Current institutional change in both liberal and ‘conservative’ welfare states is a major challenge to the social sciences. Major strands of academic thought have long argued that modernity chimes with the successive emancipation of the individual. In the Anglo-Saxon world, the ground-breaking work of T.H. Marshall (1965), shedding light on the subsequent proliferation of economic, political and social rights along with modernisation, had popularised the idea of social citizenship, viewed by many as a key reference for public policies in advanced nation states (Dwyer, 2004, pp 51-76). While the concept was awarded less paradigmatic value elsewhere, it pervaded other welfare regimes as well, including those classified by the comparative literature as ‘corporatist’ (or ‘conservative’).

This reading of modernisation is now fraught with serious doubts, however. While social citizenship was always a rationale informing policy agendas rather than empirical reality, the recent transformation of Western welfare regimes suggests that there is no future for the concept as we have known it. Both liberal and conservative welfare regimes have witnessed the spread of market values (Gilbert, 2002, pp 99-135) and a (more or less) radical transformation of basic benefit schemes, through workfare policies, for example (Handler, 2003; Ellison, 2005, pp 77-99). This appears to undercut the post-war promise of guaranteeing each citizen both a protection against material hardship and a right to self-determination in basic areas of human existence. Therefore, as a policy model, social citizenship would appear to be outdated.

At closer inspection, however, things are more complicated than this. While major welfare programmes have been subject to retrenchment, social rights have in some fields of welfare provision continued to be a strong normative reference, or have seen a comeback. Moreover, the cult of the individual, emblematic of late modern society, has strengthened the position of citizens in their encounter with public bureaucracies, at least at ideological level. With an eye on these inconsistencies, this chapter examines institutional change in two major Western European countries – Britain and Germany – commonly deemed to belong to different ‘families of welfare’. It starts by reviewing some theoretical reflections on social citizenship and its prospects. It then undertakes a comparative assessment of developments relevant to social citizenship by drawing on the wider literature and a rough review of public debate.