Keywords

How do abstract principles of citizenship translate into concrete programs of social support? To what extent do these apply to migrants who do not yet—and may never—attain the civic or political elements of citizenship? The answer to such questions, we argue in this chapter, is not determined once and for all but depends critically on the citizenship regime in place. A better understanding of how and why citizenship regimes have evolved over the past century is thus a necessary starting point.

1 The Rise of Industrial Citizenship

The various types of “welfare state” established in Europe and North America after 1945 were reactions to the traumatic social transformations brought on by a century of industrialization and economic crisis, from the nineteenth century’s “hungry 40s” that form the backdrop of Engels’ study of the English working class, to the twentieth-century trauma of the 1930s’ “great depression.” Underlying the choices made in the 1940s and 1950s, however, were debates that went back much farther on the role of social class and both the effectiveness and the moral status of markets. It is in this broader historical context that we begin our story.

1.1 The Rise and Fall of the First Market Society

For T.H. Marshall, “social citizenship” (by which he meant integration into the economy) was made possible initially by the reduction of economic inequality subsequent to the rise of the industrial economy. While throughout he uses the language of social class, his sense of this term is far more English than Marxist. The existence of class, for Marshall, did not necessarily imply conflict any more than industrialization necessarily led to “pauperization.” Quite to the contrary, he noted that (in England at least) “[a] rise in money income … altered the economic distance which separated the classes from one another, diminishing the gap between skilled and unskilled labor and between skilled labor and non-manual workers” (Marshall 1950: 46). At the same time, the rise in saving and the invention of progressive income tax blurred the distinction between the propertied classes and the rest, while the advent of mass-produced consumer goods contributed to a much more equal material standard of living than had ever been possible before. It was in this context that “the diminution of inequality strengthened the demand for its abolition” (46).Footnote 1 In Marshall’s logic, this ultimate abolition of inequality with regard to the essential elements of social welfare could only be achieved through limiting the scope of the market. The concrete examples he proposes focus on universal access to socially necessary goods and services, housing, education, and health, for example, and more generally to “the progressive divorce between real and money incomes” (81), that is, between market transactions and standard of living.

Using a different vocabulary to express a similar sentiment a generation later, this removal of socially necessary goods and services from the market was labeled by Esping-Andersen (1990) as “de-commodification.” In making this point, Esping-Andersen, much more than Marshall, emphasized an element of economic history that will prove central to the argument of this book: the relevance to the present of the economic and social heritage of preindustrial society. In such a society what we subsequently labeled social welfare was “only imperfectly commodified” in the sense that nonmarket forces played a determining role in defining access to socially necessary goods and services. “Thus, in the middle ages, it was not the labor contract but the family, the church, or the lord that decided a person’s capacity for survival” (Esping-Andersen 1990: 35). Esping-Andersen, here, echoes the sentiments of Marc Bloch (1939: 109) who, writing about the “first feudal age,” had noted that “Buying and selling were not unknown to the society of that time, but it did not live, as does ours, by buying and selling”—(our translation). The limited role for market transactions noted by these authors in premodern Western Europe is not an artifact of a distant period of history. Rather, it persisted well into the nineteenth century even in Britain, and longer elsewhere. Putting this statement back into Marshall’s vocabulary, we see that the “divorce between real and money income” was already present—or more to the point that the marriage between the two had yet to be fully consummated. Indeed, as Polanyi (1944/1957) famously chronicled, it was the move toward a social and economic system in which both the means of survival and the labor that allowed access to them were treated as commodities subject to a market price that constituted the socially disruptive “great transformation” of the nineteenth century.

It is noteworthy that among the opponents of this transformation were found the most conservative, as well as most revolutionary elements of European and North American societies. The subjugation of workers to market forces beyond their control was central to the Marxist critique of the capitalist system of production, but conservatives, as Esping-Andersen (1990: 36) points out, “opposed outright the principle of commodifying humanity” because they feared—rightly, we might add—that this “would lend a fatal blow to the perpetuation of the old order.” Nor was this fear a new one. Fontaine (2014: 144) in her study of the evolution of market relations in early modern Europe returns again and again to the antagonism between the market and the aristocratic views of society. To enter into a market bargain with someone was, at some level to acknowledge him or her as a social equal. She points to the profound aristocratic resistance to the expansion of market transactions whose point of reference was “the validity of the exchange rather than the social rank of the persons involved”—(our translation). As seen from the summit of society, the market was a threat to “quality” in the social sense, and thus to social order more generally.

The twentieth-century welfare state can be understood as one of several possible responses to Polanyi’s “great transformation” toward the all-encompassing market that threatened both workers and aristocrats, an attempt to attenuate the market’s social costs while consolidating its productive capacity. When we take into account the multiple sources of opposition to the market, we understand why Esping-Andersen emphasizes that welfare state regimes had two distinct and not altogether compatible purposes: to decommodify labor and to support—or restore—“a system of stratification.”

1.2 The “Industrial” Model of Citizenship and the Twentieth-Century Welfare State

In his 1967 study of “the new industrial state,” the economist J.K. Galbraith emphasized the largely successful counterattack against the all-encompassing market, not by labor but rather by major industrial corporations. Beside a “market system” made up of small firms, which really are subject to market rules, Galbraith posited the existence of what he labeled the “planning system” made up of firms whose position was quite different. The dominant position of the largest corporations largely insulated them from market forces, allowing them to devote their energies to ensuring long-term security rather than short-term profits. Support for social policies, in this context, came as managers saw the opportunity to “trade profits for protection against such undirected events with such unpredictable consequences as a strike and its accompanying effect on identification and motivation.” This was made possible in large part because the postwar era was the high-water mark of managerial—as opposed to shareholder—control of corporations, which meant, as Galbraith put it, that “those who make the decisions do not have to pay” (Galbraith 1967/1979: 240). Swenson, looking back on this moment a generation later, also emphasized the role of business interests in the establishment of the “regulatory welfare state” from the 1940s to the 1970s, concluding that: “… changing alignments or sharing of interests across class lines, not a shifting of the balance of power favoring labor at capital’s expense, might be the most significant source of progressive change” (Swenson 2004: 3).

This is the world that gave rise to the model of “industrial citizenship.” As defined by Canadian legal scholar Henry Arthurs, in a text exactly contemporary to Galbraith’s New Industrial State but looking at the question from a legal point of view, this was a system in which “the worker lives increasingly in a world of rights and duties created not only by his employment contractual act, but by a process of public and private legislation.” (Arthurs 1967: 787) Such legislation set the terms of permissible employment contracts, and recognized the central role of labor unions in bargaining for them, as well as providing support for those who could not work due to accident, sickness, or old age.

A “formidable array of rights” (Marshall 1950), was indeed produced in twentieth century Europe and North America, but so was “a system of stratification.” (Esping-Andersen 1990) This took the form of corporatist governance of social policy in “conservative” regimes such as France and Germany, in which different professional groups received very different benefits. In the “liberal” United States and United Kingdom, stratification took the form of means-tested support programs, the social stigma of which was such that they were refused by some who might have been eligible for them—as is still regularly the case today in the United States (Esping-Andersen 1990: 58–65). Social democratic regimes faced a different set of challenges. The first, as Esping-Andersen points out, was overcoming the heritage of labor-union dominance that tended to segregate industrial workers into self-contained communities to the exclusion of all other classes. The prestige and power that such systems brought to unions made them reluctant to abandon it, despite the universalist aspirations of socialist ideology. It is noteworthy that Arthurs’ definition of “industrial citizenship” in Canada was explicitly limited to unionized workers, and did not include other types of employees, let alone all Canadians. The legal “rights and duties” that existed beyond the scope of employment contracts were seen, in this logic, as a natural extension of industrial relations; they served above all to ensure equal treatment across unionized sectors—not beyond them.

The move to universalism, moreover, brought challenges of its own. Even the most all-encompassing social democratic models saw the need to introduce earning-graduated benefits in order to retain the support of higher earners (Heclo 1974: 227–283; Esping-Andersen 1990: 65–69; Steinmo 2013). The point of these arguments is not to suggest that redistribution in favor of workers, children, and the elderly was an illusion. It did indeed occur, especially in states following social-democratic models. Even in such systems, however, it was accompanied by continued inequality and consolidated social control.

Introducing the question of social control reminds us that often lost in critiques of the market are the social and human costs of the absence of markets, especially as these relate to interpersonal relationships. A world in which it was “family, the church, or the lord that decided a person’s capacity for survival,” to return to Esping-Andersen’s characterization of the preindustrial world, was a world of personal dependence. In such a world, the capacity to give was a source of power, understood as such by both givers and receivers at all levels of society. As seen from the top of society, we have Montaigne’s defense of the practice of venality: “to purchase an office is to give only money; to receive it as a grant is to give one’s self.”Footnote 2 The view from the bottom, on this topic at least, was not so different. Judith Shklar (1991: 83) in her essays on American citizenship evokes the joy and pride expressed by Frederick Douglas, escaped slave and subsequently a leader of the campaign against slavery in the nineteenth-century United States, at being for the first time paid for his labor, the “tremendous fact” that truly placed him “in a state of independence.” For the American former slave just as for the French aristocrat, to pay one’s own way was to be one’s own man.

In return for the protection it offered from market risk, the model of “industrial citizenship” displaced rather than eliminated dependence. From church, lord, and family, it was shifted to corporations, unions, and the public institutions of the welfare state. Individuals, whether in their role as workers or as receivers of services, were protected from the insecurity of the market, but at the price of accepting a passive role. As put by Julian Le Grand (2003), they were “pawns” and not “queens.” Le Grand emphasizes the extent to which, in Britain at least, the collectivist ethos of the 1940s and 1950s was translated into an increase in the power of civil servants, whose genuinely public spirited motivations in no way diminished—indeed strengthened by legitimating—their quest for control. In its public ideology and perhaps in its collective memory, this was the society that provides the model for Root’s (2007) ideal of citizenship, in which individuals accept responsibility for each other. In practice, however, the altruistic “knights rampant” (Le Grand 2003: 4) of the civil service took responsibility for everyone. Citizens, for their part, were expected to display a passive form of altruism through their uncomplaining willingness to accept the redistributive tax system that paid for it all. Le Grand’s observations rest on analytical foundations that go back a generation; in 1974, Hugh Heclo demonstrated through close empirical study of the policy-making process the extent to which British and Swedish social-policy bureaucrats worked to solve policy “puzzles” that they themselves had identified, rather than responding to any identifiable social or political demand. Looking to a subsequent generation of policy-making in Sweden, Steinmo (2013: 85) comes to similar conclusions, noting that: “the unique features of the Swedish political economy are the products of a particularly successful brand of social democracy that was invented by a particularly technocratic and remarkably autonomous governing elite.”

The industrial regime of citizenship was indeed “inextricably linked to the growth of the welfare state and social rights,” and an “element in the attempt to build a bridge between citizenship and class” (Fudge 2005, 632) through efforts to limit the commodification of workers. We are brought back to Marshall’s prediction of an increasing distinction between real and money income, and the ever-growing importance of the former. What Marshall and other proponents of the welfare state and the citizenship regime that accompanied it failed fully to appreciate was that this came at the price of agreeing to live by the rules of the paternalistic society and the industrial planning system; by the 1960s, this was a price that increasing numbers of citizens in Europe and North America were no longer willing to pay.

2 From Industrial to Market Citizenship

The regime of industrial citizenship was closely tied to the historical moment in which it arose; it was part of what historians of the twentieth century have long designated as the “post-war consensus” (Addison 1975) founded on trade union strength, Keynesian demand management, and the various models of the welfare state. As one after another of these elements were eroded, the industrial regime of citizenship itself was called into question.

2.1 The Revolt against Industrial Citizenship

Not all, even at the high point of the “industrial” system, were equally enthusiastic. The critiques and warnings of unrepentant liberals such as Fredrich Hayek are well known, but more ironic, as Le Grand (2003: 6) points out, is the fact that Keynes was at best a “reluctant supporter” of the welfare state that is too often associated with his name. The “welfare state” was many things, but it was “Keynesian” only indirectly and coincidentally. Keynesian macroeconomic management was meant to reduce the need for any targeted “welfare” policies on the part of the state by ensuring full employment; it depended fundamentally on the acquisitiveness of consumers, not the solidarity of citizens, for its organizing logic and economic engine. There can be no doubt, however, that the crisis of Keynesian demand management that erupted in the 1960s and paved the way for the liberalization of the 1980s coincided with and contributed to mounting pressure both on welfare state policies and, more generally, on the “industrial” citizenship regime. In addition to the economic crisis, however, it is critical to recall that the social transformations that ultimately led to the “neo-liberal turn” (Jobert 1994) toward a market model of society had a number of converging causes. The liberalism of the 1980s triumphed over an economic and social model that, by then, had been on the defensive for over a decade.

One line of attack was philosophical: the “critical sociology” associated with the Frankfurt school in Germany and the French “new left” of the 1960s. Taking for granted the economic success of “advanced capitalism,” these writers and activists sought to undermine its social and moral status: for them, “the impending crisis of capitalism was not one of production but of legitimation” (Streeck 2014: 14). Against the prison of lifetime employment in hierarchical firms, they promoted empowerment through workers’ collective self-management of those same enterprises. In a similar vein, the burgeoning environmentalist movements of this same period saw the danger not in the collapse of the industrial system but in its unchecked economic success, accompanied by mounting ecological damage.

Although it is generally understood as a critique of an economic and political model, the revolt against the postwar attempt to establish “democratic capitalism” (Streeck 2014) should also be seen, in the context of this book, as a growing rejection of the “industrial” regime of citizenship whose foundations were acquiescence to top-down control (of the economy by large firms and of social policy by national governments) and to the centrality of the patriarchal family as the fundamental unit of social intervention. Along with the erosion of authority came a calling into question of the enforced uniformity that seemed to be the price to pay for the security of lifetime industrial employment and the assurance of a universal social safety net. As pointed out by Le Grand (2003: 8) “… it became increasingly apparent that many people—particularly but not exclusively the middle classes—wanted different kinds and different levels of services.”

A second fundamental element of industrial citizenship, the patriarchal family associating a male “bread-winner” and a female provider of unpaid domestic services, was also under attack. This family model, especially but not exclusively in the “conservative” variants of the welfare state, had bridged the gap between policies tailored above all to unionized salaried workers and the aspiration to universal social rights. It was through their association with an employed man that wives and children, in this idealized model, had access to the rights and benefits of industrial citizenship. Feminist contestation of the patriarchal family necessarily brought contestation of the industrial model as well. An important manifestation of this was a massive turn by women to the market. To the consternation of neo-Marxists, “Beginning in the 1970s, women throughout the western world poured into labor markets, and what had been branded shortly before as historically obsolete wage slavery was now experienced as liberation from unpaid household drudgery” (Streeck 2014: 17).

Whether we understand these developments as a genuine social desire for greater individual autonomy (Le Grand 2003; Barnett 2005), or as a victory for the propaganda of the wealthy and a deplorable descent into collective false consciousness (Blyth 2002; Root 2007; Streeck 2014), the fact remains that industrial citizenship was well on its way to being rejected as a social model before the economy that supported it entered into open crisis. It was a much weakened economic and social order that was left to face the inflation and unemployment crises of the later 1970s. Between them, these brought down the Bretton Woods system of fixed exchange rates and opened the way to what proved to be a devastating counterattack from philosophical liberals and leaders of finance on both the managerial capitalism of the “new industrial state” and the paternalistic welfare programs central to “industrial citizenship.”

2.2 Toward a New Citizenship Regime

On both sides of the Atlantic, the movement away from “industrial citizenship” was led by a coalition of financial interests and a generation of political leaders who were at once politically conservative and economically liberal. In the business world, this took the form of the devastatingly successful counterattack by shareholders and financial interests more generally on the managerial planning system of the “new industrial state” (Lazonick and O’Sullivan 2000). Generally couched in terms of “shareholder rights” this became the new orthodoxy of “good corporate governance” by the 1990s, consecrated as such by a “Principles of Corporate Governance” produced by the OECD at the end of the decade (OECD 1999). From the “leveraged buy-outs” and “de-regulation” of 1970s America to the financial “big bang” of the 1980s in Europe, the “neo-liberal turn” (Jobert, ed. 1994) was underway within the corporation. Quantitative study of its impact largely validated Galbraith’s hypotheses by showing that while managers left to themselves preferred a “quiet life” (Bertrand and Mullainathan 2003), the threat of hostile takeover typically led to a fall in salaries and a reduction in capacity. The policy of ensuring labor peace through salary increases, fringe benefits, and guaranteed employment was increasingly a thing of the past. A point too often ignored in the literature on the resurgence of business influence in the politics of Europe and North America in the 1980s (Vogel 1989; Blyth 2002) is that this influence was wielded by corporations that had undergone, or were in the throes of, this internal revolution. What these new-model corporations wanted from government was very different from what their equally influential predecessors of the 1950s required, and high on the new list of demands was the reduction of the union influence that had been at the heart of the “industrial” regime of citizenship.

Political leadership converged with this economic movement after 1979. For Reagan, Thatcher, and those who emulated them, the inflationary crisis of the late 1970s provided the perfect pretext for action against both the entrenched power of labor unions and the expansion of the welfare state (Blyth 2002). The proximate result of this was the “supply side economics” of the 1980s, which provided justification for tax cuts and the deregulation of economic sectors ranging from banking to air transport. A far more lasting development went beyond popular economics: the concept of the market as an ideal of personal liberty and empowerment, in past decades largely the province of a small albeit influential group of philosophical liberals ranging from Friedrich Hayek to Milton Friedman, had become by the mid-1980s a mainstream view, and would remain so for a generation.

While the attack on unions was remarkably successful, the outcome for the social policies that, collectively, had typified the various models of the welfare state was more nuanced. Many of the specific institutions and programs central to the postwar social model, from the US Social Security System to the British National Health Service proved surprisingly resistant to direct “retrenchment” (Pierson 1994). The broader regime of industrial citizenship, however, with its collectivist ideal, found itself with few active supporters. In its place grew a vision of individualized citizenship better suited to the resurgent market ideology. In this context, the history of the welfare state was reimagined by its critics in the 1970s and 1980s. From a heroic narrative of working class conquest, it was recast as a story of public sector hubris.

At the core of this new narrative were two distinct streams. At the broadest level was what Pierson (1994) called “systemic retrenchment,” subsequently better known and much studied as “austerity” (Blyth 2013; Schäfer and Streeck 2013). Among the founding documents of this stream was the 1975 Trilateral Commission report on “The Crisis of Democracy” (Crozier et al. 1975: 9), whose diagnosis could be summed up as: “The demands on democratic government grow, while the capacity of democratic government stagnates.” Numerous observers of all political stripes have pointed out that while the debate on “austerity” has raged for now almost 50 years, public spending has continued to rise. Change was more subtle but ultimately more important; the belief, central to the postwar ideal of industrial citizenship, in a state monopoly on the provision of welfare-enhancing services, has arguably never recovered. A second, more targeted stream of argument strengthened this effort to discredit the welfare state by claiming that actual harm was caused by attempts to secure welfare outside the market economy. The indisputably poor quality of some public services lent—and continues to lend—credibility to this argument. For welfare state supporters, the idea of de-commodified social services may evoke images of bright cheerful child-care centers, presumably somewhere in the suburbs of Stockholm. The frankly Dickensian analysis of the calculated cruelty of the New York City system of shelters for the homeless in the 2000s given by Bonnet (2019) serves as a reminder that what Polanyi referred to as the “workhouse test,” that is, the explicit policy of making the conditions of public assistance so degrading that only the truly desperate will accept them, cannot be consigned to the history of a less enlightened time.

At the heart of the vision of citizenship that rose to prominence in the 1980s and remained dominant for a generation was a skeptical assessment of public action and a renewed belief in the empowering virtue of markets. At the societal level, this implied an end to efforts to impose a public sector monopoly on social services. From the return of “corporate social responsibility” and “social enterprise” to the rise of nongovernmental organizations and the trend to public–private partnerships, the idea that the state should be, at best, one actor among many in the social field became widespread. Religious groups, the public role of which some believed to have been relegated to distant history, played a part as well. In fact, they had never gone away, as attested by the prevalence of religiously affiliated schools in Germany and the United Kingdom, or the quasi-official role of the French Secours Catholique in working with irregular migrants. The renewed prominence in the United States of “faith-based initiatives” since the 2000s is likewise the recognition of a long-standing reality. Underscoring the compatibility of all of these with a certain vision of modernity, the nebulous but increasingly ubiquitous notion of “social innovation,” frequently put forward by the European Union, has emerged to encompass initiatives that combine the use of innovative technology with the systematic blurring of the lines between public and private. (Ark-Yıldırım and Smyrl 2019)

At the individual level, this vision idealized the decision-making agent rather than the passive subject, valuing initiative rather than solidarity. The feminism of the 1970s, as we have noted, had anticipated this turn as large numbers of women found in salaried work outside the home not merely increased financial autonomy but, perhaps more importantly, personal and social validation. Individual autonomy was also at the heart of calls for change in public and professional services, ranging from individualized education programs to patient-centered medicine. In the field of economic development, individual empowerment increasingly displaced collective solidarity as the organizing principle. This took forms as diverse as the sale of public housing and other schemes to promote homeownership in Europe and North America, or micro-credit schemes and incentives for self-employment in developing economies. All of these had in common, to return to Le Grand’s evocative language, the presumption that citizens wished to be “queens” rather than “pawns” and that empowering them to achieve this was in the general interest. If the ideal citizens of the industrial regime were the corporate manager and the salaried union member, the new model was the entrepreneurial property owner—even on a very small scale.

Marshallian “full equality of membership,” in this context, was centered on market participation. In a society that “lives by buying and selling,” as Bloch put it to mark the contrast with earlier ages, engaging in the petty market transactions of daily life becomes the clearest marker of the responsible adult citizen. Being one’s own man (or woman …), in such a world, just as it had for Frederick Douglas a century earlier, implied paying one’s own way.

3 Policies for Market Integration

Critics of the market turn have typically pointed to the policies outlined above as exacerbating the marginalization of those who, for one reason or another, failed to live up to the neo-entrepreneurial ethos of the market regime. It does not follow, however, that a market-enhancing perspective is incapable of going beyond policies intended to provide opportunities for personal enterprise or to mitigate life accidents such as sickness or temporary unemployment. Market-enhancing policies can also seek to address issues of chronic poverty. In the terms we have used throughout this discussion, the former seek to prevent persons who would normally enjoy full social citizenship from losing it due to mischance not of their own making. The latter tackles the more difficult problem of including those who in Marshall’s terms lack the “modicum of economic welfare and security” necessary to “live the life of a civilized being according to the standards prevailing in the society” (Marshall 1950: 11).

3.1 From Income Maintenance to Cash Transfer

The question of how best to accomplish this is not new. A major conceptual step, as described by Heclo (1974/2010) was taken in the first half of the twentieth century by the move from “relief” as an exceptional measure, with its uneasy mixture of charity and stigma, to “income maintenance” understood both as a right for those receiving it and as socially useful for the public at large. The development of unemployment insurance, but also of early forms of health insurance, such as the 1911 British scheme intended to replace earnings lost through illness or accident, can be put into this category. Each sought to maintain “money income” rather than replacing it though the provision of services outside the market.

For contemporary proponents of such schemes, the key is to go beyond “income maintenance” to income creation through cash payments to low-income persons. This could, in principle, take the form of universal basic income, but while much spoken of, this has so far never been attempted.Footnote 3 Despite this, a point of view frequently found in academic writing on social policy is that anything short of a universal benefit represents, at most, a second-best solution. Thus, Buğra and Adar (2008: 91) propose that while policies such as universal old age and health benefits and non-means-tested income maintenance schemes are most compatible with citizenship, “in those socio-economic contexts in which poverty is a serious problem and resources are scarce, means-tested benefits may be the only way to prevent social exclusion due to the inability of certain segments of the population to gain access to basic minimum means of social integration.”

An alternative approach begins from the premise that if the ultimate goal is to protect citizens against poverty—or in the more sweeping terms of the UN’s sustainable development goals, to “eradicate poverty”—then means-tested benefits can be the most effective instrument for achieving universal protection against poverty. Returning, as we do, to Marshall’s construction of social citizenship, Leisering (2019: 57) emphasizes the point that “equality of membership” rests on the capacity to participate in social and economic life. It is this that must be universal, not access to a given public program. It is because of its potential to provide the capacity for participation to those who might otherwise lack it—bearing in mind Sen’s (1981: 2) reminder that those who have little to exchange can’t demand very much—that Leisering (2019: 320) concludes that a means-tested transfer of purchasing power not only meets the requirements of universality but can be considered a “citizenship approach to poverty.”

Grouped under the label “cash transfer” (CT), policy instruments of this sort are noncontributory schemes of social support through transfer of purchasing power to individuals. They are thus distinct both from social insurance (based on contributions) and from in-kind provision of goods or services ranging from free healthcare to the distribution of food packages. Examples of this approach in Europe, such as the French “active solidarity income” (revenue de solidarité active), rely on targeting resources to those who need them most.Footnote 4 Variations on the CT model have proliferated in the global south since the mid-2000s. Honorati et al. (2015) count some 130 low- and middle-income countries that have at least one noncontributory unconditional CT program (including poverty-targeted transfers and old-age social pensions). Similarly, 63 countries have at least one conditional CT program, compared with two countries in 1997 and 27 countries in 2008 (Bastagli et al. 2016). By another accounting, CT programs had reached 750 million people in low- and middle-income countries by 2010 (Molyneaux et al. 2017: 1). The Cash Learning Partnership notes in the context of humanitarian assistance that

The benefits of cash-based assistance have been shown to cut across multiple sectors. And opportunities have been identified to align CT Programs with major reforms at every level, from achieving the Sustainable Development Goals and the 2030 Agenda for Sustainable Development, to strengthening social protection… (CaLP 2020: 3)

Assessments such as these suggest that CT is the ideal social policy for the regime of market citizenship. Questions, however, remain on at least two dimensions: the first focused on the relative advisability of broad policy types and the second assessing empirical outcomes of specific programs.

In the first category is found the ongoing debate between proponents of “conditional” and “unconditional” CT. The debate is framed by a deceptively simple question: if the situation to be remedied is inadequate income, why not, to cite the evocative title of the study by Hanlon et al. (2010), “just give money to the poor,” and let them decide how best to spend it? The second half of the question gives away the answer most frequently put forward by proponents of conditional CT. It has been shown repeatedly that cash payments would be the most cost-effective way to provide “relief” (Marical et al. 2008), but from the perspective of those providing it, the idea of allowing “the poor” to spend it as they wish has more often than not proven unacceptable. We are once more confronted with the persistence of the moral stratification most recently encountered with the “knights rampant” of the de-commodifying welfare state (Le Grand 2003), but seen previously in the aristocracy’s fear of loss of privilege based on moral superiority (Fontaine 2014). At the core of this moral paternalism is the deeply held belief that “the poor” must not only be “relieved” but “improved.” The underlying fear is what Milton Friedman (1962/1982: 21) ironically pointed to as the problem with economic freedom: “It gives people what they want, rather than what a particular group thinks they ought to want.”

Conditional CT encourages people to seek “what they ought to want” through cash incentives for socially approved behavior. Contemporary systems of conditional CT such as Brazil’s much studied Bolsa Familia are contingent on actions such as sending children to school or pursuing job training. Proponents of conditional transfers point to their potential for encouraging longer-term social transformation and poverty reduction through building human capital. The popularity of such programs is undeniable; Morais de Sá e Silva (2017: 3) refers to conditional CT as “a magic silver bullet in the policy world.” When it comes to assessing concrete outcomes, however, this same author takes a more measured tone, noting that in the case of Brazil there was consensus among officials that the Bolsa Familia was effectively an incomes policy, rather than an educational one. Evidence linking the program to longer-term educational outcomes is at best ambiguous. (137).

What can be done with the purchasing power transferred can also be constrained. Most common are programs that explicitly link purchasing power to food, from the SNAP food assistance program in the United States (Alderman et al. 2018) to the local cash-transfer schemes we will study in Turkey. The Turkish local programs discussed in Chap. 4 also embrace another common constraint: the designation of specific businesses in which purchases can be made. A final type of limitation is the link between CT and unrelated policy priorities. CT for Syrian refugees in Turkey, as we will see in Chap. 6, is presented as unconditional, but requires recipients to be registered with Turkish immigration authorities and imposes limits on their mobility within Turkey.

On the other side of the divide are programs not linked to behavior (“unrestricted” CT) or to specific purchases (multipurpose cash, or MPC). For Hanlon et al. (2010: 11) the choice is a starkly moral one: “Cash transfers are a direct challenge to the traditional belief, explicit or at least subconscious, that impoverished people are at least partly responsible for their plight.” Low-income households, in this view, do not need to be morally improved, or “nudged” into more productive behavior; they need to be economically supported.

Just as with conditional CT, empirical evidence concerning concrete outcomes is somewhat harder to come by than sweeping theoretical pronouncements. A sense of cautious optimism, nevertheless, seems to be emerging. Focused studies of unconditional CT programs in Africa have pointed to positive effects on early childhood nutrition (Agüero et al. 2007) or on economic outcomes and psychological well-being (Haushofer and Shapiro 2016). Other researchers have pointed to improvements in mental health (Kilburn et al. 2016; Angeles et al. 2019) or, more generally, to improved health and educational outcomes (Marinescu 2018). With respect to education, however, studies or unconditional CT, just like those of the conditional programs cited above, tend to assess “educational outcome” in terms of school attendance; evidence of improvement in educational attainment is much less evident. (Baird et al. 2014) Summing up the state of current knowledge, the 2020 report of the Cash Learning partnership cites evidence that:

Cash is usually spent according to a hierarchy of needs—most immediate needs first (e.g. food, basic shelter, primary health) and other needs later (e.g. livelihoods, less essential goods). (CaLP 2020: 106)

Bringing together these streams of evidence suggests that the distinction between conditional and unconditional cash may be less obvious in practice than in moral theory. Evidence from World Bank funded conditional CT programs in Turkey suggest that they do work to motivate families to send their children to school (World Bank 2006). A similar outcome, however, is reported for the unconditional CT for refugees in Turkey that will be our focus in Chaps. 5 and 6 (Maunder et al. 2018: 29). A recurring theme in reporting on these programs is that CT can help to overcome stigma. From Brazil, comes the view that the Bolsa Familia is first and foremost an incomes program:

“The fundamental premise is that poor children are not in school because their families lack the means to do so. In the words of interviewee C16, “sometimes poor children do not attend school because they do not have basic items such as school uniforms.” Morais de Sá e Silva (2017: 138)

Likewise from a beneficiary of the conditional CT program in Turkey: “It’s money we can spend on pencils, shoes and uniforms, so the children don’t feel humiliated at school” (World Bank 2006: 1). To return to the vocabulary proposed by Sen (1981), the problem is not one of supply or even of rights, but of (market) entitlement. In an example directly relevant to our final case, Baban et al. (2016: 10) make this point directly noting that in the case of Syrian refugees in Turkey:

The kimlik (registration card) enables Syrian children to have identical rights to Turkish children regarding the right to a free education in a Turkish school. However, as with health care, accessing this right can be more difficult in the everyday realities of Syrian families in the face of poverty, where families cannot afford to clothe and pay for the transportation costs of sending their children to school.

The premise of unrestricted cash, supported at least partly by some of the studies cited above (Maunder et al. 2018; Marinescu 2018), is that this is a spending choice families will make as soon as they have the means to do so, with or without explicit conditions.

With this discussion, we are brought back to two of this book’s central points of focus. In the first place, it highlights the limited value of theoretical rights for those who do not have the practical means to access them. “Equality of membership,” as exemplified here by school attendance, depends on more than the existence of a universal school system. The explicit reference to Syrian refugees, moreover, reminds us that one of the questions we ask is whether and to what extent some elements of Marshallian social citizenship might be extended, using market-enhancing instruments such as CT, to migrants—including forced migrants. In general terms, this is the question of scope: Is assistance a right or privilege? If the former, how is it earned? If the latter, who is entitled to it—all workers, all citizens, all persons regardless of status? It is in this context that we turn to the question of migration in the following section.

3.2 Market Citizenship and Migration

A recurring criticism of Marshall’s model of citizenship is that it makes no allowance for—indeed takes no notice of—migration (Joppke 2010). Although this is self-evidently true with respect to Marshall’s empirical examples, it is much less so if we consider his analysis in the more abstract sense employed in these pages. Here, Marshall’s division of citizenship into distinct components proves surprisingly useful. If “citizenship” were seen as a binary question of status, an indivisible whole, it clearly could not apply to “non-citizen” migrants. The position we have taken throughout this book, however, precludes such summary dismissal. Instead, we follow not only Marshall but much of the contemporary discourse on citizenship by understanding it as a more complex and evolving array of rights and duties.

This starting point allows us to consider the prospect that the social and economic aspects of citizenship may have partial autonomy from the civil and political elements. Marshall’s historical analysis provides a mirror-image argument in favor of this proposition through its demonstration that civil and political citizenship can, and long did, exist in the absence of economic and social rights. In this book, we reverse the perspective to ask a question beyond the scope of Marshall’s analysis but not, we suggest, incompatible with his logic, namely, whether and to what extent the economic and social rights granted to migrants constitute elements of citizenship in Marshallian terms, as “basic equality of membership.”

Granting the elements of “social citizenship” to migrants is far from obvious. It is no coincidence that the classic exponents of the mid-twentieth century European welfare states from Titmuss to Esping-Andersen make no more mention of immigration than does Marshall. Welfare states, as Freeman (1986: 52) pointed out a generation ago, are “by their nature meant to be closed systems” because “individuals who agree to share according to need have to experience a sense of solidarity that comes from common membership.” Deploying a more instrumentalist argument, Rieger and Leibfried (1998: 375) suggest that “Only closure seemed to protect the massive investments in national human capital—the welfare state’s move toward the education, health, and social state—and to increase the efficiency of political rule.” Complementary to these arguments are those made by Castles (1989) about mid-twentieth-century Australia and New Zealand, where strongly egalitarian working-class culture and powerful labor unions—the perfect context for industrial citizenship—ensured high levels of social and economic equality without the need for extensive redistribution, through strong labor regulation and high wage levels made possible by an extremely restrictive immigration regime that prevented labor market competition.

In this context, it is a mark of the relative weakness of labor in Western Europe, even at the apogee of the industrial era, that the industrial regime of citizenship proved to be not only open to migration but, in a dynamic unintended by its political architects, served as a stimulus for it as employers turned massively to immigrant workers as a way to restore a measure of flexibility to the labor market. (Freeman 1986: 55) Perhaps to the surprise of these same employers, however, “… guest workers without formal citizenship have been incorporated into various aspects of the social and institutional order of their countries” (Nuhoğlu Soysal 1994: 2). For this author, this was attributable to an emerging model of “postnational citizenship” in which “what were previously defined as national rights become entitlements” legitimated by an emerging norm of “human rights as a world-level organizing principle” (3). Giving substance to these rights, however, was by no means automatic. Rather, it required an “incorporation regime” conditioned by “the institutional repertoire of the host political systems, which afford the model and rationale for both state and migrant action” (5).

The notion of an incorporation regime is one to which we will return in subsequent chapters, but in so doing two critical elements must be added to the analysis. Most obviously, we will focus on the features of the Turkish institutional repertoire that distinguish it from the European examples studied by Nuhoğlu Soysal. A more radical question is to what extent a concept originally conceived for the case of guest workers can be adapted to the problem of refugees.Footnote 5 Access to employment is only the most obvious difference between guest workers and refugees, and the likelihood of their being treated differently not only from citizens but also from other migrants by host country institutions is significant. When we speak of an “incorporation regime” for refugees, thus, we do not imply that these will face a situation identical to that of the guest workers analyzed by Nuhoğlu Soysal. Rather, we seek to underscore two key elements of her insight: that rights long associated with national citizenship are now strongly influenced by international laws and norms, and that the translation of legal abstractions into daily reality depends critically on the “institutional repertoire” of host countries.

On one level, the various postwar international commitments from the Universal Declaration of Human Rights to the 1951 Geneva Convention Relating to the Status of Refugees and its subsequent protocols would seem to provide a paradigmatic example of “human rights as a world-level organizing principle.” The Universal Declaration pointedly employs the word “everyone” to designate the holders of the rights it enumerates, avoiding all reference to citizens or residents. Among the rights held by “everyone” is to “seek and enjoy in other countries asylum from persecution” (Article 14). While the 1951 Convention and its protocols subsequently attempted to impose a strict definition of “refugee” as a legal status,Footnote 6 the texts taken together suggest that even those denied this status cannot simply be expelled (the principle of non-refoulement) and that while they remain they are entitled to the same human rights as anyone else—including, if one takes the Declaration at face value, freedom of movement, equal access to public services, education, and employment.

Even before the Syrian crisis, the number of migrants classified by the UN as “international displaced persons,” whatever the legal status granted by their host country, numbered in the tens of millions. The example of the Palestinians, moreover, reminds us that such “displacement” can last for generations. Can any form of citizenship, even “postnational,” be applied to persons in this situation? It requires neither expertise in international law nor extensive knowledge of world affairs to discern that translation of principles into reality is far from automatic. As with the guest workers studied by Nuhoğlu Soysal, the question of national “incorporation regimes” is critical.

Experience in the past decades suggests that there is a close link between such “incorporation regimes” and domestic welfare regimes, although not exactly the one anticipated by Rieger and Leibfried (1998), as cited above. Rather than turning to closure to protect their “massive investment in national human capital,” contemporary states have generally chosen to extend certain economic and social rights to migrants, even in situations where these are not, or not yet, considered to be candidates for other types of rights. As a rule, moreover, the rights extended to migrants are patterned on those already in place for permanent legal residents (Sainsbury 2006), although they may not be identical. Leerkes (2016: 149) notes that in cases where migrants are considered to be illegally present in host states—after they have formally been refused asylum, for example—economic and social policies may be characterized by “ relatively unattractive and, in some ways, quite archaic form of poor relief and pauperism control.” In cases where migrants’ presence is acknowledged, even provisionally, as legitimate by the host state, nonetheless, this same author acknowledges a tendency for the rights of immigrants—whether guest workers or refugees—to resemble those of citizens. Different welfare regimes, accordingly, will tend to produce different “incorporation regimes.”

While such isomorphism may be institutionally and morally coherent, it has proven politically problematic in numerous cases. Looking at the examples of Canada and Denmark, Kevins and van Kersbergen (2019: 13) suggest that there is a clear correlation between “inclusive” regimes of citizenship, with their focus on “broad solidarity and access to welfare state provisions” and strong political resistance to any broad rights-based “incorporation regime” for migrants. Political opposition to migrants claiming the status of refugees has become particularly strong. The irony here is that it is the institutional proclivity of states to pattern the attributes of “social citizenship,” in the Marshallian sense, of migrants on those of permanent legal residents (Sainsbury 2006) that may make states where social citizenship comes closest to Marshall’s ideal—and closest to the ideal industrial citizenship regime—reluctant to admit migrants in the first place, or that ensures that they will pay a high price in the form of political push-back if they should do so.

In the context of our broader argument, this observation leads to an obvious question. Would economic policies and a welfare regime closer to the ideal type of “market citizenship” make incorporating migrants easier? The observations of Kevins and van Kesbergen with respect to Canada suggest that this may be the case. Joppke and Morawska (2003: 27) likewise assert that “More market-based welfare states, such as the United States, where paths from school to work are much less regulated by public policies, allow more space for immigrants to incorporate themselves ‘on their own’ by applying their cultural and social capitals.” Looking to the European Union, Joppke (2010) notes a shift toward a “thinner” regime of social and economic citizenship for everyone, with fewer public services and a greater centrality of market approaches to policy. To the extent that the twentieth-century welfare state, by focusing on de-commodification and social cohesion, made states and societies less able to integrate migrants—either refusing them altogether or consigning them explicitly (as in Germany) or implicitly (as in France or the United Kingdom) to a second-class status, moves in the direction of the more market-oriented pattern may make it easier not only to accept but also to integrate migrants. Bartle’s (2006) discussion of “market citizenship” in the EU following the implementation of the Single Market notes its link to free movement of persons among the member states of the Union. In such a scheme, the social and economic rights associated with citizenship are centered on being an active consumer, making choices in a competitive market place (Bartle 2006: 421). This shift to a market vision allows a market-compatible version of “social citizenship” to be extended to nonnationals. This, however, comes at a cost; Bartle’s conclusions are clearly critical of what he considers to be an impoverished citizenship regime. By designating market-compatible citizenship as “thinner,” Joppke is likewise staking out clear normative ground. He subsequently underscores this, referring to “citizenship light.” Even more explicit is the argument made by Turner (2016: 7) that the net effect of market reforms and migration is the general erosion of social citizenship so that “citizenship” and the “denizen” status of permanent noncitizen residents becomes in effect identical: “Denizenship is becoming more common not because citizenship is becoming more flexible, but because it is becoming weaker.” In taking this position, these authors join other critics of market citizenship, to whose views we now turn.

3.3 Critiques of Market Citizenship and their Limits

It is perhaps no coincidence that the term “market citizenship” has most frequently been used by critics of this new regime. For many of them, indeed, it seems to be intended as irony, bringing with it the strong presumption that the social and political relationships so labeled do not, in the best and truest sense, correspond to “citizenship” at all. In this way, Schild (2000: 276) states: “Because the cultural contents shaping these neo-liberal political subjects are none other than the liberal norms of the marketplace, I refer to such citizens as market citizens.” Under such conditions, she concludes that the weakening of collective bargaining laws and minimum employment standards calls the state’s commitment to economic solidarity into question. Noting the coresponding market turn in social policy, Fudge (2005: 645) notes that “Increasingly, there is an obligation either to work or to engage in training as a condition for obtaining social assistance.” More insidiously, by insisting on treating people as individuals rather than as members of constituted groups, the market approach encourages the belief that people are equal by ignoring relevant differences among them, of which gender is only the most obvious (Schild 2000; Fudge 2001). In this way of thinking, the logic of distribution within society is changed as an expansion of the domain of the market necessarily leads to a contraction of social rights. In particular, the monopoly of both regulatory and redistributive action claimed for the public sector by partisans of the welfare state no longer applies (Fudge 2005: 645): “Government responsibility for the social welfare of its citizens is replaced with a new political and social order in which governments are only responsible for helping citizens to help themselves.” In such a system, citizenship is based on “active participation of clients as consumer in the delivery of services” (Schild 2000: 276).

Underpinning this generalized social critique is a practical point. The state has become, in the provision of social services, one of several partners along with philanthropic and professional organizations and, in some cases, for-profit enterprises. For Root (2007: 43), the participation of for-profit firms amounts to a “major structural change in citizenship.” Bonnet (2019) points out that even reliance on the nonprofit sector brings a loss of public control and the risk of policy capture by self-interested actors. In the Turkish context, Buğra and Adar (2008, 103) point to the increased role of philanthropic actors in social assistance as an erosion of citizenship.

Arguments about the loss of state monopoly in social services, however, rely for their critical force on an implicit historical comparison that is at best misleading. The twentieth-century welfare state in each of its variations was built through the cooperation of the state and private actors. In the American case, Hacker (2002) has detailed the rise of the “private sector welfare state” in the 1950s and 1960s, as major corporations established wide-ranging (albeit not universal) health and pension plans made possible in large part by tax incentives provided by the US federal government. The Bismarkian model, for its part, relied on the active participation of employers and labor unions. Even in France, the ideology of “dirigisme” and the myth of the “strong state” (Smyrl 2018) gave way to the reality of cooperation with the “social partners” along lines inspired by a corporatist, rather than a statist, vision (Merrien 1990). Even in those examples that seemed from the outside to approach most closely the collectivist ideal of state-led solidarity, the state was never alone. Steinmo (2013: 90) emphasizes in the case of Sweden that the policies implemented by social-democratic governments of the 1950s and 1960s were explicitly pro-business, noting that: “The welfare state, in this sense, was intended not to compensate for the market but to help make it more efficient and more competitive.”

This rejoinder with respect to the role of the state is, in fact, one example of a larger problem with much of the critical literature on market citizenship: a tendency, at least implicitly, to compare an untarnished (and never realized) ideal of rights-based democratic citizenship with the tawdry practices of the market. This is as much a logical fallacy as its mirror image, the tendency of liberals such as Friedman and his disciples to blithely assert that the only alternative to their libertarian utopia is the Gulag. In the chapters that follow, we strive to compare like to like. In practice, this means contrasting the reality of Turkish CT programs to the corresponding reality of the policies (or policy vacuum) that they replaced. We seek to avoid the logical trap of comparing the messy reality of policy regimes and their associated instruments with the austere utopias of universal rights, be these of citizens or of migrants. To the extent that we consider broader principles, our purpose is to propose an internal critique of market-enhancing policies and instruments. We question their coherence and ask whether they advance in practice the social ideals that they themselves claim as justification.