Perspective Chapter: Beyond Borders – Can European Citizenship Build a Shared Identity?

2.1 Origins, development, case law

The roots of EU citizenship lie in the freedoms of movement and residence granted to workers under the Treaty of Rome of 1957. Initially, these were economic rights, reflecting the founding logic of a common market that prioritized economic integration over political identity. The right to move was limited to workers and their families, excluding large swathes of Europe’s population from cross-border benefits. Nevertheless, the seeds of citizenship were present: the notion that rights could derive directly from supranational law, enforceable against member states, was a profound departure from traditional international arrangements. By the 1970s and 1980s, the Court of Justice had expanded these rights incrementally, often broadening categories of beneficiaries. Cases such as Levin (1982) [8] and Cowan (1989) [9] extended protections to part-time workers and even tourists, establishing that market freedoms implied a wider set of personal entitlements. At the same time, political leaders grew increasingly aware that economic integration alone could not sustain legitimacy. Jacques Delors [10], in particular, pushed for a more “people-centred” Europe. These pressures culminated in the Maastricht Treaty of 1992, which established EU citizenship as a legal status additional to national citizenship. It was a revolutionary move: for the first time, an international organization created a transnational citizenship binding individuals directly.

The Maastricht Treaty codified four core rights of EU citizenship, later expanded by subsequent treaties and directives:

Mobility and residence: All EU citizens gained the right to move and reside freely across member states, subject to conditions related to resources and public policy. This was later consolidated in Directive 2004/38/EC, which clarified the rights of permanent residence after five years and the conditions under which states could restrict access [11]. This marked a decisive shift from economic status to universal entitlement: students, retirees, and jobseekers were now included.

Political participation: Citizens could vote and stand in municipal and European Parliament elections in their country of residence, irrespective of nationality. This challenged traditional notions of political community tied exclusively to nationality, although voting in national elections remained off-limits.

Diplomatic and consular protection: EU citizens abroad could seek help from any member state’s embassy when their own was not represented. Although rarely used, this provision reinforced the idea of a shared European bond beyond national frontiers.

Accountability and petition rights: Citizens could petition the European Parliament, appeal to the Ombudsman, and correspond with institutions in any official EU language, symbolizing responsiveness and inclusivity at the supranational level.

These rights distinguished EU citizenship from other forms of dual nationality or residency permits. They created a direct legal relationship between the EU and individuals, an innovation in international governance.

The Court of Justice of the EU (CJEU) played a central role in transforming citizenship from a symbolic add-on into a substantive legal status. In the case of Martínez Sala (1998), the Court ruled that a lawfully resident EU citizen could not be denied child benefits available to nationals, establishing a principle of nondiscrimination that applied irrespective of economic activity [12]. In the case of Grzelczyk (2001), the Court famously declared that “Union citizenship is destined to be the fundamental status of nationals of the Member States,” affirming its constitutional importance [13].

Later cases expanded these principles. In the case of García Avello (2003), the Court ruled on cross-border family naming rights, signaling the extension of citizenship into private law [14]. In the case of Chen (2004), the Court held that a child with Irish citizenship (and thus EU citizenship) conferred residency rights on her non-EU mother, demonstrating the doctrine’s reach into family life [15]. In the case of Baumbast (2002), the Court extended residence rights to non-economically active citizens with sufficient resources and health insurance, a landmark in defining the substance of EU citizenship [16]. In the case of Rottmann (2010), the Court intervened in nationality law, ruling that member states must respect proportionality when withdrawing nationality if it would deprive individuals of EU citizenship [17]. In another case, Zambrano (2011) further extended protection, preventing the expulsion of non-EU parents of EU citizen children as this would undermine the children’s rights [18]. In the case of Coman (2018), the Court recognized same-sex spouses’ residence rights under EU law, showing the evolving reach of citizenship in line with human rights norms [19]. In another case, McCarthy (2011) and Dereci (2011), however, signaled a retrenchment: the Court ruled that citizenship rights could not be used to circumvent national immigration laws unless expulsion threatened the “genuine enjoyment of the substance” of EU citizenship [20, 21].

These cases underscore the evolving nature of citizenship jurisprudence. While the Court empowered individuals and extended rights into sensitive domains, it also introduced limits, demonstrating that EU citizenship is both a constitutional innovation and a site of political contestation.

2.2 Crises and symbols

The early 2000s marked a period of constitutional ambition and crisis. The Charter of Fundamental Rights, proclaimed in 2000, consolidated civil, political, and social rights, many overlapping with the rights of EU citizenship [22]. The 2004 draft Constitutional Treaty sought to enshrine these principles, but its rejection in French and Dutch referenda highlighted the fragility of a shared European identity. In France, opponents mobilized fears of neoliberal globalization and loss of sovereignty, while in the Netherlands, concerns focused on democratic accountability and migration. The double rejection shook the Union, halting integration and feeding Euroskepticism. Media coverage framed the verdicts of the referenda as a popular backlash against elites, widening the gap between European institutions and public opinion. Critics argued the treaty lacked democratic legitimacy, while supporters lamented the missed opportunity to anchor citizenship in a broader constitutional order.

The Lisbon Treaty (2007/2009) salvaged much of the content, confirming in Article 9 TEU that “Citizenship of the Union shall be additional to and not replace national citizenship.”[23] It also gave the Charter binding force and introduced the European Citizens’ Initiative (ECI), enabling one million citizens to request new legislation. Although the ECI’s impact has been limited in practice, it represented an attempt to link EU citizenship with participatory democracy. The Lisbon settlement reaffirmed the derivative nature of EU citizenship: it was still rooted in national membership but increasingly shaped by supranational principles and rights. The episode also highlighted the fragility of political identity: while elites viewed citizenship as a unifying force, publics remained skeptical of ceding sovereignty.

Beyond legal provisions, citizenship also operates symbolically. EU passports, Erasmus exchanges, and the euro currency function as visible markers of integration. For many young Europeans, Erasmus mobility in particular has provided a formative experience of Europeanness, creating transnational friendships and networks [7]. The Erasmus+ expansion further diversified opportunities, extending mobility beyond universities to apprenticeships, volunteering, and schools. The euro, circulating (as of 2025) in 20 member states, embodies shared sovereignty and is often cited as the most tangible sign of integration in daily life. Even symbols like the EU flag, anthem, and Europe Day have become part of a common repertoire, though they resonate unevenly across societies.

Comparisons with federal systems highlight both achievements and limits. In the United States, citizenship entails common taxation, welfare, and military service – institutions that foster solidarity. Switzerland blends multiple languages and cantonal autonomy within a federal citizenship supported by redistribution. Canada, meanwhile, offers a model of citizenship rooted in multiculturalism, where diversity is institutionalized within a federal framework. William Kymlicka’s [24] work on multicultural citizenship is particularly instructive here. He argues that inclusive recognition of diversity can reinforce, rather than weaken, shared citizenship. This helps explain how the Canadian model balances unity and pluralism – a dynamic that offers a useful comparative lens for the EU’s evolving citizenship framework. By contrast, EU citizenship lacks robust fiscal and welfare dimensions, making solidarity harder to sustain in times of crisis. Jo Shaw [25] aptly calls EU citizenship a “laboratory” for experimenting with identity beyond the state, but it remains an unfinished experiment.

Symbolism has also been contested. Euroskeptics deride EU symbols as artificial impositions, while pro-Europeans view them as crucial in fostering attachment. Media representations, cultural programs such as Creative Europe, and cross-border media projects like Arte have attempted to construct a European cultural space. The uneven reception of these initiatives illustrates both the promise and limits of symbolic integration. In Central and Eastern Europe, EU symbols are often associated with modernization and prosperity, while in parts of Western Europe they are seen as distant or bureaucratic. Beyond Europe, regional organizations such as Mercosur and the African Union have experimented with free movement and symbolic integration, but none have created a comparable legal citizenship. This underlines the EU’s uniqueness: it stands alone in granting transnational citizenship, yet struggles to imbue it with emotional depth.

3.1 European citizenship in practice

Of all the rights attached to EU citizenship, the freedom of movement and residence has been the most consequential in everyday life. Originally conceived in the Treaty of Rome as an economic right for workers, Maastricht generalized it as a right for all citizens. The Citizens’ Rights Directive (Directive 2004/38/EC) codified and expanded these provisions, guaranteeing EU citizens and their family members the right to reside in another member state for up to three months without conditions, and longer if they are workers, students, or have sufficient resources and health insurance [11]. The scale of mobility is striking. By 2020, more than 13.7 million EU citizens were residing in another member state, around 3% of the Union’s total population [26]. Germany, the United Kingdom (before Brexit), Spain, Italy, and France attracted the largest numbers of intra-EU migrants, while Romania, Poland, and Bulgaria saw significant outflows. The enlargements of 2004 and 2007, which admitted twelve new member states from Central and Eastern Europe, intensified these trends. Between 2004 and 2015, the number of Polish nationals in the United Kingdom increased from fewer than 100,000 to over one million [27].

Mobility is often celebrated as a cornerstone of integration, but it has also generated friction. Wealthier states have expressed concern about “welfare tourism,” the idea that migrants move primarily to access social benefits. While empirical research suggests that most intra-EU migrants move for work or study rather than welfare, the issue has been politically salient, especially in debates leading up to Brexit [28]. Sending countries, meanwhile, worry about brain drain and demographic imbalances. Romania and Bulgaria, for example, have seen large shares of their skilled labor force emigrate, creating shortages at home [29]. In this context, the CJEU has played a crucial role in balancing rights and restrictions. In the case of Collins (2004), the Court held that jobseekers could access financial benefits under certain conditions [30]. In the case of Bidar (2005), it extended student maintenance grants to non-nationals with sufficient integration in the host state [31]. Conversely, in the case of Dano (2014), the Court upheld restrictions on benefits for economically inactive migrants, signaling limits to solidarity [32]. These rulings confirm the dynamic nature of EU citizenship: a status defined not only by treaty texts but by ongoing judicial interpretation.

Educational mobility embodies the ideal of citizenship “beyond borders.” The Erasmus program, launched in 1987 and expanded into Erasmus+, is one of the most visible and popular initiatives of the EU. By 2021, more than 10 million Europeans had studied, trained, or volunteered abroad under its auspices [33]. Surveys consistently find that Erasmus alumni are more likely to identify as European, more open to intercultural exchange, and more likely to vote in European elections [34]. Michael Bruter [7] describes Erasmus as fostering a “cultural infrastructure of identity,” in which transnational experiences reshape how young people imagine Europe. Christof Van Mol’s [34] research shows that Erasmus alumni tend to maintain cross-border social networks and to be more mobile in their careers, reinforcing long-term European engagement. Politicians often invoke the “Erasmus generation” as a symbol of integration, suggesting that it represents the lived experience of EU citizenship. Yet access to Erasmus is uneven. Participation is concentrated among middle-class students from better-resourced universities. Barriers of language, finance, and institutional capacity limit involvement from disadvantaged groups and smaller institutions. Moreover, mobility is not always a positive experience: some students face isolation, discrimination, or administrative challenges. Thus, while Erasmus promotes European identity, it risks reinforcing inequalities if participation remains stratified.

EU citizenship also confers political rights. Citizens residing in another member state may vote and stand in local and European Parliament elections under the same conditions as nationals. This innovation is significant: it recognizes residence as a basis for democratic participation, decoupling rights from nationality. In practice, however, uptake has been limited. Turnout in European elections has historically lagged behind national elections, though the 2019 elections reversed a long decline, reaching 50.6% – the highest in two decades – driven partly by young voters [35]. Mobile citizens’ participation is especially low, often due to a lack of information, language barriers, or administrative complexity [25]. In some countries, mobile EU citizens represent a significant share of the electorate, yet their impact on outcomes remains limited. The scope of political rights is also constrained. Mobile citizens may not vote in national parliamentary elections in their state of residence, nor in referenda. This creates what Richard Bellamy [36] calls “partial membership,” where EU citizens enjoy some political inclusion but remain excluded from core national decision-making. Proposals to deepen political rights, such as transnational lists for European Parliament elections, remain politically controversial [37].

The practice of EU citizenship highlights inequalities of access and experience. Mobility is shaped by class, gender, and region. For many Western Europeans, citizenship enables cosmopolitan choice – studying abroad, second homes, lifestyle migration. For many Eastern Europeans, it means economic necessity – long-term labor migration, often in low-wage sectors. These contrasting experiences foster divergent perceptions of Europe: opportunity for some, precarity for others [38]. For instance, the Erasmus student completing a semester in Barcelona embodies Europe’s cosmopolitan promise – mobility as self-fulfillment and cultural exploration – while the Polish construction worker on a long-term contract in Belgium illustrates mobility as necessity, accompanied by uncertainty and limited rights. Juxtaposing these experiences underscores that the freedoms of movement, though universal in law, are highly stratified in practice.

Gender dynamics also matter. Women are more likely to participate in short-term educational mobility but less likely to migrate for long-term employment, partly due to care responsibilities. Class divides are evident in Erasmus participation, where middle-class students dominate. Thus, the benefits of EU citizenship are not equally distributed.

3.2 Identity and belonging

Does EU citizenship nurture a shared identity? Empirical data suggest a complex picture. Eurobarometer surveys since the 1990s show that most citizens feel both national and European, but national identity is stronger. In 1996, only 36% of respondents reported feeling attached to Europe; by 2021, the figure had risen to 57%, though still below attachment to the nation (89%) [39]. The European Social Survey similarly records dual identities, with considerable variation across states [40]. Generational divides are striking. Younger people, especially those who studied or worked abroad, are more likely to identify as European. This “generational replacement” effect suggests that European identity may strengthen over time as cohorts socialized with mobility and digital connectivity become dominant [41].

The “Erasmus generation” has become emblematic of European identity. Erasmus alumni often describe themselves as more cosmopolitan, more tolerant, and more European. Political leaders, from José Manuel Barroso to Emmanuel Macron, have celebrated the program as proof that European identity can be cultivated through practice [42]. Yet Erasmus also reveals the limits of identity-building. Participation remains a minority experience, and its effects are strongest among already privileged groups – not to mention that not all mobility experiences are positive. For labor migrants, especially in low-wage sectors, cross-border mobility can breed resentment rather than belonging, as experiences of discrimination undermine identification with Europe [43].

European identity is uneven across the continent. In Benelux countries, long-standing integration and high mobility foster strong identification. Southern Europeans often express pro-European sentiment linked to structural funds, modernization, and the role of EU in stabilizing democracy after authoritarian rule. In Central and Eastern Europe, enthusiasm is often instrumental: EU citizenship is valued as a gateway to jobs and rights abroad, while national identity remains primary [44]. The United Kingdom exemplified the fragility of European identity. Despite strong support for Erasmus and mobility among younger populations, the Brexit referendum revealed that, for many, EU citizenship carried little emotional weight compared to national sovereignty. Millions surrendered EU citizenship rights in exchange for reaffirmed national control, underscoring that legal entitlements alone cannot anchor identity.

A persistent theme is the gap between utilitarian benefits and emotional belonging. Many citizens appreciate rights to travel, work, or study abroad but do not translate these into deeper identification. As Neil Fligstein [45] argues, the EU has created “a common set of opportunities” but not necessarily “a common people.” For some, EU citizenship is valued as a toolbox of rights; for others, it is distant and abstract. Michael Bruter’s distinction between civic identity (attachment to institutions and rights) and cultural identity (emotional and symbolic attachment) is helpful. The EU has achieved more progress on the former than the latter [7]. Without emotional resonance – symbols, narratives, solidarity – citizenship risks remaining technocratic. Brexit, the Eurozone crisis, and the migration crisis revealed how quickly utilitarian attachments can unravel when costs appear to outweigh benefits.

3.3 Theoretical perspectives

Theoretical debates add to this picture. As mentioned earlier in the “Introduction,” Thomas Risse’s [5] concept of nested identities suggests that European identity can coexist with national and local identities, layered rather than mutually exclusive, while Jürgen Habermas [6] insists that cultural identity is unattainable in such a diverse continent; instead, Europe must cultivate constitutional patriotism – loyalty to shared democratic principles. At the same time, Claus Offe [46] warns that solidarity requires more than principles: it demands redistributive practices that remain underdeveloped at the EU level, while Antje Wiener [47] emphasizes the contested nature of European norms, arguing that identity is not fixed but constantly negotiated through practice. Together, these perspectives highlight that European identity is both fragile and dynamic. It emerges unevenly, shaped by mobility, symbols, and lived experience. EU citizenship has created the legal infrastructure of belonging, but whether it can foster solidarity remains an open question.

4.1 Contemporary challenges

The United Kingdom’s withdrawal from the EU exposed a paradox at the heart of EU citizenship: its rights are robust at the individual level, yet collectively vulnerable to political rupture. On January 31, 2020, British nationals ceased to be EU citizens, save for limited protections under the Withdrawal Agreement for those already resident across borders [48]. Campaigns such as “British in Europe” documented everyday losses – work qualifications that no longer traveled, family reunifications slowed or blocked, and students priced out of continental education markets [49]. The Leave campaign’s “take back control” slogan distilled a potent counternarrative: sovereignty as emotional belonging, trumping the functional benefits of mobility. As several scholars note, Brexit demonstrated that legal architectures cannot substitute for affect; in the absence of a strong emotional attachment to Europe, citizens will prioritize national identity when pressed to choose [50, 51]. For the EU, Brexit was both a caution and a catalyst. It reminded the public what could be lost, reinforcing the visibility of citizenship rights. But it also highlighted a vulnerability: supranational citizenship is mediated by national membership. If a state exits, millions lose status in one stroke. This contingency complicates the Court of Justice’s claim that EU citizenship is “destined to be the fundamental status” of Member State nationals; the status is fundamental, but not inalienable [13].

Euroskepticism is neither monolithic nor static. In northern Europe, skepticism often targets perceived moral hazard (fiscal transfers, shared debt); in western economies, anxieties focus on welfare competition and migration; in the east, it mixes cultural conservatism with claims of “uneven integration.” Parties such as the AfD (Germany), Rassemblement National (France), Fidesz (Hungary), and Lega (Italy) leverage these frames differently but converge on narratives that cast EU citizenship as diluting sovereignty and blurring communal boundaries [52]. Paradoxically, Euroskepticism coexists with persistently high support for membership itself. Eurobarometer surveys after 2016 recorded a rebound in the view that EU membership is “a good thing,” even in states with strong populist parties [39]. The tension is instructive: citizens may value the EU’s problem-solving functions and the insurance of the single market while resisting the symbolic claims of supranational belonging. In other words, they are “functionally European, emotionally national.”

Moreover, the generational dimension of Euroskepticism deserves attention. For citizens who have grown up with Erasmus mobility, digital communication, and the absence of border checks, the idea of Europe as a lived social space is largely taken for granted. This younger cohort – the aforementioned “Erasmus generation” – engages with the Union less as a distant authority and more as an everyday framework of opportunity. By contrast, older generations who remember a pre-EU Europe interpret crises through a sovereignty-based lens. These divergent memories help explain why the same events – the Eurozone crisis, Brexit, or migration debates – resonate differently across age groups and why European identity remains an evolving project.

Beyond Euroskepticism lies the deeper concern of democratic backsliding – the systematic erosion of rule-of-law safeguards, judicial independence, and media pluralism in some member states. These developments, visible in Hungary and Poland, test not only the EU’s legal mechanisms but also the normative foundations of European citizenship itself. As Habermas’s notion of constitutional patriotism suggests, a shared European identity should be anchored in allegiance to democratic principles rather than ethnic or cultural homogeneity. When member governments weaken these principles, they undermine the civic basis on which a European identity might rest, revealing the fragility of postnational solidarity.

The 2015–16 “refugee crisis” forced the Union to articulate who belongs – and on what terms. Intra-EU free movement affirmed an expansive notion of internal membership, while the simultaneous struggle to share responsibility for refugees exposed hard edges at the external boundary. Some governments resisted relocation quotas, framing asylum as a civilizational test rather than a legal obligation, and securitized borders became emblems of national protection [28, 53]. The juxtaposition produced a “fortress Europe” paradox: openness inside, guardedness outside. This duality reverberates back into the meaning of EU citizenship. For some, the sharp boundary at the external frontier consolidates a sense of common European space. For others, it undermines the Union’s universalist claims, suggesting that citizenship is a “club good,” not a civic ideal. The ongoing reform of the Common European Asylum System (and efforts to balance solidarity with border management) will shape how credibly European citizenship can present itself as inclusive rather than merely exclusionary [54].

The Eurozone crisis (2009–12) revealed how thinly stretched solidarity can become when macroeconomic adjustments bite. Emergency mechanisms and conditionality helped stabilize the currency, but they also entrenched narratives of virtuous creditors and profligate debtors. For many in Southern Europe, austerity measures felt imposed by distant institutions, straining the legitimacy of supranational governance [46]. Citizenship rights continued to function – students moved, workers relocated – but the emotional economy of belonging suffered.

By contrast, the pandemic response demonstrated a more solidaristic turn. After messy early border closures, the EU organized joint vaccine procurement and, crucially, launched NextGenerationEU, a large-scale recovery instrument financed by common borrowing to support national reforms and investment [55]. Alongside SURE (temporary Support to mitigate Unemployment Risks in an Emergency), these measures suggested that EU citizenship might be buttressed by shared risk-sharing institutions, not only by mobility rights [56]. Whether these innovations endure – and are felt by citizens as fair – will determine if solidarity can be institutionalized beyond crisis moments.

Russia’s full-scale invasion of Ukraine in 2022 precipitated the EU’s swift activation of the Temporary Protection Directive (2001/55/EC), granting millions of displaced Ukrainians immediate residence, work, education, and social assistance across Member States [57]. The speed and scale of this response contrasted sharply with the hesitancy of 2015–16. Two lessons for European citizenship stand out. First, solidarity is not a fixed resource but politically elastic: when threat perception is high and cultural proximity is perceived, protection expands. Second, rapid, uniform rights for non-EU nationals can coexist with EU citizenship without diluting it; indeed, such inclusivity can reinforce the Union’s civic self-understanding. The challenge is to sustain equitable support as the war drags on and attention wanes.

Citizenship is imagined and reproduced in public spheres. Europe’s is increasingly digital, fragmented across languages and platforms. Transnational media initiatives exist, but the day-to-day consumption of news – and the circulation of symbols – remains nationally segmented. Disinformation campaigns and platform incentives amplify polarizing narratives about migration, sovereignty, and identity, often outpacing institutional communication [58]. The EU’s regulatory turn (Digital Services Act, Code of Practice on Disinformation) signals recognition that the health of a European public sphere matters for citizenship’s legitimacy [59]. Without shared narratives and trusted cross-border fora, the legal status of citizenship will struggle to translate into a felt community.