Naturalization policies, citizenship regimes, and the regulation of belonging in anxious societies

National citizenship is a core mode of social membership and belonging in ‘modern’ societies. In democratic societies, citizenship carries an aspiration to inclusion – so, citizens have a claim to equal social rights and membership. However, the institutions that are responsible for granting access to citizenship are falling well short of this vision. This gap is especially evident for migrants who want to become citizens or want to claim a long-term residence permit but find that the legal or financial barriers are too high. Citizenship has always operated to exclude some people just as much as it includes others, and indeed is argued by some to be inherently exclusionary, a story of complacency, hypocrisy, and domination, flattering to citizens and demeaning for noncitizens (Kochenov, 2019). With regard to the citizenship of migrants (especially those who naturalise), we see that inclusion and exclusion are the simultaneous experiences of the same


Introduction
National citizenship is a core mode of social membership and belonging in 'modern' societies. In democratic societies, citizenship carries an aspiration to inclusion -so, citizens have a claim to equal social rights and membership. However, the institutions that are responsible for granting access to citizenship are falling well short of this vision. This gap is especially evident for migrants who want to become citizens or want to claim a long-term residence permit but find that the legal or financial barriers are too high. Citizenship has always operated to exclude some people just as much as it includes others, and indeed is argued by some to be inherently exclusionary, a story of complacency, hypocrisy, and domination, flattering to citizens and demeaning for noncitizens (Kochenov, 2019). With regard to the citizenship of migrants (especially those who naturalise), we see that inclusion and exclusion are the simultaneous experiences of the same people. Recent innovations in policies on access to citizenship across a wide range of countries contribute to a troubling observation: getting access to legal citizenship has become increasingly difficult, in particular for the most vulnerable groups of migrants, and gaining citizenship in the legal sense sometimes does not make one a citizen in a comprehensive substantive sense.
In this Special Issue, we aim to address these transformations from a sociological perspective, to respond to two questions. 1 Through these questions, we aim to contribute to the literature on critical citizenship as well as to the emerging literature on the 'lived experience' of citizenship.
• How do we make sense of the changes in policies on access to citizenship in the last 20 years? • How do these changes affect migrants who claim access to citizenship?
The past 20 years have been characterised by a series of 'turns', of which we identify three here that have specific relevance for North America and Europe. First, citizenship requirements have been increasingly 'culturalised' as a means of protection for the 'host' country. Migrants are required to undergo lengthy procedures and pass exams to naturalise and these new requirements have been analysed as a new paradigm in immigration and integration policies (Goodman, 2014;Joppke, 2007;Ryan, 2008;Vink and de Groot, 2010). They crystallize a perceived failure of multiculturalism (Modood, 2012) and show a move towards a more assimilationist model whereby the 'culturalisation of citizenship ' (Tonkens et al., 2010) implies that access to citizenship should be based on cultural dimensions such as language or the knowledge of 'values'. Even once the hurdles for naturalisation are cleared, successful applicants may still not achieve emotional and symbolic recognition as co-citizens (Duyvendak et al., 2016). Thus 'full citizenship' is denied, particularly to racialized Others. This denial is part of the structural racism affecting racialized citizens as well as migrants that is an ongoing legacy of colonialism in many European contexts explored in this special issue and in which, it is argued, immigration law and policy have always played an active role (El-Enany, 2020). In this special issue we explore how the increasing difficulties/barriers in terms of access to citizenship and/or long-term residence status are justified in political discourses and implemented in practice, in the European as well as in the North American contexts.
Second, neoliberal citizenship policy expresses market logic through developments such as increased citizenship by investment or the 'skilling' of citizenship and immigration policy (Fortier, forthcoming;Millar, 2014) through use of points-based systems to judge competencies and human capital suited to the demands of the knowledge-based economy and communitarian social cohesion. Neoliberal citizenship and naturalisation policy require values of responsibility, self-improvement and productivity from migrants, to be achieved through naturalisation processes that devolve responsibility onto the individual who must seek private, marketised services (Suvarierol and Kirk, 2015). These developments are

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Ethnicities 21(2) theorised diversely: as vehicles of neoliberal governmentality (L€ owenheim and Gazit, 2009;Turner, 2014) or as an 'instrumental turn' for which the 'Roman' tradition of legal citizenship serves as the best foil to understand current citizenship developments (Joppke, 2019). Third, at the same time, citizenship policy is increasingly securitised following on from the so-called war on terror through strategies such as 'Countering Violent Extremism' in the UK. Securitisation can take the form of an increased focus on citizenship and border making to stem mobility and re-establish specific social orders (Bigo, 2002). Citizenship, through community cohesion and subsequently through integration, has often been deployed as a defence against extremism. Policies include a focus on language competencies (and demonstrate, for example, conflation involving Muslims, language and security to argue that a lack of English among Muslim migrants in the UK had led tosense of separatenesswhich could also make them susceptible to 'Radical Islam'; Khan, 2020), good character (Kapoor and Narkowicz, 2019), and adherence to national values tested through naturalisation policies. Extradition and increasing deprivation of citizenship (as in the case of British woman Shamima Begum who went to Syria) (Kapoor, 2018), are the continuation of this securitising logic, but applied to those who hold formal citizenship. These developments demonstrate the malleability of citizenship to socio-political circumstances rather than its 'full' protection as a legal status.
These developments contain distinctive priorities and rationales. For example, while the first and third processes are often related to the general idea of a 'failure' of multiculturalism and a push towards stricter border controls in the context of increasingly divisive politics, the second process is more closely linked with broader tendencies towards economic rationalisation across contemporary societies. Also, it should be noted that, in contrast with the two other processes, policy changes that relate to the securitization of citizenship have been largely guided by concerns about international security which go beyond national models of integration (Huysmans, 2000). Finally, as the papers in this Special Issue highlight, the three turns that we identify take distinct forms in different national contexts. In fact, as Meer et al. (2015) and Borevi et al. (2017) highlight, the civic turn that can be observed in Europe is built on different political traditions and can incorporate multiculturalism in some countries. At a more general level, the three 'turns' all point toward a broader intensification of citizenship as a technology of governance in the last decades (Tyler and Marciniak, 2013: 144). The driving logic of the culturalization, neoliberalisation and securitisation of citizenship permits more onerous and difficult requirements as well as stronger border-making processes. Overall, they lead to the further entrenchment of citizenship as a 'privilege' that is granted on the basis of increasingly selective processes. In this respect, as the papers in this Special Issue highlight, the three turns that we identify should be read as being related to both inclusion and exclusion processes These policy changes are based on a discourse that aims to favour the inclusion and participation of some migrants -according to hierarchies of race, gender and class that shape the policies of receiving societies -while making the life of others more difficult. Long-standing debates over whether citizenship is a tool of inclusion and even emancipation, or of inequality and exclusion (see for example Anderson and Hughes, 2015) are thus reinvigorated on new terms and, as we now explore, make competing and challenging demands on migrants experiencing these policies.
Although the changes in terms of the nature and content of naturalisation policies have been well analysed in the last decades, the question of how these policies concretely affect migrants' lives in their country of residence remains underexplored. As a matter of fact, few empirical studies have focused on how the introduction of measures such as the citizenship test and the citizenship ceremonies has been experienced by migrants who now have to face a longer, more difficult, more expensive and uncertain process to become citizens in the country in which they live. One of the aims of this special issue is to contribute to the literature about the lived experience of the naturalisation process and -more generally -an approach that aims to analyse 'citizenship from below' (Aptekar, 2015;Bassel et al., 2018;Leitner and Ehrkamp, 2006;Miller-Idriss, 2006;Monforte et al., 2019). The review of this literature leads to underline three main ideas, which we develop throughout the special issue.
First, studies exploring the citizenship tests and ceremonies through empirical data about the experience of migrants show the exclusionary and discriminatory effects of these policy instruments. In his reflexion on naturalisation policies in France, Sayad (1993) has analysed the citizenship process as a ritual that leads to reinforce distinctions between 'natural' citizens and new ('naturalised') citizens as it symbolically reifies the idea that newcomers have to 'earn' their citizenship and more generally their right to live in their country of residence. This approach leads to focus on the inequalities and exclusions produced by naturalisation policies.
From this perspective, it is clear that the new criteria used for granting citizenship -i.e. the citizenship tests and the citizenship ceremonies -create and reinforce boundaries and concretely limit immigrants' access to citizenship by making it more complex, uncertain and expensive (Byrne, 2014;Morrice, 2017b). Moreover, studies show that these policies exclude certain groups of immigrants disproportionately. In particular, they exclude migrants who have a low socioeconomic background (Blackledge, 2006;Cooke, 2009), who have a temporary residence status (Guildet al., 2009), who come from poor countries (Ryan, 2008), and whose native language is different from that of their country of residence (Khan, 2019), with significant differences when these challenges intersect with gender (Morrice, 2017a(Morrice, , 2017b. These groups are disproportionally affected by the rising costs and the increasing difficulties of the naturalisation process, in particular in the context of neo-liberalisation and cuts to services providing support (courses on language and culture and guidance in terms of the administrative procedure) to migrants (Suvarierol and Kirk, 2015). Thus, depending on their cultural and social background, migrants can experience this process as oppressive (Cooke, 2009;Scheffer, 2011) or irrelevant (Hagelund and Reeg˚ard, 2011). Moreover, as shown by Mazouz (2012), the citizenship tests and ceremonies can create or reinforce feelings of exclusion among immigrants that are stigmatised

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Ethnicities 21 (2) because of their race or religion. Finally, for many, the tests and the ceremonies can be a very disappointing experience because it is not experienced as a rewarding encounter (Harding, 2012). This shows how the inclusionary/exclusionary dynamic of citizenship (Tyler and Marciniak, 2013) is one of the guiding principles of the changes that have been made to naturalisation policies in the last decades: although some groups of migrants will experience the citizenship process merely as an administrative formality, others -more vulnerable groups -will be strongly affected by it. Second, the empirical focus on how migrants experience current naturalisation policies shows their divisive effects. Policy instruments such as the citizenship tests and ceremonies are based on principles of deservingness: to gain access to citizenship, migrants must prove that they deserve it on the basis of criteria that are established by public authorities (Kostakopoulou, 2010). Therefore, they are often led to strategically endorse and reproduce discourses that fit with what is expected by state representatives (Menj ıvar and Lakhani, 2016;Monforte et al., 2019). As shown by Fassin and Mazouz (2007) and Mazouz (2012) in the French context, this leads to think citizenship as a 'favour' -rather than a right -that the state grants to migrants depending on the demonstration of their good-will and attachment to what are perceived as the dominant cultural norms. Similarly, Byrne (2014) and Fortier (2013Fortier ( , 2017 show that migrants are led to present themselves as 'good citizens' throughout their interactions with state representatives and to emotionally engage with the cultural values they are expected to demonstrate. Looking at the language tests in the British case, Khan (2019) shows how migrants are expected to demonstrate their knowledge of dominant monolingual discourses. As shown by Mazouz (2012), these processes are divisive because they lead migrants who apply for citizenship to distinguish themselves symbolically from those who are perceived as less compliant or less inclined to reproduce dominant cultural values. Similarly, as shown through the focus on the British case (Monforte et al., 2019) these processes create and reinforce distinctions and divisions between different groups of migrants because they can lead would-be citizens to endorse and reproduce dominant discourses that separate 'deserving' migrants from 'underserving' Others. These distinctions are enforced in particular through narratives that fit with dominant neo-liberal and culturalist definitions of what it means to be a 'good citizen'.
Finally, one should highlight the ambivalent effects of policy instruments such as the citizenship test in terms of the civic and political participation of migrants. As one of the main reasons why the citizenship tests were introduced was to increase the political participation of migrants and minorities (in the context of the political agenda on 'social cohesion'; Ratcliffe, 2012), this raises questions about the effectiveness of this instrument in producing 'good citizens'. Empirical studies have thus shown variations across national contexts. In their analysis of nineteen European countries, Just and Anderson (2012) argue that access to citizenship can have a positive effect on migrants' political engagement, in particular among "individuals who were socialised in less democratic countries". From a comparative perspective, Hunger (2018) shows how naturalisation can have a positive effect on migrants' political participation, in particular in 'restrictive citizenship regimes' (see also Goodman and Wright, 2015). However, looking at the effects of the citizenship test in the British context, Bartram (2019) shows that this requirement tends to have a negative effect on migrants' political participation as it leads to alienate new citizens (see also Osler, 2009). These ambivalences show that the way migrants experience naturalisation policies remains difficult to measure. More generally, these ambivalences show the complexity of how policy instruments such as the citizenship tests and ceremonies are perceived and negotiated by migrants in the course of their experience (Bassel et al., 2018).
The papers in this special issue explore these concerns from a number of angles, with empirical research drawn from the UK, Netherlands, France, Germany, Canada. Taken together, the papers show that policy connected with citizenship and naturalization is typically highly consequential for immigrants in these countries -there is much at stake for people's lived experiences.
The first contribution, by Ricky van Oers, engages directly with the equality issues identified above and connects to the 'cultural' turn associated with new citizenship requirements. Citizenship tests and other components of civic integration regimes are often promoted with an inclusionary vision: immigrants gain knowledge in preparation for tests, and in theory that knowledge will facilitate social and political participation. The difficulty is that there is often wide variation in dispositions and capacities to succeed, and policy interventions typically fail to engage with that variation, instead adopting a one-size-fits-all framework. Using interview data drawn from respondents in Germany and Netherlands, van Oers shows the unequal consequences of uniform policy approaches that have developed in broadly similar ways. Highly capable immigrants experience the various test/evaluation requirements as an unwelcome and sometimes even offensive intrusion that does nothing to enhance their (already high) integration. At the other end of the scale, in each country the immigrant population includes some individuals who gained very little formal education; their ability to engage with tests is very limited, and so the requirements operate mainly as exclusionary. The requirements are rooted in part in perceptions that immigrant integration has 'failed' -but in this regard the 'solution' might only exacerbate the perceived problem, perhaps even reinforcing an impression that some immigrants are 'culturally' incapable of being full citizens.
In her paper, Elke Winter focuses on the experiences of naturalised citizens in Canada -a country with a long reputation for a more open citizenship regime explicitly embracing multiculturalism. Canadian policy has become stricter in recent years, in ways that seem to reflect developments in key European countries. Even so, the highly-educated respondents interviewed by Winter do not experience these requirements as particularly onerous or insurmountable: their high levels of human capital provide a strong foundation for gaining citizenship -they are well placed to complete applications, pass the test, etc. In that respect Canadian

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Ethnicities 21 (2) naturalization policy mirrors the earlier immigration/selection policy (the 'points system'); it also reinforces our impressions about the strength of Canadian multiculturalism, where belonging to a racial/ethnic/religious minority appears not to matter. But Winter notes the important implications for other categories of immigrants -in particular, people who come as refugees or 'family class' immigrants. Many people in those categories do not enjoy the same level of human capital -and their chances of benefiting from Canadian multiculturalism are rather lower (as seen in lower naturalization rates). Even in Canada, then, citizenship falls short of achieving an ambitious vision of equality; in line with the 'neo-liberal' turn, it gives heavy emphasis to individuals' capacities, as against a collective logic of inclusion. The paper by Leah Bassel, Pierre Monforte and Kamran Khan explores immigrants' experiences in the UK via extensive interview data drawing on naturalised citizens, as well people at an earlier stage in the process and others who remain noncitizens. Their investigation addresses the 'neo-liberal turn' as well and is framed with reference to the 'active citizen' construct, in particular asking: does citizenship policy in the UK lead people to become reflective/critical citizens (engaged in collective efforts to achieve or prevent change), or does the test requirement produce instrumental 'box-tickers' whose sole focus is on meeting the requirements? Some of the interviewees in this research clearly fall in the latter category: their engagement with the citizenship process appears to lead them mainly to gain knowledge of law and other expectations, and they then seem more inclined to conform. A few respondents say they value the knowledge they gained in studying for the test and then engage in a more critical/reflective mode -though the analysis also suggests that these individuals might already have been more disposed to act in that mode. Overall, then, the findings show that the injunction to become an 'active citizen' (in the way it is defined by public authorities) leads to ambivalent and sometimes contradictory responses about what it means to be a 'good citizen' on the part of those who go through the citizenship process. These coexisting and contradictory narratives bring to light the paradoxes of active citizenship more generally.
In his contribution, Kamran Khan (2019) explores how border-making trials are confronted in the UK citizenship process beyond the citizenship test. Drawing on a notion of 'raciolinguistics' developed by Flores (2015, 2017), Khan examines how these trials use a figurative and ideological 'white listening subject' as the standard against which migrants are judged. Each negotiation represents a kind of 'shibboleth' (Derrida, 2005) in which migrants must make visible particular linguistic practices to 'pass' the assessment. What is striking is how these trials appear at various points of the citizenship process beyond the citizenship test itself. These trials range from 'pre-emptive' testing as part of spouse reunification in the country of residence prior to arriving, in citizenship ceremonies (Khan and Blackledge, 2015) as well in the passport interviews that occur after the ceremony and before obtaining the passport. What emerges is a struggle to gain 'believeability' (Derrida, 1998); that is to say, an ongoing battle through the various trials to be believed that one belongs. As suggested by analyses of 'securitization' and also the 'cultural turn' of citizenship, for some people being an 'immigrant' is an ongoing burden even after formal citizenship is achieved.
In her comparative investigation of the UK, France, and Netherlands, Semin Suvarierol considers different citizenship policies and their effects on immigrants, via a significant innovation: here the is focus on the institutional intermediaries that put these policies into practice. In France, the relevant actors are mostly employees of the state, under a high degree of centralised control from the French Office of Immigration and Integration. Substantive materials (e.g. Power Point presentations) are developed centrally, and citizenship and language courses are taught by bureaucrats. By the same token, the state covers the costs associated with instruction and testing (and even a three-course bistro lunch). By contrast, in the UK the main actors associated with implementing citizenship policy are external to the state per se. To develop the policy, the state commissioned an expert panel; courses (especially for language development) were taught initially in local colleges. At a later stage study for the 'Life in the UK' test became a solely private matter; a handbook was/is provided, with content determined by another advisory/expert body. Arrangements in the Netherlands are similar to some extent (with extensive outsourcing), though the atmosphere of citizenship policy is also even more politicised than in the UK, with the government more inclined to meddle regarding expectations about content. The various ways of organising this intermediate level, then, have consequences for how aspiring citizens encounter state policies.
The paper by David Bartram is the sole quantitative contribution and connects to the 'cultural turn'. This analysis considers immigrants in the UK, using data from 'Understanding Society'. These data enable investigation of change across a period from 2010 to 2016, using Wave 1 and Wave 6. The analytical focus is on attachment to British national identity (measured on an 11-point scale) -and the core finding is that naturalised citizens in this sample reported 'importance of Britishness' at a level approximately one point higher than those who remained non-citizens. The implication is that the requirements for gaining formal/legal citizenship (including the 'Life in the UK' test and the citizenship ceremony) do not function as obstacles to achieving this particular substantive component of citizenship (i.e., an affective sense of belonging). The longitudinal nature of the data ensures that this finding is not an artefact of an already higher sense of belonging: those who became citizens were indeed already more attached to British national identity, but the finding Bartram reports is adjusted for that initial difference. This paper reinforces the importance of investigating citizenship empirically, not just theoretically: certain aspects of new requirements might have exclusionary consequences, but that pattern is not inevitable for all dimensions.
The special issue concludes with an Afterword by Anne-Marie Fortier.

Declaration of conflicting interests
The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.