The Three Levels of Citizenship in the European Union

Abstract

Against the tendency to compare EU citizenship with national state citizenship, the article argues that European Union citizenship represents a hybrid type, as it is derivative of Member State nationality. After pointing out the tensions caused by this derivative character with respect to mobility rights, the article considers the limits of some strategies of dealing with such difficulties. Finally the article argues that realistic solutions should start from accepting a potentially coherent and normatively attractive constellation of three interconnected membership regimes: A birthright-based one at the Member State level, a residential one at the local level, and a derivative regime with residence-based rights at the supranational level, which would lead to a few modest reforms.