Scandinavian responses to immigration | Northern Europe | bpb.de

Similar welfare states – yet different approaches towards immigration

Denmark, Norway and Sweden have many features in common. They are small and open welfare state economies, built around similar comprehensive, universal welfare state ideology and organization , with similar economic vulnerability e.g. to the migration of low-skilled labour. In all three countries the welfare state also plays a crucial role for the national identity with the historical achievements and the redistributive capacity of the welfare system being a source of national pride.

As striking the above-mentioned similarities, as conspicuous are the differences between the countries when it comes to issues about immigration and cultural diversity. Particularly Denmark and Sweden represent opposite policy models in this regard.

Sweden in the 1970s introduced a policy which was characterized by an intention to combine welfare state inclusion with the recognition and encouragement of ethno-cultural diversity, involving the right to mother tongue education (in other languages than Swedish) in the Swedish elementary school and public support to immigrant groups to build and maintain their own associations. In the 1980s some of the more far-going ambitions to support "long-term survival of minority cultures" within the Swedish society were abandoned , but the country is often mentioned as one of the most manifest examples in the European context of the multicultural model of immigrant integration.

Denmark instead stands out as pursuing one of Europe’s most distinct assimilatory approaches towards immigration, particularly due to the exceptionally harsh immigration and integration policies implemented by Danish governments since the early 2000s. But even prior to that, Denmark’s approach towards immigration in significant ways differed from the Swedish. Hence, whereas Sweden has become multiculturalism’s poster child, anti-multiculturalism is a more appropriate characterization of the policy approach adopted in Denmark. And where Sweden has gained the reputation of having liberal policies towards asylum and family migration Danish policies have been renowned as the opposite.

Norway is often positioned somewhere between the liberal-minded Sweden and the restrictionist Denmark. In the 1970s and 1980s, when Norway began to develop its own migration policy, introduced policy measures were heavily inspired by the Swedish approach, whereas policy developments in recent decades have moved Norway closer to the Danish position.

From the late 1990s, a ‘civic turn’ in immigrant integration policies set in that mirrored a broader political trend in Europe: Ever since immigrants’ access to entry, permanent residence and national citizenship status has been increasingly conditioned on that they can show successful integration performance, as measured by different parameters such as command of the language of the host country and labour market participation.

Denmark has gone further than most countries by introducing ever more demanding integration requirements. In Denmark, naturalization today requires nine years of legal residence combined with tough language, civic knowledge, and self-sufficiency requirements (however, Denmark introduced dual citizenship as a right in 2015). Sweden clearly deviates from the civic integration policy trend by not demanding any kind of test, oath, or proof of integration as a requirement for naturalization. The legal residence requirement (five years) has remained the same since the 1970s and dual citizenship is allowed since 2001. Again, Norway takes a position in between that of Denmark and Sweden, with a seven-year residence requirement, a requirement to document 600 hours of language training, including 50 hours of social studies, but without having introduced a right to dual citizenship.

Policy responses towards immigration involve on the one hand immigration control (who are let in?) and on the other integration policies (what rights and duties should apply once a migrant is granted stay in the country?). In relation to labour migration in the post-war period (1950s to early 1970s), all three Scandinavian welfare states maintained a common principle that immigrants should have equal social rights as citizens and that this required a careful immigration control. Immigration had to be adjusted to labour market needs, to avoid the emergence of new social inequalities. Facing the international economic decline in the early 1970s, this principle translated in a full stop of labour migration in Sweden (1972), Denmark (1973) and Norway (1975).

Immigration to the Scandinavian countries did not cease with the stop of labour migration in the early 1970s, but it changed character. Instead of foreign workers, the immigration now consisted of people applying for family reunification or asylum. Due to its humanitarian nature, this migration was much more difficult for states to control. The above-mentioned nexus between immigration control and social equality, at the root of all three Scandinavian countries’ immigration policy, now transformed into an inherent tension between on the one hand humanitarian norms (expressed e.g. in international conventions) and, on the other, concerns about economic welfare state sustainability.

In Denmark – and also Norway, although to a somewhat lesser degree –the political debate since the early 2000s has emphasized the need to protect the welfare state from strains caused by "undesired" immigration. Restrictive changes have been introduced to limit asylum and family migration. In Sweden, by contrast, there has been a stronger emphasis on human rights concerns, and in the period 1998–2014 most changes in asylum and family migration policies were made in a liberalizing direction. Yet, since 2015, Sweden has also adopted a more restrictive approach towards asylum seekers.

How can differences be explained?

Differences with regard to national identity can be one way of understanding variations in immigration and integration policies. Despite similarities between the three Scandinavian countries, each country has its own understanding of how social cohesion and welfare state sustainability comes about, which result in different policy approaches. The Danish political debates reflect the predominance of what can be termed a society-centred perspective, emphasizing social cohesion as a necessary precondition for public institutions to be sustained. The particular nature and spirit of the Danish people are regarded as a condition and guarantor of Danish democracy and the Danish welfare state. This idea is reflected in policies which base the inclusion of newcomers on a comprehensive set of demands defining a ‘settled’ idea of Danishness the immigrants are expected to adopt.

In comparison, the prevailing Swedish idea about national identity is more oriented towards a state-centred approach, in the sense that the capacity of the political institutions—notably the welfare state—is typically emphasized as the core promoter of social inclusion and a sense of national belonging. In the field of immigrant integration, this idea is mirrored in the perception that it is the organization of welfare state institutions, rather than the spirit of the people, which is referred to as the crucial condition for creating and sustaining national cohesion and integration. In stark contrast to the Danish comprehensive set of integration demands, Sweden has applied exceptionally liberal criteria for newcomers to acquire formal rights on an equal footing with natives, naturalization to Swedish citizenship is for instance not conditioned by any language- or civic skills-requirements. Norway occupies an ambivalent middle ground, with a mixture of strong concerns with cultural cohesion – reminding of the Danish debate, but with less populist undertones – and equal treatment and human rights concerns, which are closer to Sweden.

Other explanations refer to differences in party political factors, where experiences with populist right-wing parties is one crucial aspect. In both the Danish and Norwegian context, electorally quite successful populist right-wing parties have been part of the parliamentary arena for a long time, while this is a more recent phenomenon in Sweden. In Sweden a populist right-wing party – New Democracy (Ny Demokrati) – was for the first time represented in parliament during a short period 1991–1994, but it is only since 2010 that a populist right-wing party – the Sweden Democrats (Sverigedemokraterna) – has gained a more continuous representation. Contrary to Denmark and Norway, the strategy of the mainstream parties has been to isolate the Sweden Democrats – although recently this strategy has been relaxed by some parties, notably the Conservatives (Moderaterna) and the Christian Democrats (Kristdemokraterna).

Different conditions for centre-right coalitions is also an important factor to account for variations in policy approaches towards immigration. In Denmark, centre-right parties started to politicize integration issues and to pursue restrictive policies when the centrist Social Liberal Party (Radikale Venstre) was no longer seen as a viable government partner (in 1993). In Sweden, by contrast, the Conservative Party (Moderaterna) has had an incentive to take a moderate approach, as its centre-right coalition partners (the Liberals/Liberalerna, the Centre Party/Centerpartiet and (since 1991) the Christian Democrats/Kristdemokraterna) all had outspoken pro-immigration profiles.

Current developments

In 2015, the Scandinavian countries – like Europe in general – experienced a large increase of asylum immigration. Sweden received by far the largest share of asylum seekers in 2015 – 163,000 persons, as compared to 31,000 in Norway and 21,000 in Denmark. It was also in Sweden that the record-large asylum immigration had the most profound impact in terms of policy change, whereas post-2015 policy measures in Denmark and Norway were much more in line with (restrictive) approaches already taken.

In June 2016, the Swedish parliament decided to introduce a temporary law (2016-2019) whereby persons who had lodged their asylum application after 24 November 2015 would only be granted temporary residence – three years for those with a Geneva Convention refugee status and 13 months for those with a so called “subsidiary protection” status. Also, possibilities for family reunification were significantly limited. This differed from the principle that had applied since long, namely that all persons granted international protection in Sweden immediately received permanent residence permits, equal socio-economic rights and the requirement-free possibility to reunite with their families.

The changes were justified with the need to "adjust Swedish policies to the minimum EU standards" and was intended to avoid further large inflows of asylum seekers to the country. In July 2019, the above-mentioned temporary law was prolonged. A parliamentary commission is working on the future of Swedish immigration policies.

To conclude, significant differences remain across the Scandinavian countries, with Sweden as the country that diverges most from its neighbouring countries. But the 2015 “refugee crisis” has thrown Sweden into processes of profound policy change where the immigration issue has also come to play a core role in ongoing transformations of the party-political landscape.