This project has received funding from the European Union’s Seventh Framework Programme for research, technological development and demonstration under grant agreement no 320294


What are the barriers to European citizenship? Work (for those who can)

The rights of European citizenship to free movement are premised on work: on the development of the European Union as a market, with the free movement of labour alongside goods, services and capital. Notwithstanding the extension of those rights to ‘economically inactive’ EU citizens, the rights of the mobile EU citizen to reside in a member state of which they are not a national citizen, beyond three months, are contingent on work (being a worker, self-employed, a job-seeker) or self-sufficiency, on having “sufficient resources for themselves not to become a burden on the social assistance system of the host Member State” (Article 7, 1(b), Directive 2004/38/EC).


At the same time, the entry of non-EU citizens to the European Union as workers is premised not simply on work but skills and income, removing the barriers to entry to European labour markets for higher skilled, higher paid workers (Directive 2009/50/EC). Non-EU citizens’ access to permanent residence in a member state (after five years of continuous legal residence) is similarly premised on work/self-sufficiency: non-EU citizens must demonstrate economic independence by having stable and regular resources, sufficient to live “without recourse to the social assistance system of the member state concerned” (Article 5, 1(a), Directive 2003/109/EC). The status of EU and non-EU citizens as ‘workers’ structures both their mobility into/within Europe and their stability – their claiming of rights of residence in a member state of which they are not a national citizen.


The principle of inclusion on the basis of work similarly underpins policies to promote the labour market activation of national citizens across the member states: policies that range from measures to support those out of work to re-enter employment to more punitive measures that obligate benefits claimants to undergo work-related activities. Self-provisioning through work is promoted as a responsibility of the national, EU and non-EU citizen. We are all required to be worker-citizens. The 2008 economic crisis, however, exposed the limitations of the worker-citizen model, of assuming ‘employment for all’ and individual self-sufficiency within the market. Household income from employment fell in real terms in some OECD countries (including Ireland, Italy, Spain, Sweden, the UK, the USA) in the period 2007-2009, while income from self-employment fell across most OECD countries. At the same time, there was a substantial increase in social benefits as a share of household income across OECD countries (Jenkins et al., 2013).


Work-related conditions of citizenship have not, however, been relaxed – indeed proposals supported by some member states to restrict the access of mobile EU citizens to social benefits reaffirm those conditions. In the context of UK policy reforms since 2008, work-related conditions have intensified in restricting access to rights of residence and to social benefits across national, EU and non-EU citizens, with the dual purpose of controlling migration and reducing expenditure on working-age social benefits. Non-EU workers have for some time had no access to social benefits (‘no recourse to public funds’) in the UK: they are entirely dependent on their labour. Permanent residence has been the basis for access to those social rights. Recent reforms have, however, further restricted the access of non-EU workers to permanent residence: non-EU skilled workers must now acquire a salary of £35,000 to be able to apply for permanent residence after five years (they must be workers with an income above the median earnings of all full-time workers in the UK). EU workers may, in principle, have rights under EU law to access social benefits. However, in order to access those rights as an EU citizen-worker in the UK, they must provide evidence of a minimum level of earnings (approx. £150 per week over a three-month period) or be assessed as having been engaged in ‘genuine and effective work’. And while, in principle, they have automatic rights to permanent residence after five years, they must provide evidence of work/self-sufficiency in the UK over this period to claim the status of permanent resident. Of course, the UK has pushed for further restrictions on EU workers’ access to social benefits through its negotiations on the continued membership of the UK in the EU.


At the same time, low-income workers who have access to means-tested social benefits in the UK –national, EU or non-EU citizens – are subject to increasingly restrictive conditions that make not simply work but a minimum level of earnings an individual responsibility of the worker. Under the new Universal Credit benefits system, those whose earnings fall below a threshold (equivalent to 35 hours at the national minimum wage) will be required to undergo activities to increase their earnings by increasing their hours of work and/or their wages.


While ’employment for all’ across Europe may be central to supporting economic growth, tackling disadvantage, reducing poverty, and other policy goals, a market-based model of citizenship has implications for extending inequalities among different categories of citizens and non-citizens. Restricting access to rights of residence and to social benefits on the basis of paid work, level of earnings, and continuity of work and earnings, divides national, EU and non-EU citizens alike in terms of the relationship of particular groups to the market. The EU citizen-worker is not a neutral status. From a gender perspective, the EU citizen-worker may be a woman. Indeed, there are high rates of employment of EU citizen-women in some member states, compared both to EU citizen-men and national citizens overall (Eurostat). However, as a woman she is disproportionately represented in ‘atypical’ work (e.g. part-time, agency work), in low-paid sectors such as care and domestic work – in work which may not meet the requirements for providing evidence of work (in the UK) or allow her to achieve continuity of work over five years. She is also more likely to exit the labour market not simply due to ‘involuntary unemployment’ but in order to care (Lewis, 2002), also with implications over the long term for retaining the status of ‘worker’, for access to social benefits and access to permanent residence.


So what are the barriers to European citizenship? While work has for long underpinned citizenship, being a ‘worker’ is not always enough – for national citizens, EU citizens and non-EU citizens – to be able to access rights of residence/citizenship and rights to social benefits. The research carried out under Work Package 10 of the bEUcitizen project points to the ways in which work not only divides us but connects seemingly disparate groups in terms of the barriers of citizenship.


See the following reports/article for further discussion:

Deliverable 10.1.

Deliverable 10.3 (forthcoming, 2016).

Shutes, I. (forthcoming, 2016) “Work-related Conditionality and the Access to Social Benefits of National, EU and Non-EU citizens”, Journal of Social Policy.