Unblocking access to citizenship in the global South: Should the process be decentralised?

How meso-level institutions and civil society mediate access to citizenship in East Asia

Erin Aeran Chung (Department of Political Science, Johns Hopkins University)[i]

In her kick-off essay, Bronwen Manby draws our attention to a critical problem in the global South and beyond: native populations who lack citizenship due to low birth registration rates and the absence of official documentation, on the one hand, and low rates of naturalisation among long-term, often native-born noncitizen residents, on the other. Rather than focus on individual immigrant resources, such as education and income, or immigrant-related variables such as generational status or homeland ties, Manby highlights the contingencies of citizenship acquisition, shifting the level of analysis from individual immigrant choices to contextual factors, political institutions, and historical legacies. She proposes that devolution of the naturalisation process would ‘unblock’ access to citizenship.

Based on my research on East Asian democracies, I am sympathetic to Manby’s call for strengthening the local level in naturalisation procedures. Like the cases that Manby discusses, East Asian democracies—specifically Japan, South Korea, and Taiwan—have very low naturalisation rates. And their citizenship policies are similarly built on local institutions and practices. But devolution could potentially exacerbate and further institutionalise social hierarchies. Rather than focus solely on where naturalisation procedures are adjudicated, I argue that we need to examine the meso-level institutions and actors that mediate access to citizenship.

Is devolution the answer?

Manby makes clear that her proposal for devolution applies primarily to countries where central institutions have low capacity, where civil registration systems are weak, and where a form of multilevel citizenship is already in place. Central to her proposal for strengthening the local level is the call for a more transparent, predictable, and better regulated system of naturalisation.

But as others in this debate have argued, the devolution of naturalisation procedures can lead to further corruption and exacerbate social inequalities. While institutionalising already established procedures of ‘local naturalisation’ through legal regulation is a welcome first step in making the process more transparent, shifting the power to grant nationality to a subnational unit of government could create perverse incentives for local officials and political parties to use citizenship as a tool to distort local political outcomes, as Irene Bloemraad discusses for the U.S. case in the nineteenth and early twentieth century, and open opportunities for narrowing membership rules based on ascriptive criteria, as Sanzhuan Guo and Sujata Ramachandran bring up in their discussions of China and India respectively, or local customs and/or personal disputes as Barbara von Ruette identifies in her contribution on Switzerland. Although the judiciary can play an important role in restraining the exclusionary practices of state authorities, as Ramachandran describes for the South African case, legally established rules overseen by the courts do not necessarily make naturalisation policies and procedures more just (see, for example, the 1922 Takao Ozawa v. United States and 1923 United States v. Bhagat Singh Thind cases, in which the Supreme Court deemed immigrants of Asian origin ineligible for naturalisation on the basis of their non-white status). Nor would devolution remedy local informal practices that undermine or constrict citizenship in practice. The household registration system in East Asia demonstrates how formalising local membership rules may further institutionalise social hierarchies.

Meso-level membership and citizenship

As Guo points out, decentralisation is not a radical idea in East Asia because mainland China, Hong Kong, Macau, Taiwan, Japan, and South Korea already have local systems of membership management. In East Asia, the local household registry is the basis for determining legal juridical citizenship at the national level. The Japanese koseki system was established by the modernising Meiji state to determine imperial subjecthood first within Japan and later in Japan’s colonies. This system re-emerged in postcolonial South Korea’s hoju/hojeok system and Taiwan’s huji/hukou system; mainland China’s huji/hukou system has its origins in early Republican China.

Similar to civil registration records elsewhere, the household registry can serve as a form of identification or material verification of kinship ties and descent (up to three generations of households registered under the single patrilineal surname of the household). But unlike ius sanguinis-based citizenship policies, individuals must be registered as members of a household located within the given country in order to automatically gain access to citizenship. While a household registry is not a prerequisite for naturalisation (which is linked to residency requirements as elsewhere), it cannot be substituted by evidence of common ethnic ancestry through language, cultural practices and DNA evidence. For native populations, the household registration system can serve as the institutional basis for differential citizenship rights based on gender, local (subnational) origin, and/or socioeconomic status. Unregistered native populations are not eligible for numerous public services, including passports, and some are legally stateless; those with household registries outside of a given country or, in China’s case, local district have limited access to citizenship rights.

Much like India’s ration cards, the household registry is linked to basic services provided by the state and the private sector, including access to health care, property rights, and bank accounts. But a key difference is that the household registration system is a strictly formal institution created by the state that not only informs citizenship attribution but has historically provided states with a flexible tool to regulate membership and movement. Post-imperial Japan denationalised all individuals whose koseki was located outside of the Japanese archipelago, effectively excluding all former colonial subjects; post-authoritarian Taiwan amended its citizenship policies in 1992 to extend full citizenship rights only to those with hukou in Taiwan regardless of nationality, effectively excluding mainland and overseas Chinese from the expanded substantive rights extended to Taiwanese residents; and post-authoritarian South Korea revised its co-ethnic immigration policiesin 2003 to define ‘overseas Koreans’ eligible for quasi dual-citizenship rights as those with hojeok in the Korean peninsula. In mainland China, the hukou is, according to some, the most important determinant of differential citizenship rights as it has historically classified citizens into rural or urban based on their geographical location and agricultural or non-agricultural family units based on their socioeconomic status, which, in turn, regulated their access to education, employment, health care, housing, and geographic mobility. In sum, although the local household registration system in East Asia has made citizenship attribution predictable and transparent, it has also institutionalised social hierarchies, socioeconomic inequalities, and patriarchal social orders.

How civil society and local communities shape political incorporation

Until the early to mid-2000s, Japan’s, South Korea’s and Taiwan’s naturalisation rates were among the lowest of all OECD countries. Despite the growth of their foreign populations, the annual naturalisation rate had not surpassed two percent of the total foreign population until 2005 in Taiwan and 2009 in South Korea; Japan’s annual rate has not exceeded one percent since the government began to keep records on naturalisations in 1952. Like many states in the global South that Manby and Ramachandran discuss, citizenship policies in East Asia do not include ius soli and naturalisation was, until recently in South Korea and Taiwan, an exceptional process, rather than a ‘normal’ step in immigrant political incorporation.

The diverging naturalisation rates in Japan and South Korea are especially noteworthy. Although Japan has a larger and longer established foreign resident population—numbering approximately 2.9 million in 2019, including native-born foreign residents that span six generations in Japan, compared to 2.4 million in South Korea, the vast majority of whom arrived from the late 1990s—the number of annual naturalisations in Japan has continually fallen behind that in Korea since 2008. At Korea’s peak in 2009, over three percent (approximately 27,000 people) of the total foreign resident population had naturalized, compared to 0.7 percent (approximately 15,000 people) in Japan. (While the annual naturalisation rate in Taiwan closely resembled that in Korea between 2005 and 2010, it has declined precipitously to under one percent since 2013.)

These differences are not the consequences of formal naturalisation requirements. Japan’s naturalisation requirements are not any more stringent than those of South Korea (or Taiwan). They both have a five-year continuous residency requirement and applicants must demonstrate that they can support themselves financially. Naturalisation applicants in South Korea must additionally pass a citizenship exam.

But one key area that has shaped divergent naturalisation patterns in the two countries is the role of local governments and civil society organisations, such as neighbourhood associations, NPOs/NGOs, labour unions and co-ethnic organisations. Local governments and NGOs in Korea actively encourage long-term foreign residents, especially spouses of native citizens, to naturalise through public campaigns, state-subsidised support centres, and grassroots outreach programmes. Most local immigrant advocacy organizations, for example, offer assistance with the naturalisation application process and the more than 200 government-sponsored ‘multicultural family centres’ throughout South Korea provide preparatory citizenship exam courses and integration programmes that eligible applicants can take in lieu of the written exam.

In contrast, immigrant advocacy organisations and local governments in Japan rarely encourage foreign residents to naturalise. Among a wide spectrum of immigrants and local officials alike, permanent residency is treated as the final step of immigrant political incorporation. Instead of providing information on and assistance in the naturalisation process, local governments and advocacy organisations have promoted immigrant rights as non-national local citizens, or ‘foreign resident citizens’ (gaikokujin shimin), not as potential Japanese citizens. For example, the ‘Multicultural Coexistence Promotion in Local Communities’ plan from the Ministry of Internal Affairs and Communication, which is based on ‘best practices’ by local governments with high concentrations of foreign residents, encourages foreign resident participation through support of key foreign resident leaders, the formation of foreign resident advisory bodies, and the promotion of foreign resident participation in local civic associations. And permanent residency in Japan comes with generous social welfare provisions, further lowering the incentive to naturalise. In contrast to Japan’s low naturalisation rates, the number of permanent residents has grown rapidly from approximately 63,500 in 1995 to more than one million in 2018, despite the ten-year continuous residency requirement (which is double that for naturalization applicants).

Mediating citizenship

As Diego Acosta points out for South American cases, multiple state and non-state actors can alter the incentives for naturalisation. While state policies set the structural boundaries of political incorporation, civil society and local communities establish the political learning environment for noncitizens. Some community organisations may supply valuable information and resources for immigrants who are considering naturalisation, ranging from referrals to lawyers to translations of citizenship exams and materials to financial support. Others may bring attention to the disincentives for naturalisation through stories of difficult procedures, negative experiences, and high social and financial costs. And when immigrants reside in communities where very few of their family, friends, and neighbours have naturalised, naturalisation may be seen as exceptional and anomalous, especially when citizenship is closely tied to ethnocultural identity.

Rather than view political incorporation as a unilinear process by which states integrate individual noncitizens into the polity, the East Asian cases remind us that it is a relational process. By shaping how noncitizens negotiate citizenship policies and practices, civil society actors in particular play a critical role in determining whether naturalisation is a normal or exceptional step in political incorporation. Unblocking access to citizenship thus requires more than reforms to naturalisation procedures. We need to critically analyse how meso-level institutions and actors mediate the opportunities and hurdles for citizenship acquisition.


[i] This essay draws on prior research published as Erin Aeran Chung (2010) Immigration and Citizenship in Japan; Erin Aeran Chung, Darcie Draudt, and Yunchen Tian (2020) ‘Regulating Membership and Movement at the Meso-Level: Citizen-Making and the Household Registration System in East Asia,’ Citizenship Studies; and Erin Aeran Chung (forthcoming September 2020) Immigrant Incorporation in East Asian Democracies.