Notions, features, and forms of citizenship, understood as legal membership in a state, are changing the world over. While contestations of the monolithic understanding of citizenship generally focus on the content of individuals’ rights and their belonging and participation in social and political institutions, the author of this essay shows that official membership categories that are labeled ‘citizenship’ by state actors vary. Drawing on the experiences of the Overseas Citizenship of India, the British Overseas Citizenship, and Citizenship of the European Union the author proposes an analytical framework that aims at advancing the comparative study of state membership policies by introducing six key dimensions that policy actors consider when designing citizenship policies. Apart from systematising the content of citizenship, the framework sheds light on the importance of citizenship terminology, as states employ the label of citizenship and use the status as a vehicle of communication. The author highlights differences in the construction of special subjects, moral obligations and the exercise of power, analyses the aspirations of political actors, the political rhetoric, and explores the interplay between tangible rights and intangible narratives. The discussion of the three atypical membership regimes reveals that states operate in grey areas of membership statuses that partly mimic existing forms of state membership and partly push the boundaries of what state membership means. This has significant repercussions for comparative citizenship and democracy theory and the meaning of membership.

Daniel Naujoks, Atypical citizenship regimes: comparing legal and political conceptualizations, Comparative Migration studies, 2020.