Books in Dialogue: GLOBALCIT Review Symposium on Yossi Harpaz, Citizenship 2.0 and Jelena Džankić, The Global Market for Investor Citizenship


The Commodification of Citizenship

Szabolcs Pogonyi, Central European University

Since the times of ancient Greece, citizenship has been a precious status both for the political community as well as the individual. Citizenship has traditionally been a privilege as well as a burden. Citizens constitute the demos and also serve as a resource for the state: they pay taxes and serve in the military. Therefore, membership in a political community implies special political obligations for the individual, but at the same time, it also secures them important negative and positive rights. As Thomas Humphrey Marshall in the 1950s pointed out, citizenship in democratic countries implies access to civil, political and welfare rights. Moreover, as Hannah Arendt noted just a couple of years after the creation of the United Nations, even access to human rights cannot be taken for granted without citizenship in a sovereign state.

In the years since the Second World War and even more since the end of the Cold War, citizenship in the developed world has increasingly become an asset. The traditional political obligations implied in citizenship have diminished, while the rights component of membership has increased significantly. In most countries, taxes are paid by all residents rather than citizens only. Military service has been outsourced to volunteers who, in some cases, include non-citizens as well. While the obligations dimension of citizenship has been hollowed out, citizenship still secures important and valuable opportunities for individuals. In the contemporary world, citizenship is the best predictor of well-being. Not surprisingly, individuals born without citizenship in any of the first world countries make desperate efforts to gain a privileged citizenship status for themselves or their descendants.

In Citizenship 2.0. Dual Nationality as a Global Asset, Yossi Harpaz argues that citizenship has become a strategic asset for individuals in a global world. While dual citizenship has until recently been seen as an anomaly, in the past decades, an increasing number of states started to tolerate multiple membership. This allows individuals from less developed countries seek membership in more developed countries in order to maximize personal utility. As a result, citizenship increasingly becomes ‘a piece of private property’, Harpaz argues.

Harpaz’s research goes beyond the mostly legal, institutional and quantitative analysis of citizenship regimes and trends. Through three qualitative case studies (Mexico, Serbia and Israel), Harpaz shows that ‘compensatory citizenship’ is used by individuals not only to migrate and settle down in more developed countries, but also for other utilitarian purposes. Wealthy Mexicans cross the border to make sure that their children are born on US territory and thus become US citizens so that they can live and study and work in the US later in their lives. Similarly, Israelis of European descent acquire citizenship in Romania, Hungary, Serbia, Poland and Germany not only to get access to the European job market, but also as an insurance policy in case of an emergency in Israel.

While the pathways to citizenship may differ in the case of Mexican border crossers, Israelis with European ancestry and Serbian citizens with Hungarian citizen forbearers, in each case, second citizenship is perceived as a ‘luxury product’ or status symbol. Harpaz’s respondents perceive citizenship in fully instrumental terms. They see citizenship in the US or the EU as an investment, and therefore they are willing to invest money, time and energy in obtaining it. Mexicans arrange travels to the US and give birth at costly private clinics, Serbian citizens with ancestors in the former Hungarian Kingdom learn Hungarian to apply for Hungarian citizenship, and Israelis pay large sums for lawyers and other experts who help them with the complicated naturalisation procedures in Central Europe. In some cases, prospective citizens are willing to take immense risks and violate the law. Mexicans jeopardise their US visa when arranging childbirth in the US. Serbian citizens desperate to get Hungarian citizenship (and use it to work in Western Europe) buy fake birth certificates and other documents.

As Harpaz sums up the experience of Israelis with European origins, the process of ‘acquiring European citizenship is an almost naked exchange of money for passports.’ Even if his sample includes only individuals who do not consider their ancestral national origins important for their identities, Harpaz convincingly argues that a second citizenship serves as a ‘strategy of global upward mobility.’ The main beneficiaries are individuals from middle-income states who are wealthy enough to obtain a second passport in a country that ranks high in the global hierarchy. Harpaz also shows that citizenship is a valuable instrumental asset for upwardly mobile citizens from middle-tier states, while individuals from the richest countries seek citizenship in less developed states for sentimental reasons. Even if one disagrees with Harpaz that traditional citizenship was institutionalised as ‘sacred membership’ in a putatively culturally homogeneous national community, it is hard to deny his main claim that citizenship is increasingly becoming an instrumental asset for individuals trying to improve their well-being.

In the concluding chapter Harpaz notes that the overwhelming demand for valuable passports has also impacted citizenship policies. In the emerging global citizenship industry, states recognised the market potential, and supply citizenship for rich individuals. Citizenship has become an asset not only for individuals, but also for states. The strong demand for first world citizenship (and the active lobbying of private business involved in the citizenship industry) incentivized governments to monetize citizenship as well as permanent residence. In The Global Market for Investor Citizenship, Jelena Džankić gives a detailed overview of investor citizenship and golden residency visa programs designed for affluent individuals from the developing world. While Harpaz’s examples of inclusive citizenship regimes are mostly the unintended by-products of ius soli and ius sanguinis laws, Džankić engages with the literal merchandisation of membership.

In contrast with Harpaz who contrasts the recent instrumentalisation of citizenship with ‘traditional citizenship’, Džankić shows that the commodification of citizenship has a long history. Citizenship in ancient Greece was the privileged status of wealthy male aristocrats only, and citizenship was sold even in the Roman Empire. Citizenship (understood as a status as well as a bundle of rights) has rarely been fully independent from status and property.

Džankić also points out that many of the classical components of membership have been decoupled from formal citizenship. Traditional rights and obligations entailed in citizenship now are linked to residence. What Christian Joppke terms the lightening of citizenship further facilitates the commodification of membership, particularly for less wealthy countries that are ranked high on passport indices. In the European Union, Eastern and Southern states risk little by selling passports and permanent residence as most of their clients will use their EU citizenship to settle down in more prosperous Western and Northern European states. Thus, some states that offer national citizenship and residence permits actually sell access to the territories of other, more prosperous countries. As Džankić notes, Bulgarian, Cypriot and Maltese citizenship would hardly attract investors if it did not include access to the whole European Union. These examples illustrate that citizenship secures privileges not only in the country of citizenship, but in other states as well. How states relate to a non-citizen is determined by what passport the individual possesses. The same non-citizen individual may have very different entitlements in a country depending on her membership in another state. In the European Union Member States, second country nationals enjoy most of the same rights as the citizens of the host state. Some of the third country nationals (mostly those from the first world) have visa-free access to the European Union as tourists, but have no access to citizenship entitlements, while other third country nationals (mostly from less developed countries) may not even travel to the European Union without a visa that is difficult to obtain.

Concerning the future of citizenship, both Džankić and Harpaz contend that rising national populist parties may try to reinstate physical and symbolic boundaries of nation-states. This, however, will not be very simple. Investment citizenship is a lucrative business and its cancellation would decrease state revenue. The elimination of unconditional ius soli rules in the US could slow down immigration which may have adverse economic implications. The restriction of the over-inclusive ius sanguinis policies in Central Europe would exclude transborder ethnic kin populations and migrant diasporas from the national community, which would be contrary to the aims of nationalist populist parties.

The commodification of citizenship is beneficial both for wealthy individuals and states. Džankić and Harpaz acknowledge that commercialised citizenship evens out some of the global inequalities between individuals, even if it may weaken national solidarity and incentivise corruption. How less developed countries are impacted is a totally different question. If upwardly mobile citizens of middle income (and poor) countries acquire citizenship in First World states, their financial assets and capabilities will not contribute to the improvement of their less developed homelands. The same opportunity that enables elites of less developed countries to catch up with the Global North will leave the Global South even more impoverished.