Becoming One of "Us" - how Citizenship is defined in the West
- Feb 5
- 9 min read
If you’ve ever raised a child, you probably remember the phase when they constantly asked, “Why?” I do the same thing when I read about politics or public opinion. I keep asking “why,” peeling back the layers to understand what’s really going on. I use the same approach when comparing the laws, norms, and customs of different countries.
Thanks to the Trump administration, the definition of American citizenship is front and center. But why is citizenship important? Let’s dig deeper and answer why the United States is multicultural, while France doesn’t even collect racial information in its census. Let’s look at how citizenship is defined throughout the West’s four major powers and compare and contrast how one obtains citizenship in each.
Citizenship is the basis of belonging in any country. In democracies, it gives you a seat at the table by allowing you to vote and access the safety net. Every state on Earth has laws regarding immigration (and the humane treatment of those who enter illegally), but every state also has different paths to citizenship. Some grant those rights quickly, while others require years of residency before beginning the process, but those differences give us a glimpse into each nation’s history and how it has grown over time.
This week, we’ll explore how France, Germany, the UK, and the United States define citizenship and what the process looks like in each, each reflecting those countries’ histories and cultures.
Citizenship in France
France’s modern concept of citizenship was forged in the wake of a violent revolution. In 1789, the new Republic defined the citoyen as an equal participant in a shared civic order, stripped of inherited privilege or communal distinction, to distance itself from the French monarchy’s absolutist, deeply unequal regime. This universalist identity became central to France’s state-building project. To this day, France’s national motto is “Liberté, Égalité, Fraternité”, or “Liberty, Equality, Brotherhood”. Everyone is free, equal, and shares common bonds. As with other European countries during the 19th and 20th centuries, this wasn’t practiced as much as it was preached due to the massive inequities of colonialism and only applied to a minimal number of people in the “homeland” (for example, French women could not vote until the end of World War II).
However, as the country absorbed colonial subjects and waves of immigration, the state clung tightly to the idea that a single civic culture must govern all public life. Religion and ethnicity were to be kept strictly private; citizenship was an act of republican conformity. This expectation remains today. The French do not share Anglo-American views of hyphenated identity. To them, you are French, or you’re not.
Today, French citizenship is rooted in this same civic republicanism. It entitles the holder to full civil and political rights such as voting in national and European elections, equal access to public services, employment in the civil service, and protection against expulsion. The citizen is defined by public adherence to French institutions—especially laïcité (the aforementioned secularism in public life), gender equality, and democratic participation.
To naturalize, most applicants must have five years of continuous legal residence, demonstrate stable income, the ability to converse in French, and pass a character and civic integration interview conducted by prefectural authorities. This interview assesses whether the applicant embodies “the values of the Republic.” Unlike in the U.S. or UK, where citizenship is largely legalistic or procedural, France’s model inserts the state directly into the cultural evaluation of the applicant and determines how “French” they may be. It does not assume that long-term residence alone produces compatibility; it’s tested up front. That insistence on ideological alignment marks the sharpest divergence between France and its liberal peers.
Is being born in France enough to bypass the process? No, at least not like in the United States. France has conditional birthright citizenship. A child born in France to foreign parents automatically becomes French at 18 if they have lived in France for a sustained period (at least five years since the age of 11 with no long gap), and they can claim it earlier under certain residency conditions.
France also offers relatively expedited naturalization for people educated in France, long-term residents, spouses of French citizens, and those who demonstrate strong “assimilation” into French society. This reflects its assimilationist model rather than pure jus soli, the idea that one is entitled to citizenship based on the location of their birth, rather than jus sanguinis, the citizenship of their parents.
For these reasons, France ultimately defines citizenship not by where you’re born or who your parents are, but by how well you embody its civic ideals.
Citizenship in Germany
Of the four nations we’re looking at, Germany is the youngest and has the most recent and most violent shift from absolutism and liberalism. If you look at a map of Germany before the 1800s, you’ll see a hodgepodge of small kingdoms scattered across north-central Europe. These microstates combined to define their national identity to counter French aggression, first after Napoleon I in the early 1800s, and finally, after the defeat of Napoleon’s grand-nephew, also conveniently named Napoleon, in the late 1800s, forming a unified German state.
This definition was built around a shared ethnic identity that spilled into neighboring states and was used as Hitler’s justification for the annexation of Austria and the Sudetenland in Czechoslovakia in 1939 and the invasion of Poland the following year.
After the horrors of World War II, the postwar Federal Republic rebuilt itself as a Rechtsstaat, a constitutional state governed by law rather than identity. As Germany remained divided between the liberal West and absolutist East, citizenship remained defined by genetics and ancestry (known as jus sanguinis), reflecting a narrow ethnic understanding of the nation. This only began to shift in the late 1990s, after German Reunification, as Germany reckoned with its status as a long-term destination for migrants, specifically from Turkey and the Balkans, who had arrived as early as the 40s and 50s to help Germany rebuild after the war. The reform era introduced naturalization and conditional birthright citizenship, but the overall system remained procedural, rule-bound, and deeply cautious.
Modern German citizenship grants access to the full suite of democratic rights—electoral participation, welfare entitlements, protection under the Basic Law, and freedom of movement within the European Union. It is not explicitly tied to cultural values, but it does carry legal obligations. Citizens are expected to uphold the liberal democratic order enshrined in the Grundgesetz (German Constitution). The state does not test ideology directly, but it enforces loyalty through laws against extremism and through the requirement to renounce previous affiliations with nondemocratic regimes.
Applicants must have legally resided in Germany for 8 years, or 6 if they complete an integration course. They must pass a German-language test at the basic conversational level, show economic independence, submit a clean criminal record, and sign a declaration of loyalty to the constitutional order. There is no cultural interview, no values screening, and no ministerial discretion once the criteria are met. Compared to France, this model is restrained and juridical. Compared to the UK, it is less discretionary. And compared to the U.S., it moves more slowly, placing institutional stability over cultural integration or ideological testing.
As France and Germany are both EU members, citizenship in either grants you full rights to Europe’s freedom of movement, meaning one can live or work visa-free in any other EU member state.
Citizenship in United Kingdom
The UK’s multiculturalism is directly connected to its former empire. For centuries, the UK treated its subjects as part of a vast imperial hierarchy rather than as equal members of a civic polity (see: American Revolutionary War). Only in the second half of the 20th century, with decolonization and Commonwealth migration, did the state begin to distinguish between citizens and former colonial subjects. Yet the British model never experienced a revolutionary moment thanks to centuries of liberalization and a defined sense of self since the Middle Ages. The result is a system grounded more in political discretion than constitutional clarity. Today, citizens of 14 commonwealth nations are allowed to vote in UK elections and access some public services.
Full British citizenship also grants those rights, but it carries few ideological or civic expectations. The state does not require identification with British culture, monarchy, or legal traditions. In practice, citizenship affirms permanent residence and formal allegiance, but the deeper social contract remains vague. Dual citizenship is allowed, but citizenship can be revoked for national security reasons, even if it renders someone stateless—a discretionary power that can override international norms against statelessness, and is unmatched among the four systems compared here. A recent example was Shamima Begum, a British national who traveled to Syria to join ISIS in 2015. Her citizenship was revoked in 2019, leaving her stateless.
To naturalize, an applicant must usually have lived in the UK for 5 years, hold Indefinite Leave to Remain for at least 1 year, and pass the Life in the UK test. The process includes English language certification and a good character assessment, but no civic interview. Decisions are made by the Home Office, which retains broad discretionary power. Compared to Germany’s legalism and France’s ideological gatekeeping, the UK system is defined by ministerial control. It assumes cultural alignment emerges over time, without formal testing—but reserves the right to rescind citizenship if a threat arises.
If France demands ideological alignment and Germany requires procedural fulfillment, the UK preserves discretion as a tool of both inclusion and exclusion.
United States
The United States is the outlier from our previous examples. It is the only state from our list in the Western Hemisphere and thus has a colonial history. To encourage economic growth, the US had essentially no immigration restrictions and used immigrant labor to build railroads and the industrial Midwest. In this regard, immigration is a core aspect. However, for the first 80 years of its existence, many Americans identified more with their state than with any national identity. After the Civil War asserted the Federal government’s power over the states, it also formalized the definition of “American,” and the 14th Amendment clarified that everyone born in the United States is indeed a citizen. Whether or not the writers of the Amendment intended to restrict this interpretation only to the recently freed Slaves in the US South, or to draw an eternal line in the sand is up for debate. However, the text's language is clear.
All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside.
The national identity formed around belief and allegiance, not ancestry or cultural conformity. It wasn’t who you are that defines how American you are; it’s what you believe. Unlike France, it does not presume cultural uniformity. It requires only formal allegiance to the Constitution.
Over time, more and more restrictions were placed on immigration to limit entry by people from “undesirable” countries. Until the last generation, immigration was broadly welcomed by people of all political persuasions, as first-generation immigrants generally provided a cost-effective source of labor in essential industries that native-born Americans chose not to work, keeping prices on everything from homes to tomatoes relatively low compared to the rest of the world.
A U.S. citizen gains access to the complete protection of the Constitution (although the Supreme Court has found numerous times that at least some aspects of the Constitution apply to all, regardless of status). , voting rights in federal and state elections, the right to work and reside anywhere in the country, consular protection, and eligibility for public office. Naturalized citizens are functionally indistinguishable from those born on U.S. soil, unless one wishes to run for President, which requires candidates to be native born. Dual citizenship is tolerated, and revocation is limited to cases of fraud or misrepresentation in the naturalization process. There is no ideological screening. The only loyalty test is the oath.
Most immigrants become eligible for citizenship after five years as lawful permanent residents, or three if married to a U.S. citizen. They must pass a civics exam, an English test, and a criminal background check. There is no integration interview, no values assessment, and no ministerial discretion once statutory requirements are met. Compared to the European models, the U.S. process is the fastest and least subjective. It assumes that civic identity follows legal status. That procedural simplicity enables high naturalization rates, but also shifts the burden of integration to society at large, without formal state involvement.
France, Germany, the UK, and the U.S. are all liberal democracies. But each one answers the same fundamental question differently: What does it take to become one of us?
France expects you to adopt its public culture before letting you in. Germany asks you to stay, follow the rules, and become part of the system over time. The UK wants you to live there long enough and show basic loyalty, but reserves the right to change its mind. The U.S. lets you in legally early and trusts integration to work itself out later.
Yet, since the 90s in the United States and the 2010s in Europe, illegal migration has come to the forefront, and much like across Europe, has activated right-wing voters for fear of their way of life amidst comparatively rapid demographic shifts. It’s the primary cause of the rise of Le Pen in France, AfD in Germany, Farage in the UK, and Donald Trump. These systems reflect each country’s history and its anxieties. For their love of protests, France fears division and Germany fears instability after generations of aggression. The UK fears a further loss of control while the U.S. fears state overreach. Immigration policy not only shows how democracy treats outsiders but also tells the stories of countries and reveals their core values.
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