There is a highly established body of literature comparing migration policies, including citizenship (for example Brubaker, 1992; Hansen and Weil, 2001; Baubock et al, 2006; Faist, 2007; Janoski, 2010; van Oers, 2013) and integration (for example Jacobs and Rea, 2007; Goodman, 2010; 2014; van Oers et al, 2010a; Garces-Mascarenas and Penninx, 2016; Pascouau, 2018). Comparative analyses of the implementation of migration policies are rarer, the few exceptions including the studies of migration control across seven European countries by Eule and colleagues (2019), deportation policies in Germany and the US (Ellerman, 2009), and the visa procedures of different national consulates in Morocco (Infantino, 2016; 2018).

As mentioned in Chapter One, comparing citizenship and nationality policies across Belgium and the UK allows factors that are limited to a national context to be distinguished from factors that could apply to a larger number of countries. Comparing citizenship and integration policies further shows how integrationist tendencies have changed naturalization requirements as well as leading to the introduction of obligatory courses. Whereas several European countries, including the UK, have integration requirements for permanent residence and/or citizenship, but no mandatory integration courses, the countries with mandatory integration frequently link it significantly to the naturalization requirements.

In the following sections, I first present integration and citizenship policies in contrast to the ‘frontline’ migration policies (visa, border control, residence); subsequently, I discuss in more detail what the comparative approach shows about discretion and variation in the implementation of the policies. I conclude by discussing the different influences of integrationism across the cases considered.

Migration policies behind the frontline

There are a number of implementation studies that have used ethnographic methods to explore what can be considered the ‘frontline’ of migration policies (Eule et al, 2019), including visas (Infantino and Rea, 2012; Alpes and Spire, 2014; Infantino, 2017; 2019), border controls (for example Heyman, 1995; 2009; Pratt, 2010; Crosby and Rea, 2016) and residence (for example Triandafyllidou, 2003; Spire, 2008; Eule, 2016). A common thread across these studies’ findings is the tendency of officers to deviate significantly from the letter of the law, usually to make migration control practices more restrictive than the (already usually restrictive) official policy.