.g. BrLA8, BuLA7, DrLA6). The issues reported by legal advisers in this sub-section demonstrate that accessing the application form and understanding the process requires literacy, language, and computer skills from potential candidates. In this respect, the experiences of citizenship applicants as described by legal advisers reflect the problematisation of the dependent which was discussed in Chap. 2. Accordingly, legal advisers’ relationships with the naturalisation state departments varied significantly and were not always unproblematic, as the next section discusses further.

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Relationship with State Departments As a result of the structural constraints, some legal advisers criticised the state authorities. In the UK, the government has been criticised for providing the wrong incentives, as a legal adviser who had previously worked on a Legal Aid funded post and now worked in a private charity summarised: Here I have more freedom, no pressure. I can just spend a couple of hours working on a file if I need to which is great, it’s great not to be an accountant. The Legal Aid system does not encourage you to actually engage with your client, you just open and close files, that’s the way the regime is set up, it encourages you to cherry pick your cases. […] So many firms now left legal aid and went private, so the ones left are inundated. […] Citizenship is not a priority, it’s financially not deemed a priority. (BrLA07, conversation 13/11/2012)

Moreover, the criticism was made that Legal Aid not only has negative impact on legal advisers’ everyday work but may also result in significant negative material consequences for the individual applicant, while at the same time generating profits for the Home Office. Legal advisers in the UK were thus aware of, and criticised, the rationality of citizenship as commodity: The money is with the UKBA and there is no way of getting it back. When they come [to this legal advice centre], they already lost the money. The few who come on time we have to send back. So, at the point when they needed the advice we can’t help them, and at the point where we can help them, the money is lost. It’s a huge problem. (BrLA05, conversation 31/10/2012)

In Burnley, a legal adviser said this situation has created a particular “fear” and engrained mistrust of the Home Office: “People here have fear of the UKBA. If they make a mistake, they lose money. They have no confidence to fill in forms. Some can’t read English or get confused” (BuLA6, conversation 27/02/2013).

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The Dresden authorities also had a particularly negative reputation of being “lazy” (DrLA6, conversation1 28/03/2013), “in their ivory tower” (weltfremd) (DrLA5, interview 25/03/2013) and “xenophobic” (DrLA4, interview 25/03/2013). Even the Dresden Foreigner Commissioner, whose job, and therefore role, is part of the City administration, conceded that the foreigner authorities sometimes “get the tone wrong” and suggested that caseworkers should receive training to develop a new “intercultural awareness” (DrPol2, interview 15/04/2013). The Saxon practice of withholding the detailed administrative regulations has been criticised as “unlawful” (nicht rechtens) because it renders the guidelines which govern the administration’s actions non-transparent (DrLA08, conversation 10/04/2013). One particularly active private lawyer has been requesting for years that the Saxon Interior Ministry published the complete guidelines but has only obtained extracts (DrLA6, conversation1 28/03/2013). He also critically remarked that the Head of the Dresden Naturalisation Unit ruled his department like a “king” by turning every certificate presentation into an “undignified” and unnecessary “examination”, as the decision has already been made at this point (ibid.). Moreover, this private lawyer reported his belief that certain caseworkers did not read the whole file and always rejected applications. On the other hand, legal advisers also cooperated with the naturalisation authorities. For example, a solicitor in Brent noticed a positive change and found that the Nationality Group within the UK Home Office was more approachable than the other departments processing applications for asylum and permanent residence: If I’m honest with you, they’ve been getting better. For immigration, ILR [Indefinite Leave to Remain] and asylum, the Home Office does not reply to letters for months and even years, they are not answering the phone or changing numbers every week. With nationality, we are actually able to call them and speak to the caseworkers directly. The system is quite bad in terms of the Life in the UK test and ESOL classes, but the actual people dealing with it are good. (BrLA04, conversation 24/10/2012)

In Hamburg, the volunteer guides have direct contact with the naturalisation authorities so they can call the caseworkers on their personal

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phone extension whenever an applicant experiences a problem or a delay (HaLA2/CA2, interview 01/07/2013). In Dresden, by contrast, it was critically remarked that the foreigner authorities are not easily approachable, as it is unclear who has which competences, appointments are allocated only through an online system, and waiting times are long (DrLA10/ CA3, interview 15/04/2013). The by far closest and most positive relationship between advisers and naturalisation departments across the four research locations was found in Hamburg, where volunteers and caseworkers regularly met and exchanged information and experiences at informal monthly pub gatherings (Stammtisch) organised by the Turkish Community, which I was also invited to attend (observation 30/05/2012). Furthermore, regular information and training workshops for the volunteer guides have been personally run by senior caseworkers from the naturalisation authorities since 2013 (HaLA2/CA2, interview 01/07/2013). The guides and caseworkers participated together in a short promotional film1 in 2013 that formed part of the Hamburg naturalisation campaigns. One of the guides, a 19-year-old German Vietnamese high-school graduate, even aspired to become a caseworker himself (HaCA4/LA4, interview 10/07/2013). Overall, legal advisers provide crucial support for applicants to enter and complete the naturalisation process, especially in translating the legal requirements, despite a lack of funding in the UK.  Whereas the UK Home Office explicitly does not see any role for specialist agencies because it regards naturalisation as a privilege, the German Federal Ministry of Interior has created state-funded migrant advice centres to help migrants to “empower” themselves. These centres, Foreigner Commissioners and the Hamburg specific guide project provide similar support, albeit with better funding. However, legal advisers’ work remains inhibited as long as the state does not publish the administrative guidelines, as in Saxony.

 http://einbuergerung.hamburg.de/der-film/ (accessed 25 February 2017).

1

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4.2 Educating “Good” Citizens: The Role of Citizenship Course Teachers Like the legal advisers, teachers of so-called “ESOL with citizenship material courses” and “integration courses” support potential applicants at the preparation stage of their application, specifically by helping them to meet the language and knowledge requirements.

 tructural Conditions: Guidelines, Accreditation, S and Funding Teachers in both countries have been assigned a similar role, but they are less regulated in Britain and better funded in Germany. Both states have entrusted teachers with the task of making “active”, “democratic” citizens. The initial report which formed the basis for the UK citizenship materials stated that “new citizens should be equipped to be active citizens” (Crick and Home Office 2003, 9). A subsequent teachers’ guide explained that the ESOL with Citizenship course should not only educate participants in how to “be a good citizen by voting and obeying the law but this is passive citizenship” (Taylor 2007, 25). However, the aim which distinguishes a democratic from “an autocratic state” is that the course participants’ aspirations should additionally be raised to “be an active citizen by contributing to your local community, being a parent governor at the local school, running a youth group or setting up a supplementary school” (ibid.). Similarly, teachers of the “orientation course” in Germany are expected to assist participants in developing a “positive image” of the German state; they should be “empowered to participate in society”, yet remain free of “political indoctrination” (BAMF 2015, 7–8). The designated role of the teachers in the two countries is similar, but their job requirements and appointment procedures vary. In Germany, teachers must usually demonstrate a university degree in German as a Foreign or Second Language (IntV s 15 ss 1), and they must seek accreditation directly from the Federal Office for Migration and Refugees. In the

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UK, by contrast, the Home Office relies on private agencies which were numerous in the past but have been reduced to four test providers (Trinity College London, IELTS SELT Consortium, LanguageCert, Pearson) (Home Office 2022) accredited to take a “secure English language test” (SELT) for all UK visa and citizenship applications since 12 November 2015 (Home Office 2016, 29). Moreover, the course materials are only recommended in the UK, while they are compulsory in Germany. Thus, the Home Office has commissioned “Citizenship materials for ESOL learners” (NIACE et  al. 2010), which are “not designed to be complete” but are considered as a “flexible ‘menu’” from which teachers may “pick and mix”, tailor the course content to participants’ needs and the “local” context by adding “authentic source materials” (ibid., viii). By contrast, the German orientation course follows a detailed and statutory curriculum produced by the Federal Office for Migration and Refugees (BAMF 2017). Finally, course funding has been reduced in the UK and increased in Germany in recent years. English language courses for immigrants first received funding under New Labour’s “Skills for Life” strategy in 2001, but this funding was subsequently cut (Rosenberg 2007, 225; Cooke and Simpson 2008, 7, 11). The five centres I visited in 2012 and 2013 were run via a mix of funding from Local Authorities, the European Union’s Integration Fund, private donations, re-distributed funding from other courses, and fees paid directly by participants. One of these centres announced its voluntary liquidation and closed in September 2015 due to the withdrawal of government funding. By contrast, the funding of the German integration courses was statutorily regulated by the 2004 Immigration Act. However, teachers in Germany also find themselves in a precarious situation. Even though the Federal Office for Migration and Refugees requires that teachers are paid a minimum wage of 41 Euros per teaching unit (BAMF 2020), employers face few sanctions and most teachers find themselves locked into quasi-self-employment (Beyes 2015) and are not well organised in unions, as one teacher in Hamburg explained (HaT6, conversation 21/08/2013).

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 eachers’ Experiences with the “Citizenship Materials” T and “Orientation Courses” How did the teachers perceive their own role in the classroom? Their responses varied from embracing citizenship education to outright rejection, as this section explores. Some teachers argued that the courses facilitate students’ empowerment. For example, one teacher in Burnley embraced the British citizenship materials in the following way: “I think it’s very useful for them in everyday life. I think it’s a very good thing for students to integrate, and this will help them give them the confidence to do it” (BuT2, interview 18/02/2013). She observed that many female migrants depend on their families or husbands and argued that the ESOL with Citizenship course “for their own social, personal development it’s a good thing, it can only be a good thing” (ibid.). While her views as to how exactly the citizenship materials may improve participants’ everyday lives remained vague, another teacher supported her students by contacting the Home Office and making enquiries on their behalf regarding immigration application information. Some teachers argued that the British citizenship materials or German orientation course curriculum did not represent a major change, but instead, simply continued existing practices. After reading the curriculum for the first time, one teacher in Dresden thought to herself: “I am already doing all of this. This is nothing new really” (DrT1, interview 22/04/2013). Furthermore, she added that the course aim, which is to create a “positive feeling for Germany”, is “actually self-evident” (selbst erklärend) when you teach German history, but she also acknowledged that her class might not be “representative” as most of the students hold higher education degrees and are able to make fast progress (ibid.). In Britain, teachers choose whether to teach the citizenship materials as a separate course or as part of the language course; all teachers I interviewed had chosen the second option. One senior teacher in Brent explained that: “The citizenship material doesn’t really work. We tend to teach citizenship through language rather than a citizenship class. […] All our courses have citizenship embedded within them” (BrT1, interview 7/11/2012). Another teacher in Burnley agreed that “Everything is sort of citizenship, I think” (BuT1, interview 25/02/2013).

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All teachers interviewed for this research used additional materials because they felt that the given materials contained overly difficult language and were not accessible to all learners. One teacher in Burnley spoke about an Entry 1 (beginner) class as follows: “It would be impossible to speak about parliament, MPs and so on with this lot. I can think of nothing in the citizenship materials which I could do in this class” (BuT1 after BuClass2, observation 10/01/2013). Another teacher conveyed the impression that the citizenship materials were still too difficult to impart in an Entry 2 (intermediate) class: “A lot of the time I feel some of them don’t understand what I’m saying, they just don’t understand enough English at the moment, even though I speak slowly and try and make it as easy as possible” (BuT2, interview 18/02/2013). Whereas, she continued, with Entry 3 (advanced) classes: “You can just go through the material, they understand what you are saying, you can get a conversation going. It’s a much more interesting class for everybody concerned”. (ibid.) In the UK, teachers criticised that the course duration is too short to teach both language and citizenship (BrT5 after BrClass4, observation 26/11/2012). In Germany, the Federal Office for Migration and Refugees’ decision to increase the orientation course length from initially 35 to currently 100 teaching units of 45 minutes was generally welcomed because it allowed the teachers more time to deliver the course content (e.g. DrT1, interview 22/04/2013). Yet, in Germany, teachers also criticised that the Life in Germany test which concludes the orientation course is above all a language test rather than a citizenship test. The multiple-choice questions use difficult vocabulary. For example, as one teacher in Dresden explained, the questions use words that sound similar but mean different and abstract things such as “federation of state (Staatenbund), confederation of states (Staatenverbund), and federal state (Bundesstaat), which may well confuse a learner” (DrT1, interview 22/04/2013). The teachers thus argued that the Life in Germany test effectively examines applicants’ language skills more than their citizenship knowledge, so considerable time in the orientation course sessions is spent mechanically rehearsing test questions with the short-term aim of passing the test rather than engaging in meaningful discussions (HaT2, HaT4).

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Teachers tried to adapt and update the materials to make them relevant to participants’ lives. One teacher in Burnley acknowledged that the exercise sheets contained a lot of references to pork: “I’ll have to change them, it’s really not Muslim friendly” (BuT1 after BuClass4, observation 16/01/2013), thus attempting to make the materials more inclusive and to remove any possible offensive references. She also tries to connect local and global histories, the places where participants grew up, and where they live now: [I] found some pictures in Nelson of mill workers from the early days of photography, dressed very similar to the Asian women now. And showed them some old pictures from India from their area, and they were interested in that, so not just our history but their history and how everything goes together. (BuT1, interview 25/02/2013)

Similarly, when discussing the monarchy in the class, she introduces participants to the royal family and then lets them draw a tree of their own families: Just let them have a go at it. There is some stuff about the royal family in the NIACE [citizenship materials] but I found this better because it’s about people. It’s about people they can see. They always want to talk about Diana, when she went to Pakistan, that makes a connection. (BuT1, interview 25/02/2013)

Similarly, a teacher in Hamburg said that her goal is achieved when she realises that the students can personally relate to the course. One teacher in Hamburg recalled situations from her classroom or course excursions when she realised that her participants were relating to the course content; for example, some participants talked about what it is like when you have to hide from bombs in a war-torn country when they discussed the section on the Second World War in class, or have their own family history or experience of the Holocaust (HaT5, interview 19/08/2013). She has also found that participants from former Soviet countries say it helps them to learn about the GDR as they can now better understand why

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Angela Merkel has such a good understanding of Bulgaria or Romania (ibid.). The teacher in Burnley who was concerned that the course relates to her participants’ lives has also tried to give her course participants a concrete opportunity to meet their political representative and voice their concerns: We’ve had the MP here to come into a couple of classes once. I’m hoping to do that more. In fact, after he did it, he came and did a surgery here. So, we told everybody, if they had any [questions], I mean it was for everybody in town but it was here, downstairs, and some of the people, some of the students did go and asked him things. (BuT1, interview 25/02/2013)

She reflected about the need to translate abstract terms such as ‘good citizenship’ into real life and to empower participants by making them aware of their rights even if it remained difficult to claim them, as we browsed together through the citizenship materials (NIACE et al. 2010): BuT1: “I tailor it to the level of the students, otherwise it’s pointless. We do citizenship based in my mind, but then I have to ask the question: whose citizenship are we talking about? The NIACE thing or is it my opinion, or…? If they can’t understand me, it doesn’t matter what I do, we have to hope that they will continue. This thing about good citizenship, I just translate it sometimes into good neighbours. If you’re a good neighbour, you’re a good citizen. I’ve used that [pointing to p.  25, a picture of two people holding something in their hands] with the lower levels, but it is difficult because they don’t understand what on earth this is about? It’s an Aids banner, so they are demonstrating, it’s not about Aids, it’s about freedom of speech, being able to demonstrate giving your opinion. Why they put Aids here, I don’t know how to explain this really. [turning to me and pointing to another picture on the same page] What would you say this is about?” EB: “I don’t know, a lady piling things in a box?” [it’s supposed to mean donating clothes]

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BuT1: “...is a good citizen! (laughs) I’ve explained it, I’ve used those for the citizenship part. We cover health, jobs, especially, well, with the women as well but more with the men if they are working because I want to get across about minimum wages and things like that. Whether it does any good I don’t know. Sometimes they know very well that they are not being paid the correct money, but if they report it, OK, they reported it; their boss is in trouble, but they have no job. I don’t know what the answer is to that, really.”

Some teachers rejected the British citizenship materials as inappropriate. For example, the teacher in Burnley quoted above decided to not use the second revised edition (NIACE et al. 2010) because one exercise had been changed and now contained a military picture and a British flag which she deemed to resemble “propaganda”, and instead continued using the initial version of this exercise in the first edition (NIACE et al. 2006) (BuT1, first conversation 27/06/2012). She also noticed that some of the materials are “irrelevant” because they are centred on London and aimed at young adults, whereas many of her students are single or elderly mothers (ibid.). Similarly, her colleague criticised the citizenship materials for appearing to privilege a Western interpretation of culture which excludes many Asian course participants: Although it’s strange that the material is all focussed on Britain and life in the UK, the culture. Whereas in the past it was often about the culture, to get people talk, it was very inclusive, the culture of the women. I find that the women who are not from Western culture, they don’t have that much to share because they don’t have the same celebrations and they don’t drink. So, I find that the Thai or Romanian women can relate more to what we are talking about. And I feel that the others are feeling left out a bit, I do try and get them to talk as well about their traditions but we do have to focus on this, it’s part of the course, it’s British citizenship. (BuT2, interview 18/02/2013)

The most explicit criticism of the citizenship course was expressed by a volunteer teacher in a non-accredited centre in London. When, after the class, I asked: “How useful do you find the citizenship materials?”, the teacher answered promptly: “I never use it” (BrT6 after BrClass5,

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27/11/2012). She then explained that she appreciated that this course provider was a place “where you don’t have to turn people away”, that citizenship is a “sensitive” issue for some, and that she did not know and thought she should not even know if her students “are citizens or not” (ibid.). In her view, the citizenship materials were designed for aspiring new citizens or citizens-to-be and might offend and/or exclude learners who are not eligible. In Germany, teachers cannot reject the orientation course curriculum and course books as they are under the direct control of the Federal Office for Migration and Refugees, which reserves the right to inspect classrooms and course documentation at any time, without notice (IntV s 20 (5)). One teacher in Hamburg noted that the Federal Office had increased the regulations which it demands that teachers implement, without increasing teachers’ salary (HaT6, conversation 21/08/2013). For example, teachers are required to monitor attendance on two separate lists: one for the teacher to tick to signify that a participant has attended class, and one for the participants to sign when they enter and leave the classroom. The teacher also has to note whenever a participant arrives late or leaves early, a requirement which she finds “annoying” but that she can “passively subvert” by refraining from taking a note (ibid.). To summarise, teachers work in a context of tight funding (especially in the UK) and strict regulations (in Germany), yet they are expected to educate “good”, “active”, and “democratic” new citizens. The teachers interviewed here expressed different responses to the role they were given. While some appreciated the idea or pragmatically adopted it, others were concerned with ensuring that the course was as accessible and relevant as possible for participants, and designed alternative content where necessary.

4.3 Presenting the Certificate: The Role of Registrars and Caseworkers Caseworkers and registrars are the crucial legal authority in the naturalisation procedures as they do the decision work and present the certificates, thus ultimately selecting and making new citizens.

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 tructural Conditions: Guidelines, Competences, S and Working Conditions In the UK, caseworkers from the Nationality Group within the Home Office examine applications. They work in an open plan office with “hot-­ desking” and a “conveyer belt” system. This means, when an application arrives in Liverpool, it goes through several divisions within the Nationality Group as I was able to observe during my visit (observation 15/11/2012): In the “post room”, around 20 workers receive and sort over 2000 items of post per day (including around 700–800 naturalisation applications), write the entry date, country of origin, and application type (single/joint/minor) on each application and put it in a plastic envelop. In bundles of ten, the plastic envelops then go into the “file creation room” where around 80 workers debit the application fee from the applicant’s bank account with only five credit card machines—if one breaks down, it causes significant delays. They also mark those applications forwarded from a Local Authority’s Nationality Checking Service with “LA” as well as those from “war torn countries”. From there, four workers check that all financial transactions are correct in the “cashier room”. In the following “file management room”, two workers sort applications on shelves, for example, those from minors or those from “war torn countries” that have undergone additional security checks. The application then finally reaches one of more than 100 caseworkers’ desks for assessment and from there, if successful, goes to the print room where around 20 workers print certificates of naturalisation with one large machine. Unsurprisingly, the Nationality Group was referred to by research participants as an “industry” and a “sausage factory” (BrAdmin4, UKAdmin1, BuAdmin1). According to a senior official from the Home Office, many caseworkers work overtime and in shifts, and they work to targets; yet union representation is low (UKAdmin1). He concluded that: “These are not great jobs but the people are dedicated.” (ibid.) Registrars in local authorities pre-examine applications through the Nationality Checking Service and present certificates in citizenship ceremonies. In Brent, the registrars work in small shared offices with hot desks. Although the actual presentation of certificates is administered by

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local authorities, the Home Office initially recommended details pertaining to the order, content, wording, and venue of citizenship ceremonies (Home Office 2003). In Germany, caseworkers in the local naturalisation authorities receive and examine applications and they also present the certificate at the end of a successful application. Unlike in the UK, the application stays with the same caseworker throughout the process, but is shared for review with a senior caseworker (4-Augen-Prinzip). Also, unlike the UK, caseworkers in Germany have their own office where they receive applicants. There is no set protocol for the presentation of certificates in Germany.

Self-Perception and Experiences In the UK, the local registrars who do the citizenship ceremonies and Nationality Checking Service reflected on traditional and modern public perceptions of their job. The registrars in Brent distanced themselves from traditional stereotypes of registrars and instead adopted a modern self-understanding, presenting Brent as a progressive and open-minded role model compared to other registration offices across the country: In our thinking we are probably more advanced and we like to think of moving forward all the time. Whereas the other offices […], if you think about registrars, it’s such an old-fashioned position. When you look at all the other registrars elsewhere, they carry themselves very differently, they have to look a certain way […] so when it came to do citizenship, they didn’t know how to move forward. So when they came to us they were like ‘Wow!’. We are slightly,[…] we don’t sit in the way how registrars used to, the perception the world has about how registrars should behave. […] We are very different, very open, open to ideas. And then you have these ­registrar offices, […] they don’t really have that so they’ll come to us to get ideas and use it in their office. (BrAdmin2, interview 12/09/2012)

One of the few white registrars in Brent who had previously worked in other registration offices in the South of England explained the traditional stereotype of registrars in Britain based on ideas of gender, age, and ethnicity:

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Traditionally, registrars are white, middle aged people. That’s what it was in [my previous workplace], I was the youngest they had ever seen. I’d never worked with any non-white registrars before coming here. […] A lot of people think registrars are old men behind a desk […] [whereas it] has been a female thing for quite a long time. […] People are not really encouraged to go in it at all. Maybe you get flexible hours, but not always. Boys think it’s girly, births, weddings. (BrAdmin6, 16/10/2012)

The self-understanding among Brent registrars was that “we cater for everyone” in a superdiverse community (BrAdmin5, interview 20/09/2012). In the UK, many registrars had worked in different areas before, including sales, the police, a family company, or other council departments, and they acknowledged that “When you start registration, you want to quit, there is so much to learn!” (BrAdmin6, interview 16/10/2012). Yet, what they appreciated about their work was the emotional recognition it offered, as one of the registrars who had been on the Brent citizenship team since the first ceremony in 2004 explained: What is it all about? […] It’s to get people through one stage, say for example NCS, and to see them go through the Liverpool process and then to see them go through the ceremony process […] it gives me a good feeling, because it feels like I have achieved something, they’ve achieved it but I feel like I achieved something for them. Like today, I saw this man and I was like, this is really cool, because I did your checking service and it makes you feel really warm inside, you did go through, you’re British and you have so less restrictions for you to travel anymore. He’s a young boy, he wanted to go back home, he has not been home for eight years, he really wanted to go back home and see family. And I was like, you know what, you can go now because you’re going to get a British passport and it’s so much easier to travel on a British passport than it is on the current thing. It’s nice that we are introducing good citizens into society. I think that’s the main thing. And hopefully they will achieve more than their previous citizens. Hopefully it will give them a little bit of understanding to say maybe there is something that I can do better for somebody else or be a good citizen, that sort of thing. I hope they will do good in their citizenship by getting citizenship. Hopefully we’ll pass that on. The best thing is when you see them go through the stages and you see them at a ceremony it makes you feel good,

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that they’ve come through and that they have been processed and they’ve got their nationality. (BrAdmin5, interview 20/09/2012)

The registrars generally appreciated their interactions with the local community. Compared to the teachers, the registrar quoted above was more confident in describing her role as “introducing good citizens into society”. The task of running the ceremonies presented registrars with the difficulty of creating a new ritual that would strike the right balance by neither appearing “tacky” nor “overly patriotic”. The Head Registrar in Brent who cooperated with the Home Office to create the recommendations (Home Office 2003), and who designed the first British citizenship ceremony, said that they wanted to create a sense of “celebration” without adopting an American “jingoistic, flag-waving, hand-clapping” style (BrAdmin4), echoing the then-UK Home Secretary, as discussed in Chap. 3. Similarly, one registrar recalled the difficulties of selecting the right gift and of getting the meaning right: We started with something silly like pens and pencils, plenty of chocolate samples. Eventually we said, this is all looking tacky, we’re going to host the first one [citizenship ceremony], we can’t settle for this. So, then we looked at medals [which they went for]. We thought about changing it very recently. Trolley coins, something that they can use. But, I think they all appreciate something that they can put on their shelf rather than trolley coins they might lose. (BrAdmin2, interview 12/09/2012)

The administrator in charge of the Hamburg ceremonies was also concerned about how the gift might come across. She explained that they had looked at other local authorities’ ceremonies in Germany and found that the Mayor of Neukölln in Berlin distributed a copy of the Basic Law (Grundgesetz) to every newly naturalised citizen, a practice which she was indignant about: I said, I would do anything but distribute the Basic Law to naturalised citizens because that is such an impertinence (Frechheit), to give people who have been naturalised the impression once again, that they are now to fol-

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low the Basic Law! Because it insinuates equally that they have not obeyed it so far. To raise the moral warning finger at this point and place [is not appropriate]! (HaAdmin1, second interview 17/07/2013)

This administrator was clearly aware of the criminalisation which migrants experience from German state authorities. She was also acutely aware of the moral double standards expected from migrant citizens as opposed to national-born citizens, and she was very keen on designing the Hamburg citizenship ceremonies in a way that don’t make migrants feel disciplined. When we consulted the application form and read through the declaration, she commented: “Which German national respects the Basic Law?” (Welcher Deutsche hält sich schon ans Grundgesetz?) (ibid.). She also spoke about the uncertainty regarding the decision of whether or not to play the national anthem, which was eventually played (ibid.). In the UK, playing the national anthem is recommended by the Home Office (2003), and it was played in every ceremony I observed. However, some registrars chose to keep the recorder in a corner of the room rather than the middle, and to turn the volume down, as one registrar explained to me: “It depends on what you want to do. I don’t want to stand in the middle [when playing the anthem]. They all do it differently” (BrAdmin6, interview 16/10/2012). This registrar also preferred to not sing along. In Burnley, registrars explicitly advised ceremony participants not to sing along to the anthem. When I asked the Burnley citizenship administrator why this was, she replied: I was told historically it wasn’t a good idea. If there was only 12 people and the registrar didn’t like singing. I keep thinking we should give it a go, give it a try but if it goes wrong, [that would be] so horrible, so we don’t tend to sing. Would it work or not? I don’t know. (BuAdmin1, interview 27/02/2013)

Ironically, while singing the national anthem was considered problematic, a particularly long version of the anthem was chosen in Burnley, which allowed the invited guest speaker sufficient “time to put [their] hat

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and gloves on to salute” (BuAdmin1, interview 27/02/2013). Moreover, the recording is convenient because the music keeps playing in the background during the presentation of certificates and the CD length allows sufficient time to “fit in for around 20 people”, the average ceremony size in Burnley (ibid.). During one of the ceremonies I observed in Dresden, the invited guest speaker told the audience during his speech that “it is OK” not to sing along to the German national anthem (DrPres1, observation 16/06/2012). This suggests that ceremony guest speakers can play a crucial role in subverting but also reinforcing subject-formation attempts, as the final section now demonstrates.

4.4 Addressing the “New” Citizens: The Role of Honorary Ceremony Speakers A key element in all citizenship ceremonies is a speech held by a guest invited by the local authority to address the newly naturalised citizens. While the ceremony as a technique of subject-formation will be discussed in depth in Chap. 5, the following section examines the particular role of these speakers.

Guidelines The speakers’ assigned role is to engage the naturalised citizens, as a registrar in Brent explained: You know, it’s like organising any event. How are you going to bring people up? Like I said, the dignitary part is the most important; if the dignitary is interested in what he is doing, is interested in the people in front of him, then the audience will also be interested. But if they just come in, read a script out of the book, then the guests tend to get bored, tired, tend to fall asleep. You have to make it special for them, some of them have invested so much money into this, they spent over twenty grand trying to become British from the time they have entered the UK, most of this goes to the solicitors, of course, and they waited for such a long time, and for them it’s like a milestone, coming to this ceremony is the moment they have been

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waiting for, it means so much. And when you’ve got a dignitary who is not so bothered, it’s not really fair, because you want to make it a celebration thing for them. (BrAdmin2, interview 12/09/2012 original emphasis)

Thus, the invited guest speakers were expected to reward migrants’ onerous and expensive entry, settlement, and naturalisation applications. The rationality of citizenship as commodity as discussed in Chap. 3 is thus mobilised to justify the expected role of voluntary ceremony speakers (although in the above statement the responsibility of this price development is attributed to the migration advice industry, rather than to the UK Home Office). The Burnley citizenship ceremony officer expressed a similar view when she pointed out how important the dignitaries are, and that she had “trained nearly all of them now” to avoid just “sit[ting] in the corner”, and instead to engage with the citizenship applicants in conversations before the ceremony, because “greeting, asking where they are from, exchanging stories makes a real difference” (BuAdmin1, interview 27/02/2013). This task of performing emotional work was thus not only expected from the ceremony organisers but also given to the (unpaid) invited guest speakers. In Hamburg, the organising administrator explained that the guest speaker’s speech should not “lecture” (belehren) naturalised citizens but should aim to “express exactly what [citizenship applicants] feel” (aus der Seele sprechen) (HaAdmin1, interview2 17/07/2013). For this reason, the organiser in Hamburg initially wanted the speech to be delivered by one of the naturalised citizens themselves and asked for volunteers in the ceremony invitation (ibid.). This, however, did not work out very well, as those who volunteered were not used to speaking in front of 700 people (ibid.). Therefore, they specifically targeted and invited individual speakers and widened the selection criteria to people who have an “immigration history” or an “interesting biography”; these speakers did not necessarily have to be “German per se” (ibid.). In Brent, “good citizens” and “award winners” for the community were recruited by inviting them to speak at the citizenship ceremony and providing a script (BrAdmin5, interview 20//09/2012). Such “good citizens” could be “local celebrities, Councillors, MPs, the mayor” who were believed to be “interested in the community” (BrAdmin2, interview 12/09/2012). The registrars struggled, however, to keep the speakers active, as interest

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faded over time and not all local Councillors and Mayors were keen to participate (ibid.). While in Brent the dignitaries were chosen for being “award winners” and representatives of the diverse local community, speakers in Burnley did not represent the residents of Burnley but a Lancashire-wide elite close to the monarchy known as the Deputies of the Lord Lieutenant, or DLs. Like the speakers in Brent, the DLs were selected because of their “distinctive service to the County” (BuCCGC2, conversation 04/02/2013). However, unlike in Brent, they were initially appointed by the Lord Lieutenant upon recommendation rather than elected, and they represent the Monarch, not a democratically elected parliament. The DLs’ role is therefore more linked to the monarchy than to citizenship, as they spend their time, for example, visiting schools across the County to “inform pupils about the monarchy” (BuCCGC4, conversation 06/02/2013) or organising “royal visits” (BuCCGC2, conversation 04/02/2013). None of the speakers saw a contradiction in the fact that they represent the monarchy and yet address new citizens. The DLs are proud of their status, as all new DLs are announced in the “big national newspapers”, and they receive a “lovely certificate which I put in a frame on my wall” (ibid.). The dignitaries I met were retired lawyers, businessmen, or heads of schools who lived in the countryside and only came to Burnley to speak at the citizenship ceremony or to shop at Marks and Spencer. One of them reported that citizenship applicants often thought that she was, in fact, the Queen (BuCCGC3, interview1 12/02/2013). The organiser of the Burnley ceremonies told me that only a few of the 45 Deputy Lieutenants in Lancashire were willing to make their citizenship ceremony speech in Burnley, as they preferred to attend ceremonies in Preston (BuCCGC1, conversation 03/02/2013). In order to induce more DLs to come to Burnley, the citizenship ceremony officer planned a strategy: she started giving out the dates, and only after the DLs had confirmed their availability she announced which ceremony was to be held in Preston and which in Burnley (BuCCGC2, conversation 04/02/2013). However, she also recalled a dignitary who called her up and said “he would come if there were no women in veils”, so the officer never called him again (BuAdmin1, after BuPres4 observation 06/02/2013).

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The Brent registrars also reported having had to deal with problematic speakers. One registrar remembered how in her previous registration office in the South East of England where the citizenship applicants included many EU nationals, for example from Poland, they had “a few older mayors” who would say during the ceremony: “I used to fight the war against you!”, and the registrars simply had to “put up with it” (BrAdmin6, interview 16/10/2012). In Barnet, the Mayor insisted that the registrars rehearse the singing of the national anthem with the ceremony participants and their guests before the start of the ceremony, as a registrar explained to me while rolling her eyes in annoyance (BrPres12+13, observations 28/11/2012). To address concerns similar to those voiced by the registrars and speakers, the Head Registrar in Brent wrote two pages of “Notes for dignitaries at citizenship ceremonies” in which he expressed an awareness that “Sometimes concerns are expressed by dignitaries about new citizens whose command of English appears either non-existent or too weak for the new citizen to comprehend what is being said”. Furthermore, dignitaries are concerned that this may “affect their [new citizens’] ability to take the oath and pledge”. However, as the Brent Head Registrar pointed out, “If you yourself learned a foreign language in school, even to GCSE standard, you might not feel that confident in dealing with officials abroad”. He continued by reminding the dignitaries that “The important thing to remember is that the ceremony is celebratory; it is not part of the immigration control and consideration process”. To summarise, while the external guest speakers were invited to address naturalised citizens’ emotions, some of the speakers in the UK reportedly misused their position in various ways, e.g., by insulting naturalised citizens, refusing to speak to veiled women, trying to force everyone to sing the national anthem, or wishing to examine candidates’ English skills. Yet, some of the speakers interpreted their role as it was assigned to them, as is now explored below.

Self-Perception Some of the speakers appreciated that the ceremonies celebrated immigrants and that speaking the oath at a ceremony made the act of

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naturalisation more “meaningful” than the previous postal procedure, as the then Mayor of Brent summarised: The purpose is to officially welcome the new immigrant, to let them know they are fully and well accepted as a British citizen. And this is to give them reassurance and so they can plan a new future for themselves. […] When I became [a] citizen here, I did not have this opportunity, to have this kind of ceremony. (BrCCGC1, conversation 13/09/2012)

Having migrated to the UK from Nigeria many years ago, this speaker compared the current system to his own naturalisation experience and wished he had had the chance to attend a ceremony. Another speaker, who had initially come from India, agreed that having received his certificate through the post, he felt it “didn’t mean anything”, and he also thought that the ceremony is “a good idea” as it creates a “psychological effect you are swearing to something superior, need to stick to it” (BrCCGC4, interview 09/10/2012). He thus affirmed the idea that ceremonies are a technique to self-bind migrants to the commitments they make through entering citizenship. The female speakers expressed enjoyment of their social interactions with naturalised citizens. For instance, a speaker in Burnley appreciated that the ceremony facilitated the creation of a link between the individual and the state, as the ceremony “helps to build up that relationship between the Council and the community” (BrCCGC4, interview 09/10/2012). Another speaker mainly enjoyed the social interaction with naturalised citizens and the chance to create a “link” between her own travels and their countries of origin (BuCCGC3, interview1 12/02/2013). She also tried to connect and empower naturalised citizens whenever she saw the option to do so, for example: [A] little girl said she wanted to be a doctor. So, I whispered to her when I gave her the certificate, have a word with the two doctors here [other citizenship applicants] and maybe they’ll give you a few tips. Not sure if she did it (laughs). That’s why I like to talk to them, otherwise it’s a very sterile role if you’re just handing certificates out. (BuCCGC3, interview1 12/02/2013)

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Others emphasised the aspect of speaking from one immigrant to another. For the Brent mayor, who was born in Nigeria and naturalised in the UK many years ago, it was the “greatest joy” to “see more people joining me here”, when I asked him whether he was given any guidance for his speech: No, you speak from experience. Being an immigrant is easier to talk about that because I speak with my own experience, I come through the same route as these people are going. So, it’s not difficult for me to impart to these new immigrant[s] whatever experience and the benefit[s] of becoming [a] British citizen. (BrCCGC1, conversation 13/09/2012)

There was little awareness, however, among these participants that their experiences of migration and naturalisation might be different and possibly less onerous compared to the current situation. In Burnley, the dignitaries were encouraged to customise the template speech, so one dignitary mentioned their family history from centuries ago to present themselves as immigrants: The covering letter was, you customise it as you wish, and if you can bring in anything personal, like I always mention my French family. They will have felt much the same as these people felt when they came over to England 8, 9, whatever years ago. When you are strangers in a strange place, you need to have an understanding of what they feel like. So, I do have an empathy. I am an empathetic person. (BuCCGC3, first interview 12/02/2013)

While many speakers thus tried to insert personal notes of immigration histories or experiences, others regarded their speeches as a final opportunity to remind newly naturalised citizens about their duties. A speaker in Burnley spoke about the importance of combining a human, informal welcome with a reminder of the duty to “respect”: It is a formal framework and they [the registrars] humanise it to make them feel significant, enjoyable, be part of it and a great warmth, the human side of it rather than make it too intimidating, which they have probably felt when dealing with all the paperwork before. I try to make them feel valued

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and welcome. Where the seriousness comes in is what citizenship of the United Kingdom means: tolerance to other people, tolerance to other faiths, tolerance to other cultures. I always try and remember the last paragraph but that’s why I always read out the last bit, I want them to be totally aware of what they undertake, for example equality between men and women, that’s not in all religions, we should understand each other and respect each other, the world would be a lot better if we all respected our responsibilities. I want to be sure that I get this part right, so I always read it out, onerous and slow. So overall, it’s a mixture really. (BuCCGC2, conversation 04/02/2013)

One speaker in Brent explicitly talked about the need to “educate”, and to make “good citizens” and “responsible citizens” (BrCCGC4, interview 09/10/2012). He encouraged the newly-naturalised citizens to cast their vote because “back home, they don’t do that” when they come from “dictatorships” such as “Africa, [a] Sub-Indian country, Venezuela”; he therefore saw his role in raising awareness of democracy and against a “lack of interest in politics” because “each vote makes a lot of difference”. However, he also wanted to draw attention to “local issues”, such as informing naturalised citizens that the mosque is not allowed to make announcements “through [a] microphone”; that you don’t play “loud music”; and that naturalised citizens should “behave” and not be a “nuisance to society” (ibid.).

4.5 Discrepancies Between Structurally Prescribed and Self-Perceived Roles This chapter has analysed the authorities involved in the current citizenship admission procedures in the UK and in Germany. The authorities of subject-formation were defined as those persons who are given or assume power over migrants who subject themselves to naturalisation. In the case of naturalisation, the authorities are the officials and other professionals who migrants will encounter at various stages of the citizenship admission procedure. By proceeding along the main stages before, during, and at the end of the naturalisation application process, this chapter

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identified four main authorities who contribute to the construction of the Super Citizen subjectivity. Legal advisers interpreting legal guidelines, teachers teaching citizenship courses, caseworkers assessing naturalisation applications, and guest speakers at local citizenship ceremonies all govern citizenship applicants, albeit to varying degrees, and each of these groups exercise their role with different nuances in the UK and Germany. The combined analysis of the document and interview data suggests that there are significant discrepancies between the structurally prescribed and self-perceived roles of these authorities. These discrepancies were perhaps most visible in the case of legal advisers at the pre-application stage. Legal advisers’ authority consists of their knowledge of the relevant legal regulations and the advice they can provide on how to enter and successfully complete the citizenship application procedure. Because naturalisation is defined as a discretionary award in the UK, as discussed in the previous chapter, the role of legal advisers is not publicly funded, nor indeed even envisaged, in the British case. This development is part of a wider trend in cuts to legal aid funding and the simultaneous increase in regulation of migration and of the migration advice industry in the UK. This represents a contrast to Germany where, following the logic of entitlement, publicly funded basic legal advice has been introduced to “empower” migrants. However, legal assistance was nonetheless sought in all four research locations. In the UK, lawyers working in publicly funded advice centres either tried to circumvent the strict funding regulations and provide limited assistance by proxy through volunteers whom they supervised, or to affirm the rationality of award by turning citizenship applicants away, arguing they should be able to apply on their own. Most of the legal advisers interviewed for this research, however, acted as translators in making the written (and in the UK, exclusively online) legal information and application form accessible to all citizenship applicants, particularly to elderly, disabled, illiterate, and formerly irregular migrants or those with complicated previous immigration applications, that is, precisely those being problematised under the current regulations, as discussed in Chap. 2. The volunteer guides from Hamburg’s migrant communities were assigned the explicit task by the city state to inform migrants of their entitlement to naturalisation and to help them to claim their right. Compared to the professional and

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volunteer legal advisers in the other research locations, the Hamburg guides enjoyed the closest relationship with the naturalisation authorities. In Dresden, by contrast, the legal advisers voiced criticisms of the Saxon authorities in relation to the opaque and unnecessary stressful application procedure. This confirms that a federal state system such as Germany may ultimately yield very different policy implementations at the member state and local levels. The role of teachers of citizenship courses was also situated at the pre-­ application stage. Their authority lies in preparing and assessing migrants to meet the knowledge of language and society requirements necessary for naturalisation. Unlike the legal advisers, the teachers’ role was deliberately envisaged both in the UK and Germany, and they were assigned an explicitly disciplinary task: to “equip” migrants to become “active citizens”, as the UK Home Office citizenship materials put it; and to “empower” migrants without “political indoctrination” to become “democratic citizens”, as the curriculum of the German integration course framed it. Like the legal advisers, the teachers also acted as translators and support for migrants by helping them to learn the English or German language and preparing them to take the citizenship test (in Germany). In the UK, teachers both welcomed and criticised the citizenship materials suggested by the Home Office, especially the third edition revised by the Coalition Government under the then-Home Secretary Theresa May as nationalistic “propaganda”. By comparison, the teachers in the UK had more freedom regarding whether, and how, to use the course materials suggested by the state than their colleagues in Germany, who were more regulated but also better funded. While teachers have no formal power in the citizenship admission process in either country, they have by far the most regular contact with migrants compared with the other authorities discussed in this chapter. Whereas some teachers showed understanding of the difficulties of their students and tried to encourage them, others dutifully exercised their given role, voicing the expectations that the migrant students should “integrate” and “be active citizens”. This created an intersection of sexism, racism, and classism in a few classroom situations where white female middle-class English or German teachers suggested to the predominantly black and ethnic minority female students that they should not only be “housewives” but engage in activities such as volunteering, as Chap. 5 discusses in more detail.

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Like the teachers, the guest speakers at local citizenship ceremonies have no formal power in the citizenship application procedure. They are given the symbolic role of speaking to the citizenship candidates at the end of the process, after their successful examination and selection. Their authority lies in addressing the citizenship applicants’ emotions and making them feel “welcome”; their involvement in the naturalisation process is thus justified by the rationality of emotional attachment and commodity as they shall make it a special celebration because citizenship applicants paid lots of money. To accomplish their task, ceremony speakers were either expected by the organisers (in Hamburg), or deemed themselves (in Brent), to be more qualified if they had personally experienced migration. In the two super-diverse locations in this research, the role of welcoming “new” migrant citizens was thus handed over to already settled ‘old’ migrants, regardless of whether they have naturalised or not. In Burnley, by contrast, the ceremony speakers officially represented the Monarch and were characterised by their shared British nationality by right of birth, exclusively white ethnicity, and old age. This has the effect that the welcome for “new citizens” in Lancashire is given by the most archetypical representatives of the British monarchy. Although the Deputy Lieutenants in Lancashire are encouraged to adapt the template speech by including their personal migration history, they must search deep into history to do so, for example, by going back to the arrival of French Huguenot refugees at the end of the seventeenth century. The Huguenot migration experience is, however, less visible and audible than contemporary migration, and has been regarded as Britain’s “most successful” migrant minority group (Tonkin 2015). Quite different migration experiences are thus being capitalised upon by ceremony organisers and speakers to address the “new” citizens. Compared to the legal advisers and teachers, the ceremony speakers are the least regulated authority involved in naturalisation, and their role is entirely voluntary or honorary. Ironically, even though they are assigned a purely symbolic role to provide a “welcome”, some assume the role of informally testing citizenship candidates’ language skills or reminding them of their “duties” even though the audience consists of citizenship applicants who have already successfully passed the scrutiny of the state and been found worthy of full membership.

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Caseworkers are by far the most powerful authority, since they decide the granting or denial of a citizenship application. While some ceremony speakers, teachers, and to a lesser extent legal advisers may assume the role of “guardians of good citizenship” (Anderson 2013, 6) in deciding who should belong to the nation and who should not, naturalisation officials are the ultimate border guards by assessing whether a candidate is to be included into the community of national citizens or to remain excluded from national membership. The analysis showed that naturalisation officers in the UK and Germany exercise their authority under quite different working conditions. Perhaps the biggest difference is that naturalisation is centralised in the UK but administrated by local authorities in Germany. The UK Home Office nationality group is located in one large, open-plan office in Liverpool, and uses a conveyer-belt system which means that every application for British naturalisation goes through different units, managed by different staff. In Germany, by contrast, naturalisation applications are usually seen only by the local caseworker and their supervisor (the “four-eyes-­ principle”) who work in individual offices. This different structural set-up also has the effect that the British caseworkers never see the actual applicant, while the German caseworkers have direct personal, repeated contact with each applicant. This may have positive or negative effects on the application outcome, as Chap. 6 elaborates. In the UK since the recent introduction of the Nationality Checking Service, only local registrars meet the citizenship candidates as they receive, pre-select, and forward naturalisation applications to the Home Office in Liverpool, and then again when the applicants return to take their ceremony.

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Howard, Emma. 2014. Legal Aid in England and Wales: What Is Changing? The Guardian, 9 September. Accessed 14 March 2023. http://www.theguardian.com/law/datablog/2014/sep/09/legal-­aid-­in-­england-­and-­wales-­what­is-­changing. NIACE, LLU+ London Southbank University, Department for Business, Innovation and Skills, and Home Office. 2006. Citizenship Materials for ESOL Learners. (1st ed.). Leicester: NIACE (National Institute of Adult Continuing Education). Accessed 10 December 2015. http://www.niace.org. uk/projects/esolcitizenship/Home-­Eng.htm. NIACE, LLU+ London Southbank University, Department for Education and Skills (DfES), and Home Office. 2010. Citizenship Materials for ESOL Learners. (2nd ed.). Leicester: NIACE (National Institute of Adult Continuing Education). Accessed 1 August 2016. http://www.niace.org.uk/projects/ esolcitizenship/. Office of the Immigration Services Commissioner. 2012. Guidance on Competence. 15 July. Accessed 30 November 2015. https://www.gov.uk/ government/publications/competence-­oisc-­guidance-­2012. Rose, Nikolas. 1998. Inventing Our Selves: Psychology, Power and Personhood. Cambridge: Cambridge University Press. Rosenberg, Sheila K. 2007. A Critical History of ESOL in the UK 1870–2005. Leicester: NIACE. Singh, Anne, and Frances Webber. 2010. Excluding Migrants from Justice: The Legal Aid Cuts. 7. IRR Briefing Paper. Institute of Race Relations. Accessed 14 March 2023. http://www.irr.org.uk/publications/issues/excluding­migrants-­from-­justice-­the-­legal-­aid-­cuts/. Stadt Dresden. n.d. Dresden Integrations- und Ausländerbeauftragte. n.d. Accessed 15 April 2013. http://www.dresden.de/de/rathaus/aemter-­und-­ einrichtungen/oe/dborg/stadt_dresden_5923.php. Taylor, Chris. 2007. ESOL and Citizenship: A Teachers’ Guide. Leicester: NIACE. Tonkin, Boyd. 2015. Refugee Week: The Huguenots Count among the Most Successful of Britain’s Immigrants. The Independent, 18 June 2015. Accessed 14 March 2023. http://www.independent.co.uk/news/uk/home-­news/ refugee-­week-­the-­huguenots-­count-­among-­the-­most-­successful-­of-­britains-­ immigrants-­10330066.html.

5 Techniques of Subject-Formation: Citizenship Courses, Tests, and Ceremonies

The previous chapter presented the authorities, that is, the various actors who are involved in the enactment of citizenship admission procedures in the UK and Germany. This chapter focusses on the citizenship courses, tests, and ceremonies as specific techniques of subject-formation which are defined as the means through which the UK’s and Germany’s naturalisation procedures create a particular subjectivity (cf. Rose 1999; Bröckling 2012; Dean 2003). Based on an initial distinction proposed by Michel Foucault (1988a, 1988b), two aspects of techniques of subject-­ formation are considered here. On the one hand, techniques of subject-­ formation present to citizenship applicants a specific understanding of the state whose membership they seek. This shifts the focus to the “self-­ representation” (Brubaker and Cooper 2000, 18) of the British or German state as an imagined collective self, including the various levels of the state (national, regional, local). Following what Foucault termed “political technology” (Foucault 1988b, 146), citizenship applicants adopt a specific understanding of themselves “as part of a nation or a state” (ibid.). On the other hand, techniques of subject-formation suggest “self-­ guidance” (Lemke 2007, 49). Such a “technology of the self ” (Foucault 1988a, 18) recommends a number of concrete “actions” to individuals © The Author(s), under exclusive license to Springer Nature Switzerland AG 2023 E. Badenhoop, Calling for the Super Citizen, Palgrave Politics of Identity and Citizenship Series, https://doi.org/10.1007/978-3-031-34260-8_5

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(Cruikshank 1994, 31). Citizenship applicants, for example, are thus encouraged “to do certain things and to refrain from doing other things” (Bröckling 2007, 134), in order to transform themselves and achieve acceptance as full members of the state. This chapter argues that citizenship courses, tests, and ceremonies are techniques of subject-formation par excellence because they require or invite citizenship applicants to expose themselves to a specific knowledge and presentation of the state while also suggesting a certain conduct, thinking, and self-understanding for the new state’s members. The measures of the courses, tests, and ceremonies were invented for migrants, not nationals, so they primarily separate naturalising citizens from national-born citizens. Secondly, the test questions, the classroom exercises, and the ceremony protocol and speeches give the state the stage to present itself and its expectations from its new members. This chapter examines the imaginations of the British and German states and the conduct expected from British and German naturalising citizens, based on the analysis of interviews, documents, and ethnographic observations in classrooms and ceremony halls. Unlike the courses and ceremonies, the test centres denied access to the researcher, so the analysis of the tests is based on the official test materials that are publicly accessible. The analysis shows that the presentation of both the British and German state oscillates between nostalgic visions of ethno-culturally homogenous nations and modern ideals of diverse democracies ruled by law and committed to welfare, equality, and human rights. Accordingly, the suggested self-conduct for new citizens ranged from disciplinary reminders, for example, to recognise national symbols, to idealised expectations, for example, to vote and stand for vote. The analysis demonstrates that the tests, courses, and ceremonies are all highly efficacious techniques of subject-formation even though they differ in length, frequency, and their compulsory or voluntary nature. While the tests are mandatory and allow only for “right” or “wrong” answers, the classrooms allow collective space for discussion, debate, and potentially diverging interpretations. On the other hand, unlike the tests, the courses rehearse the presentation of the state in a group setting rather than via individual study, repeatedly and regularly over time. The efficaciousness of the ceremonies, whether mandatory (as in the UK) or voluntary (as in Germany),

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lies in the fact that they formally and symbolically conclude the naturalisation process in a theatrical setting which includes speeches by state representatives. The comparative analysis of the UK and Germany reveals that the German case placed a greater emphasis on state duties and citizens’ rights, for example, in the areas of welfare, equality, and human rights, a finding concurrent with the rationality of citizenship as empowerment. Moreover, the UK case was characterised by a strong sense of historical nostalgia and a striking silence on colonialism, immigration and Europe, while significant parts of the German test and course are dedicated to the historical awareness of sensitive topics such as the Nazi and GDR regimes. On the other hand, the UK data showed a greater awareness of religious diversity, including Jewish, Muslim, and Hindu festivities, whereas the German test and course focus predominantly on Christian festivities. The first part of the chapter jointly discusses the courses and tests, before the second section turns to the ceremonies. Each section first outlines the structural conditions and regulations and then examines the content.

5.1 Citizenship Courses and Tests The courses and tests satisfy the legal requirement that citizenship applicants should demonstrate “sufficient knowledge about life in the United Kingdom” (2002 NIAA s 1 (1)) and “knowledge about the legal and social order and living circumstances in Germany” (StAG s 10 (1) 7), respectively, in addition to sufficient English and German language skills. At the time of the fieldwork, this knowledge requirement could be met either by passing the citizenship test or by taking the citizenship course. In the UK, the course route is no longer accepted proof of this knowledge requirement. In the UK, there used to be few regulations of the English language course industry. For example, a so-called English for Speakers of Other Languages (ESOL) course had no set length, and the citizenship materials commissioned by the Home Office (NIACE et al. 2010) were only recommended, not binding, and their actual usage was rarely investigated

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or enforced. This lack of regulation led to a high variation in the course quality, length, and costs and created a risk of fraud that was picked up by the prevailing discourse of “dodgy” colleges. In short, it was difficult to identify approved ESOL with citizenship course providers. Nowadays, the language and knowledge requirements in the UK are assessed separately. The language requirement can be met through a Secure English Language Test (SELT), and the knowledge requirement can only be met through taking the “Life in the United Kingdom” test. This test is mandatory for applicants for naturalisation as well as for Indefinite Leave to Remain (ILR). It costs 50 GBP and consists of 24 multiple choice questions, 18 of which must be answered correctly within 45 minutes. The actual test questions in the UK are not published. Migrants are expected to prepare themselves by reading a handbook (The Stationary Office and Home Office 2022), practice questions and answers (The Stationery Office 2021), as well as a study guide (The Stationary Office 2022) that are available for purchase (19.16 GBP) from The Stationery Office. The UK test content is not regulated by law and more at risk of becoming subject of political interventions. Indeed, in 2013 the coalition government of Conservatives and Liberal Democrats led by David Cameron significantly changed the content of the third and current edition of the handbook (The Stationary Office and Home Office 2022) by dedicating more space to British history, as discussed below. In Germany, the test and course are both accepted pathways to citizenship because the course is concluded by the citizenship test, too. Since the enactment of the 2004 Immigration Act (Zuwanderungsgesetz), the German government has offered so-called integration courses which consist of a language course (600 hours) followed by a civic knowledge “orientation course” (100 hours), which is examined in this research. Unlike in the UK, the funding, length, content, and accreditation, as well as the teachers and providers of the German integration courses are regulated by statutory order (Integrationskursverordnung, IntV) and administered by the federal Office for Migration and Refugees (BAMF). While the British citizenship materials are not subject to specific examination, the German orientation course is formally assessed through the “Life in Germany test”, which is congruent with the German naturalisation test (see below). Thus, if migrants successfully pass the integration course, including the

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Life in Germany test, they will not have to take the citizenship test again when they apply for naturalisation later. The integration courses illustrate the change in German integration policies following the recommendations of the Süssmuth commission. Prior to the 2004 Immigration Act, German language courses were funded only for German ethnic immigrants. Since 2005, the new integration courses have been offered to all newly arriving migrants. These courses represent an offer because migrants are entitled and encouraged to participate in them. The costs are shared between the individual migrant who pays 2,20 Euro per hour and the state (i.e., the public) who pays the other half (ethnic German immigrants may still participate free of charge). Travel and childcare support are available, and 50 per cent of the costs may be reimbursed upon successful completion as another incentive. The integration courses have been continuously reviewed and further developed, including specialised courses for women, young adults, and illiterate people. However, certain migrants who “have special integration needs” (in besonderer Weise integrationsbedürftig, official translation) (AufenthG s 44a (1)) may also be required to participate in an integration course by the local Foreigner or Work Authorities, with significant sanctions in case of noncompliance or failure.1 The German citizenship test is mandatory for naturalisation as well as settlement, as in the UK. It costs 25 Euro and consists of 33 multiple choice questions, 17 of which must be answered correctly within 60 minutes, so it is slightly less expensive. Unlike in the UK, all test questions are stipulated by statutory order (Einbürgerungstestverordnung, EinbTestV) and published online free of charge, in the form of a question catalogue or through an interactive online learning tool administered by the BAMF.2

 The Foreigner Authorities have the power to oblige migrants to participate in an integration course and to cut their benefits or reject any further applications to extend their residence right, should the migrant fail to attend or pass the course (AufenthG s 8 (3), s 44a (3)). 2  https://www.bamf.de/SharedDocs/Links/DE/O/oet-bamf-­interaktiv_einbuergerungstest_fragenkatalog.html?nn=282388 (accessed 18 August 2022). 1

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Presentation of the State A tension was evident in the self-presentation of the British and German nation-states in the classrooms and test materials, which reflected the dialectics inherent to citizenship as membership of modern nation-states, as well as the dialectics inherent to European modernity, more generally (cf. Brubaker 1992; Joppke 2010; Kivisto and Faist 2007; Bhambra 2007). Thus, the presentation of Britain and Germany oscillated between ideas of traditional, ethnically homogenous nations, and those of modern, liberal, and diverse states ruled by law. The courses and tests familiarised citizenship applicants with the UK’s and Germany’s national symbols and examined their knowledge of these. The United Kingdom was notably presented as a state made up of four different nations. The handbook explained where to locate England, Wales, Scotland, and Northern Ireland on a map and how to correctly refer to the whole or its parts, clarifying the difference between Britain, the British Isles, and Great Britain (The Stationary Office and Home Office 2022, 13). It also showed the four nations’ flags and how three of them constitute the Union flag (ibid., 45–46). Similarly, during one course session I observed in Burnley, the teacher gave students an exercise sheet about the “National days of the UK”, which asked students to understand, recognise, and draw links between the flowers, flags, and patron saints associated with Wales, Northern Ireland, England, and Scotland (observation BuClass07, 11/02/2013). This exercise thus trained the course participants to think of the UK as a state made up of four different nations and to distinguish them by their national symbols. These inner-state national specificities within the UK were reinforced through a series of PowerPoint slides presented by the teacher during the same session, showing “traditional food and drink, famous landmarks, famous people”, and other “symbols” associated with England, Scotland, Wales, and Northern Ireland in turn. The selection included a rather stereotypical selection, such as Fish and Chips, Haggis, and Guinness. This created the impression that Britain had somehow been untouched by colonialism, globalisation, and immigration. Fish and Chips, for example, were initially brought to Britain by Jewish immigrants (Rayner

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2003). Tea and (Irish) coffee were the only products produced outside the UK which were included in this culinary imagination of the nation. The colonial relations through which these products initially entered the nation’s palate were not mentioned in the classroom. Similarly, the German test requires applicants to possess detailed knowledge of national symbols. Candidates may be asked, for example, “With which words does the German national anthem start?” (BAMF 2022, 15), or “Who wrote the lyrics of the German national anthem?” (ibid., 25). Consequently, one teacher was rehearsing this with her students in one of the sessions I observed in Hamburg (observation HaClass03, 16/08/2013). She was reluctant, however, to sing the anthem when prompted to do so by one of her students. As in the UK, citizenship applicants in Germany were also familiarised with the regional diversity within the state. The German test contains a set of tasks asking candidates to recognise the geographical location, capital city, and crest of each of the sixteen German federal states. Regional diversity was also highlighted in an exercise used in a classroom in Dresden which informed students about the differences between the Protestant North and the Catholic South of Germany, as well as regional differences in dialect, clothes, and dishes. The text presented inner-German differences as so significant that: “When North Germans speak ‘Low German’ (Plattdeutsch) and people in Southern Germany speak ‘Bavarian’ or ‘Swabian’, they cannot understand each other” (textsheet, observation DrClass03, 22/05/2013). Diversity was understood above all in terms of regional differences within the state’s territory, for instance, between Bavaria and Swabia, or between Scotland and Northern Ireland. The differences that were acknowledged in this way resulted from nation-state building processes in the past. Unlike Germany, the UK was presented as possessing a pre-modern history and landscape similar to Byrne’s (2012) argument about UK ceremony speeches. While the German course and test examines historical knowledge focussing on the twentieth century, the British handbook’s first substantial chapter begins in the Stone Age, then proceeds through the “Norman conquest” in 1066, the 1688 “Glorious Revolution”, the Industrial Revolution, before it discusses the two World Wars and events after 1945 (The Stationary Office and Home Office 2022, 14–69).

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Similarly, the PowerPoint slides used in a classroom in Burnley presented York Minster and Stonehenge, creating an image of Britain as characterised by ancient cultures, military conquest, technological progress, and Christianity, among other forces. A major difference in the narration of British and German history in the two tests was observed in terms of the relationship to the European Union. Fourteen out of 300 questions (BAMF 2022, 63, 83–90) present Germany as a member of, and as being situated within, international and European organisations, whereas information on the European Union and Common Market in the British handbook’s third edition has been reduced to four sentences in the history chapter (The Stationary Office and Home Office 2022, 66). By contrast, the German course curriculum explicitly states that participants shall be made aware of the “significance of European integration in everyday life” (BAMF 2017, 33). Both Britain and Germany were presented as states which practice specific religious and cultural customs. For example, practice questions for the British test included questions on Remembrance Day, Bonfire Night, Valentine’s Day, and Father’s Day (The Stationery Office 2021, 17, 46). Similarly, the selection of “festivities” in classroom exercises focussed on Christian, Western, and royalist occasions such as a baptism, Halloween, and Bonfire Night (observation BuClass08, 18/02/2013). The cartoonish illustrations both trivialised and accentuated this narrow interpretation of what is particularly British about these celebrations. The images depicted, for instance, a heterosexual couple getting married and white children offering flowers on Mother’s Day. Moreover, the pattern of the phraseology reinforced the idea that this is the way “we” do things in the UK. Such Western cultural practices were less pronounced in Germany, where only one question in the German test asked: “When do people in Germany dress up in colourful costumes and masks?” with the optional answers being Carnival Monday and Oktoberfest among others (BAMF 2022, 98). However, the German test examined exclusively Christian customs such as Christmas, Easter, Pentecost, and Advent (BAMF 2022, 100, 108–109) and asked test candidates: “Which religion influenced European and German culture?”, expecting them to affirm that this has been Christianity, not Hinduism, Buddhism, or Islam (ibid., 108). The

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British handbook also discussed Christian customs but subsequently also included Hindu, Sikh, Jewish, and Muslim religious festivals (The Stationary Office and Home Office 2022, 79–82), so a greater religious diversity was evident in that regard in the UK. Despite these traditional, rather homogenous depictions of the UK and Germany, courses and tests also included references to some unfavourable elements of national history. For example, the British handbook mentioned the slave trade and the British empire (The Stationary Office and Home Office 2022, 42–43, 47), while the German test made explicit reference to Adolf Hitler’s transformation of Germany into a “dictatorship” (BAMF 2022, 57–58), and that the German Democratic Republic was also a “dictatorship” (ibid., 73). Yet, while the British handbook only dedicates two out of 163 pages to the topics of slave trade and the British empire, the German course curriculum spends one of its three modules on “history and responsibility” (BAMF 2017). In this module, the participants are intended to learn to recognise the “incompatibility” of “national-socialist ideology” with the democratic FRG and the “implications” of the GDR’s state apparatus on “human rights” (ibid. 29). As one teacher pointed out in a Hamburg classroom, “Germany is still a relatively young democracy” (observation HaClass02, 30/07/2013). Thus, elements of the state’s self-critique were less pronounced in Britain than in Germany, but the presence of these self-reflections leads to the second overall presentation of Britain and Germany as modern, diverse states, as is discussed further in the following section. The self-presentation of the UK and Germany as modern, diverse states relies on three main features: the rule of law, their commitment to equality and human rights, and the welfare state, each of which is now discussed in turn. In a classroom in Hamburg, for example, the teacher wrote on the whiteboard that “Germany is a state ruled by law” as well as “checks and balances” (HaT5, observation HaClass03, 16/08/2013). She further explained to the class that in Germany “unlike in a dictatorship, we separate powers. The state and politicians, too, must obey the laws.” (ibid.) In order to illustrate the application of law and to rehearse vocabulary such as “process” and “court”, the teacher then asked the students to simulate a jury case. She distributed the different roles of a “defendant”, “prosecutor”, “barrister”, “witness”, “judge”, and “juror”, stressing that

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“jurors” are recruited by ballot from among the “ordinary people”. This made the jurisdictional system in Germany appear to be in touch with those subject to it.3 Similarly, a teacher in a classroom in Brent did an exercise with his class which simulated a “mugging” incident and asked students to rehearse giving an oral report to the police (observation BrClass02, 12/11/2012). While this exercise was primarily aimed at students exercising their speaking skills, it also presented the UK as a state with a functioning police system, and familiarised students with the idea of contacting the police when they need to. Another exercise in a classroom in Burnley aimed to train students in recognising road signs and the duty of wearing a seatbelt, emphasising that public traffic is subject to regulations in the UK (observation BuClass05, 21/01/2013). The courses and tests also presented the UK and Germany as liberal states which grant and protect civil rights, and that respect equality and human rights. For example, both tests discuss freedom of expression and press freedom: Which of the following statements is correct? A. A free press means that what is written in newspapers is free from government control. B. A free press means that newspapers are given out free of charge. (The Stationery Office 2021, 160) In Germany, people may openly criticise the Government because … …freedom of religion is in force here. …they pay taxes. …people have the right to vote. …freedom of speech is protected here. (BAMF 2022, 2)

The content of these two questions is similar; however, the design of the British question checks that applicants select the correct statement,  However, jury trials are in fact not part of the German justice system and it remains unclear why the teacher decided to do this exercise. 3

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whereas the German test question explains the reason for it. This is also the case for questions on gender equality: Which of the following statements is correct? A. In the UK, pregnant women have the same right to work as anyone else. B. In the UK, employers have the right not to employ pregnant women. (The Stationery Office 2021, 179) A woman in Germany loses her job. Which reason for this redundancy is unlawful? • • • •

The woman has been ill for a long time and is not fit for work. The woman often arrives late at work. The woman does private business at work. The woman is pregnant, and her boss knows that. (BAMF 2022, 39)

Both of the above-cited questions simulate a situation in which a woman loses her job because she is getting married or having a child. Again, the German test examines whether candidates understand the reason for this discrimination while the British test expects candidates to confirm the correct legal norm, here the protection from discrimination on grounds of gender. The current edition of the British practice questions has been amended and now includes a brief explanation and reference to the handbook for every sample question. Germany was presented in classes as granting entry to refugees fleeing from political persecution. In a classroom in Dresden, the teacher checked that the students knew the meaning of “asylum”, with the following conversation: Teacher: Student:

What does asylum mean? If I have a political problem, I can call Germany and I can come. Teacher exclaimed: Don’t call, you can come straight over! (observation DrClass02, 15/05/2013)

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The above examples from German classrooms were all based on exercises from course textbooks recommended by the BAMF or from the test questions, meaning that while the teachers had decided to use them in the classroom, they did not create them. In Britain, the topic of equality and human rights was less pronounced in the classrooms but emerged spontaneously on a few occasions initiated by teachers. For example, a teacher in a classroom in Brent explained to students the situations in which they may prefer the title “Ms” as opposed to “Mrs” and “Miss”: “If you don’t want to tell if you are married or not, if you think this is private information. Some women don’t want to tell if they are married or not, because ‘Mr’ does not reveal this information either” (BrT05, observation BrClass04, 26/11/2012). This female teacher thus informed her (entirely female) class that they have a right to privacy and can opt out of the discriminatory cultural practice which publicly distinguishes married women from unmarried (and hence still “available”) women, and she also implicitly pointed to the male privilege inherent in the fact that no vocabulary exists to infringe upon men’s privacy when directly addressing them. The UK and, especially, Germany were also presented as welfare states providing public services and allowing workers’ self-organisation. For example, both British and German test questions highlight the existence of trade unions as legitimate forms of workers’ self-representation. Yet, whereas the British study guide informs migrants that “trade unions were too powerful in the 1970s” (The Stationary Office 2022, 71), a German test question explains that trade unions are “pressure groups” of employees (BAMF 2022, 38). More significantly, after the cutting out of two chapters on “Everyday Needs” and “Employment” from the two initial editions of the Life in the United Kingdom handbook, the current third edition significantly reduces information relating to public services and welfare. The German test includes questions explaining that Germany provides “social security” through national insurance, health insurance, and care insurance (BAMF 2022, 13–14, 17). Other questions more explicitly list the funding and/or provision of transport and education, child care benefits, museums and sport as “responsibilities” of the state (ibid., 17). While museums and sport, arts and culture are also topics of the Life in the UK test, these are presented as an “important part of

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British culture” (The Stationary Office and Home Office 2022, 90) and are hence used to illustrate specific features of the British nation, rather than to explore its social economy. Similarly, the handbook presents the National Health Service and social security from “the cradle to the grave” as specifically British achievements (The Stationary Office and Home Office 2022, 60–61). In the German case, the theme of workers’ rights explicitly included foreign workers’ rights. For instance, a teacher in Hamburg discussed the topic of “social market economy”, which is suggested by the textbook (Gaidosch and Müller 2013, 23–25). She explained that trade unions “help to organise strikes, help employees to get their rights” and pointed out the “advantage” of collective representation, for example, in negotiating “labour agreements” (Tarifverträge) to prevent the reduction of wages. While the textbook confirms what the teacher said, that is, that “The [German] state respects workers’ rights” (ibid. 25), the teacher’s own explanation and interpretation of key terms such as strike went further: “What is a strike? We decide not to work and to demonstrate to our bosses that we have power, too” (HaT5, observation HaClass03, 16/08/2013). In this instance, the teacher in this classroom discursively created a newly imagined “we” uniting workers against employers with the potential to transcend nationalities. Another exercise in the same classroom aimed to familiarise students with a form of workers’ representation within a company, the workers’ council (Betriebsrat) (Gaidosch and Müller 2013, 24). In the fictitious example, an Asian employee sought advice from his workers’ council representative (a white German woman) because he had received a warning which he thought was connected with him being a “foreigner” (Ausländer). The coursebook thus presents Germany as having concrete mechanisms in workplaces to deal with racist discrimination against migrant residents in Germany. The tests and courses present Britain and Germany as traditional, homogenous nations on the one hand, and as modern diverse states, on the other. Thus, the test questions and course exercises refer to national symbols such as the flag, anthem, or cuisine. Knowledge of Christian festivities and Western cultural customs is also examined. While the British handbook acknowledges religious diversity (unlike the German test), the German course and test place a greater emphasis on the

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European Union than is the case in the UK. The historical knowledge is focussed on the twentieth century in the German case, whereas the UK is presented as a nation with an ancient history and landscape. This traditional presentation of the two states resonates with the rationality of naturalisation as a privilege and “sovereign grant”. The modern presentation, on the other hand, depicts Britain and Germany as states which are ruled by law, and committed to equality and workers’ rights. While in the UK the welfare state is presented as a national achievement, the German test and course are designed to actually enable applicants to access the resources and services provided. This relates to the rationality of naturalisation as an entitlement and empowerment which was more prevalent in Germany than in the British case. The courses and tests not only present views of the two states but also recommend self-guidance which reflects this ambivalence, as the next part demonstrates.

Suggested Self-Guidance The courses and tests included disciplinary elements which were both planned and unplanned. For example, before the start of a session in Brent, the teacher happened to spot a student’s class folder, whereupon he seized it, held it up, and turned to the class: “We’re in Europe here. Which way do we have our folder?” (BrT02, observation BrClass02, 12/11/2012). The student immediately reacted and, upon receiving back her folder, took out all the sheets, hole-punched them on the other side, and inserted them back in the folder, this time from the left to the right. Such a direct call to adopt the way “we” do things “here in Europe” was exceptional, but it reveals that certain everyday practices are understood in national and cultural terms, in this case through a European lens, and it is non-negotiable that these should be followed. Such disciplinary reminders were also found in the area of waste recycling, for example, in a homework exercise distributed in a classroom in Dresden (observation DrClass03, 22/05/2013). While the exercise explained that waste is recycled in differently coloured bins, it also presented “Germans” as a distinct ethnic group united by their shared dislike of “foreigners” and a national need, if not obsession, to obey rules to such

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an extent that they will check and remind their new neighbours how to recycle waste properly. The recycling reminder was thus coupled with a rather unfavourable, possibly self-ironic presentation of “the Germans” similar to the self-critique in the presentation of German history discussed above. The tests also include suggestions regarding self-conduct and “responsibility” as a citizen or permanent resident. For example, British applicants should be “looking after the environment” (The Stationary Office 2022, 25), know the responsibilities of dog owners (ibid., 108), and should not drink in “alcohol-free zones” (ibid., 122), while German applicants are reminded that the law requires them not to make noise after 10pm at night (BAMF 2022, 99). One exercise used in a class session in Burnley perhaps most comprehensively spelled out what the “active” and “good” citizen “is” and “should do” in a list of concrete attitudes, actions, and habits which included assisting “the elderly”, “the disabled”, “children and animals”; making donations; displaying “good manners”; “always pick[ing] up litter”; and “always pay[ing] their bills and taxes” (observation BuClass10, 26/02/2013). This exercise ended with the question, stated in capitalised letters: “ARE YOU A GOOD CITIZEN?”, asking the course participants to assess themselves according to the suggested criteria. This led to the following discussion in one of the student groups: Student A turned to student B:

“Are you a good citizen, (name of student B)?” Student C commented (laughing): “I don’t think so!” Student B muttered: “I don’t know.” Student C confidently continued: “I am a good citizen because I always look after my children (laughed).” (observation BuClass10, 26/02/2013)

As they had been instructed, the students assessed each other with regard to whether they thought they were “good citizens”. Before student B could answer, student C interjected and discursively denied that student B was a “good citizen”. Student B consequently did not claim to be

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a “good citizen”, but student C did, referring to her motherhood. In making this claim, she could draw on one of the sentences suggested on the sheet: “By being a good parent I am a good citizen”. Whether student C fully believed what she said, or was just joking, is unclear. However, this exercise facilitated a situation where students could claim and deny each other the categorisations suggested by the teacher based on the materials suggested by the state. These categorisations are not value free. Some students were encouraged, while others were possibly discouraged from thinking of themselves as “good citizens”. Volunteering (Ehrenamt) is a common topic in tests both in Britain (The Stationery Office 2021, 180) and in Germany (BAMF 2022, 49) and was particularly evident as a suggestion in the classrooms. One teacher in Burnley showed a YouTube video4 to her class which portrayed an elderly Muslim woman from Iran, now resident in Bradford (observation BuClass10, 26/02/2013). The film followed the woman as she carried out voluntary work in four (!) different charities (a legal advice centre, a women’s group, a soup kitchen, and a charity shop) during what was, for her, a typical day. At the end, the film revealed why the woman appeared to be a Super Citizen: she felt the need to keep herself “busy” (video transcript), to take care of her mental health while waiting several years for the Home Office’s decision on her application for asylum. Yet, the film failed to mention the structural constraints imposed by the state which had aggravated her situation as she, like every asylum seeker in Britain and in Germany, does not enjoy the immediate right to work. Volunteering is the key element in the courses’ definitions of “integration” in Germany and “good” or “active citizenship” in Britain. As one teacher told her class in Hamburg: I always say, integration does not only mean to know the other culture but to actively participate in [communal] life through volunteering. Many say ‘computer games, television, I am a housewife, my husband is working’— but that is not enough. (HaT02 in observation HaClass01, 30/07/2013)

 ‘One Day in May’ by Our Lives Project, 10 min, uploaded 3 Jul 2009, http://www.youtube.com/ watch?v=PGMw1YB9nx4&feature=youtube_gdata_player (accessed 16 March 2015). 4

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The teacher also suggested that it is common for mothers to help out in their children’s primary school kitchen or library. Similarly, another teacher in Burnley encouraged her students to work as volunteers, for example, in care homes, museums, and primary schools, as these institutions “don’t get much money” (BuT02  in observation BuClass10, 26/02/2013). It was therefore implied that the students should not expect the state to fully provide these public services. While it was suggested that it is not acceptable for a woman to say “I am a housewife”, the withdrawal of the neoliberal state in the funding or provision of education, culture, and welfare was not openly criticised. The responsibility for maintaining the common good was thus shifted to individual citizens, in this case the predominantly female course participants. Citizenship applicants are encouraged to vote and to stand for election. In the German case, this suggestion was explicitly extended to migrants not yet holding German citizenship. To this end, the teachers in classrooms in Germany informed and encouraged their students to exercise their right to political self-representation. One textbook exercise (Gaidosch and Müller 2013, 9) used in a session in Hamburg asked students to self-assess their knowledge about the political system in Germany in the form of a quiz (observation HaClass01, 30/07/2013). As it turned out, all fifteen students had assumed that “Non-German citizens are not allowed to participate in any election” and had marked this sentence as true. The teacher corrected this collective error, explaining to them that “You have the right to elect your representation, the Foreigner Council”. Almost in passing, the teacher thus informed her students about the existence of a political body representing them as non-German citizens. Teachers encouraged their students not to see themselves as disenfranchised because of their non-citizenship status, but instead to become politically active in these Councils. In a classroom in Dresden, the teacher explicitly told students that they not only can, but should, become politically active by joining and standing for vote in the Foreigner Council (observation DrClass01, 06/05/2013). During a student-led discussion, some students shared their personal experiences of interacting with the local Foreigner Authorities; for example, when trying to marry their German partners. All the students in this discussion quickly agreed that the Dresden Foreigner Authorities cause (rather than solve) issues. Upon

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hearing the difficulties students reported about the local Foreigner Authorities’ management of bi-national marriages, the teacher spontaneously exclaimed: Teacher:  “Then get active! Take part in the Foreigner Council!” Student (continued): “After that, we filed a complaint and they changed the system.” (clenching his fist) Teacher: “Well done!” (observation DrClass01, 06/05/2013)

This exchange can be seen as an instance where the teacher suggested and praised the fact that students speak up against, and work towards changing, state authorities providing ineffective and/or unhelpful services to “foreigners”. The suggestion of claiming one’s rights was particularly present in Germany, as the following section explores. Unlike the British test, the German test educates applicants as to how to claim their civil and consumer rights. Question 276 rehearses how to deal with a case of discrimination by state authorities by exploring what to do when one is “ill-treated” by a “German authority” (BAMF 2022, 102). Similarly, question 283 asks how to react when one mistakenly receives a wrong bill from a “German authority” (ibid., 104). These questions can be seen as techniques of empowerment. By indicating the right and wrong actions to adopt in response, they equip applicants with the knowledge and confidence to complain and criticise wrongdoing, even when it has been committed by the state. And yet, the institutional discrimination that these two questions hint at is presented as being caused by individual failure, not by structural factors. The German test question 290 informs applicants of their right to return faulty goods, thus providing them with a self-help tool against ill-­ treatment by companies on the market (BAMF 2022, 107). Similarly, an exercise used in a classroom in Dresden prepared participants for uncooperative German officials as the text explained the meaning of the German term Zuständigkeit, which may be translated as responsibility, competence or authority:

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Zuständigkeit is a key term in Germany. If you want to obtain anything, you have to find the authority that is the office and the officer in charge. The phrase ‘That is not my responsibility’ may have two different meanings: • It is helpful advice because the official is honest about the limits of his/ her competences and points you to the right place that has the capacity, authority (and willingness) to help you further. • It is an excuse on behalf of the official who does not want to openly admit that he/she doesn’t want to take on your case. (Textsheet, observation DrClass03, 22/05/2013)

The above text aims to make the migrant course participants independent citizens who can handle persons of authority. It equips them with the knowledge of how to successfully interpret the administrator’s replies and navigate a bureaucratic, potentially hostile system. This relates to the problematisation of the figure of the dependent citizenship applicant and the rationality of entitlement. The topics of gender equality and human rights were particularly prevalent in Germany, both in the test and the classroom. The German test made clear that violence against children as well as polygamy are prohibited by law (BAMF 2022, 94, 101); for example: A 22-year-old woman lives together with her boyfriend in Germany. The woman’s parents disapprove of this arrangement because they don’t like the boyfriend. What can they do? • • • •

They have to respect their daughter’s decision as she is of full age. They have the right to take her back to the parental home. They can report their daughter to the police. They search for another man for the daughter. (BAMF 2022, 99)

Two exercises used in a classroom in Dresden aimed to create an awareness of gender equality (observation DrClass01, 06/05/2013). The first exercise, “How do people in Germany live together?”, confronted students with seven photographs representing different constellations of intimate social relationships (Feil and Hesse 2012, 138–139). The depicted relationships ranged from the nuclear family or three

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generations living together to more recent models such as unmarried couples, single parents, patchwork families, or same sex couples. Having shown them the photographs, the exercise then asked the students to discuss in groups what a family means to them and to order the given photographs on a scale between “This is not a family for me” to “This is a family for me”. The second exercise, “Who is supposed to do that? Role allocation in the family”, showed cartoons depicting various forms of housework, for example, cooking, washing, and food shopping (Feil and Hesse 2012, 142–143). This exercise asked students “Who does that in your home?” and, as in the first exercise, suggested that the students arrange these household duties on a scale from left to right, associating each activity as female or male. Clearly, both exercises aimed to promote an understanding of gender and sexual orientation equality among course participants. However, the discussions that followed the first exercises also produced unintended effects and tensions among them. For example, one elderly woman from China stated that for her, a “patchwork family” is “too big”, that it has “too many children”, and that children should grow up and leave home first before parents choose new partners. Her idea of a family was that of a nuclear family. She then placed the photograph of the homosexual couple at the far end of the scale and said: “This is impossible for me”. The rest of the class had remained quiet until that point, but upon this remark, one participant incredulously asked “Do you really believe that?”. The elderly woman from China was clearly in a minority with her traditional ideas of a family in this classroom of predominantly young, highly-qualified participants with transnational biographies. Before the student could defend herself, the teacher intervened, possibly anticipating a controversial discussion, and reminded everyone in a conciliatory tone that “We all need to respect each other”. Like the “good citizen” exercise discussed above, this exercise had created tension in the classroom. The unanticipated dynamics of students’ interactions effectively marginalised some students such as the Chinese elderly lady and a middle-aged man from Moldova who denounced the increase of single parents. These were implicitly or explicitly branded as “not good”, and therefore as “undemocratic” citizens.

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5.2 Citizenship Ceremonies As in the tests and courses, the self-presentations of the British and German states reflected an inherent tension of the concept of the nation-­ state. On the one hand, the state was presented as a traditional nation recognisable by its flag and music, while on the other hand, it was interpreted as a liberal democracy that has benefitted from the influence of immigration. Unlike the courses and tests, the ceremonies emphasised the local state and thus to a greater extent negotiated the relationship between the local and national/federal levels of the state. The local both contested and amplified the national, as this part of the chapter demonstrates.

Presentation of the State The ceremonies presented the state as a traditional nation through the sound of the national anthem, which was heard in every ceremony albeit in different forms. While “God save the Queen” was played when the registrar pressed the button of a portable CD player in the British ceremonies, the music of the national anthem in the two German locations was played live by musicians present in the room. The character of the German anthem thus changed according to the invited musicians (ranging from a solo pianist to a school string orchestra, and to a rhythmic Klezmer band), whereas the recordings in Britain ensured the same triumphant drums and brass sound throughout each of the ceremonies. On a special occasion, a local black school girl was invited to sing the anthem in Brent (video 05/10/2007). Individual registrars in Britain do have some leeway in the regulation of sound. For example, in Brent, the CD player could be placed in the middle or in a corner of the room, and the volume could also be adjusted manually. I once observed a more experienced registrar training a new one regarding how she plays the anthem: BrAdmin3: “I usually stand by it [the recorder placed on the table in the centre of the chamber] and sing to it”.

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BrAdmin6 (embarrassed): “Oh my God!” BrAdmin3 (continues): “And then I turn the volume up to five [the highest possible volume]”. (presses Play and turns up Volume, which makes BrAdmin6 jump back as the drums start playing). (observation BrPres4, 18/09/2012)

The anthem was usually deployed as a tool of national self-­presentation, except in Hamburg where the ceremonies concluded by first playing and singing three verses of the local Hamburg hymn (Hammonia—Stadt Hamburg an der Elbe Auen) before the first verse of the German national anthem. Thus, the Hamburg ceremonies combined the national with the local even at this traditionally national moment. National flags were another tool for national self-presentation in all the observed ceremonies, but their size, location, and number varied. A large British Union Jack flag was present in ceremony rooms in Brent and Burnley; in Brent this was placed in the centre of the room hanging down from the speakers’ podium in such a way that it was impossible not to see the full flag as opposed to the local flag of Brent, which was kept on a flagpole in a corner and thus less visible. In Burnley, the UK flag hung from a standing flagpole so that the full cross was not visible. In Hamburg, two German flags framed the central seat of the podium, themselves flanked by equal-sized Hamburg and European flags. This produced the effect that the local, national, and supra-national flags were all equally visible. Furthermore, a 1.50 metre large model of a ship’s anchor was located most visibly at the centre of the stage and painted in the black-­ red-­yellow national colours—this central item on stage thus ostentatiously linked the national to the local in a way which was unique across the locations. In Dresden, no German national flag featured as part of the official room décor, and only a Saxon flag and map were displayed in the ceremony room behind the speakers. The Dresden particularity in the use of flags became noticeable after the ceremony when organisers handed small German flags to participants and guests alike, to take outside and home. Additionally, during the 2012 European football championships, some children returned from the child care room with small German flags painted on their cheeks (observation DrPres1, 16/06/2012). So,

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even the minor citizens who had missed the spectacle of the ceremony were carrying and displaying German national flags when they departed. These practices in Dresden produced a more individualised display and a more bodily-focused experience of national symbols than in the other three locations. The British ceremonies also presented the UK as a monarchy through the obligatory display of a photograph of Queen Elizabeth II, another central element of the room décor. The photograph used in Brent was out-of-date, showing a young Queen, and was hardly noticeable as it was hung high on the back wall of the room in the distance, where it presumably had been located for decades. In Burnley, the framed picture was usually kept in a storage room and only taken out for citizenship ceremonies, when it was placed right next to the dignitaries. In that picture, the grey-haired Queen had a friendly smile and was at eye level. The image was a life-sized photograph of her wearing a glittering silver gown at her 2012 Diamond Jubilee.5 This perhaps made the British Head of State and Head of Church appear more approachable, and many new citizens posed for a picture next to the Queen’s photograph after the ceremony. The regional self was also represented through culinary experiences such as “Saxon potato soup” served among other dishes after the Dresden ceremonies, and national and local symbols were also found on the ceremony gifts given to the newly-naturalised citizens. Citizenship applicants who attended their ceremony in Brent received a heavy Bronze medal presented in a jewellery box like a ring or necklace, not on a string like at a sports competition, which formed the basis of frequent jokes from the registrars and speakers (see below). The medal itself displayed the national Home Office logo imprint on the front and the Brent Council crest and motto on the back. The gift is symbolic, and yet to some citizenship applicants it means more than just a souvenir of their ceremony. One registrar in Brent recalled with amusement: “One day a woman came up to me, all nervous, and said: ‘I’ve lost my medal, how can I prove I am British now?’”  This is the only photograph of the Queen approved by Buckingham Palace for use in Citizenship Ceremonies: http://royalimages.co.uk/government/government-citizenship.htm (accessed 1 March 2016). 5

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(BrAdmin6 in observation BrPres4, 18/09/2012). This implies that the object which is offered as a gift by the local state to new members may be perceived as another means of examination by an individual applicant. In Burnley, citizenship applicants are also presented with a medal, which displays a rose. Initially, they were given a porcelain box of “fine bone China made in England”, with a red rose on the lid. Hamburg ceremony organisers offered a miniature of the black-red-yellow anchor to pin to a bag or jacket to all the ceremony guests, as well as a gift book about the Town Hall. In 2013, Dresden started to offer a professional photoshoot for ceremony participants holding a model shape of Saxony’s territorial borders, thus representing a local yet personalised item to take home. These gift items equipped participants with an individual object commemorating their (national) citizenship ceremony even though they mainly, or solely, displayed local features. These items also served to promote and advertise the ceremonies afterwards, as participants could show them to their friends and family or visibly carry them around, with items like the Hamburg anchor pin. In the UK, the sense of past state power was also visible in the clothes that invited guest speakers at British ceremonies were wearing. In Brent and Barnet, the Mayor attended dressed in a long red gown with fur lining, white quilling, and a heavy gold chain. Before they entered the room, the registrar asked everyone to stand up. This created a stage, as though the monarch herself was about to walk into the room. The Mayor of Brent referred to himself as the “First citizen” and “number one citizen” in the Borough, thus highlighting the hierarchical, feudal origin of British citizenship. In Burnley, one male dignitary wore a military uniform including a sword (which must have passed the security control), and the female dignitaries wore a special medal, ribbon, and hat as representatives of the Monarch. These theatrical elements were only found in the British ceremonies, where they presented the local state as a military and royal state. Traditional local and regional features and sources of pride in the state were also stressed in the ceremony speeches. Sometimes, these local aspects reinforced or amplified the national state. For example, the script for dignitaries in Brent proudly presents the local authority as the “home” of the English national football stadium, Wembley. Burnley was

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presented by its situation in a region characterised by close ties from medieval times onwards to the ruling royal family. In this instance, a region within Britain (Lancashire) was being defined by a national feature (the monarchy). Thus, a dignitary emphasised that: […] a Duke of Lancaster eventually became King and from that day to this, the reigning monarch has not only owned land in Lancashire, and indeed the Queen owns a lot of Lancashire, but whoever is the monarch retains the title Duke of Lancaster. (BuCCGC2 in observation BuPres3, 29/01/2013)

This created the impression that the national Head of State is (at least partly) defined by belonging to the regional County of Lancashire which, by implication, gives the region a particular significance within the wider nation. Moreover, the space in which the ceremonies took place reinforced this sense of local historical importance. The ceremony rooms in Brent and Hamburg both inspired a sense of awe through their sombre light (from having few windows), wood-panelled walls or ceilings, and elevated front podiums, including one large seat from which, like from a throne, a person in power can oversee the whole room. By contrast, the rooms in Burnley and Dresden were unlevelled or circular, light functional rooms in newly-built buildings, so they presented the state as more modern, transparent, and equal (see the following sub-section). As in the courses and tests analysed above, the German ceremonies presented the national and regional state with some self-critique. For example, Saxons were presented as “reserved” (observation DrPres1, 16/06/2012) and as “shy travellers” (documentation of Dresden ceremony 05/06/2010). According to this narrative, Saxons needed a nudge, for example from immigrants, to become more curious about foreign people and places. While this narrative possibly had the effect of trivialising racist attitudes among Saxons, the presence of hostility towards immigrants was also to some extent acknowledged among the wider German civil society. One invited guest speaker in Hamburg mentioned “the anxiety of foreign infiltration” that some “try to consciously fuel”, implicitly referring to Thilo Sarrazin (observation HaPres1, 17/05/2013).

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Another invited guest speaker in Dresden made the explicit criticism that the neo-Nazi party NPD (Nationaldemokratische Partei Deutschlands) officially held seats in the Saxon parliament, meaning that every day they sit and vote from the very seats on which the new citizens and their guests were sitting (observation DrPres1, 16/06/2012). These critical voices were, however, singular, and often limited the problem of racism to the individual level, rather than seeing it as a structural problem. Contrary to the above-described presentation, the UK and Germany were also characterised as democratic, ethnically diverse, and modern states, especially through the spaces and speeches. Most of the ceremonies (except in Burnley) were held in the buildings of the actual seat of the local or regional legislative and/or executive powers. In Brent, the observed ceremonies took place in the Borough’s Council Chamber and several speakers emphasised during the ceremonies that this is the place where the laws are made that affect new citizens, as the following speech extract demonstrates: “This is the Council Chamber, this is where all major decisions get taken, to raise your taxes, where lively debates take place and bananas and eggs are thrown” (laughter in the audience) (BrCCGC4, observation BrPres01, 11/09/2012). This speaker thus made the about-to-be-admitted citizens and their guests aware that the room in which they were obtaining British citizenship is also the site of local political self-representation and self-rule. The Dresden ceremonies take place in the Saxon State Parliament’s plenary assembly room. A senior civil servant in Dresden put the room’s significance into words by explaining that the Saxon Landtag building is “the best Saxony can offer […] the first address of the state”, thus suggesting that it is a highly appropriate place to welcome new state members (observation DrPres3, 31/08/2013). Similarly, in Hamburg, citizenship ceremonies are held in the Town Hall’s Large Ceremonial Hall, where foreign Heads of State are normally received. The Ceremonial Hall is located within the Town Hall, so it connects the local state’s legislative and executive powers as the building accommodates both the parliament and government of Hamburg. All the observed ceremonies presented the local or regional, more than the national, state as explicitly embracing ethnic diversity. The ceremony programme handed to Burnley ceremony participants presents Lancashire

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(not Burnley) as “home to a diverse population with people settling from all over the world”. This is also affirmed by the script that invited guest speakers in Burnley are suggested to use: Lancastrians are people of contrasts. For over two thousand years, people have come from elsewhere to settle in the county, enriching our culture and experience. Today, many Lancashire folk have origins in Ireland, India, Pakistan, Bangladesh, the Caribbean, and Eastern Europe—yet all play their part in the county’s life, and all are Lancastrians.

Such emphasis on a long history of immigration was also found in the Hamburg and Dresden speeches. For example, Olaf Scholz as then SPD First Mayor and organiser of the Hamburg ceremonies regularly pointed in his speeches to the arrival of “Protestant religious refugees” from the Netherlands in the sixteenth century, and to Spanish, Portuguese, French, English, and Dutch merchants throughout the seventeenth and eighteenth centuries (HaPol2, observations HaPres1, 17/05/2013 and HaPres2, 30/08/2013). Hamburg was repeatedly presented as a “gateway to the world” (Tor zur Welt) through its international harbour (Hamburg ceremony documentation, 14/12/2009, 23/04/2010, 19/08/2011). This also reinforced the self-presentation of Hamburg as a Protestant state and an economic hub through the harbour. In Dresden, the CDU president of the Saxon Parliament and “patron” of the ceremony affirmed the Saxon state’s “aspiration” to be a “welcoming society” (observation DrPres3, 31/08/2013). The CDU Saxon Minister of the Interior and co-organiser of the Dresden ceremonies confirmed this aspiration and presented it not only as a present characteristic of the local (Dresden) and regional state (Saxony), but also as a historical one: What would Dresden be without the craftsmen? What would Leipzig be without the international merchants? What would Saxony be without foreign companies and what would the universities do without foreign students? Saxony was, and remains, an open country. (Observation DrPres1, 16/06/2012)

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Another speaker in Dresden even further emphasised that Saxons are made up of immigrants: “I don’t know if there are even one per cent of true Saxons. At some point, all of them came over” and went on to mention that the very first settlers were indeed “Slavic Sorbs”, one of the officially recognised national minorities in Germany (Dresden ceremony documentation, 21/05/2011). Ethnic diversity was also a significant feature of the self-presentation in Brent. This was, however, done by pointing to the present, not to the past. The script suggested to Brent dignitaries reads as follows: Brent’s most striking feature is undoubtedly the diversity of its residents. The population is one of the most culturally and racially diverse of all local authorities in England and Wales. Black and Asian communities account for over 50% of the local population and a further 10% are of Irish descent. Each ethnic group enriches the cultural life of the Borough and we are very proud of the contribution they make to life in this community. Indeed, over the years we have had annually elected mayors from a variety of backgrounds. It may also surprise you to learn that over 130 languages are spoken in Brent. We are also very proud that this Council employs an ethnic majority workforce to serve this diverse population and we are one of very few large organisations that have managed to achieve this significant milestone. (Brent script for dignitaries)

A guest speaker referred to Brent as “a mini United Nations” and proudly stated that “we speak more languages than they speak in Brussels” (BrCG4, observation BrPres10, 16/10/2012). Finally, this embrace of ethnic diversity was linked to a narrative of social, political, and technological progress. These achievements were partly recognised as having been driven forward by immigrants and foreigners. While social and political progress was emphasised in the two superdiverse, metropolitan research locations (Brent and Hamburg), the notion of technological progress was particularly present in the two less diverse and de-industrialised research locations (Burnley and Dresden). For example, Hamburg was presented as a progressive melting pot due to its harbour while Lancashire was presented as the home of the industrial revolution:

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Two hundred and fifty years ago, this [Lancashire] was the birthplace of the Industrial Revolution. New technologies, invented by Lancashire people, transformed the society and economy not only of the county but also of England and the world. It was in Lancashire that the modern world was born. (Burnley script for dignitaries)

Similarly, guest speakers in Dresden referred to Saxony as the “industrial heartland of Germany” (05/06/2010). A few features not found in any of the other three locations made Dresden appear particularly inclusive. The Saxon Foreigner Commissioner and co-organiser of the ceremony greeted each of the several hundred invited participants with a personal handshake at the entrance of the building upon their arrival. The ceremony thus started with a personal welcome for all, and it also ended with a shared experience. After the formal procedure and buffet, the organising staff team handed out colourful balloons to children and adults alike, and the Foreigner Commissioner personally made sure that nobody missed the collective release of the balloons outside on the Parliament square, as a symbolic commitment to, and publicly visible affirmation of, diversity to conclude the ceremony. Large colourful balls were also used inside the ceremony plenary room during a clown pantomime (observation DrPres1, 16/06/2012). This element of humour was a deliberate, significant element of the ceremony programme and was allocated one third of the entire ceremony (DrPol1, conversation 18/06/2012). One of the Dresden ceremonies I observed included music performed in languages other than German, including English and Thai (16/06/2012). And finally, while in general children were more (Burnley, Hamburg) or less (Brent) tolerated inside the ceremony rooms, Dresden was the only place where the organisers offered simultaneous childcare in an adjacent room free of charge so that parents could attend their ceremony without having to worry about their child. The presentation of the state in the observed ceremonies was similar to that in the courses and tests, as the UK and Germany were characterised as traditional nation-states recognisable by their flags and anthems, yet they were also interpreted as modern states shaped by immigration. Unlike the courses and tests, the technique of the ceremonies is only applied to successful citizenship applicants, as the state already decided to

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accept these new members. Accordingly, the self-guidance that speakers recommended at ceremonies idealised, rather than disciplined, citizenship applicants, as naturalised citizens were called upon to compensate for national-born citizens’ deficits in the political, economic, and cultural spheres of the state, as the next part highlights.

Suggested Self-Guidance Firstly, the ceremonies held citizenship applicants accountable with regard to political participation, that is, to enhance democratic self-­ representation by using their right to vote. Calls to exercise their newly-­ gained right to vote were a routine act in the UK, as the Conservative British Home Secretary at the time of observation, Theresa May, urged naturalised citizens in a written message handed to every successful British candidate along with their certificate of naturalisation that: “I hope that you will use your vote, take part in the political process, and play an active part in your local communities” (Home Office n.d.). The call to vote was sometimes linked to actual upcoming elections, for example in Dresden: “You now have the active and passive right to vote and I do hope that every one of you will make use of it and cast your vote on 22 September at the federal election (Bundestagswahl)” (observation DrPres3, 31/08/2013). As the last quote indicates, the suggestion that new citizens make use of their right to vote referred to the notion of full suffrage. Naturalised citizens’ assumed foreignness and the knowledge supposedly derived from it was instrumental in this plea to become politically active: “Do become members of a democratic party. Enrich us with your cosmopolitan perspectives, so that we can gain new insights […]” (ibid.). Secondly, citizenship applicants were held accountable for strengthening the local, regional, and national economy by providing their paid or unpaid work. The importance of unpaid labour through voluntary work in the informal care and civil society sector was stressed in every ceremony observed in this research. For example, the speakers suggested to the newly admitted citizens that they join the civil fire brigade, that they help out at school, or that they assist elderly neighbours:

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Since the Olympics last year there has been a boost for voluntary work […] So if you can find some spare hours in probably what are busy lives, you may be able to squeeze some time into serving people in your community. It can be done informally like helping a neighbour with cooking or shopping or taking them to hospital appointments […] So I do hope that you will enable the volunteer spirit to shine. (observation BuPres5, 12/02/2013)

Furthermore, citizenship applicants were valorised as highly skilled workers: “We need foreign specialists in addition to what we can ourselves achieve”, and “This potential has to be used to the maximum” (observation DrPres3, 31/08/2013). These speech acts reduced “new citizens” to the workforce they represent, which should be exploited in the interests of the national economy in a competitive global market. Thirdly, citizenship applicants were held accountable for enhancing the state’s cultural diversity. They were expected to speak English or German in addition to keeping their supposed previous languages and cultures. Successful citizenship applicants were generally seen as possessing multiple “cultures”, a feature which was regarded as a benefit and “enrichment” to the state. Thus, ceremony participants were urged to maintain and nurture their “cultural identities” in addition to the new British or German identity that they had supposedly adopted through their naturalisation. The suggestion to practice multiple cultures, for example, to “nurture your own traditions, keep your own language because multilingualism enriches our country” (observation DrPres1, 16/06/2012), is based on the assumption that successful applicants have acquired the language, self-identified with the new state, and found a “home” (Heimat) in Germany (observation HaPres1, 17/05/2013) or become part of the “British family” (observation BrPres2, 12/09/2012). The expectation is therefore that naturalised citizens combine the “cultures” associated with their citizenship of birth and of naturalisation: Today we are not asking you to lose your heritage or country of origin, your language, your culture, your lifestyle. But what we are asking you to do is move forward with the British culture. You are asking to become British here today, so there is something about our culture, our lifestyle,

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our language that you like. So, we are asking you to move forward together with both of those cultures. (observation BrPres2, 12/09/2012)

It is important to note that Muslims were being largely ignored in these calls to enhance the state’s cultural and religious diversity. Only one of the ceremony speakers observed in Brent mentioned the topic of Islam. He concluded his speech by citing from the Quran “Be a community that stands for what is good, what is right, and forbids that is wrong” (BrPres8, observation 09/10/2012). While this suggestion may be read as an attempt to present Islam as a natural part of Brent’s religious diversity, this quotation was followed by a list of appeals to “respect other people’s culture, their values, their standards” (ibid.) and therefore appeared rather like another reminder of self-disciplinisation directed explicitly at the Muslim candidates among the citizenship applicants assembled in the room. The three main features of the Super Citizen subjectivity characterise naturalised citizens as a political, economic, and cultural asset to the nation-state, and expressly make them responsible for utilising their potential in the national interest. This referral of responsibility, or “responsibilisation”, “is not a simple ‘downsizing’ of the state, but requires a new kind of activist government to create freedom and those capable of inhabiting it” (Rose 1999, xxiii). It also requires a new self-understanding from migrant citizens, as the next section discusses. As local state representatives recommend that naturalised citizens think of themselves as citizens “by choice” and re-define the act of naturalisation from a bureaucratic nuisance to an “individual contribution” and a “conscious choice” (DrPres3, observation 31/08/2013), the characteristics of the individual applicant literally come to be seen as “capital”: And even if […] your migration background is often portrayed exclusively as a handicap […] please recognize that this is a very special capital to be made use of. With your knowledge about other countries and cultures and your potential multilingual skills you are predestined to further develop Germany’s partnership links to other regions in the world. (observation HaPres1, 17/05/2013)

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Citizenship applicants’ (assumed) individual experiences of crossing national, linguistic, and cultural boundaries are thereby discursively re-­ framed as “knowledge” and “skills” that are deemed valuable to the self-­ image of the nation-state as made up of an ethnically, culturally, linguistically diverse population which, in turn, enables the nation-state’s global involvement and competitive success. In return, the state is portrayed as actively offering services specifically to migrant citizens. For example, in Germany the state administration was depicted as a “service provider” (Dienstleister) in accommodating the needs of “people who come from other countries” by pointing to the newly opened “Welcome Centre” in Dresden (observation DrPres3, 31/08/2013). However, the speaker omitted to mention that these controversial “Welcome Centres”, which have been established in several German local authorities, do not “welcome” all migrants without question; rather, they only serve legally documented, highly skilled immigrants with an annual income exceeding 30,000 Euros (Ludwig 2013). The Super Citizen subjectivity thus reinforces a hierarchy of “deservingness” and merit, thus contributing to the discursive maintenance and reproduction of a capitalist economic order in liberal-democratic, diverse nation-states. Once discursively created as role model citizens, naturalised citizens are asked to develop a new nationalism. In the British case, the neonationalism instilled by the ceremonies appeared in the form of a regionalism and royalism, as naturalised citizens were expected to “catch […] loyalty” to the local state, such as the Borough or County, and above all to the Queen (observation BuPres2, 15/01/2013). In the German case, the call for a new nationalism to be developed by naturalised citizens was situated in the context of the recent re-emergence of far right nationalism. Thus, the Saxon Interior Minister from the CDU called upon naturalised citizens to “set an example” to “neo-Nazis” who stir up racist hate, and to those against whom this hate is directed, in a speech at a Dresden ceremony: In these days, when neo-Nazis once again fuel sentiments against people from other countries and other cultures, I call upon you: Please pass on your experience, set an example, give your fellow citizens (Landsleute) a

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hand! And I make it very clear, this state (Bundesland) needs people like yourselves […]. (observation DrPres3, 31/08/2013)

The literature on xenophobia and neonationalism mainly attributes racism towards migrants to new far right parties across Europe (Berezin 2006; Gingrich and Banks 2006). Yet, the neonationalism found in ceremony speeches itself represents a new phenomenon in responding to these far right movements, as the following statement from a speech in Hamburg demonstrates. The speaker is a 32-year-old officer in the German armed forces (Bundeswehr), founder of the association “German soldier” (Deutscher Soldat e.V.) bringing together members of the armed forces with a migration history. He was also a PhD student in political science and an SPD adviser. After he narrated his own naturalisation story, being born in Germany to political refugees from Burundi, he called upon the naturalised citizens to initiate and facilitate a new German nationalism compatible with modern liberal-democratic principles: Because ‘the migrants’ who are so often presented as a problem do not exist as a homogenous collective and ‘the Germans’ are not a genetically distinguishable race either. ‘We Germans’ are one people, a diverse people that has always been diverse but that unfortunately seems partly overwhelmed by its increasing diversity nowadays. And yet, this could be the starting point for your own involvement, to which I would like to encourage you. I would be pleased if, in your everyday lives, you could demonstrate to your fellow citizens that there are not only problematic cases and that the increasing diversity in Germany does not only create challenges, but also opportunities. Take away their fear of foreign domination that seems to be a human instinct and that some deliberately try to fuel. Show them that you consciously opted for Germany with your decision to apply for citizenship. […] Pride is a difficult topic in this country and that is understandable given the heavy historical burden that weighs on this country and that must forever be a warning to all people around the world. But perhaps you, as new Germans, can make a contribution also in this sense and assist your people with fresh perspectives and impulses to yet develop a modern, moderate and healthy national pride that is, in my opinion, a natural element of any nation. (observation HaPres1, 17/05/2013 original emphasis)

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This statement is noteworthy because it included the most explicitly formulated expectation that naturalised citizens should help foster a new type of “national pride”. This call was, first of all, based on the problematisation of national-born citizens who had embraced racist ideas of “foreign infiltration”. Naturalised citizens were then constructed as ideally suited candidates to assist the re-integration of neo-Nazis. This task should be accomplished by educating the previously misled national-­ born Germans that naturalised Germans in fact “master” the German language, and have “internalized the values and norms of our country as manifest in the constitution (Grundgesetz)” (observation HaPres1, 17/05/2013). The neonationalism to be developed by naturalised citizens should thus serve as an antidote against the racism and xenophobia prevalent among some of the country’s national-born citizens. In short, the neonational aspect of the Super Citizen subjectivity is seen as instrumental in maintaining, or renewing, the image of Germany as an anti-racist, liberal-democratic state of law. According to this rationality, racism is presented as being caused by individual, not structural, societal reasons which make plausible the recommended solution to counter this problem. For, the task to fight racism is being handed to those who may (or may not) have personally experienced it themselves, namely the individual applicants, without mentioning the responsibility of the national-­ born citizens or the state.

5.3 The Dialectics of Citizenship Courses, Tests and Ceremonies: Between National Nostalgia and Democratic Modernity The courses, tests, and ceremonies serve as “political technologies” as they familiarise citizenship applicants with imaginations of the UK and Germany, which oscillate between traditional, homogenous nationhood and modern diverse statehood. Whether, for example, the elements of the Union Jack were rehearsed through PowerPoint presentations in classrooms, examined in test questions, or displayed on the walls of ceremony halls, the courses, tests, and ceremonies all familiarised the citizenship

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applicants with traditional national symbols such as the flag or anthem. On the other hand, both Britain and Germany were presented as modern states governed by elected parliaments and an independent judiciary. This was emphasised through classroom exercises, test materials, and/or the plenary room settings of citizenship ceremonies. This ambivalent self-­ representation conveys the dialectical tension inherent to citizenship which offers democratic and supposedly equal membership status; however, membership is primarily defined as belonging to a nation which excludes non-nationals and migrants. The courses, tests, and ceremonies also recommended specific self-­ guidance and set out examples of proper conduct to prospective new citizens, thus functioning as “technologies of the self ”. These included reminders to obey the rules in areas such as waste recycling and being a quiet neighbour and, most explicitly and repeatedly, the suggestion that they should do volunteer work and vote in elections. In this regard, the three techniques all suggest similar self-representations of the state and ideals of self-conduct of citizenship applicants. There were, however, also four important differences between the two countries. First, the German test and courses more explicitly encourage migrant citizens to be aware of their rights and claim them, including social rights to access benefits; this encouragement was largely absent in the UK. Even though the tests share the same format (multiple choice questions), the design of the German test questions and answers explains the knowledge being examined, while the Life in the UK test merely checks that applicants tick the right boxes. The German test explicitly mentions the “responsibilities” of the state, such as providing public services, while the UK test presents the National Health Service, museums, and sport facilities as achievements of British “culture”. Similarly, the suggestion that naturalised citizens should use their newly-gained right to vote was present in both British and German ceremonies, but in Germany this call explicitly referred to full suffrage. Ceremony speakers both in Dresden and Hamburg encouraged naturalised citizens not only to cast their vote, but also to stand for election. The responsibilisation of the state and enablement of its citizens was thus more prevalent in the German case than in the British one, as demonstrated also by the rationality of naturalisation as empowerment. This finding may be partly

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explained by the different constitutional arrangements and legal cultures in the two countries. In Germany, the Grundgesetz lists the basic rights which form part of the test questions and course materials, and a copy of the text may be distributed in classrooms or ceremony halls. The UK has no written constitution, and relevant legislation for the protection of human rights in the UK such as the 1998 Human Rights Act (cf. Wolfsteller 2020) and/or the 2006 and 2010 Equality Acts were conspicuously absent from the courses, tests, and ceremonies. The second important difference between the two countries was that the presentation and function of the sub-state and supra-state levels in the tests, courses, and ceremonies differed in the research locations whereby the local level could act to reinforce the national state (in the German case), and the supra-national dimension challenged the nation-­ state (in the UK case). All three techniques presented the state as a regional and local entity, with corresponding collective symbols such as flags, crests, and hymns, but the Hamburg ceremonies particularly mobilised local symbols and combined them with national symbols in a specific way. For example, the Hamburg hymn was played and sung before the German anthem, and a full-scale replica of an anchor, the city’s symbol, was displayed on the centre stage, painted in the colours of the German national flag. This was a strategic element of the two naturalisation campaigns, as CDU and SPD politicians had tried to persuade migrant residents to apply for national membership by appealing to their local self-identification with the city of Hamburg. A significant difference between the UK and Germany could also be found in the respective relationships to the European Union. While the German test, courses, and ceremonies presented Germany as a member state of the European Union through specific course information and test questions on the EU or the display of the European flag at ceremonies, the EU was almost entirely absent from the UK data. The first Life in the UK test handbook of 2004 commissioned by the then-New Labour government contained information on the EU, but this was reduced to six sentences in the third edition published in 2013 under the coalition government of Conservatives and Liberal Democrats. The theme of superiority; more specifically, that the UK does not rely on the EU, was also suggested at the Brent citizenship ceremonies where a guest speaker regularly praised the Borough’s

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super-­diversity in his speech, emphasising that “we speak more languages than they do in Brussels” (BrCG4, observation BrPres10, 16/10/2012). Even though the fieldwork conducted for this research took place before the UK Brexit referendum, these may be regarded as early indicators of anti-­European sentiments in British politics and society. Also related to the role of the EU, the third difference between the UK and Germany lay in the presentation of the history of the state. While the German test and course focused on the twentieth century, the UK test started with the Stone Age, giving the impression of ancient origins and the longevity of the nation-state. The German test and course place greater emphasis on the self-reflection of the undemocratic and illiberal elements in the making of the nation-state than the UK test does. One of three modules of the German course curricula was dedicated to the Nazi and GDR regimes, whereas the Life in the UK test handbook dedicated only two of its 55 pages to the topics of the slave trade and the British Empire. The persistent historical nostalgia and lack of self-reflection in the UK test has recently been criticised by more than 175 historians in an open letter (Historical Association 2020). Fourth, differences were evident between the two countries’ interpretations of religious diversity. While the UK test and course discussed a greater variety of religious festivals, including Jewish, Muslim, and Hindu holidays, the German test and course only mentioned Christian festivities. Overall, the topic of Islam remained largely absent, except in the Brent ceremonies where one guest speaker regularly cited from the Quran to demonstrate that “respect” for human rights is compatible with Islam. By implication, the suggestion that naturalised citizens should assess, and if necessary, re-adjust themselves to ensure that they “respect” the law was aimed specifically at Muslims. While the tests, courses, and ceremonies are powerful techniques of subject-formation in their endorsement of the Super Citizen subjectivity, their efficaciousness varies. The tests are significant because all applicants for naturalisation and for settlement are subject to passing the test; it is difficult to evade this mandatory requirement as exemptions are rarely granted. The courses have a more specific reach because they target migrants who do not hold an English or German language certificate or education degree. The courses reinforce the tests as they repeatedly

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rehearse the same knowledge over time in a classroom setting. In this light, the courses could be regarded as even more efficacious subject-­ formation techniques than the solitary self-study preparation and (usually) singular examination involved in the tests. The ceremonies are obligatory in the UK and voluntary in Germany, but they are all forms of the exercise of power. Their efficaciousness lies in the fact that they formally or symbolically conclude the naturalisation process in a theatrical setting. In requiring or inviting successful candidates to subject themselves to speeches made by representatives of the state, some of the most explicit suggestions of the Super Citizen were found in those ceremonies. In the UK, these external calls for subject-formation were preceded and reinforced by the spoken self-commitment through the obligatory taking of the oath or affirmation in a semi-public setting.

References BAMF. 2017. Curriculum für einen bundesweiten Orientierungskurs. Überarbeitete Neuauflage für 100 Unterrichtseinheiten. April 2017. https:// www.bamf.de/SharedDocs/Anlagen/DE/Integration/Integrationskurse/ Kurstraeger/KonzepteLeitfaeden/curriculum-­o rientierungskurs-­p df. html?nn=282388. Accessed 14 March 2023. ———. 2022. Gesamtfragenkatalog zum Test “Leben in Deutschland” und zum “Einbürgerungstest”. Stand: 14 October 2022. https://www.bamf.de/ SharedDocs/Anlagen/DE/Integration/Einbuergerung/gesamtfragenkatalog-­ lebenindeutschland.html?nn=282388. Accessed 14 March 2023. Berezin, Mabel. 2006. Xenophobia and the New Nationalisms. In The SAGE Handbook of Nations and Nationalism, edited by Gerard Delanty and Krishan Kumar, 273–284. London: SAGE. Bhambra, Gurminder K. 2007. Rethinking Modernity: Postcolonialism and the Sociological Imagination. Basingstoke: Palgrave Macmillan. Bröckling, Ulrich. 2007. Regime des Selbst—Ein Forschungsprogramm. In Kulturen der Moderne. Soziologische Perspektiven der Gegenwart, edited by Thomas Bonacker and Andreas Reckwitz, 119–139. Frankfurt a.M.: Campus. ———. 2012. Der Ruf des Polizisten. Die Regierung des Selbst und ihre Widerstände. In Diskurs—Macht—Subjekt. Theorie und Empirie von Subjektivierung in der Diskursforschung, edited by Reiner Keller, Werner

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Schneider, and Willy Viehöver, 131–144. Wiesbaden: Verlag für Sozialwissenschaften. Brubaker, Rogers. 1992. Citizenship and Nationhood in France and Germany. Cambridge: Harvard University Press. Brubaker, Rogers, and Frederick Cooper. 2000. Beyond “Identity”. Theory and Society 29 (1): 1–47. Byrne, Bridget. 2012. A Local Welcome? Narrations of Citizenship and Nation in UK Citizenship Ceremonies. Citizenship Studies 16 (3–4): 531–544. Cruikshank, Barbara. 1994. The Will to Empower: Technologies of Citizenship and the War on Poverty. Socialist Review 23 (4): 29–55. Dean, Mitchell. 2003. Governmentality: Power and Rule in Modern Society. 2nd ed. London: SAGE. Feil, Robert, and Wolfgang Hesse, eds. 2012. Miteinander Leben. Unterrichtsmaterial für Orientierungs- und Sprachkurse. Stuttgart: Landeszentrale für Politische Bildung Baden-Württemberg. Foucault, Michel. 1988a. Technologies of the Self. In Technologies of the Self: A Seminar with Michel Foucault, edited by Luther H. Martin, Huck Gutman, and Patrick H. Hutton, 16–49. Amherst: University of Massachusetts Press. ———. 1988b. The Political Technology of Individuals. In Technologies of the Self: A Seminar with Michel Foucault, edited by Luther H.  Martin, Huck Gutman, and Patrick H.  Hutton, 145–162. Amherst: University of Massachusetts Press. Gaidosch, Ulrike, and Christine Müller. 2013. Zur Orientierung. Basiswissen Deutschland. 5th ed. Ismaning: Hueber. Gingrich, André, and Marcus Banks, eds. 2006. Neo-Nationalism in Europe and Beyond. Perspectives from Social Anthropology. New York: Berghahn. Historical Association. 2020. Historians Call for a Review of Home Office Citizenship and Settlement Test. History Journal (blog), 21 July. https://historyjournal.org.uk/2020/07/21/historians-­call-­for-­a-­review-­of-­home-­office-­ citizenship-­and-­settlement-­test/. Accessed 14 March 2023. Home Office. n.d. ‘Being a British Citizen’. Envelope Containing “Message from the Home Secretary”, “You Can Now Apply for a British Passport” and “Some Information for British Nationals” distributed at local citizenship ceremonies together with certificate of naturalisation. (Obtained 13 June 2012 in Brent). Joppke, Christian. 2010. Citizenship and Immigration. Cambridge: Polity. Kivisto, Peter, and Thomas Faist. 2007. Citizenship: Discourse, Theory, and Transnational Prospects. Malden: Blackwell.

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Lemke, Thomas. 2007. An Indigestible Meal? Foucault, Governmentality and State Theory. Distinktion: Scandinavian Journal of Social Theory 8 (2): 43–64. Ludwig, Kristiana. 2013. “Welcome Center” für reiche Einwanderer: Migranten erster und zweiter Klasse. Die Tageszeitung, 25 January. http://www.taz. de/!5074644/. Accessed 14 March 2023. NIACE, LLU+ London Southbank University, Department for Education and Skills (DfES), and Home Office. 2010. Citizenship Materials for ESOL Learners. 2nd ed. NIACE (National Institute of Adult Continuing Education): Leicester. http://www.niace.org.uk/projects/esolcitizenship/. Accessed 1 August 2016. Rayner, Jay. 2003. Enduring Love. The Guardian, 19 January. http://www.theguardian.com/lifeandstyle/2003/jan/19/foodanddrink.restaurants. Accessed 14 March 2023. Rose, Nikolas. 1999. Governing the Soul: The Shaping of the Private Self. London: Free Association Books. The Stationary Office. 2022. Life in the United Kingdom: Official Study Guide. Norwich: The Stationary Office. The Stationary Office and Home Office. 2022. Life in the United Kingdom: A Guide for New Residents. 3rd ed. London: The Stationery Office. The Stationery Office. 2021. Life in the United Kingdom: Official Practice Questions and Answers. Norwich: The Stationary Office. Wolfsteller, René. 2020. Out of Sync: The Failed Translation of International Human Rights in the Creation of the UK Human Rights Act. Journal of Human Rights 19 (3): 325–343.

6 Responses to the Super Citizen: Migrants’ Lived Experiences of Naturalisation

The analysis presented in this book so far has focussed on how naturalisation processes aim to produce a particular type of subjectivity: the Super Citizen. To this purpose, the previous chapters have examined the problematisations, rationalities, authorities, and techniques that are deployed and mobilised in contemporary British and German citizenship admission procedures. This chapter shifts the focus onto the question of how these subject-formation attempts are received and answered by those who submit themselves to naturalisation procedures. It analyses the lived experiences of naturalisation based on interviews and conversations with people who are preparing or have already completed their application procedure. In so doing, this chapter moves beyond the conceptual limits of traditional analyses of subject-formation regimes and discourses that have concentrated solely on subject-formation attempts and on the suggested subjectivities while neglecting the aspect of people’s interaction with them, as well as their actual influence on the behaviour and self-­ understandings of individuals. The call to citizenship applicants to become Super Citizens suggests that they should optimise and model their behaviour and self-­ understanding according to this subjectivity. Yet, the data analysis for this © The Author(s), under exclusive license to Springer Nature Switzerland AG 2023 E. Badenhoop, Calling for the Super Citizen, Palgrave Politics of Identity and Citizenship Series, https://doi.org/10.1007/978-3-031-34260-8_1

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book showed a range of different reactions and responses which can be subsumed under three distinct response types: embrace, contestation, and disaffection. The first response refers to the active embrace and welcoming of the new naturalisation requirements as an opportunity to acquire and demonstrate special knowledge or loyalty as part of the naturalisation procedure. The second response encompasses the many criticisms voiced by citizenship applicants that the new forms of assessment through tests, courses, and ceremonies disregarded their previous integration achievements and alienated long-term settled migrants. The third response describes an awareness of the high expectations combined with a sense of disaffection, pragmatism, or ignorance. These three types of responses were found in all research locations both in Germany and in the UK, and across demographic features such as gender, age, class, nationality, and entry route. These response types are not meant to be mutually exclusive, stable categories, but should rather be seen as fluid and even potentially inconsistent because, sometimes, elements of all three response types were expressed by the same research participant. Moreover, the Super Citizen call facilitates a dynamic of competition and creates new hierarchies, as naturalised citizens distanced themselves from national-born and non-national citizens. The experience of naturalisation may thus have both equalising and alienating effects.

6.1 Embrace One way to respond to the Super Citizen call is to listen to and embrace the state expectations as expressed in the courses, tests, and ceremonies. Some participants felt addressed by this subjectivity, in that they could identify themselves with the features of the Super Citizen as it matched their self-understanding and/or aim of being well “integrated”. This affirmation of the Super Citizen subjectivity took ambivalent, contradictory forms. On the one hand, the Super Citizen call was embraced as a way for migrants to achieve empowerment and inclusion, confirming the normative ideals of the civic integration literature discussed in Chap. 1 (see, e.g. Etzioni 2007; Joppke 2010; Goodman 2014). Participants welcomed

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taking the test or the course, seeing them as sources of support in their settlement process. From this perspective, studying for the Life in the United Kingdom test was seen as enhancing their knowledge and understanding of British society, and some participants deliberately kept their textbook months after passing the test for future reference on their bookshelves, because it contained “interesting information” (BuCA05, interview 29/01/2013). Similarly, the German integration course was appreciated as an opportunity to undergo civic education about political rights in a modern state ruled by law, and to learn about their rights, such as “freedom of speech”. Taking the course could therefore strengthen an individual migrant’s self-identification with the state, as it made them “feel closer to Germany” (DrCP2, conversation 28/05/2013). The citizenship ceremony could also be experienced as an offer of belonging and reassurance in an individual’s sense of self-identification, as an equal member of the nation-state. For example, one participant in Germany recalled her personal ceremony at the local naturalisation authority in the following way: And then he suddenly took the EU free movement certificates [of herself and her children] and put a huge ‘invalid’ stamp on them and I just thought: ‘Oh my God, it took months to get them!’ But then he was right, because I no longer need them, because now I belong here. He said that really well, that we are just as German as everyone else. It was very important to hear that. Sometimes I repeat that to myself and to others, when someone does not think that, then I say: ‘I am just as German as you are’. There are many nationalists in Germany. (DrCA09, conversation 21/05/2013)

This statement illustrates the equalising aspect of the Super Citizen subjectivity in the form of the state promise of full membership. This respondent initially felt anxiety and panic when the official invalidated her previous identity and travel documents, but then she quickly felt reassured and empowered when the official confirmed that now she was an equal citizen of the country. She utilised this inclusive aspect of the Super Citizen subjectivity to claim her own, full German membership when encountering anti-immigrant attitudes among national-born citizens.

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On the other hand, the Super Citizen was also embraced by some of the interviewees as a means of distinction, selection, and exclusion. The introduction of the test, in particular, was justified as a way for candidates to prove their worthiness based on their language skills. Passing the test is seen as a source of pride and achievement. A participant in the UK explained that the Life in the UK test: […] is a screening device, really, and it will screen out those people who don’t know English because at the very least you need to have a basic understanding of English. […] I would consider mastering the language as a requirement to become a citizen of a country. […] On that front, it has set [a] minimum hurdle, and so in that sense it’s good. (BuCA06, interview 29/01/2013)

From this perspective, the citizenship test and/or ceremony represent opportunities to show one’s knowledge of, and willingness to perform, national rituals such as singing the national anthem. The participant quoted above had prepared himself for his ceremony and learned the text of the British national anthem by heart. He felt disappointed when, at his ceremony, he started to sing along to the music and realised that no one else was joining in (ibid.). This Kafkaesque situation is an example of migrants’ internalisation, anticipation, and over-achievement of the state’s expectations. It also illustrates the contingency of subject-­ formation, as these individual efforts may well have been expected and rewarded in a different place and at another time. For example, in the other UK research location, migrants were actually expected to sing along to the anthem, the lyrics were handed out in advance to this end, and the officials checked whether the ceremony participants moved their lips.

6.2 Contestation Another way to respond to the call for the Super Citizen is to hear and challenge it. The second type of response to the Super Citizen call is therefore contestation. Citizenship applicants voiced criticisms of the exaggerated expectations of the Super Citizen subjectivity, having

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experienced their application for naturalisation as a process of alienation, deterrence, and disempowerment. The majority of interviewees had lived in the country for longer than the required minimum residence period, yet they felt treated like newcomers, not permanent residents. They were surprised and annoyed that the state asked them to demonstrate their knowledge and loyalty through tests, courses, and ceremonies. They felt that their existing integration and settlement achievements were being ignored and that their efforts would never be deemed sufficient. This confirms the critique of tests as neoliberal citizenship requirements where the burden of integration is shifted onto migrants (cf. Suvarierol and Kirk 2015), as discussed in Chap. 1. For example, a participant in the UK was upset to discover that he had to take the Life in the UK test even though he had already successfully completed ESOL courses from level one to level five; he felt he was well educated and was disappointed that he should have to pass the test, too (BuCA13, conversation 27/02/2013). Similarly, another participant in the UK who had years of experience in teaching English to speakers of other languages found her situation difficult to comprehend: “Why do I need to go to a citizenship ceremony when I teach English?” (BuCA11, conversation 26/02/2013). Citizenship applicants in the UK from Commonwealth countries were generally bewildered that they had been asked to affirm their allegiance to the Queen whom they considered to be the symbolic Head of State already under their previous citizenship. The naturalisation process was thus perceived as a moment of exclusion, suspicion, and control rather than a moment of welcome and inclusion. Participants expressed criticism not only of the formal knowledge and loyalty requirements, but also about the way the tests, courses, and ceremonies were being implemented. The UK is characterised by an increasingly (and, indeed, officially) immigration-hostile environment and by a public discourse of “fraud” and “impersonation”, as visible in the problematised figure of the “insincere” citizenship applicant and in current policy developments. In this context, the interaction with staff at a Life in the UK test centre was experienced as a form of state surveillance and an unpleasant form of identity control, as one participant vividly remembered: “And then they checked your passport, your name, at least ten times. You felt so examined (durchsucht)” (BrCA04, conversation

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25/10/2012). This statement demonstrates that the securitisation critique not only applies to the citizenship courses (cf. zur Nieden 2009) but also to the tests. Even the ceremony which formally or symbolically concludes the process for successful applicants was experienced by some as a moment of separation and boundary-drawing, confirming the dialectical critique (cf. Byrne 2014; Aptekar 2015) discussed in Chap. 1. Participants acknowledged that the ceremonies offered migrants a symbolic recognition by the state, but they also pointed out that this recognition was too selective or came too late: “Why only now? If a guest came to visit, you would also immediately welcome him and not wait until he can demonstrate a three-year rent agreement, that would be ridiculous!” (HaCA17, interview 27/08/2013). In this sense, the ceremonies were a painful reminder that “previously you did not belong to society” (DrCA02, conversation 31/08/2013). The speech acts made at local citizenship ceremonies could also be upsetting, as they reinforced the boundaries between “Us”—national citizens and “Them”—non-national citizens (cf. Anderson 2013). Naturalisation was also experienced as a moment of subordination, disciplinisation, and infantilisation, pointing to the racialisation critique (cf. Tyler 2010; Hà 2010). For many adult participants, the reality of taking the course and preparing for the test was that it felt like being back at school. Participants in both countries further criticised the test due to “the way the questions are written” (BuCA08, interview 02/02/2013); that they were “designed to trick you” (BrCA04, conversation 25/10/2012) and required “stupid learning by heart” (HaCA16, interview 27/08/2013). This finding is evidence for the critique of the tests as a form of illiberal social selectivity (cf. Bauböck and Joppke 2010). However, even highly skilled migrants admitted that they had to “sit down and cram it in” in the evening and at the weekend (BuCA06, interview 29/01/2013). The ceremony was sometimes perceived as a final lecture to be endured. For example, a participant in Germany remembered that the state official told him before handing over his naturalisation certificate alongside a copy of the German Basic Law that: “When you go abroad, behave like a German!” which this participant felt was an especially inappropriate instruction, since he had been serving in the City Council as a social worker for many years (DrCA12, interview 05/06/2013). Some

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participants also explicitly spoke about how they perceived their naturalisation process as an unwelcome form of top-down enforced “state nationalism” (BuCA11, conversation 26/02/2013).

6.3 Disaffection Yet another way to deal with the expectations of the Super Citizen subjectivity is to note the call and treat it like background noise. The third type of response to the call for the Super Citizen is to ignore it, or disaffection. Some migrants felt unimpressed by the Super Citizen call because they adopted a pragmatist approach and focussed their efforts on gaining the passport. From this perspective, taking the course, passing the test, and attending the ceremony were all means to a specific end. The naturalisation process was just another bureaucratic hurdle to make life a little bit easier, and all the “hailing” they encountered during the process had little effect on their self-understanding or actions. A participant in Germany recalled how she was asked to describe what naturalisation meant for her before receiving her certificate, and she gave the following answer to the official: You know, this certificate will only help me with some things. Papers do not make humans, I am a human being. And even when I was not yet a German national my task was to use all my given opportunities and skills for the peaceful living together and I will continue to do that, whether paid or unpaid. I am a volunteer assistant for young offenders in prison, a volunteer assistant for people in detention, a community translator, a member of [a local migrant support group]; here [at the legal advice centre] I work paid and sometimes unpaid. I am concerned whenever there is a conflict here, I answer questions about Islam, I care to live in an open and peaceful society and whenever possible I make my contribution. Even though paper-wise I was not yet a German national. And then he just looked at me like that [apparently bewildered]! (DrCA02, interview 09/04/2013)

This statement is noteworthy because this citizenship applicant picked up the economic and cultural features of the Super Citizen subjectivity

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when listing her work and volunteering activities, as well as her efforts as a translator and mediator. At the same time, she clearly disassociated these actions and motivations from her citizenship status, thus undermining the logic of the Super Citizen subjectivity and the associated expectations. Apparently, the caseworker was not satisfied with this answer, as he had expected a response that attributed more meaning to the naturalisation process and to the new state membership gained through it. This caseworker was the senior official in Dresden who thinks of naturalisation as a “sovereign act” that should not be given away “like old rolls” and therefore insists that citizenship applicants individually speak the declaration so that “they take something home” before presenting their certificate of naturalisation, and who has been criticised by lawyers for making the application process unnecessarily stressful (see Chaps. 3 and 4). The interviewee’s response, however, requires a strong sense of self as in this instance the about-to-be successfully naturalised citizen already appeared secure as she stressed that her change of legal status was unrelated to the way she understood herself and felt about the state and society she lived in. Similarly, another participant said: “I felt relatively well integrated without holding German citizenship” (DrCA08, interview 08/05/2013). Others were disaffected by the Super Citizen call because they were sceptical about the subjectivity’s promise of equality and full inclusion. This scepticism was related to personal experiences of persistent racism towards migrants and an acute awareness that neither the process of naturalisation nor self-modification efforts are able to undo someone’s perceived “foreignness”, for example, in terms of their accent, physical appearance, or migration history. Even though they felt confident that their application would be successful, participants expressed doubts as to whether they would pass as German or British on the street. When comparing herself to her younger sister who had learned German more quickly and easily at school, one participant was well aware that: “When I speak I am still perceived as a foreigner” (HaCA01, interview 19/06/2013). For others, language was not the main marker of “foreignness”; instead, this was their physical appearance. Speaking to me in impeccable and eloquent German without any trace of an accent, one Latin American

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participant explained that for many locals, she was “like a Martian”, or at best someone “from Asia”, because they were unable to distinguish her Spanish-sounding surname and only saw her tanned skin, dark hair, and dark eyes (DrCA08, interview 08/05/2013). With a note of cynicism, she thought she would have to “dye the hair blond” and wear “blue contact lenses” in order to achieve full recognition as a German national. For this research participant, naturalisation was a pragmatic means for migrants to deal with institutional racism and more easily pass instances of state suspicion and identity control that she was weary of: Imagine you come back home. I returned from Peru and when I was getting off the plane, two police officers blocked my way and first of all checked my passport while I was still on the plane, even before I had set foot on German soil, not even on the staircase! So, they checked if I had papers. You see, this is normal, this is part of normality. […] And they call this a ‘welcoming society’ (Willkommensgesellschaft) (laughs) (DrCA08, interview 08/05/2013)

According to this pragmatist response, research participants applied for naturalisation because it provided the most secure residence right and safety from deportation. This response was sometimes coupled with a note of cynicism and acute awareness that the acquisition or change of nationality is just “on paper”, as one participant explained: I want to live here, with my children. I have built a life here, I want to be sure that I won’t be put aside, removed (weggeschoben). I want a little bit of security. My child is growing up here, my oldest daughter speaks Bulgarian but she does not read Cyrillic. For her it would be a problem to go back. I have settled here, I would say. I also want that my children are allowed to learn German, study here, have a future. But I am German only on paper; everybody thinks that I am not a German. I became German, but the majority of people here think that I am a foreigner (Fremde). However, in Bulgaria, too, people think that I am a foreigner because I am there only for two weeks of holiday per year. In Bulgaria, I have only my family; here is my work, here I know how things work. Here I feel more at home than at home. (DrCA09, conversation 21/05/2013)

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This refers to the personal dilemma experienced by some naturalised citizens who feel attached to, and as members of, two states (the one of their birthright membership and the one of their acquired membership) but whose membership is contested in both states. This suggests that the self-optimisation required by the Super Citizen subjectivity does not end with obtaining the certificate of naturalisation. Instead, successfully naturalised citizens may find themselves having to convince other members of their membership every day, again and again. Several participants expressed exhaustion and despair having gone through several lengthy immigration applications that this final one (naturalisation) still does not provide the emotional reassurance needed, as the following participant explained: Because it will help me with the bureaucracy. I don’t actually need German nationality (laughs). I would be German only on paper. I am not German, I feel neither German nor Afghan. I feel like nothing. Sometimes I feel German, sometimes nothing, sometimes international (…). I am grateful that I have the permanent residence permit. That is almost like German citizenship to me because it is already a status that allows you to live here. (DrCA06, interview 03/05/2013)

6.4 Migrants’ Competition for State Recognition and New Hierarchies of Worthiness Regardless of the response adopted, the Super Citizen call facilitates a dynamic of competition for recognition among migrants aspiring to citizenship status. The Super Citizen subjectivity is problematic because it induces citizenship applicants to compare themselves to other applicants. The interview data suggests that this dynamic took three forms: migrants assessed themselves; they assessed others; and they were assessed by others regarding whether or not they “deserved” citizenship. A candidate’s “worthiness” was often ascertained based on their willingness and efforts to optimise their English or German language skills. For example, one participant in Germany expressed a note of resentment when he compared

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his own lengthy application procedure to that of others: “I know people who had a tenth of myself then [in terms of ] languages, possibilities— and it took them only six months [to obtain German citizenship]!” (DrCA04, interview 17/04/2013). It is noteworthy that this person quantified his own linguistic skills even though language is difficult to measure. Some participants distinguished themselves from other migrants who supposedly had the “wrong” motives, such as one participant in the UK: “A lot of people came for British citizenship. I was not there for British citizenship, I was there to learn English.” (BuCA09, interview 08/02/2013) By implying that some of his fellow students had taken the ESOL with citizenship course with no motivation to learn English, but simply to get the course certificate in order to be eligible for naturalisation, he seemed to adopt the idea that citizenship should not be granted “by mistake” to those who do not “deserve” it, in line with the rationality of naturalisation as an award. This self-assessment and assessment of others was also based on migrants’ contribution to the national economy. For example, one participant in the UK whose naturalisation application had been rejected told me the story of another, successful British citizenship applicant whom she knew: I don’t need it [citizenship], it doesn’t bring me any difference to my life. […] I’m just so upset [about] not getting it. […] She is not capable of writing a word of English. […] Came to England with no English, no friends, and no money. Had to clean toilets, trapped in homes, cleaning Romanians’ houses. […] But she is British! It’s annoying. She got it. I’m just pissed. She left in October, too old to clean, all these Polish 16-year-olds coming to London, [she was] forced to go back home. Why did she get British citizenship? In order to get [a] British pension. […] Now [she is] back home with [a] British pension. (BrCA08, interview 18/11/2012)

It is noteworthy in this statement that the features which are deemed to make a migrant worthy of citizenship are language, but also social networks and financial solvency. In so doing, this participant mobilised the problematised figures of the dependent and insincere discussed in Chap. 2. By narrating the story of this older Romanian national to imply

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that she only naturalised in the UK “in order to get [a] British pension”, she presented the case as an issue of dishonesty, similar to the “scrounging off the system” discourse prevalent among state officials. The statement also demonstrates how various layers of neoliberalism reinforce each other, for example, inter-ethnic competition in the labour market among low-skilled migrants in the service sector overlaps with competition for citizenship status. This dynamic of mutual assessment was by no means invented by citizenship applicants, as they also found themselves assessed by others, especially in their interactions with officials. Indeed, the structurally required personal office appointment in Germany may produce very ambivalent effects, both discouraging from, and encouraging to, submitting one’s naturalisation application. One participant had difficulties producing sufficient proof of her Afghan national identity. Even though she had been told that her application might still be successful, the Dresden authorities remained ambiguous, and she anticipated that they would “decide with gut instinct anyway”, experiencing this uncertainty as a never-ending worry: “They always present it in a way as if something could still go wrong, you can never be sure.” (DrCA06, conversation 13/06/2013) This demonstrates that naturalisation may be experienced as a moment of powerlessness and subordination to the state. Another participant with particularly impressive achievements was surprised to discover at his first appointment that the Dresden naturalisation authorities did not “welcome my application” but instead started an ad hoc interrogation: I myself was asked the question: ‘What outstanding integration efforts can you demonstrate?’ I said, I studied in German at a German university. I have a German university degree, not everyone who applies for citizenship has that. I am married to a German woman, our shared future is here. I have led large projects [international business cooperation bringing significant funds to the region]. I volunteered while I was at university. I was awarded honorary citizen of [a neighbouring town]. These are the integration achievements I have. […] If these do not count as outstanding integration efforts, then God knows what that is supposed to be! (DrCA05, interview 30/04/2013)

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The caseworker acknowledged that “For me, you may appear special but I don’t know if the person who reviews your case will think the same.” She thus referred his case to her line manager and ultimately affirmed that his application would be rejected. Ironically, this participant found himself in a situation described in one of the classroom exercises discussed in Chap. 5 which aimed at raising awareness among migrants how to navigate a bureaucratic, potentially hostile system. However, in this instance it remained unclear whether the caseworker was not willing or not allowed to apply the clause foreseen by law which rewards “outstanding efforts at integration”1 by reducing the required residence period from eight to six years (StAG s 10 [3]). This empirical example illustrates the necessity to provide a clear definition of this vaguely formulated legal provision, an issue that remains unresolved even by the current liberalisation of the German Nationality Act (see Chap. 7). It also shows that the agency of caseworkers is limited not just by the written law and caseworker instructions but also by their respective line managers. In Dresden, the senior official adopted a rather restrictive understanding of naturalisation as an award that should be earned and not given away too easily. And yet at the same local authority, another research participant made a quite different experience. This participant had difficulties fulfilling the economic self-subsistence requirement but she engaged in a range of volunteer activities, for example, as translator, mediator and adviser. During our interview, she told me how “careful” she was what to submit to the naturalisation authorities in order to create a certain impression: And I had a folder with news articles where I was interviewed, where I contributed, with me. That had not been requested from me, but the caseworker was delighted. […] The caseworker said: ‘Of course, we do have a certain amount of discretion, so when someone takes care of themselves, is motivated and involved and contributes, and so on. We are quite aware that not everyone can find a full-time job immediately; most people do not work at all.’ (DrCA02, interview 09/04/2013)

 Translation by the Federal Ministry of the Interior (https://www.gesetze-im-internet.de/englisch_ stag/index.html, accessed 21 April 2023).

1

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This participant managed to compensate for her lack of a full income by documenting her numerous voluntary activities, information which impressed the official and encouraged her to exercise discretion. The caseworker’s discretion to disregard the woman’s insufficient income was, however, granted in relation to another group of the state’s population who are seen as even less desirable, in this case unemployed migrant (or national) residents. In other words, this participant managed to disassociate herself from the problematised figure of the dependent citizenship applicant. These two examples from Dresden show how contingent the naturalisation experience and result may be. Both participants were able to show an impressive list of voluntary activities, awards and other features that aligned them to the Super Citizen subjectivity but only one of the two was allowed to naturalise in the end. This also suggests that the features of the Super Citizen may be adopted by migrants in a strategic way, for example, to create a certain impression to compensate for a lack of formal requirements such as minimum residence in the first example and full income in the second. One participant in Hamburg experienced the discretionary power of state officials in a positive way, as he recalled an appointment at the foreigner authorities where the official encouraged him to think of himself as a role model to other migrants: [The official] just tried to find out if I can speak German at all. When I spoke fluently (laughs), I was so good, that the man stood up and gave me a handshake and told me that I am a very good example to millions of people who are living in Germany who have been living here for thirty years and still cannot speak German. (HaCA09, interview 21/08/2013)

Migrants are thus not only themselves aware of the problematised figure of the dependent citizenship applicant who does not work and cannot speak the language, but also that they may have received this awareness from, or that this awareness was being reinforced by, their interactions with officials. It appears that caseworkers utilise their position to conduct informal, spontaneous language tests, that good language performance may impress them, that they consider applicants with better language

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skills as role models for other non-citizens, and that they encourage them to think of themselves in this way. Similarly, at his final naturalisation appointment, a different caseworker confirmed the same impression that this participant “deserves” citizenship: So, on the day of the appointment I was there, [the caseworker] was very happy with me, she told me that: “Mr [name], you fought like a man. And this citizenship grant is well deserved. We are not giving it by mistake, we are giving it to somebody who deserves it.” So, she was happy to welcome me as a German. (HaCA09, interview 21/08/2013)

These examples suggest that caseworkers do compare citizenship applicants based on their economic and cultural-linguistic integration efforts, and that they indirectly or directly encourage migrants to compare themselves to other migrants. This dynamic of competition creates new hierarchies of worthiness among successful and unsuccessful migrants, but also among naturalised and national-born citizens. Participants both in Germany and in the UK were aware that their national-born neighbours, colleagues, and friends would have been unable to pass the citizenship test if they had to sit it. While some merely noted this with bemusement, others explicitly criticised the apparent inadequacy of native knowledge, and derived a sense of superiority from being somewhat “better” German or British citizens due to actually having passed the test. For example, the participant in Dresden who failed to achieve recognition for his integration achievements noted: What is there to prepare, tell me? I know about daily life, the constitution. […] I passed the [sample] test at 88%—without prior preparation! Even my wife would not have known all that, what Hitler put into place, a dictatorship, when that started, when the wall came down. Go out onto the streets, almost 80% of the Germans fail the test, they showed that on television several times. […] Every person should know that actually, what’s written in the constitution. (DrCA05, interview 30/04/2013)

This situation was perceived as particularly ironic and inappropriate when some officials and decision-makers were apparently unable to meet

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the knowledge requirements they expected from migrants. For example, one participant was disappointed that his caseworker was not impressed when he demonstrated his test certificate showing that he had achieved the best possible result: She did not want to understand. She just looked at it, copied it, and put it to the side. She did not even notice that I know history, politics and society here. I wanted to tell her, I know Germany’s history before you were born. The Germanics or Barbarians, as they were called. Excuse me, that is history, you should know that, right? When they discuss what is meant by Leitkultur. (DrCA04, interview 17/04/2013)

6.5 The Ambivalent Effects of the Super Citizen This chapter has examined migrants’ lived experiences of contemporary naturalisation processes. By examining whether, or how, citizenship applicants respond to the problematisations, rationalities, authorities and techniques of subject-formation analysed in Chaps. 2, 3, 4 and 5, this chapter moved beyond existing analyses of subject-formation, which have been limited to attempts at subject-formation, and which have disregarded its reception by those targeted (Bröckling 2007, 2012). As discussed in Chap. 1, the subjectivity of the Super Citizen suggests to migrants that they should aspire to become political, economic, and cultural assets to the new membership state. Based on a thematic analysis of interviews with migrants naturalising in either Germany or the UK, I identified three types of response to the call for the Super Citizen, namely: embrace, contestation, and disaffection. This analysis yielded three important insights. First, by examining the perspective of those who submit themselves to this subject-formation regime, that is, migrants who apply for naturalisation, this chapter has shown that the Super Citizen is indeed a powerful subjectivity. The analysis of the interviews revealed that this call is heard throughout the naturalisation process, from pre-application to the final stages, in all four research locations in Germany and the UK. This confirms that these two

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countries’ citizenship tests, courses, and ceremonies are highly powerful techniques of subject-formation and sites of “hailing” calls. The Super Citizen call is influential as it compels migrants to engage with it, but it does not prescribe a response. Indeed, the Super Citizen call did not produce a uniform reaction. The analysis of the interview data showed that the three response types identified were highly ambivalent, ranging from embrace to contestation to disaffection. On the one hand, some migrants embraced the ceremony, test, or course as a means of receiving helpful support, civic education, and as a welcome source of pride—a confirmation of their worthiness as migrants who saw themselves as Super Citizens. In this sense, the Super Citizen had inclusionary and equalising effects, corresponding to the arguments of the state-centred civic integration literature (cf. Etzioni 2007; Joppke 2010; Goodman 2014). On the other hand, as some migrants saw the naturalisation requirements as reinforcing boundaries and posing irrelevant, overly high hurdles, for them, the Super Citizen call had exclusionary, alienating, and differentiating effects, thus confirming the migrant-centred critiques in the existing sociological and anthropological literature (cf. Byrne 2014; Aptekar 2015). My empirical analysis thereby provided evidence for both the state-centred and the migrant-centred approaches; however, neither of these two can sufficiently explain the complexity of contemporary naturalisation processes and the lived experiences by migrants. Moreover, this analysis found that migrants are not just targets or agents of subject-formation, as some suggested (Monforte et al. 2019); citizenship applicants may also remain unimpressed by the Super Citizen call, as the third response type showed, which offers an alternative strategy to thwart subject-formation attempts. It is important to note that the reception of the Super Citizen subjectivity was highly inconsistent, sometimes even fluctuating in the same participant’s responses in one interview. For example, the young graduate from India in Dresden initially assumed that he would qualify for the “outstanding efforts at integration” clause, then collected support letters to convince the caseworker of his integration achievements, and eventually became angry and indignant when he realised that his university degree was not recognised, and that he would be required to pass the German citizenship test. While the current German government plans to

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further reduce the required residence period to three years for applicants with “outstanding efforts at integration”, it has yet failed to provide a transparent definition of this requirement (see Chap. 7). This example also indicates that citizenship applicants adopted responses in a strategic way in order to pass the scrutiny of the state and to credibly perform the Super Citizen subjectivity, especially if they did not fulfil all the statutory requirements. Respondents took pride in passing the citizenship requirements and even derived a sense of superiority vis-à-vis other migrant and national-born citizens, yet they also felt the state’s disdain when their language skills or integration efforts were not officially recognised. This suggests that subject-formation is not necessarily as deterministic and “totalitarian” as has been previously suggested (Bröckling 2016, 196). Governmentality and critical citizenship studies should therefore be careful not to overestimate the effects of subject-formation and should treat its efficacy as an open empirical question by considering the individual agency of all those involved in the process. Resistance to a subject-­ formation regime also has some structural limitations, particularly in the case of naturalisation procedures where the conditions are set and controlled by powerful state institutions. If migrants want to obtain citizenship status, they have little choice but to comply and meet the requirements. Second, by comparing the migrants’ perspectives with the institutional side of subject-formation, this chapter revealed significant discrepancies between the lived experiences and the written laws and policies of naturalisation. For example, the analysis of the interviews with officials and the document data showed that the rationality of citizenship as entitlement was more prevalent in the German case than in the British case, which was dominated by the rationality of discretionary award. This chapter, however, demonstrated that several research participants in Germany expressed the feeling that their citizenship application depended on the state’s discretion, even though they had applied through the legal provision of conditional entitlement (StAG s 10). The state’s discretion was sometimes experienced in a negative way, as in the case of the young Afghan woman in Dresden who struggled to produce proof of her national identity and felt that her case was being decided “with gut instinct” (DrCA06, conversation 13/06/2013). In other instances it was

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experienced in a positive way, for example, in the case of the elderly woman in Dresden from Iraq who was told by the caseworker that “of course we have a certain amount of discretion” (DrCA02, interview 09/04/2013), and whose application was accepted due to the numerous volunteering activities, part-time work, and care work she had documented. While research participants in both German locations experienced examples of caseworkers’ discretion, the reports generally tended to be more positive in Hamburg and more negative in Dresden. This finding corresponds with the local authorities’ different approaches to naturalisation, as analysed in Chap. 3: While Hamburg has adopted the explicit political aim of increasing naturalisation grants through two consecutive campaigns, the head of the Dresden naturalisation authorities has suggested that citizenship grants through entitlement are a “mistake”. This discrepancy between the official rationalities and citizenship applicants’ perceptions not only demonstrates the need for further qualitative empirical research to check and enhance the analysis of laws and policy documents. It also suggests that personal encounters with decision-­ makers are highly ambivalent as they may enhance or limit migrants’ agency. This confirms the crucial role of street-level bureaucrats in migration policy making and implementation (cf. Lipsky 1980; Guiraudon and Lahav 2000). Third, in comparing two different state administrations—the UK, which processes naturalisation exclusively in writing at a central level, and Germany, where migrants submit their citizenship application in person at local naturalisation authorities—this research has found that the central UK system is not necessarily more transparent (in particular, the “good character” requirement), but the federal German system facilitates a plural and complex policy implementation which depends on the member states and individual caseworkers involved. Moreover, the comparative research design yielded the insight that all three response types were found in both Germany and the UK. This finding is perhaps surprising given that the two countries’ differing immigration histories and policies continue to be regarded as examples of the traditional distinction between “civic” and “ethnic” models of citizenship and nationhood (cf. Meer and Modood 2012). On the other hand, this result can be interpreted as a logical outcome of the transnational

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convergence towards increasingly restrictive immigration policies since the early 2000s. My analysis has shown that the Super Citizen call impacts on all migrants, and the responses to it do not seem to be determined by gender, age, nationality, class, or immigration route as they were found to be scattered across a highly diverse sample. One hypothesis arising from this qualitative empirical analysis is that a person requires strong intellectual and language skills to be in a position to reject the Super Citizen call. The likely conditions under which migrants adopt one or the other response is therefore an area for further research. It is notable that many responses placed a strong emphasis on language and work/volunteering, thus stressing the cultural and economic features of the Super Citizen. The political element was picked up less frequently, confirming the results of a recent survey in the UK, according to which naturalised migrants tend to be less involved in politics than non-naturalised migrants (Bartram 2019). This raises the question whether the Super Citizen subjectivity underlying the British and German naturalisation procedures entails an empty promise of recognition and inclusion, and for some participants, this was indeed the case. As this chapter has demonstrated, participants were acutely aware that their belonging and full membership status remained contested even after successfully completing the naturalisation process. They felt that their integration efforts would never be deemed sufficient as long as they experienced persistent racism in everyday or institutional settings. A recurrent theme in the interviews was that naturalisation is “just a paper”. According to this pragmatist or sceptical perspective, the passport provides safety in terms of granting a permanent residence right, reduced risk of deportation and respectful treatment by authorities as it helps to navigate migration control. However, the certificate of naturalisation does not necessarily provide emotional reassurance of being accepted as British or German citizen by wider society. Indeed, some participants felt that their act of naturalisation did not resolve the personal dilemma of feeling attached to the state of naturalisation as well as to the state of birthright membership but not passing as a member in either one because emigration has turned them into foreigners in their state of birthright membership and they remain perceived as immigrants, not citizens, in their state of naturalisation. This suggests that some

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naturalised migrants remain caught in limbo between several types of (formal and/or emotional) state memberships. By requiring migrants to undergo citizenship tests, courses, and ceremonies, naturalisation produces highly ambivalent equalising and alienating effects. By choosing to naturalise and striving to meet both the formal requirements and the informal expectations of the Super Citizen call, migrants may seek to signal to natives their “worthiness” to be full citizens, just like those who are citizens by birth. This chapter showed that one inadvertent effect of the new, stricter naturalisation regimes is that, while some migrants pick up this subjectivity and see themselves as a Super Citizen, they also think of themselves as better citizens than both non-citizens and natural-born citizens. Contemporary citizenship admission procedures thus not only facilitate formal inclusion, but also foster perceived inequalities and competition between naturalised and non-­ naturalised migrants, as well as between naturalised and national-born citizens.

References Anderson, Bridget. 2013. Us and Them? The Dangerous Politics of Immigration Control. Oxford: Oxford University Press. Aptekar, Sofya. 2015. The Road to Citizenship: What Naturalization Means for Immigrants and the United States. New Brunswick: Rutgers University Press. Bartram, David. 2019. The UK Citizenship Process: Political Integration or Marginalization? Sociology 53 (4): 671–688. Bauböck, Rainer, and Christian Joppke, eds. 2010. ‘How Liberal Are Citizenship Tests? EUI Working Paper RSCAS 2010/41’. European University Institute, Robert Schuman Centre for Advanced Studies. Bröckling, Ulrich. 2007. Regime des Selbst—Ein Forschungsprogramm. In Kulturen der Moderne. Soziologische Perspektiven der Gegenwart, edited by Thomas Bonacker and Andreas Reckwitz, 119–139. Frankfurt a.M: Campus. ———. 2012. Der Ruf des Polizisten. Die Regierung des Selbst und ihre Widerstände. In Diskurs—Macht—Subjekt. Theorie und Empirie von Subjektivierung in der Diskursforschung, edited by Reiner Keller, Werner Schneider, and Willy Viehöver, 131–144. Wiesbaden: Verlag für Sozialwissenschaften.

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———. 2016. The Entrepreneurial Self: Fabricating a New Type of Subject. London: SAGE. Byrne, Bridget. 2014. Making Citizens. Public Rituals and Personal Journeys to Citizenship. Basingstoke: Palgrave Macmillan. Etzioni, Amitai. 2007. Citizenship Tests: A Comparative, Communitarian Perspective. The Political Quarterly 78 (3): 353–363. Goodman, Sara Wallace. 2014. Immigration and Membership Politics in Western Europe. Cambridge: Cambridge University Press. Guiraudon, Virginie, and Gallya Lahav. 2000. Comparative Perspectives on Border Control: Away from the Border and Outside the State. In The Wall Around the West: State Borders and Immigration Controls in North America and Europe, edited by Peter Andreas and Timothy Snyder. Lanham: Rowman & Littlefield. Hà, Kiên Nghi. 2010. Integration as Colonial Pedagogy of Postcolonial Immigrants and the People of Colour: A German Case Study. In Decolonizing European Sociology: Transdisciplinary Approaches, edited by Encarnación Gutiérrez Rodríguez, Manuela Boatcă, and Sérgio Costa, 161–177. Farnham: Ashgate. Joppke, Christian. 2010. Citizenship and Immigration. Cambridge: Polity. Lipsky, Michael. 1980. Street-Level Bureaucracy: Dilemmas of the Individual in Public Services. New York: Russell Sage. Meer, Nasar, and Tariq Modood. 2012. The Multicultural States We’re In. In European Multiculturalisms: Cultural, Religious and Ethnic Challenges, edited by Anna Triandafyllidou, Tariq Modood, and Nasar Meer, 61–87. Edinburgh: Edinburgh University Press. Monforte, Pierre, Leah Bassel, and Kamran Khan. 2019. Deserving Citizenship? Exploring Migrants’ Experiences of the ‘Citizenship Test’ Process in the United Kingdom. The British Journal of Sociology 70 (1): 24–43. zur Nieden, Birgit. 2009. ‘… und deutsch ist wichtig für die Sicherheit!’ Eine kleine Genealogie des Spracherwerbs Deutsch in der BRD. In No integration?! Kulturwissenschaftliche Beiträge zur Integrationsdebatte in Europa, edited by Sabine Hess, Jana Binder, and Johannes Moser, 123–136. Bielefeld: Transcript. Suvarierol, Semin, and Katherine Kirk. 2015. Dutch Civic Integration Courses as Neoliberal Citizenship Rituals. Citizenship Studies 19 (3–4): 248–266. Tyler, Imogen. 2010. Designed to Fail: A Biopolitics of British Citizenship. Citizenship Studies 14 (1): 61–74.

7 The Super Citizen and the Future of Naturalisation

With the study of the procedures through which migrants gain citizenship status, this book has shifted the focus of analysis back onto the state and state membership. In the 1990s and 2000s, the field of citizenship and migration studies was characterised by an idealistic belief that national citizenship was in decline (Soysal 1994; Sassen 2002) and that citizenship had become more inclusive (Bauböck 1994; Kivisto and Faist 2007; Joppke 2010). Some researchers were so optimistic to argue that citizenship, as the “right to have rights”, had become irrelevant (Isin 2013). The study of “acts of citizenship” (Nyers 2006; Isin and Nielsen 2008) shifted the focus of analysis to individual acts of resistance and tended to ignore the powerful state structures that shape and limit migrants’ agency. At the same time, research on “securitizing” and “rebordering” processes in migration policies criticised that migrants were increasingly perceived and policed as a “threat” in Western liberal democracies (Huysmans 1995; Andreas 2003; Walters 2006). Important as they are, these developments have perpetuated an academic “neglect” of citizenship as state membership and of the procedures through which migrants can access this status; a neglect that Brubaker had already critically observed at the beginning of the 1990s (Brubaker 1992, 22). © The Author(s), under exclusive license to Springer Nature Switzerland AG 2023 E. Badenhoop, Calling for the Super Citizen, Palgrave Politics of Identity and Citizenship Series, https://doi.org/10.1007/978-3-031-34260-8_7

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However, naturalisation laws and policies have been significantly reformed over the past 30 years in many Western liberal democracies, and in that time, perhaps the most significant change has been the introduction of citizenship courses, tests, and ceremonies. By analysing contemporary citizenship admission procedures in two major Western European states, this book has argued that naturalisation not only separates and selectively includes migrant citizens (cf. Byrne 2014); it also defines and produces a new subjectivity, that of the Super Citizen. The techniques of the tests, courses, and ceremonies; the authorities such as caseworkers, teachers, and ceremony speakers; the rationalities of award, entitlement, attachment, and commodity; and the problematisations of the dependent, insincere, and indifferent citizenship applicant analysed in this research all represent elements of a specific subject-­formation regime. These elements form an ensemble of institutionalised appeals and pleas directed at citizenship applicants, conveying expectations that naturalised citizens will contribute to the nation-state’s democracy, economy, and cultural diversity. In other words, naturalisation procedures attempt to modify and optimise migrants aspiring to citizenship, and induce them to model themselves according to the Super Citizen. This subjectivity is more than an abstract “normative” category (Anderson 2013, 4), or a specific “rhetoric” found in citizenship ceremony speeches (Aptekar 2015, 119), or in the extraordinary privileges of the global financial elite (Nash 2009, 1073). Rather, the Super Citizen is a subjectivity that is structurally formed throughout the citizenship admission procedure, which represents a highly powerful and efficacious “regulatory ideal” (Rose 1998, 23) because it suggests to individual citizenship applicants that they should assess, modify, and understand themselves, as well as other migrants and citizens, according to the features of the Super Citizen, thereby creating a constant neoliberal and neonational competition. This call for the Super Citizen transcends national borders, as it was found in all four research locations. This finding suggests that we need to rethink, and perhaps even abandon, the persistent distinction in the literature according to which Germany and the UK are seen as representing two opposing models of “ethnic” versus “civic” citizenship (Meer and Modood 2012; Diez and Squire 2008; Baldi and Goodman 2015). More importantly, the distinction between “discretionary” and “as-of-right”

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naturalisation systems proposed by Brubaker (1989, 108–109) is not as clear-cut in practice. While German naturalisation law nowadays contains a conditional entitlement, it may still be experienced in practice as a highly discretionary and arbitrary system, as this research has demonstrated. The UK, on the other hand, represents a discretionary system which is in some respects more transparent than the German system. For example, most of the British nationality caseworker instructions are accessible online (except the sections on the “good character” requirement), while some German states such as Saxony still refuse to publish their administrative guidance. The “discretionary”/ “as-of-right” distinction must therefore be read together with institutional memories, the crucial role of street-level bureaucrats, and local or regional differences within a state. While the Super Citizen is suggested in contemporary citizenship admission procedures, some elements of this subjectivity have a longer history, such as the loyalty oath in the UK or the statutory requirement of economic self-sufficiency in Germany. The Super Citizen is a highly powerful subjectivity insofar as it confronts citizenship applicants with certain ways of conduct, actions, discourse, and self-understanding at all stages of the naturalisation process. In contrasting the institutional attempts of subject-formation with the citizenship applicants’ perspective, however, this research has demonstrated that citizenship applicants are by no means only passive victims of the state’s “gentle violence” (Sayad 2004). Migrants’ experiences of naturalisation are highly ambivalent, and they may become agents of subject-­ formation themselves. While some attempted to mobilise features of the Super Citizen subjectivity for themselves, others criticised it. For example, some found it difficult to understand why they had to take the test or swear allegiance to the Monarch in the UK. Others were proud to have passed the test without any mistakes or suggested that the test should be applied to everyone, including citizens by birth. Some applicants adopted and appropriated the neoliberal and neonational discourse underpinning the Super Citizen subjectivity insofar as they perceived other migrants as competitors. It can thus be stated that naturalisation procedures contribute to the creation of new hierarchies of worthiness among successful and unsuccessful migrants, but also among naturalised and national-born citizens.

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In the remainder of this conclusion, I examine the most recent policy developments in the UK and Germany in the area of immigration and naturalisation before I present some recommendations for future policymaking which are based on my research findings.

7.1 Current Policy Developments in the UK and Germany Over the past decade, the global political situation has changed insofar as the political far right has gained significant electoral successes across the West. In Britain, a narrow majority voted for leaving the European Union in 2016, and the Conservative government has taken a radical turn towards the political far right as demonstrated by the quick succession of Prime Ministers (Boris Johnson 2019–2022, Liz Truss from 6 September until 25 October 2022, Rishi Sunak since 25 October 2022), all of which contributed to the political, economic, and social destabilisation of the country. In Germany, the so-called Alternative for Germany (Alternative für Deutschland, AfD) established itself as a (numerically) strong opposition party in most German parliaments. At the same time, we have seen significant international migration movements to Europe with the arrival of Syrian refugees in the summer of 2015, Afghan refugees in 2021 and Ukrainian refugees in 2022. As international migration is expected to increase with the ongoing political and military conflicts, economic hardship, as well as the global health and climate crises, naturalisation will also gain more significance because it is difficult for many migrants to return to their home countries, and staying permanently in their host countries will become an increasingly attractive option. Both in the UK and in Germany, migration and naturalisation continue to be the subject of political debate and public policy, with different nuances. In the UK, we have seen the intensified securitisation of migration and the creation of a “hostile environment” aiming to deter migrants through a range of policy measures over the past decade. Since the 2010 election of the coalition government of Conservatives and Liberal Democrats led

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by David Cameron, the UK government has committed itself to reduce immigration “from the hundreds of thousands to the tens of thousands”, known as the “net migration target” (see Boswell 2018). In 2012, then Home Secretary Theresa May launched the “hostile environment” policy which aims at making life in the UK as difficult as possible for migrants without a permanent residence right, especially those considered “illegal,” so that they would leave “voluntarily”. This policy included highly controversial measures such as vans driving around superdiverse London boroughs, including Brent in 2013, with billboards displaying the message “In the UK illegally? Go home or face arrest. Text HOME to 78070 for free advice, and help with travel documents. We can help you to return home voluntarily without fear of arrest or detention.” The 2014 Immigration Act further strengthened this policy by holding landlords, banks, and driving licence providers responsible to check migrants’ legal status and, if necessary, refuse service provision. This Act also expanded the competences of the Home Secretary to withdraw citizenship from naturalised citizens if their conduct is “seriously prejudicial to the vital interests of the United Kingdom”, even if that deprivation would make the individual stateless (section 66). The 2016 Brexit referendum further aggravated the hostile environment as it forced approximately six million EU migrants in the UK to apply for settlement under the EU Settlement Scheme to secure their rights to live and work in the UK after 31 December 2020 when Brexit came into effect (https://the3million.org.uk/eu-­citizens-­issues). However, when applying for settled status or for naturalisation in the UK, numerous EU citizens experienced difficulties in proving that they exercised their residence rights (Yeo 2018). The “hostile environment” policy nurtures an institutional and public culture of mistrust which creates severe problems not only for migrants but also for British citizens, as the Windrush scandal perhaps most strikingly demonstrates. In 2017, journalists and charities began to reveal that a significant number of black, Asian, and ethnic minority British citizens were being wrongly denied services, detained, and deported. These people or their parents or grandparents had come to the UK from British colonies or Commonwealth countries, for example, with the ship “Empire Windrush” in 1948. As then “citizens of the UK and colonies” they held

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full entry, residence, and work rights and therefore they neither required nor were given any documentation of their arrival or those rights, except for the ships’ landing cards which the Home Office destroyed in 2010 as part of a clean-up. Even though they were and are legal citizens, they could not prove it and became victims of the “hostile environment” policy. Ironically, the institution that tests migrants’ knowledge of language and life in the UK was advised to catch up on its own knowledge as the “Windrush Lessons Learned Review” recommended, among others, that the Home Office staff should undergo a learning programme to understand “the history of the UK and its relationship with the rest of the world, including Britain’s colonial history, the history of inward and outward migration and the history of black Britons” (cited in Harvey 2020). In a most recent turn, the Home Office’s “hostile environment” policy agenda no longer aims at inducing migrants to “leave voluntarily” but to enforce their removal following the Australian approach of offshoring immigration control. On 14 April 2022, then Home Secretary Priti Patel announced plans to fly asylum seekers to Rwanda which have been criticised by human rights and medical associations (Taylor 2023). The first flight was due to take off on 14 June 2022 but was halted by an “interim measure” issued by the European Court of Human Rights. Nevertheless, the UK government has commissioned accommodation blocks being built in Rwanda and the current Home Secretary, Suella Braverman, is determined to enforce the plan as soon as legal proceedings have concluded (ibid.). At the same time, it was revealed by the charity Migrant Voice (Townsend 2023) that the conditions of temporary accommodation of asylum seekers in hotels in the UK have deteriorated to a standard worse than in prisons. Immigration minister Robert Jenrick plans to house asylum seekers at disused army bases and cruise ships (Walker 2023) in a new attempt to deter people from entering the UK and to appeal to right-leaning voters. Moreover, the UK has become “the most eager citizenship stripper” in Europe (Birnie and Bauböck 2020, 270) as the UK Home Secretary’s deprivation powers have been extended over the past two decades. Section 10 of the Nationality and Borders Act 2022 exempts the Home Office from giving “notice of decision to deprive a person of citizenship” if it is not “reasonably practicable” to do so. Effectively, the Home Office may

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now legally withdraw British citizenship from someone who is considered a security threat without telling the affected person. This measure aggravates the UK made problem of statelessness and might affect around six million British citizens, many of ethnic minority (van der Merwe 2021). In Germany, by contrast, we have seen an overall liberalisation of immigration, integration and naturalisation policies, including the official launch of a “welcoming culture”, albeit not for entirely humanitarian reasons but with the specific utilitarian aim to tackle the country’s increasing labour shortage (cf. Schammann and Gluns 2021, 94–99). While far right populism and violence is manifest also in Germany, this did not translate into such far reaching immigration hostile policies and laws as in the UK. For example, in his controversial book Deutschland schafft sich ab published in 2010, former SPD politician Thilo Sarrazin denounced Muslim migrants in Germany for their supposed unwillingness to integrate, and the Islamophobic movement PEGIDA sparked demonstrations in Dresden and other German cities. In 2011, public awareness turned to the neo-Nazi group National Socialist Underground which had committed a series of racist murders between 2000 and 2007 which the German authorities had failed to prohibit and investigate, revealing severe institutional racism within the police and security forces. In the area of asylum policy, there have been some restrictions such as access to welfare benefits and more countries being added to the list of “safe countries” whose citizens are unlikely to obtain refugee status in Germany. However, in the area of economic immigration the current government is preparing a new law to further facilitate the arrival of (highly) skilled workers, the successful implementation of which yet requires a major step-up and digitisation of local immigration authorities (Sachverständigenrat 2023). Moreover, in the area of integration we see a further extension and additional funding of the German language and orientation courses introduced in 2004, including specialised courses, for example, for women, young adults, or illiterate people, as well as childcare support so that parents can attend courses. In addition, since 2010 there have been official attempts at the federal and local levels to create a “welcoming culture” (Willkommenskultur), that is, to give migrants the feeling of being “welcome”. This included, for example, the creation of official “welcome centres” in many cities, including Hamburg and

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Dresden. However, the name is misleading insofar as these centres do not welcome all migrants but only serve legally documented, highly skilled ones with annual incomes exceeding 30,000 Euros (Ludwig 2013), thus illustrating the utilitarian logic underlying German migration policies. The oft-cited phrase “We can manage this” (Wir schaffen das) and the decision by then CDU chancellor Angela Merkel to not close the borders when about 890 000 refugees entered and registered in Germany in 2015 represents the very antithesis to the UK government’s “hostile environment” approach. Merkel refrained from following the Dublin Regulation by not deporting asylum seekers back to the countries where they first entered EU territory, such as Greece or Hungary. While the sudden arrival of such large numbers of refugees represented a major challenge for the robust German state monitoring capacity (Badenhoop 2021), there was a simultaneous surge of civil society initiatives to provide support and accommodation. Some of these migrants moved on but many stayed in Germany, making German citizenship an increasingly attractive and attainable status, as a recent study found (Gülzau et al. 2022). While the current UK government under Rishi Sunak and the incumbent Home Secretary Suella Braverman remain firmly committed to the “hostile environment” approach, the current German coalition government led by Olaf Scholz affirmed that Germany is an “immigration country” and announced to further liberalise the nationality and naturalisation law. As outlined in the coalition agreement, the Social Democrats (SPD), Greens and Free Democrats (FDP) intend to allow for German citizens to hold multiple nationalities and facilitate a faster route to naturalisation after five years of regular residence or three years in case of “outstanding efforts at integration” (Bundesregierung 2021, 118). Moreover, they want to reduce the required language skills for descendants of the “guest worker” generation and in cases of hardship, and they are committed to clarify the vague statutory requirement in section 10 of the Nationality Act (StAG) according to which migrants are naturalised if “their acceptance of German social norms is assured”1 ([ihre] Einordnung in die deutschen Lebensverhältnisse gewährleistet ist). Finally, the coalition  Translation by the Federal Ministry of the Interior. https://www.gesetze-im-internet.de/englisch_ stag/index.html (accessed 21 September 2022). 1

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government announced the promotion of naturalisation through a national campaign and encourages the continuation of naturalisation ceremonies (ibid.). These plans were criticised by leading Christian Democrats who feared that this reform would “sell German citizenship at a loss” (verramschen) and create “pull factors” for irregular migration (similar to the concerns voiced by some officials and politicians interviewed for this research, see Chap. 3) (ZEIT ONLINE 2023). Nevertheless, the draft act including the changes outlined above has gone into interdepartmental coordination in January 2023, and it is expected to be adopted as law in the course of 2023 (ibid.).

7.2 Recommendations for Future Policy-Making The policy measures outlined above would certainly improve accessibility of naturalisation in Germany. However, a number of major problems identified in this research remain to be resolved both in Germany and the UK. To this end, I conclude this book by highlighting the main empirical insights and recommendations for future policy-making to render naturalisation a more accessible, transparent, and inclusive procedure in the UK, Germany, and other states with similar naturalisation regimes.

De-Symbolise Naturalisation This research demonstrated that citizenship tests, courses, and ceremonies contribute to a symbolic overload of naturalisation in the subjectivity of the Super Citizen. This subjectivity facilitates both material and discursive hurdles through the idealisation of naturalised citizens according to which they will make a political, economic, and cultural contribution to the state. My analysis shows that this overload of expectations entails the risk of creating two unintended and counterproductive effects: (1) the alienation of settled, well-integrated migrants and (2) the creation of new social hierarchies between naturalised and national-born citizens, as well as between naturalised and non-national migrants, because

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naturalised citizens may develop a sense of bewilderment or superiority through their experience of naturalisation (see Chap. 6). In my view, it is unlikely that these effects could be avoided by deploying alternative subjectivities (e.g., along republican, cosmopolitan, or multicultural frames). Indeed, any symbolic overload is likely to generate unintended and counterproductive effects. In the current climate of highly politicised and polarised debates on immigration dominated by far right populist narratives, a pragmatic approach that focuses on the liberalisation of the formal requirements and their consistent and transparent implementation may be the most promising road to a more accessible, transparent, and inclusive naturalisation procedure. My first recommendation for both the UK and Germany is therefore to de-symbolise naturalisation. Concretely, this can be done by refraining from idealising both the state and naturalised citizens in test questions, course exercises, and ceremony speeches. Instead, the idealisation of the Super Citizen could be replaced by a narrative that recognises the legal equality of naturalised and national-born citizens, and the expectations could be scaled down to a pragmatic focus on explaining the rights (and duties) that come with a residence permit and citizenship status and how to enforce or claim them in practice. For example, regarding the economic aspect of the Super Citizen subjectivity, ceremony speakers or course teachers could explain the minimum wage and how to enforce it (as indeed some teachers did, see Chap. 5), instead of encouraging naturalised citizens to engage in unpaid work. Similarly, the handbook to prepare for the “Life in the United Kingdom” test could be revised. It currently starts as follows: Britain is a fantastic place to live […] We are proud of our record of welcoming new migrants who will add to the diversity and dynamism of our national life. […] Good citizens are an asset to the UK. We welcome those seeking to make a positive contribution to our society. (The Stationary Office and Home Office 2022, 7)

Instead, the text could begin, for example, by expressing the state’s gratitude that migrants came to the UK and showing recognition of their efforts to become full members.

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Introduce a Conditional Entitlement to Naturalisation and a Right to Appeal (in the UK) Unlike in Germany, naturalisation in the UK has always been defined exclusively as a discretionary grant since feudal times (see Chap. 1). Still today, as stipulated by the 1981 British Nationality Act (section six), the Home Secretary “may, if he thinks fit, grant […] a certificate of naturalisation”. This means, in case of a rejection, the Home Secretary’s decision must not be justified, and it cannot be appealed. This definition creates uncertainty and risks for migrants who wish to apply for citizenship. It is often unclear to migrants whether (or when) they qualify in the eyes of the Home Office and which type of proof is accepted to demonstrate this. In case of a rejection, they have little agency as there is no right to appeal, and they risk significant financial loss as the application fee is not refunded. The discretionary definition coupled with vague statutory requirements such as “good character” makes naturalisation an opaque, potentially arbitrary process with uncertain outcome, where the Home Office may withhold citizenship and migrants appear like subordinate petitioners, rather than rights-holders. To create a modern, transparent naturalisation process, I would recommend to introduce a conditional entitlement to naturalisation in the UK, based on clearly defined requirements, with a right to appeal. This would give migrants who wish to stay permanently a clear prospect and pathway to citizenship.

Reduce the Naturalisation Fee (in the UK) In the UK, the fee for an application for naturalisation has increased exponentially from 218 GBP in 2004 to 1330 GBP in 2022. The actual administrative cost for processing an application is estimated to be 372 GBP but since 2004, the Home Secretary may charge fees beyond cost recovery. Since then, naturalisation alongside other immigration applications have generated a steady and significant source of income for the Home Office. For many migrants the high naturalisation fee is a major deterrent, citizenship is simply not affordable as the application fees and related costs quickly add up to several thousands of pounds, especially for

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families. However, in the current “hostile environment” for immigrants, citizenship offers the most secure status migrants can attain. Thus, many find themselves forced to apply and borrow or save which aggravates personal debt, austerity, and financial distress in economically difficult times. I would therefore recommend to reduce the British naturalisation fee to the level of the actual administrative costs of the process. This would require a shift away from the rationality of citizenship as commodity and a structural change in the Home Office’s funding strategy, but it would help make naturalisation more accessible and attractive regardless of socio-economic background. It would also reinforce the idea that migrants are rights-holders, not customers of an unreliable service.

 estore the ESOL with Citizenship Materials Course R Route (in the UK) When the “knowledge of life in the UK” requirement was first introduced in 2002, this knowledge could be demonstrated by either passing the “Life in the United Kingdom” test or taking an English language course with citizenship materials, like in Germany (see Chap. 5). At the time, the course length, quality, and costs were not fully regulated so they varied significantly and it was difficult for migrants to identify an accredited course centre. In 2013, the Conservative and Liberal Democrat coalition government led by David Cameron made the test mandatory for all citizenship and settlement applicants. The test is a major hurdle for applicants with limited literacy and/ or English language skills. It disproportionately favours highly skilled migrants and those from English-­ speaking countries of origin. Unlike the test, the course offers a more effective collective learning process over time, as well as social interaction, which many participants in this research welcomed. I therefore recommend to restore the course route as an additional option to meet the knowledge requirement which would reduce the social selectivity of the test hurdle. Moreover, if the course is coupled with public funding and course accreditation, like in Germany, then migrants’ integration efforts would be acknowledged and consistent course quality ensured.

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 estore Public Funding for Legal Advice R on Naturalisation (in the UK) In the UK, naturalisation is not included in publicly funded “Legal Aid” advice centres. Indeed, the Home Office used to explain to citizenship applicants that naturalisation a “straightforward process which does not require the use of specialist agencies” (Home Office 2015, 4), as discussed in Chap. 3. The “Nationality Checking Service” offered by Local Authorities does not provide legal advice. Registrars merely check if the application is formally complete. In reality, however, for many migrants, naturalisation is not “straightforward” and they need qualified legal advice and support to assess their eligibility and to understand how to make a successful application with sufficient evidence or how to negotiate an exemption. Legal advisers reported cases of unnecessary rejections, that is, when migrants make a minor mistake that could easily be avoided. For example, a miscalculation of the qualifying period for the residence requirement may result in the application being rejected and the fee not reimbursed, without a right to appeal. Legal advisers working in publicly funded “Legal Aid” centres openly expressed their frustration about the naturalisation procedure: The money is with the [Home Office] and there is no way of getting it back. When they [citizenship applicants] come [to this legal advice centre], they already lost the money. The few who come on time, we have to send back. So, at the point when they needed the advice we can’t help them, and at the point where we can help them, the money is lost. It’s a huge problem. (BrLA05, conversation 31/10/2012)

I therefore recommend to restore “Legal Aid” funding for naturalisation so that migrants can access qualified legal advice and make informed choices before the application submission, irrespective of socio-­economic background. This would help to reduce unnecessary cases of rejections and thus also facilitate the decision work of Home Office caseworkers.

Allow Dual Nationality (in Germany) German citizenship law still adheres to the principle that dual nationality should be avoided. This means that citizenship applicants must normally

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give up their previous citizenship before they can acquire German citizenship (StAG s 10 (1) 4). While the law provides for exceptions to this rule (see StAG s 12), this requirement is still a major deterrent for many candidates. The renunciation of one’s previous nationality may be a big emotional demand, creating loyalty or identity conflicts. Practically, it is a difficult if not impossible task as some states, for example Vietnam, are reluctant to release their citizens. And it may create financial problems because it ignores the reality of transnational lives and lifestyles such as real estate properties or inheritance rights. I therefore recommend that German nationality law adopts the recognition of dual (or multiple) nationality by principle, thus following the international trend (cf. Vink et  al. 2019). While the present coalition government is committed to allow for multiple nationality, it yet remains unclear if, when and how exactly this will be turned into law and be implemented in practice. Given the strong resistance to dual nationality of children under the ius soli provisions in CDU-led Länder in the past and the heated debate of the current reform, this announced legal change is likely to be watered down in the legislative process.

 learly Define “Outstanding Efforts at Integration” C (in Germany) German citizenship law offers an incentive and fast-track option for applicants who can demonstrate “outstanding efforts at integration” as they may be eligible for naturalisation earlier, currently after six instead of the usually required eight years of residency (StAG s 10 ss (3)). While the current government aims to strengthen this incentive by further reducing the residency period to three years with the latest reform, it still remains unclear how exactly “outstanding efforts at integration” are defined and there is some indication that different Länder apply different interpretations of this provision. As long as the federal administrative guidelines (Bundesministerium des Innern 2015) remain provisional recommendations that are not binding, the interpretation of this section is likely to continue to vary between the sixteen states, depending on the political and administrative culture in each state and local authority. In some

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places, this provision seems to exist only on paper, revealing the discrepancy between the law on the books and the law in practice. I therefore recommend that the vague legal term of “outstanding efforts at integration” be specified and clarified. If set out in binding federal regulations, a transparent definition of these requirements would help reduce arbitrary implementation in the Länder and local Foreigner Authorities and ensure that this option is available irrespective of whether the application is submitted to a liberal or restrictive local authority. Moreover, this would create a reliable fast-track route to naturalisation across Germany that is accessible for those who already meet the requirements.

Publish the Administrative Guidelines (in Germany) In Germany, naturalisation is regulated by the federal Nationality Act (StAG). However, in the federal state system, the implementation of naturalisation is carried out by several hundred local authorities in the sixteen states. The decision work by local caseworkers is guided by the state specific caseworker instructions which are binding, as opposed to the federal administrative guidelines which remain provisional recommendations. Unlike in the UK, these sixteen states’ specific caseworker instructions are not all published. While some states published them, e.g. Hamburg, others refrained from doing so, e.g. Saxony. This creates the problem that the state’s interpretation of the law is unclear in some states, making it difficult to give legal advice and make informed choices, as criticised by legal advisers and citizenship applicants. Ironically, migrants in Germany hold an entitlement to naturalisation but often feel like petitioners, not rights-holders, while naturalisation in the UK is discretionary but migrants often (mistakenly) believe they hold a right to citizenship or at least a right to appeal a negative decision. There continues to be a massive mismatch between the legal entitlement to citizenship stipulated by the German Nationality Act and local naturalisation practices in the federal state system. For example, my study shows that citizenship applicants found it a lot easier to convince the authorities of their integration efforts in Hamburg than in Dresden. Indeed, some caseworkers think that naturalisation should be a discretionary award, not a legal

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entitlement. To reduce this discrepancy between the naturalisation law on the books and in practice, a real welcoming culture is needed in the local Foreigner Authorities to enable migrants to successfully claim their right to naturalisation and not be discouraged by local caseworkers. One pragmatic step toward such a culture of welcome inside the Foreigner Authorities would be to publish the caseworker instructions in all sixteen German states so that the administrative interpretation of the law is made transparent to citizenship applicants and legal advisors.

 edefine the Economic Self-Sufficiency Requirement R (in Germany) In Germany, citizenship applicants must demonstrate that they “are able to support themselves and their dependants without recourse to benefits in accordance with Book Two or Book Twelve of the Social Code, or if recourse to such benefits is due to conditions beyond their control” (StAG s 10 ss (1) sent 1 no. 3). This requirement is a real barrier for unemployed persons, self-employed persons, or those with unpaid care duties, for example, mothers of young and/or disabled children, and it may aggravate gender and class discrimination, especially in difficult economic times. Moreover, the vague formulation of this provision entails the risk of inconsistent, potentially arbitrary interpretation by local Foreigner Authorities and may lead to cases in which an applicant is discouraged as not eligible in one local authority but might qualify for citizenship status in another. The rationality behind this requirement is that the German state suspects cases of “indolence” (Arbeitsunwilligkeit) among citizenship applicants (Bundesministerium des Innern 2015, 26). Even though the problematised figure of the dependent citizenship applicant and the discourse of “benefit scroungers” was also prevalent in the UK, such a statutory economic self-sufficiency requirement does not exist in British nationality law. Instead, financial soundness is included in the “good character” requirement. Financial soundness is not given, for example, in cases of non-payment of Council Tax (which is a mix of property and personal tax in the UK that is difficult to avoid). If Germany

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adopted an approach similar to the UK and transformed the economic self-sufficiency requirement into a requirement of freedom of financial debts vis-à-vis German public authorities, this would be one way to effectively abandon the current economic threshold for naturalisation. Yet, these policy changes would require a general shift away from the subjectivity of the Super Citizen and its underlying neoliberal and neonational discourse; a move that can only be effected by policy makers, initiated by civil society actors, and informed by critical social research.

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Index1

A

B

Alliance 90/The Greens (green political party in Germany), 212 Alternative for Germany (Alternative für Deutschland, AfD), 25, 208 Anthem, 88, 89, 126, 127, 130, 147, 153, 161, 162, 169, 176, 177, 186 Appeal, right to, 17, 22, 29, 68, 73, 109, 215, 217, 219 Asylum, 20, 21, 24, 25, 45, 59, 92, 93, 105, 109, 112, 151, 156, 210–212 Attachment, rationality of, 86, 89, 91, 94, 98, 99, 136, 206 Award, rationality of, 73, 91, 96, 97, 99, 134, 206

Basic Law, German (Grundgesetz), 20, 21, 71, 125, 126, 175, 177, 188 Blunkett, David, 25, 39, 61, 75, 84, 90, 97, 98 Braverman, Suella, 210, 212 Brent, London Borough of, 1, 1n1, 24, 37, 38, 41, 46–48, 53, 54, 56, 60, 61, 84, 85, 88, 95, 99, 107, 109, 112, 116, 122–125, 127–130, 132, 133, 136, 150, 152, 154, 161–166, 168, 169, 172, 177, 178, 209 Brexit, 29, 51, 53, 178, 209 British citizenship and nationality acts British Nationality Act (BNA) 1948, 17

 Note: Page numbers followed by ‘n’ refer to notes.

1

© The Author(s), under exclusive license to Springer Nature Switzerland AG 2023 E. Badenhoop, Calling for the Super Citizen, Palgrave Politics of Identity and Citizenship Series, https://doi.org/10.1007/978-3-031-34260-8

225

226 Index

British citizenship and nationality acts (cont.) British Nationality Act (BNA) 1981, 18, 22, 40, 44, 56, 67, 68, 109, 215 British Nationality and Status of Aliens Act 1914, 17 Immigration Act 2014, 209 Immigration Acts 1962, 1968, and 1971, 17 Nationality and Borders Act 2022, 210 Nationality, Immigration and Asylum Act 2002, 18, 68 Naturalization Acts 1844 and 1870, 17 British National Party (BNP), 24, 88 Burnley, 1n1, 24, 25, 56, 60, 88, 89, 96, 99, 109, 111, 116–120, 126–129, 131, 132, 136, 146, 148, 150, 155–157, 162–169 C

Cameron, David, 144, 209, 216 Caseworker instructions, 26, 38, 44, 46, 195, 207, 219, 220 Caseworkers, 11, 13, 25, 27, 44, 50, 51, 53, 56, 58, 70, 72, 73, 80, 81, 86, 92, 95–98, 104, 108, 110, 112, 113, 121–127, 134, 137, 190, 195–199, 201, 206, 217, 219, 220 Centralisation, 4, 15, 18, 19, 27, 104, 137 Christian Democratic Union of Germany (CDU), 66, 69 Citizenship, 1n1, 2–16, 18–29, 35–62, 65–99, 103–111,

114–131, 133–137, 141–179, 183–190, 192–194, 196–201, 203, 205–207, 209–220 applicants, 1n1, 4, 5, 11, 13, 22, 25–28, 36–60, 62, 65–67, 70–74, 76, 77, 82, 84–87, 89, 90, 92, 96, 98, 99, 103, 105–110, 128–131, 134, 136, 141–143, 146, 147, 157, 159, 163, 164, 169–173, 175–176, 183, 184, 186, 187, 189, 190, 192–194, 196–201, 206, 207, 217, 219, 220 by birthright, 3, 13, 53, 59, 192, 202 by birthright (ius sanguinis), 3, 15, 19 by birthright (ius soli), 3, 15, 17, 18, 21, 218 civic versus ethnic models of, 201 investor, 56, 93, 94 ceremony, 1n1, 2, 13, 14, 16, 18, 19, 21–25, 27, 45, 46, 50, 77, 78, 82–89, 93, 94, 99, 104, 122, 123, 125–130, 134, 136, 161–177, 163n5, 185, 187, 188, 206 course, 9, 11, 13, 18, 25, 28, 77, 114–121, 134, 135, 141–179, 188, 193, 206 materials (NIACE) for ESOL courses, 114, 115, 216 by naturalisation, 9, 11–16, 24, 25, 27–29, 35–62, 65–99, 103–108, 121, 134–137, 141, 144, 145, 170–172, 174, 178, 183–203, 205–221 policies, 61

 Index 

by residence (ius domicilii), 3, 17, 19–23, 36, 41, 42, 51–55, 57, 80, 93, 94, 109, 112, 145n1, 187, 191, 192, 195, 196, 200, 202, 209, 210, 212, 214, 217 studies (academic), 4, 200 test, 4, 7–9, 14, 15, 22, 25, 27, 39, 49, 71–73, 75, 99, 117, 135, 143–145, 186, 197, 199, 203, 213 withdrawal of, 23, 68, 105, 107 Commodity, rationality of, 27, 98 Comprehensive Sickness Insurance (UK), 52 Conservative Party (UK), 144, 208, 216 Culture, “guiding” or “leading” (German Leitkultur), 198 Culture, “welcoming” (German Willkommenskultur or Willkommensgesellschaft), 191, 211, 220 D

Decentralisation, 15, 27, 104 Dependent, problematisation of, 82, 108, 110 Discretion, 15, 16, 19, 27, 66, 67, 69, 109, 195, 196, 200, 201 Discrimination, 151, 153, 158, 220 Diversity, 1n1, 2, 5, 14, 168, 169, 174, 214 ethnic or cultural, 2, 13, 24, 82, 95, 166, 168, 171, 172, 206 religious, 143, 149, 153, 172, 178 Dresden, 1n1, 2, 24, 40–42, 58, 60, 69–73, 83, 86, 91, 96, 98, 107, 108, 110, 112, 113, 116,

227

117, 127, 135, 147, 151, 154, 157–159, 162–170, 173, 176, 190, 194–197, 199–201, 211, 212, 219 Duty, 8, 9, 16, 27, 61, 72–75, 91, 105, 132, 136, 143, 150, 160, 214, 220 migrants, 135 state’s, 9 Duty to naturalise, 75 E

East African Asians, 17 English for speakers of other languages (ESOL) course, 41, 48, 53, 54, 112, 114–116, 143, 144, 187, 193, 216 Entitlement, rationality of, 74, 76, 82, 97, 99, 106, 159 Ethnicity, 123, 136 Ethnicity, German (Volkszugehörigkeit), 20 Europe, European Union, European Nationals, 3, 15, 25, 36, 43, 46, 47, 51–55, 57, 59, 76, 93, 94, 115, 130, 143, 148, 154, 174, 177, 178, 185, 208–210, 212 EU Settlement Scheme, 52, 209 Exclusion, 4, 7, 9–11, 76, 186, 187 F

Federalism, 15, 16, 19, 71, 117, 135, 147, 161, 201, 211, 219 Federal Ministry of the Interior, 16, 57, 106

228 Index

Federal Office for Migration and Refugees (BAMF), 114, 115, 117, 121, 144, 145, 147–152, 155, 156, 158, 159 Federate states (Länder), German, 58, 218, 219 Feudalism, 16, 19, 71, 96, 164, 215 Flag, 85, 88, 89, 120, 125, 146, 153, 161–163, 169, 176, 177 Foreigner Authorities, 15, 107, 112, 113, 145n1, 157, 158, 196, 219, 220 Foreigner Commissioner, 107, 113, 169 Foreigner Council, 157 Foucault, Michel, 10, 141 Free Democratic Party (Germany), 212 Frequent fliers, 36, 55–57 G

Gender, 47, 50, 123, 151, 159, 160, 184, 202, 220 Genealogy German citizenship and nationality acts Foreigner Act 1990 (Ausländergesetz, AuslG), 20, 21 German Empire and Nationality Act 1913 (Reichs- und Staatsangehörigkeitsgesetz, RuStAG), 19 German Federal Expellees Act 1953 (Bundesvertriebenengesetz, BVFG), 20 German Immigration Act 2004 (Zuwanderungsgesetz, ZuwandG), 21, 106, 144

German Residence Act 2008 (Aufenthaltsgesetz, AufenthG), 145, 145n1 Prussian Subjecthood Act 1842, 19 since 2000 Nationality Act (Staatsangehörigkeitsgesetz, StAG), 16n4, 19, 21–23, 40, 44, 57, 67, 73, 91, 97, 143, 195, 200, 212, 218–220 German Empire, 19 German Weimar Republic, 19 Germany, 2–7, 3n3, 13, 15–29, 36, 37, 41, 42, 44, 49, 52, 55–58, 60–62, 65–67, 69, 71, 73, 74, 77, 81, 82, 84, 89, 91, 92, 94, 96–99, 103, 109, 114–117, 121, 123, 125, 133–135, 137, 141–154, 156–159, 166, 168, 169, 171–179, 184, 185, 188, 189, 192, 194, 196–198, 200, 201, 206–221 Germany, East (German Democratic Republic, GDR), 20, 118, 143, 149, 178 Germany, West (Federal Republic of Germany, FRG), 149 H

Hamburg, 1n1, 24, 25, 39, 49, 58, 60, 66, 70, 73–75, 77–83, 85, 97–99, 107, 110, 112, 113, 115, 118, 121, 125, 126, 128, 134–136, 147, 149, 153, 156, 157, 162, 164–169, 174, 176, 177, 196, 201, 211, 219 Home Office (UK), 15, 25, 38, 40–42, 44, 48–51, 56, 60, 67,

 Index 

67n1, 68, 73, 75, 85, 90–94, 97, 104, 108–113, 115, 122, 126, 128, 135, 137, 143, 144, 146–149, 153, 156, 163, 170, 210, 214–217 Home Secretary (UK), 15, 17, 25, 27, 39, 44, 45, 61, 66–68, 75–77, 81, 86, 90, 96–99, 125, 135, 170, 209, 210, 212, 215 Hostile environment policy (UK), 209, 210 I

Immigrants, German (Aussiedler), 19, 20, 39, 57, 106, 145 Immigrants, (highly) skilled workers, 171, 211 Immigrants, irregular or “illegal,” 43, 45–47, 134, 209, 213 Immigrants, labour, 20, 75, 115, 194, 211 Immigrants or migrants, 2–6, 9, 12–15, 19–22, 24–28, 35, 37, 39, 43–46, 52, 54–57, 59–62, 67n1, 69, 70, 72, 74–82, 85, 93, 96–99, 104, 106–108, 113, 115, 116, 126, 128, 130–136, 142, 144–146, 145n1, 152, 153, 157, 159, 165, 168, 172–174, 176–178, 183–203, 205–217, 219, 220 Immigrants, refugees, 17, 58, 59, 85, 136, 151, 167, 174, 208, 212, 2055 Inclusion, 4, 7, 9–11, 28, 62, 77, 97, 184, 187, 190, 202, 203

229

Indifferent, problematisation of, 26, 36, 37, 55, 59, 60, 62, 82, 206 Insincere, problematisation of, 59, 187, 193 Integration, 4, 9, 37–55, 59, 61, 69, 73, 75, 97, 106, 109, 145, 148, 156, 184, 187, 194, 195, 197, 199, 200, 202, 211, 212, 216, 218–219 Integration course, 21, 98, 104, 114, 115, 135, 144, 145, 145n1, 185 Intersectionality, 135 Ius soli, 3, 15, 17, 18, 21, 218 J

Jews, 20 Johnson, Boris, 208 L

Labour market, 39, 49, 60, 194 Labour Party (UK), 39, 68, 75, 90, 98, 177 Lancashire, 88, 89, 129, 136, 165–169 Language skills, 4, 5, 13, 22, 27, 45, 46, 49, 93, 105, 109, 117, 136, 143, 186, 192, 196, 200, 202, 212, 216 Law in practice, 219 Law on the books, 23, 40, 219, 220 Legal advisers, 1n1, 25, 27, 42, 49, 53, 55, 104–114, 134–137, 217, 219

230 Index

Liberal/illiberal, 2, 4, 5, 7, 8, 12–14, 59, 62, 76, 82, 97, 146, 150, 161, 178, 188, 205, 206, 219 Liberal Democrats (UK), 144, 177, 208, 216 Local authorities, 16, 19, 22, 41, 48, 50, 53, 66, 71, 85, 88, 94–96, 98, 115, 122, 123, 125, 127, 137, 164, 168, 173, 195, 201, 217–220 M

Macro, meso and micro levels of analysis, 6 May, Theresa, 76, 135, 170 Medal, 125, 163, 164 Merkel, Angela, 119, 212 Minors, disabled and elderly people, 37, 40–41, 122, 163, 217 Modernity, 146, 175–179 Monarchy, 96, 118, 129, 136, 163, 165 Multi-sited state ethnography, 6, 7, 23–26 N

National Democratic Party, German (NPD), 25, 166 Nationalism, 14, 28, 173, 174 methodological, 24 state, 189 Nationality, 3, 20, 23, 25, 35, 38, 39, 44, 46, 47, 52, 53, 55, 57, 58, 73, 83, 95, 98, 112, 125, 136, 137, 153, 184, 191, 192, 202, 207, 212

Nationality Checking Service (NCS), 25, 38, 42, 50, 85, 91, 94, 95, 122–124, 137, 217 Nationality law, 15, 22, 23, 26, 37, 60, 218, 220 Nationality, dual or multiple, 11, 23, 29, 53, 54, 57, 58, 212, 217–218 Naturalisation, 1–29, 35–62, 65–99, 103–137, 141, 143–145, 154, 171, 172, 174, 176–179, 183–203, 205–221 application of, 25, 68, 78, 90, 92, 94, 104, 122, 128, 133, 134, 137, 193 certificate of, 13, 70, 72, 94, 170, 188, 190, 192, 202, 215 discretionary (Ermessenseinbürgerung), 15–17, 19, 21, 22, 27, 66–68, 71, 73, 96, 106, 109, 134, 200, 201, 206, 207, 215, 219 by entitlement (Anspruchseinbürgerung), 20 fee for, 23, 27, 91, 93, 98, 215–216 policies, 4, 6, 15, 29, 39, 211 studies, critical, 4 Naturalisation requirements dialectical critique of, 9, 187, 188 economic self-sufficiency, 37, 207, 220–221 exemption from, 40, 61 good character, 11, 17, 22, 23, 38, 44–46, 60, 109, 201, 215, 220 language and knowledge of life in the UK or Germany respectively, 40, 48, 61, 114, 144

 Index 

loyalty oath and declaration, 207 neoliberal critique of, 9 postcolonial-racist critique of, 9 residence, 21, 80, 93, 217 special integration achievements, 184 Nazi regime, 20 Neoliberalism, 194 Neonationalism, 173–175 Neo-Nazi, 166, 173, 175, 211 Nostalgia, 143, 175–179 O

Olympics, 171 P

Parliament, 2, 85, 117, 129, 166, 176, 208 Passport, 9, 17, 39, 50, 53, 54, 60, 69, 98, 124, 187, 189, 191, 202 Patel, Priti, 94, 210 PEGIDA, 211 Populism, right wing and far right, 14, 211, 214 Proof, burden of, 22, 38, 52, 143, 194, 200, 215 Public policy, 36, 208 Public policy, recommendations, 29, 213–221

231

R

Racialisation, 188 Racism, 5, 9, 15, 62, 135, 166, 174, 175, 190, 202 individual, 166 institutional, 191, 211 Registrars, 1, 25, 38, 40–42, 45–47, 49, 50, 53–55, 60, 61, 68, 85, 86, 91, 94, 104, 121–128, 130, 132, 161, 163, 164, 217 Responsibility or responsibilisation, of the state or of migrants, 9, 176 Rights, 3, 3n3, 8, 15–18, 20–22, 24, 27, 29, 36, 44, 51, 53, 55, 57–59, 65, 68, 72–74, 81, 82, 84, 87–91, 93, 94, 98, 99, 104, 107, 109, 119, 121, 125, 133, 134, 136, 142, 143, 145n1, 150–154, 156–160, 163, 172–174, 176, 177, 185, 191, 198, 202, 208–210, 214, 215, 217–220 Rights, human, 3, 18, 92, 142, 143, 149, 150, 152, 159, 177, 178, 210 Right to have rights, 205 Right to naturalise, see Naturalisation, by entitlement Right to vote, 3n3, 13, 150, 170, 176 Rose, Nicholas, 11, 12, 35, 60, 65, 96, 103, 141, 172, 206 Rwanda, 210

Q

Queen of the United Kingdom and of the other Commonwealth realms, 187

S

Saxony, 16, 71–73, 83, 96, 99, 113, 164, 166, 167, 169, 207, 219

232 Index

Scholz, Olaf, 25, 39, 57, 74, 80, 167, 212 Scroungers, 35–62 Securitisation, 9, 36, 61, 188, 208 Sexism, 135 Skilled worker shortage (Fachkräftemangel), 211 Social Democratic Party of Germany (SPD), 39, 57, 66, 74, 80, 82, 98, 167, 174, 177, 211, 212 Statelessness, 3, 211 Street-level bureaucrats, 24, 201, 207 Subject-formation, 1–29, 35, 61, 65, 82, 96, 99, 103, 104, 127, 133, 141–179, 183, 198–200, 206, 207 attempts of, 10, 12, 207 authorities of, 11, 12, 27, 103, 133 problematisations of, 11, 206 rationalities of, 11, 206 responses to, 12, 28 techniques of, 11, 12, 28, 99, 141–179, 198, 199, 206 Subjecthood, British, 16, 96 Subjecthood, feudal, 16, 96 Sunak, Rishi, 208, 212 Super Citizen subjectivity, 5, 6, 12, 14, 27, 28, 37, 43, 55, 59, 65, 96, 104, 134, 172, 173, 175, 178, 184–186, 189, 190, 192, 196, 199, 200, 202, 207, 214 T

Teachers, 1n1, 9, 11, 25, 27, 53–55, 60, 61, 104, 114–121, 125, 134–137, 144, 146, 147, 149–154, 150n3, 156–158, 160, 206, 214

Test, Life in Germany, 21, 22, 117, 144, 145 Test, Life in the United Kingdom, 18, 22, 144, 185, 214, 216 Textbook, 26, 152, 153, 157, 185 Truss, Liz, 208 U

Unification, German, 20 United Kingdom (UK), 2–7, 3n3, 13, 15–26, 36–43, 65–67, 73, 77, 94, 99, 103, 106–109, 133, 141–144, 146, 152, 184, 186, 206–213 United Kingdom Border Agency (UKBA), 47, 48, 90, 92, 111 V

Volunteering, 5, 66, 77, 135, 156, 190, 201, 202 Vote, right to, 3n3, 13, 150, 170, 176 Vote, right to stand for, 14 W

War criminals, 43–45, 60 Welcome, 9, 27, 79, 85, 88, 104, 131–133, 136, 166, 169, 173, 187, 188, 197, 199, 211, 212, 214, 220 Welfare benefits, 13, 36, 37, 211 Welfare state, 12, 41, 52, 55, 61, 75, 106, 152, 154 Windrush scandal, 209 Workers’ Council (Betriebsrat), 153