Institute of Political Science

FuS - Freedom of Movement and Social Policy in Historical and International Comparison

An interdisciplinary research group, funded by the German Federal Ministry of Labour and Social Affairs, will compare the EU and Germany with other historical federations to better understand tensions between free movement and social policy.


Freedom of movement of persons has become a politicised and contested issue in the European Union. At the centre of this contention stand EU citizens’ rights to access social benefits in countries of destination. The salience of free movement and access to welfare has grown in pace with the 21th century extension of free movement to all EU citizens, including the economically inactive, and the waves of enlargement which have increased economic and institutional diversity between EU Member States.

However, anxieties and tensions arising from internal freedom of movement of – in particular economically inactive – persons and access to social benefits are historically not unique to the EU but are visible also in other contexts with internal migration and devolved welfare responsibilities. In particular, it resembles other federations. Against this background, the ambition of the FUS project is to historicise and compare political and policy processes tied to internal movement and social rights in the EU with those that have taken place in other federations.

Research and Relevance

In particular, the FUS project focuses on free movement and minimum subsistence programs, with the ambition to better understand the politics of social citizenship in federations. That is to say, that we study how access to social assistance for all federal citizens – i.e. a guaranteed social minimum and thus social citizenship – has been achieved in jurisdictions where citizens enjoy the right to free movement, but social assistance is provided at sub-federal levels and typically only to local residents. To this end the project’s three separate work packages examine the adoption, reform and repeal of laws that have extended and restricted access to social assistance for internal migrants, as well as the impacts that such laws have had at the administrative level at which social assistance is provided (primarily the local).

Studying this is relevant for a number of reasons. First, it can provide insights into processes of social policy integration in federal structures, which are typically marred by large numbers of actors, multi-level interests shaped by economic diversity and regional identities, and thus the risk of lowest-common-denominator policies. In other words, very similar challenges that the EU faces in achieving ‘a more social’ Union. Second, it contributes to the study of citizenship in federal structures, which are inherently marred by the contradiction between federalism’s logic of diversity and citizenship’s ideal of equality. Finally, it is of clear policy relevance: it shows how gaps in social protection for free movers that we currently see in the EU could be resolved, and what implications different policy solutions may have.

To study the laws regulating intra-federation migrants’ access to social minimum benefits and associated implications, the project takes and exploratory, diachronic and comparative case-study approach. In line with other research that adopts a comparative perspective to study the EU, the project conceptualises the EU as a ‘coming-together’ federation, namely those that results from a bargaining process whereby previously independent states join to form a bigger unit by pooling sovereignty to secure a common good. Accordingly, the project compares the North German Confederation (19th century), the United States (20th century) and the EU today.

The cases at the same time differ in important respects. Each is at a different stage in the process of integration at the time examined: the US is one of the oldest existing federations, the EU has matured for several decades and the North German Confederation was a very young federation. They are equally set in different historical, geographical, cultural, political and institutional contexts. Despite that, they compare on key dimensions that we expect to heighten the political tensions associated with free movement and social minimum benefits, in that they have: (i) comparatively high numbers of sub-federal jurisdictions, (ii) strong sub-federal social policy authority and (iii) large internal diversity.