1 Introduction

In recent years, NTA has developed into a broad, often vaguely defined concept denoting a variety of arrangements for the accommodation of diversity in settings across the world. Thus, alongside the plethora of different forms of NTA catering for national minorities in contemporary Central and Eastern Europe (CEE) and the Balkans, one can cite those that exist in the Brussels-Capital Region in Belgium and for Francophones living in provinces of Canada other than Quebec. Other well-known contemporary examples apply to indigenous peoples—the Maori in New Zealand and the Sámi populations that live in the Arctic Sápmi region today divided between Norway, Sweden and Finland. Nearly all these arrangements, however, share features derived from the original NTA model devised by the Austrian Social Democrats Karl Renner and Otto Bauer at the start of the twentieth century.

This original incarnation of NTA was closely bound up with questions of national self-determination that arose within the context of the Habsburg and other polyethnic empires of CEE during the second half of the nineteenth and early years of the twentieth century. This period saw the development of substate movements among these empires’ subject peoples exemplifying the three tenets of nationalist discourse outlined by Özkirimli (2017): they defined different groups of the population in national terms, as having a shared cultural, historical and political identity; they sought to create and preserve distinctive boundaries and sovereignty for these national groups; and, finally, in nearly all cases, they asserted a claim to rule over a defined territory deemed to be the national ‘homeland’ of the group in question.

As Social Democrats belonging to the dominant German-speaking political elite of the empire, Renner and Bauer feared that these nationalist movements would undermine the integrity not only of the workers’ movement, but also of a Habsburg state that they wished to preserve within its existing boundaries and reform along democratic, federalist lines. To counter this threat, they sought to ‘[decouple] the politics of “people” and “place”’ (Spitzer & Selle, 2020, p. 1) by framing the nationalities of the empire not as territorial entities, but as ‘communities of persons’ defined by identification with (and commitment to maintaining) a shared cultural identity. Renner and Bauer argued that each such community should be recognised as a distinct political subject with rights to cultural (but not territorial) self-determination within the framework of common belonging to a single federal state. Belonging to a particular national community was deemed to be a matter of personal choice for each individual citizen, regardless of where they lived within the state. National affiliation was to be determined through voluntary enrolment on a separate electoral register for each community, which would elect a cultural self-government responsible for native-language schooling and other cultural matters specific to the community in question (Renner, 2005).

While Renner and Bauer defined nations in ethno-cultural terms, as historically constituted ‘communities of character’ with a common origin and shared political interests, they clearly regarded language as the primary marker of ethnicity (Bauer, 2000, pp. 100–102). This assumption is problematic, in so far as linguistic and ethnic identity do not always coincide in practice (Smith & Hiden, 2012, pp. 59–63). The assumption is nevertheless still widely held by minority actors in CEE, many of whom continue to adhere to the multinational conception of statehood and society advanced by Renner and Bauer over a century ago. In one of the project interviews used for this paper, for instance, a Hungarian–Romanian respondent stated that autonomy should give citizens belonging to a minority the possibility to ‘live the same full life’ as those belonging to the majority. For him, a ‘full life’ implied ‘the ability to use our symbols, and the ability to use my language in administration and governance, and about having the same chance of getting a well-paid job as the other’.Footnote 1 By this understanding, effective equality for minorities means not only freedom from discrimination on ethnic grounds, but also the right to preserve an already established societal culture and ensure its longer-term reproduction (Kymlicka, 2007).

How tenable, though, is Renner and Bauer’s NTA vision? Given the diverse range of minority identities, situations and claims that exist in the world, the definition of and practical possibilities for ‘living a full life’ vary widely. Can one therefore ‘prescribe uniform solutions for diverse needs’ (Purger, 2012, p. 12) in the way that Renner and Bauer did, and can attachment to place ever be fully taken out of the equation? Surveying the field of NTA scholarship back in 2010, Osipov (2010, p. 30) pointed to a preponderance of legal and political philosophical approaches, encouraging a normative ‘focus on what could and should be done rather than on analyzing and describing what, in fact, exists’. A subsequent shift towards studying the actual practice of NTA in different contexts (Prina, 2020) has cast critical light on key assumptions of the original NTA model relating to deterritorialisation, political participation and group identity, themes which I examine here through an exploratory analysis of two cases: the Hungarian autonomy established in Vojvodina under Serbia’s 2009 Law on National Minority Councils and the Sámi NTA arrangements operational in Norway, Sweden and Finland. The paper brings together findings from two research projects: the first, carried out in 2014–2018, investigated the contemporary politics of NTA in six countries of CEE (including Serbia), with a particular focus on semi-structured elite interviews exploring the perspectives and experiences of minority political actorsFootnote 2; the second, from 2021 to 2022, explored current practices relating to protection and promotion of the Scottish Gaelic and Sámi languages, through a series of webinars uniting academics and practitioners from the two settings.Footnote 3 While the two cases I discuss are very different in terms of socio-political context, they nevertheless highlight some more general issues and challenges related to the practical application of NTA. In what follows, I first briefly overview recent scholarly debates on NTA relating to deterritorialisation, participation and identity, before illustrating these further with reference to the two case studies.

From the preceding overview of Renner and Bauer’s thought, it becomes clear that NTA was originally conceived as an instrument of statecraft driven by a securitised understanding of ethnic diversity. In other words, it was posited as a catch-all alternative to territorially based claims for national self-determination that were deemed to threaten the integrity of existing states. A similar approach was apparent in the initial revived discussions of NTA in CEE during the 1990s, following the collapse of communism and the demise of Yugoslavia and the USSR. At this time, NTA was often understood as a kind of ‘“magic bullet” in the armoury of those seeking to cope with problems of ethnic diversity and conflict’ (Coakley, 2016, p. 166). Similarly, Roshwald (2007, p. 373) observes that NTA was ‘presented as situated at the golden midpoint between Balkanization and banalization … [offering] … minorities the option of substantive cultural self-determination without linking it to territorial autonomy, with all the centrifugal tendencies the latter may awaken’.

Other authors, however, have questioned whether it is possible or desirable to ‘deterritorialise’ minority identities completely, arguing for a need to shift the paradigm away from state security towards a focus on justice and optimal arrangements for minority empowerment in particular contexts (Bauböck, 2001; Kymlicka, 2007). Even if minority claims do not follow the Westphalian logic of seceding to create a sovereign state ‘of one’s own’, it is doubtful whether the politics of people and place can be decoupled by limiting self-determination to functional control over language and culture as opposed to land and resources. This is especially so in the case of linguistic minorities that live compactly, for here, ‘living a full life’ would imply the possibility to use the language in communications with state authorities and other routine everyday interactions. Moreover, one might ask whether ethnic demography should be the determinant factor when deciding on optimal arrangements for minorities. For, even where a given community has become numerically small and dispersed in terms of settlement, the distinct ‘way of life’ that it aspires to protect is invariably rooted in connections to a specific place (MacKinnon, 2021).

While Roshwald (2007, p. 373) speaks of NTA as offering the possibility for ‘substantive cultural self-determination’, reference to this concept is today lacking from key international documents on minority protection such as the Framework Convention on National Minorities and the various recommendations and guidelines issued by the Office of the OSCE High Commissioner on National Minorities. In so far as autonomy is mentioned in these documents, it is typically referred to as ‘self-governance’ and is bracketed under the heading of ensuring effective minority participation in public life. The key yardstick for assessing the functionality of NTA has thus become the extent to which different arrangements give minorities a meaningful voice in decision-making on matters relevant to preservation and longer-term reproduction of their identity (Malloy et al., 2015). Linked to this are issues of legal entrenchment and status, competences and—not least—access to funding and other resources (Salat, 2015). Also crucial is the extent to which an NTA arrangement accommodates the range of different voices typically found within minorities’ communities (Marsal, 2020), which brings into focus the relationship between autonomy and collective identity. Central to any form of NTA (including the two considered here) is the question of what criteria should serve to define identity and belonging within the community that constitutes the legal subject of autonomy—and, by extension, who decides on the criteria. While Renner and Bauer’s NTA model made ethnic identity a matter of individual choice and group membership a matter of voluntary adhesion to a register, critics frequently contend that this approach rests on an essentialised ‘groupist’ logic (Nootens, 2005, pp. 56–57; Osipov, 2010). The necessity to opt for one ethnic identity, they argue, is ill-suited to the complex realities of a social world in which individuals frequently have mixed ethnic backgrounds and multiple cultural affiliations. Whatever view one takes on this issue, ethnic identities are never fixed or monolithic, and the political communities constituted through NTA are therefore always internally heterogeneous. If this intragroup pluralism is not properly accommodated and NTA institutions become monopolised by one section of the community to the exclusion of others, the representativeness and legitimacy of the institutions—and the willingness of individuals to participate in them through elections and other channels—will suffer accordingly (Salat, 2015; Smith & Hiden, 2012). In the remainder of this paper, I analyse how these issues surrounding deterritorialisation, participation and identity manifest themselves in the cases of Vojvodina Hungarian and Sámi NTA.

2 Hungarian NTA in Vojvodina

Numbering just over 250,000 according to 2011 census data, Serbia’s Hungarian minority is concentrated in the Vojvodina region that was detached from Hungary in 1920. Highly politically mobilised and well organised, the minority has received strong support from neighbouring Hungary. These factors, coupled with the legacies of institutionalised ethnicity inherited from the Yugoslav system, would appear to offer good preconditions for preserving Hungarian minority identity. The Vojvodina region, however, has always had a distinct, strongly multicultural identity within Serbia, with traditionally high levels of inter-ethnic marriage increasing prospects for longer-term acculturation and assimilation (Smits, 2010). Hungarian minority parties were instrumental in pushing through Serbia’s 2009 law on elected national minority councils, which follows the precepts of the NTA model. At first sight, therefore, this appears to be an instance where a minority community that is comparatively large and relatively compact in terms of settlement has embraced non-territorial over territorial autonomy.

This impression is, however, misleading, since the proposals initially tabled by Hungarian minority representatives at the start of the 1990s in fact envisaged a three-tier system of autonomy: territorial for Hungarian-majority districts in northern Vojvodina alongside non-territorial for Hungarians living in more dispersed fashion elsewhere, with this arrangement nested within regional autonomy for the multiethnic province of Vojvodina as a whole.Footnote 4 In the event, the proposal for a Hungarian autonomous area was never adopted, meaning that only two of the initial demands have been realised in practice. Yet, NTA alongside regional autonomy has represented an acceptable political compromise in so far as it has gone hand in hand with a framework of territorial decentralisation in Serbia, which provides for the official use of minority languages alongside Serbian in municipalities where the relevant minority constitutes more than 15% of the local population. Thus, we see a combination of territorial and non-territorial arrangements which—at least on paper—has been well suited to the practical requirements of the Hungarian minority, though perhaps less so to that of smaller, less politically mobilised groups.Footnote 5

Among contemporary NTA arrangements established in CEE and the Western Balkans since the early 1990s, Serbia’s system of national minority councils is often hailed as one of the most substantive in terms of actual practice (Korhecz, 2014; Malloy et al. 2015; Petsinis, 2012). The original 2009 law indeed introduced far-reaching provisions, under which the Hungarian Minority National Council (HNMC, first elected in 2010) not only had to be consulted by state and local authorities on all matters relevant to the minority but was also entitled to claim cofounding rights in relation to minority schools and other institutions. If the establishment of the HNMC initially brought a ‘new quality of life’ to the Hungarian minority (Korhecz, 2014, p. 162), the 2009 law was soon contested by more nationalistically minded elements among the Serbian majority, resulting in a 2014 Constitutional Court ruling that significantly diluted the competencies of national minority councils. This had significant implications, with one member of the second HNMC (2014–2018) noting that its opinion was no longer decisive if, for instance, a local authority decided to change an historic street name within an area where Hungarians live. The HNMC, he suggested, ‘lost its essence’ when it ceased to have any meaningful role in decision-making and was downgraded to little more than an advocacy body, since minorities cannot rely on goodwill from the side of municipal authorities. In the sphere of language use, the same respondent noted that even where the law provides for use of Hungarian alongside Serbian in local administration, public organisations often do not employ any Hungarian speakers. This is one factor that has fuelled calls for the introduction of policies of proportional representation in public sector employment.Footnote 6

Proportionality within this sector obviously requires that the people employed are fully conversant in Serbian as well as their mother tongue, a consideration that brings into focus the quality of Serbian language tuition within schools that teach primarily in Hungarian. Here, a member of the second HNMC highlighted the fact that Serbian is taught as a native rather than a second language—i.e. there are no separate materials or pedagogical approach specifically tailored to the needs of school learners from minority-language communities. As outlined further below, this language barrier has had significant implications, with the HNMC often struggling to persuade ethnically mixed Serbian–Hungarian families to enrol their children in Hungarian language schools. The HNMC has lobbied (thus far unsuccessfully) for reform, drawing attention to the inadequacies of a system that leaves students in Hungarian language schools better practically equipped to speak English than they are the majority state language.Footnote 7 In practical terms, HNMC’s main contribution has been to fund additional classes in Serbian (often immediately before graduation) for students in Hungarian language secondary schools, in an attempt to equip them better for study in Serbian universities and for the demands of the national job market. For many of our respondents from the HNMC, the Serbian state’s rhetoric of ‘integrative multiculturalism’ was therefore not matched in practice. A further key issue here relates to the limited funding made available to the HNMC by the authorities, where it was noted that the annual sums received from the state budget were barely sufficient to cover administrative running costs.Footnote 8 In this respect, the Hungarian minority has relied heavily on financial support from its external kin state, with one respondent noting that around seven-eighths of the funding allocated to Hungarian language schools is provided by Hungary itself.Footnote 9

This external kin state support has enabled the HNMC to perform valuable work towards the promotion of minority education and culture. Nevertheless, these efforts have been undermined by the difficult socio-economic situation within Serbia more generally. One theme to which respondents alluded constantly was the long-term existential threat to the minority posed by emigration and demographic decline, with one HNMC member noting that ‘lots of people go abroad and try to find their happiness there, either alone or with their whole family. This obviously influences the number of children, students and schools. … From year to year, the number of students decreases by hundreds in our secondary schools and universities. And we know what it means; if the number of students decreases, then the teacher’s work decreases as well, which slowly leads to the teacher being unemployed, which again leads to more people going abroad. We are already in this process, unfortunately’.Footnote 10 Another similarly observed that ‘the biggest challenge is to keep the youngsters here somehow. … They think whatever is here is bad and everything that is beyond the border is good and they just want to leave and continue their lives there’.Footnote 11

The existence of the HNMC has allowed Hungarian elites to address this problem, by channelling funds in a way that encourages young people to commit their futures to Serbia rather than leaving for study or work in neighbouring Hungary or elsewhere. In addition to Serbian language classes for secondary school students, the HNMC has established a variety of scholarships and other forms of support (e.g. the Vackor programme) for students to study in Hungarian schools, on the condition that they undertake higher education in Serbia itself. Those who complete primary and secondary school in Hungarian and university in Serbian, it is reasoned, will possess an excellent knowledge of both languages and will therefore be more likely to remain in Serbia once they have completed their education. By contrast, those Hungarian minority students who travel the short distance across the border to study at Szeged University in Hungary ‘still cannot say three sentences in Serbian’ following graduation, according to one respondent, and are accordingly disadvantaged within Serbia’s labour market.Footnote 12

For all this, the functions of the HNMC remain limited to issues of language, culture and education. Members of the local Hungarian minority, our respondents suggested, did not always understand this, and turned to the Council with ‘problems of migration and unemployment’ it is not authorised (or indeed practically able) to address.Footnote 13 In the words of one respondent, ‘some think that the National Council can influence everything—economy, agriculture, industry. But we are only authorised to make changes in education, culture, official usage of language and public information’.Footnote 14 In this respect, the Hungarian minority’s close relationship to the kin state can be seen as a double-edged sword: on the one hand, Hungary has made considerable economic investment in the local area in an attempt to curb emigration, including establishing the Európa Kollégium dormitory for Hungarians studying at the University of Novi Sad. On the other hand, the mass passportisation of local Hungarians which Viktor Orbán’s government initiated in 2010 has given local people an additional means and incentive to emigrate. As noted by the same respondent, ‘sadly many don’t choose to use [local scholarships] but to go to Hungary—with Hungarian citizenship—where they receive free education as well. Hungary has a much better system of dormitories than here. It is very competitive and difficult to keep the students here’.Footnote 15 A member of the first HNMC, meanwhile, called the extension of Hungarian citizenship:

catastrophic, because we are becoming empty. … We really appreciate that we are welcomed as Hungarian citizens since our ancestors appeared to have been locked out of their own country; … but, in practice, since 2008, there has been a decreasing standard of living. People put up with this for a while, but they can’t any longer. Thousands of young Hungarians are leaving as there is a huge existential uncertainty; this is the easier way, as working in the EU becomes an option for them. And I don’t think it will change. … I don’t know how we could stop it or reverse it, … as who has the right to put the Hungarians over the border into ghettos? … We simply have to face the fact that the law is de facto and objective, carrying the death sentence of the Hungarian community here.Footnote 16

A member of the second HNMC concurred with this view, noting that when he had finished secondary school in 2003, 24 out of 28 students had gone on to university and all had continued their studies in Serbia: ‘It never even occurred to us to study abroad. Now out of 16 students, 14 are going to Hungary to continue their studies’.Footnote 17 While this exodus was partly attributed to a lack of adequate Serbian language knowledge among students, respondents also alluded to a sense that Hungarian university degrees were of higher value, since they can be used anywhere in the European Union. Local students thus do not travel to Hungary to study because they want to stay there but use the kin state purely as a launch pad for a career in another EU country. It was claimed that many later regretted this decision, as they fail to find employment abroad that is commensurate with their qualifications. By this point, however, it is often too late to find a good job back in Serbia.Footnote 18

Critics of Hungary’s post-2010 kin state policies whom we interviewed further contended that passportisation of Hungarian minorities abroad (which includes the entitlement to vote in parliamentary elections in Hungary) has been done with an eye to the domestic political interests of Hungary’s ruling Fidesz Party rather than to those of Hungarian minorities themselves. According to several respondents, financial support for the HNMC had been used to build a clientelist relationship between Fidesz and the largest Hungarian minority party in Serbia, VMSZ (Vajdasági Magyar Szövetség/The Alliance of Vojvodina Hungarians). One noted that whereas under Serbian law political parties cannot be financed from abroad, this restriction does not apply to HNMC as a non-governmental organisation. He alleged that VMSZ and its sympathisers (having held the overwhelming majority of seats in the HNMC since 2014) had used cultural and educational funding to promote the particular interests of the party, without regard to wider views and concerns within the community itself.Footnote 19 Others alluded to a diminution of internal democracy within the HNMC from 2014, with the executive committee assuming an increasing share of decision-making power at the expense of different functional committees.Footnote 20 The incumbent VMSZ President of HNC stood accused of ‘ruling from above and directing from above’, shutting down debate and ostracising opposition voices within the organisation.Footnote 21

Criticising this turn in governance after 2014, a member of the 2010–2014 HNMC asserted that ‘in minority society, one must be open for all interests and layers of society and all needs to communicate and aim for consensus within the given possibilities’.Footnote 22 Closing down space for internal pluralism within the HNMC runs the obvious risk of undermining its legitimacy and standing as a representative organ among the community whose interests it is supposed to protect and promote. In this respect, it was noted that levels of participation in elections to the HNC were already low, with 130,000–140,000 citizens having signed up on the Hungarian electoral register but only 50,000 having voted.Footnote 23 In instrumentalising Hungarian minorities for its own domestic political purposes, the Fidesz regime in Hungary has frequently cast them as members of a single, undifferentiated ethnic Hungarian nation that extends across borders. This essentialised framing disregards the local particularities of Hungarian minority identity, which one respondent encapsulated in terms of a desire to ‘keep my Hungarian ethnicity here, where I live. I am a Hungarian who lives in Vojvodina, which is a special kind of animal as we live in a very multicultural community. I am very proud of and am holding on to being Hungarian in this multicultural community’.Footnote 24 By treating the Hungarian minority as a diasporic extension of the Hungarian state and its policy agenda, Hungary completely disregards questions pertaining to the minority’s capacity for agency and actorness on its own behalf.

Some interview respondents alluded to this problematic situation, arguing in effect that kin state engagement should more properly function as a complement to (rather than substitute for) a better functioning framework of multiculturalism within Serbia itself. Here it was noted that it was wrong for the Hungarian state to have the primary role in supporting the HNC and its activities, when this responsibility should fall primarily to Serbia itself.Footnote 25 According to a representative of the opposition Democratic Party of Vojvodina Hungarians, for instance, it was not appropriate that the terms of reference concerning language rights should be assigned to national minority councils, when this was in fact the duty of the state under the relevant international documents which Serbia has signed.Footnote 26 In the meantime, the shortcomings of the current system lend further weight to arguments by Serbian critics of the NTA system such as Goran Bašić, who argues for fully ‘integrative bilingual education’ for minorities (Bašić, 2018). This suggestion was, however, rejected by our respondents, who saw it as a stepping stone to longer-term assimilation.Footnote 27 Referring to the perceived current deficiencies of the NTA model more broadly, an opposition representative within the second HNMC restated the case for a form of Hungarian territorial autonomy in northern Vojvodina, arguing that functional competencies related to ‘culture, education, official use of language and the public information are not enough. The whole thing must have an economic and thus a territorial element to it as well, which makes people stay, do business, farm and make decisions based on a faith in their own micro-communities’.Footnote 28

3 Sámi NTA in the Arctic Region

In the case of Vojvodina, we see NTA applied to an ethnic Hungarian population in a territory detached from the Hungarian national state and attached to a neighbouring one. Sámi NTA, by contrast, applies to an indigenous people whose minority status derives from settler colonialism within its historic area of settlement, known as Sápmi and extending from the northern parts of present-day Norway to the Kola Peninsula in Russia. As part of processes of modern nation-state formation within the region during the nineteenth and twentieth centuries, Sámi populations were historically subject to racist discourses and practices of forcible assimilation, later mitigated (but not reversed) by the development of comprehensive welfare states that drew Sámi more closely into the ‘mainstream’ society of Norway, Sweden and Finland (Spitzer & Selle, 2020, p. 12). Those identifying as Sámi across the three Nordic nation states are today small in number and territorially dispersed. Most now live outside Sápmi, with an increasing concentration in the larger cities of the south. The different varieties of the Sámi language are all severely endangered. From the 1970s onwards, however, a discourse of Sámi self-determination gained purchase, as minority activists began to ‘[demand] not mere integration but accommodation as a distinct, rights-bearing Indigenous nation’ (Spitzer & Selle, 2020, p. 13). In all three Nordic states containing Sámi populations, these claims for accommodation have since been met through structures of NTA.

In the academic literature, Sámi NTA is frequently held up as an example of good practice, being categorised by Malloy et al., (2015) as a system of ‘voice through self-governing institutions’ and—in the same edited volume—described as ‘one of the most prominent models for addressing indigenous rights questions’ (Salat, 2015; Stępień et al., 2015, p. 117). The title of ‘Parliament’ often ascribed to elected Sámi NTAs is, however, something of a misnomer, since these bodies have no legislative authority and function primarily as consultative bodies rather than organs of self-government as such (Stępień et al., 2015, pp. 121–124). This is especially so in Sweden, where the Sámediggi simultaneously functions as a national administrative authority—so, basically as an arm of the Swedish state government (Lawrence & Mörkenstam, 2016). It is only in Norway and Sweden, moreover, that rights to personal autonomy for Sámi extend to the whole of the state territory—in Finland, the right to vote in Sámediggi elections is limited to four municipalities in the northern Sámi Domicile Area.

The claims in the literature and the external image held by these arrangements, moreover, prompt deeper reflection on the nature of the Sámi ‘voice’ articulated through the parliament, as well as on the essence of indigenous peoples’ rights questions more broadly. In the case of indigenous peoples as traditionally defined, the territorial aspect can hardly be ‘decoupled’ from claims to self-determination, given that such claims have typically focused on claiming control not just over the ‘lives’ of the community but also over the lands and resources through which it has historically secured its means of subsistence (Stępień et al., 2015, p. 120). The Sámi offer a clear case in point, given their identification with a pre-existing territory (Sápmi) and the fact that the political mobilisation of the post-war decades was largely inspired and underpinned by conflicts over land use. Use of land, moreover, remains central to Sámi politics, as witnessed by the ongoing fallout in Sweden from the 2020 Supreme Court ruling giving the Girjas Reindeer Herding Community the right to control hunting and fishing on what it considers to be its ancestral lands (Orange, 2020; Ruin, 2021). A further contemporary example in Sweden can be seen in opposition to the planned establishment of an iron ore mine on Sámi ancestral lands in Gállok, which was given approval by the Swedish government in December 2021 (Boffey, 2022). As Spitzer and Selle (2020) also observe in a recent article, Sámi self-government in Norway has recently begun to expand beyond NTA to encompass more and more elements of territorial authority, a move which reflects the perceived inadequacies of the NTA model.

The aforementioned developments would seem to confirm the view expressed by authors such as Kymlicka (2007, p. 390), who claims that, from the point of view of state authorities, NTA has often been conceived not so much as an optimal model of accommodation for indigenous peoples, but rather as a convenient way of ‘sidestepping’ far more politically contentious disputes over ownership and use of land. In this regard—precisely as Renner and Bauer intended back at the start of the twentieth century—NTA has the potential to limit the discussion to issues such as language protection and promotion, without deeper reflection on how identity and way of life might be linked to place. The competencies and funding devolved to Sámi NTAs have indeed enabled them to undertake and support important educational and cultural initiatives geared to the younger generation of Sámi, while helping older speakers to reclaim an ethnolinguistic identity previously lost to them through forcible assimilation. As in the case of Serbia, this support through NTA has been supplemented by measures of territorial decentralisation that allow for Sámi language provision within designated administrative areas or municipalities. In only two districts of northern Norway, however, do Sámi speakers constitute a majority of the local population. Limitations of this system remain apparent, with Sámi language activists who participated in project webinars alluding to insufficient state funding. Although Sámi language support has helped to instil a new pride in identity and dispel previous ‘feelings of hopelessness’, the small number of speakers means that these measures might amount to little more than ‘palliative care’ for languages that remain severely endangered.Footnote 29 Thus, echoing recent debates in Scotland, it would seem more appropriate to talk about symbolic promotion of Sámi languages rather than measures to ensure their protection as a means of everyday communication (Ó Giollagáin & Caimbeul, 2021).

As already observed, the Sápmi case mirrors that of Vojvodina, given that in neither context has it proved possible to ‘decouple the politics of people and of place’ entirely. In the case of the Sámi, however, Spitzer and Selle (2020, p. 22) come back to ethnic demography as a central factor limiting the scope for further territorialisation of self-governance, given the increasingly dispersed and urbanised character of the referent population group. Among other things, the fact of demographic dispersal raises important questions around how Sámi identity should be defined and who speaks for ‘authentic’ Sámi interests. Until now, the work of Sámi NTAs and influential NGOs has focused primarily on preserving core Sámi livelihoods (most notably reindeer herding) which are intrinsically linked to place; such a focus, however, has only limited relevance to the interests and concerns of those Sámi (the majority) who live outside Sápmi, often in big cities, and who may have reconnected with their Sámi heritage only later in life. This inevitably feeds growing contention with Sámi NTA bodies, with those speaking for traditional livelihoods finding themselves challenged politically, not only by the majority within the respective nation states where they live (over issues such as hunting rights and access to mineral resources) but also by other elements within their own community which perceive them as representatives of a traditional ‘elite’ that disregards other voices within the wider community. Here one clearly sees the dilemma (intrinsic to all forms of NTA) of how to delimit the ethnopolitical group that forms the basis for autonomy and ensure that all elements of it are adequately represented within structures of self-governance (Stępień et al., 2015, pp. 135–136).

4 Conclusions

This exploratory paper has analysed two contemporary cases which, while they in many ways differ completely in terms of context, both cast doubt on understanding of NTA as a modality that can ‘decouple the politics of people from the politics of place’. The paper argued that NTA was originally conceived from the top-down as an instrument of statecraft, reflecting a securitised view of diversity that casts national minorities and their self-determination claims as an ‘anomaly’ (Nancheva, 2016) and a threat to existing sovereign states. It can thus be understood as an attempt to deterritorialise (and depoliticise) such claims by confining them to functional autonomy in matters of language and culture. This understanding has persisted into the contemporary post-Cold-War era, when notions of collective rights for minorities have slipped down the international agenda and ‘autonomy’ has come to be discussed not under the rubric of national self-determination but rather under that of effective participation by persons belonging to minorities (Csergő & Regelmann, 2017).

In discussing the practice of NTA in the two cases, the paper sought to show how they illustrate the inherent difficulties of deterritorialisation, while also highlighting some problematic issues and essentialist assumptions relating to participation and identity. In the case of Hungarians in Serbia, the arrangements put in place since 2009 have indeed forestalled (until now) initial claims for an autonomous Hungarian region. However, Hungarian NTA has arguably proved workable only because it complements a system of territorial decentralisation (language thresholds in areas where minorities make up a sizeable share of the local population) which caters for the needs of those Hungarian speakers who live compactly. This whole arrangement, moreover, is nested in provincial autonomy given to Vojvodina, a region with a historically multicultural identity. It would therefore seem more appropriate to talk of a combination of territorial and non-territorial elements.

Does this, though, equate to genuine autonomy or self-governance that meets the needs of the minority concerned? The respondents from Vojvodina who were interviewed for this paper were preoccupied above all with the growing emigration of Hungarians from the region, largely for economic reasons. This is a problem that functional autonomy in the spheres of language and culture alone cannot address, bringing into focus the importance of control over local socio-economic development for the protection and longer-term development of a minority societal culture. In this regard, the extensive support provided to Vojvodina Hungarians by their neighbouring kin state (a factor usually seen as highly beneficial for identity protection) has in fact been a double-edged sword, since the blanket extension of extraterritorial Hungarian citizenship by Viktor Orbán’s regime has only served to give further impetus to out-migration. This is symptomatic of a kin state policy which has increasingly been conducted with an eye to the domestic political interests of the incumbent Hungarian government rather than to the context-specific identities, needs and claims of Hungarian communities abroad. The increasing financial dependency of these communities on Budapest (see Udrea in this volume) has done little to boost their agency and scope for effective participation within their home states, while also shutting down internal pluralism in a way that denudes the legitimacy of the HNMC. One obvious conclusion that emerges from this is that state and regional authorities in Serbia would do well to give more practical substance to their declared policy of fostering integrative multiculturalism, through a more holistic approach that would include greater attention to the socio-economic development of the regions where Hungarians live compactly. Without this, claims for greater minority agency will most likely be expressed through continued calls for a territorially based form of regional autonomy, giving greater control over economic resources.

It is harder still to take territory out of the equation when it comes to Sámi autonomy, given that this relates to an indigenous people. Even though the Sámi are today small in number and live dispersed both within and beyond their ancestral Sápmi homeland, their claims have continued to be bound up with rights to land. NTA has brought at least some tangible benefits regarding the promotion of Sámi language and culture, though in this case too it is hard to talk of genuine self-governance. Until now, moreover, issues of language and culture (the core focus of any NTA arrangement) have also been inextricably linked to land use as the basis for a traditional way of life centred on reindeer herding. This understanding of Sámi identity has become increasingly contested within the context of territorial dispersion. Nevertheless, if existing communities of first-language speakers disappear within historic areas of Sámi settlement, it is hard to see any continued role for Sámi as a societal language, as opposed to one that receives only symbolic recognition. In this respect, our recent project uncovered interesting overlaps with the debate over the future of Gaelic in Scotland, where, in the context of a shrinking ‘vernacular’ community of first-language speakers, critics contend that current policies amount to language promotion but not to the actual protection of Gaelic as a societal language rooted in a traditional way of life. They thus call for these (territorially rooted) vernacular communities to be given a greater say in their own cultural affairs via a set of new arrangements—an ‘ethno-linguistic assembly’ for the territories where Gaelic is still widely spoken (Ó Giollagáin et al., 2020). If adopted, this would amount to a further example of NTA, though one that would be dedicated to preserving the link between people and place rather than decoupling it.