Swearing loyalty: Should new citizens pledge allegiance in a naturalisation oath?

Oaths as Signals and the Perceived Membership of New Citizens

Keith Banting (Queen’s University)

This fascinating debate focuses primarily on the normative implications of requiring citizenship oaths of individuals becoming citizens, with most contributors criticising such oaths as unfair to new citizens. However, a minor theme suggests that citizenship oaths may represent a signal to existing citizens that newcomers are committed to their new community and willing to assume the burdens of membership. Patti Lenard argues that an oath “signals to current citizens that incoming citizens….can be trusted to take their role as citizens in their new state seriously.”  Rainer Bauböck joins her, arguing that a naturalisation oath is “a signal to the wider audience of citizens they should trust the new members to be good citizens”. Others share the view.

The difficulty this argument confronts is the absence of empirical evidence that citizenship oaths actually do influence the perceptions of newcomers held by the wider citizenry. Daniel Sharp argues that such speculation is “inconclusive”, given the lack of empirical evidence. Elsewhere, Liav Orgad argues that “social science provides no evidence” to support the premise that a citizen oath contributes to social cohesion. There is substantial evidence that being a citizen increases public support for the inclusion of newcomers in some countries, such as the United States. But what about the nature of the act of becoming a citizen?  What about a citizenship oath itself?

Given the intensity of anti-immigrant sentiments across contemporary democracies, the debate should not stop here. Perhaps citizenship oaths, despite their questionable normative status, do advance the cause of a more inclusive society and – on balance – contribute to more equitable treatment of newcomers.  David Owen suggests such a prudential argument in the following terms: “Let us assume for the sake of argument that states with mandatory oath-taking are more receptive to immigrants becoming citizens and more equitable in outcomes for naturalised citizens across a range of measures. In such circumstances, it would be plausible to argue a mandatory citizenship oath is a small price to pay and well worth paying”. This prudential argument captures the issue well.  

While there is no direct empirical evidence in support of this pragmatic argument for citizenship oaths, there is a broader literature on the importance of signalling commitment that is relevant. This comment draws on an extended cross-national research project on membership and inclusion in culturally diverse societies, conducted by Allison Harell, Will Kymlicka and me. Our findings underscore the importance of public perceptions of immigrants’ commitment to their new country and the power of signalling processes to influence those perceptions. Moreover, although not designed explicitly to analyse the effects of oaths, our findings provide both theoretical reasons and some initial evidence that oaths may play such a role in support of the equitable inclusion of newcomers.

Perceived membership and inclusion

The focus of our research is the perceived membership of immigrants. That is, we measure the extent to which the majority population sees immigrants as committed to their new shared community and willing to bear the burdens of membership. Our hypothesis is that the inclusion of immigrants is fundamentally a matter of perceived commitment, and that the majority is responsive to signals of commitment. That is, the willingness of the majority to support the inclusion of immigrants in the political and social mainstream depends in part on whether immigrants are seen as committed to the larger society. Obviously, such commitment can take a number of forms. One metric often deployed in public debates is whether immigrants make an economic contribution by working hard and paying taxes. However, the commitment that matters is not just economic. Full membership in a new political community also involves an affective commitment to that community and to the responsibilities inherent in belonging. In our view, the majority population’s perceptions of the commitment of newcomers – which we call “membership perceptions” – are critical to societal support for the full inclusion of newcomers.

The essence of this conception of membership can be seen in questions we use in surveys to tap the beliefs of the majority population about newcomers’ commitment to the wider society.

  • IDENTIFY: Compared to other people living in the country, how much do you think immigrants identify with [COUNTRY]? 
  • CARES: Compared to other people living in the country, how much do you think immigrants care about the concerns and needs of other [NATIONALITY citizens]?
  • SACRIFICE: Compared to other people living in the country, how willing do you think immigrants are to make sacrifices for others in our society?
  • CONTRIBUTE: One way citizens contribute to society is by working and paying taxes. Compared to other people living in the country, do you think immigrants are contributing their fair share, or more or less than their fair share?

This is not a complete evaluation, of course. Immigrants make myriad contributions to collective life. Yet, the membership scale that we build from these questions captures important dimensions of majority perceptions of the commitment of immigrants to the shared community.

We now have data on perceived membership levels in seven democracies (Demark, Sweden, Italy, France, the UK, Canada and the United States). Strikingly, immigrants in all seven countries are seen as less committed to the shared community than the rest of the population. In effect, immigrants in all seven countries bear what we call a “membership penalty”. Critically, these penalties are not simply reflections of racism and xenophobia. Statistical analysis with a full set of controls confirms that these membership penalties are not reducible to racial prejudice or a highly ethnicised conception of national identity.  There is a larger point here. Much attention focuses on the drivers of outgroup exclusion such as racism, but less attention is devoted to the sources of ingroup inclusion. They are not the same. Inclusion into a solidaristic community is not simply a matter of overcoming perceptions of outgroup threat, bias and prejudice, but also involves active processes of membership-making, and of inclusion into a ‘we’. These processes reflect deep assumptions about what it means to be a community, including a shared identity and powerful norms of reciprocity. Membership penalties reflect the majority’s perceptions of how committed newcomers are to the shared community.  

Critically for this debate, an experiment conducted within our survey in four of our countries demonstrates that membership penalties are not immutable but are malleable in response to signals of commitment. When immigrants perform acts of charity aimed at the host society, majority respondents’ beliefs about the level of commitment among immigrants shifts upwards; in contrast, charitable initiatives directed toward an immigrant’s country of origin perversely have the opposite effect.

Finally, membership penalties matter. In an early study in Canada, we found that perceived membership is strongly related to public support for immigrant participation in the political life of the country. Our more recent cross-national survey finds that membership penalties are strongly associated with the level of public support for ‘inclusive redistribution’ – that is, public support for immigrant access to social benefits (as opposed to welfare chauvinism). These indicators make clear that membership penalties matter to public support for the inclusion of immigrants in the political and social life of their new home.

Membership, signals, and citizenship oaths

Can one draw implications from this research for the role of naturalisation oaths? One point of leverage comes from the size of membership penalties across our seven countries, which vary considerably. Membership penalties are smaller in the United States, Canada, and Great Britain, and considerably larger (and remarkably uniform) in the four continental European countries, Denmark, Sweden, France and Italy. Moreover, there is a striking relationship between the size of the membership penalty in a country and the presence or absence of a requirement that naturalising citizens publicly swear an oath of allegiance, as recorded in the GLOBALCIT dataset on acquisition of citizenship. All three countries with smaller membership penalties (the United States, Canada and Great Britain) are known for such oaths and ceremonies. In contrast, three of the four continental countries with much larger membership penalties do not require such an oath. On first glance, Denmark is the one exception. Those acquiring Danish citizenship by naturalisation are required to declare allegiance to Denmark and Danish society. However, the swearing of the oath takes place in private as part of a digital application. There are ceremonies once a year for new citizens. However, “the Danish ceremonies do not include swearing-in ceremonies but are rather informal public celebrations including an official welcome speech, entertainment, and refreshments”. Perhaps Denmark is not a significant exception.

Policy domains are never static, and the regulations governing naturalisation are no exception. Proposals for change can trigger interesting debates, as recent Canadian experience attests. During the pandemic, the government shifted from in-person to online ceremonies, which retain a collective swearing of the oath before a public official but which are clearly less public than the traditional ceremonies and, as a result, attract much less media attention. After the pandemic, the government decided to retain this approach, presumably for administrative reasons. In 2023, the government opened an online feedback forum, inviting individuals to comment on the new approach. The response was intriguing. The small number of current applicants for naturalisation who expressed an opinion tended to support online ceremonies as a means of accelerating the process. However, the largest number of responses came from current citizens. They overwhelmingly opposed the change (94.1%) and defended the importance of public ceremonies

Obviously, our research findings do not constitute the conclusive social science evidence that might convince sceptics. Seven countries represent a limited sample; and there are undoubtedly many other factors beyond oaths influencing the size of membership penalties. Nonetheless, there are four key conclusions here. First, the evidence of the impact of membership perceptions highlights the importance of understanding the factors that shape membership penalties. Second, the full analysis confirms that such penalties are not simply a result of racism or xenophobia, but reflect a distinct process of inclusion. Third, the survey experiment indicates that such penalties are not immutable but respond to signals of commitment. Fourth, the relationship between the size of membership penalties and the presence or absence of citizenship oaths in our seven countries suggests that such oaths may well represent a signal to the wider audience of citizens that newcomers share their commitment to the collective community.  

The wisdom of prudential thinking

The inclusion of newcomers in the shared political community faces two challenges. Much has been written about the first challenge: how to overcome deep legacies of ethnicised and racialised definitions of the nation among the historic population.  But much less has been written about the second challenge: how do newcomers signal their commitment to the nation, to membership in the collective “we”, with its associated ideas of belonging and the sharing of obligations to each other? And, by extension, what signals do others in society recognise?

Citizenship oaths need to be evaluated in this context. There are undoubtedly normative dilemmas here. Citizenship oaths may well come with normative costs, which Lenard’s critics highlight. However, what are the alternative signals?  Several unpleasant possibilities confront us. A search for alternatives shifts the burden onto immigrants to find signalling opportunities; and some of the alternative mechanisms might be even more unfair to newcomers, as suggested by the negative response to charitable efforts to assist their countries of origin. Finally, in the absence of effective modes of signalling, the default position presumably prevails, with serious membership penalties and their associated barriers to inclusion, which are manifestly unfair.   

In the end, this commentary points to the wisdom of Owen’s prudential argument. Admittedly, the evidence presented here is suggestive, not determinative. However, in light of the pace of social science research, waiting for definitive evidence implies a lengthy period of inaction. Given the intensity of public anxiety about immigration, there is wisdom in more prudential thinking about citizenship oaths.