(Non-)Moderating the Migration and Mobility of EU Citizens: A Literature Review

Introduction

The right of free movement is a ‘by-product’ of the European integration process (Johns 2014: 17). It had already been enshrined in the 1957 Treaty of Rome as part of the common internal market and is, today, one of the core components of a consolidated European Union. The elaboration and implementation of free movement indicate the current state of European integration (Roos and Westerveen 2020), also because the intra-EU movements of citizens provoke and open up institutional action that differs from other forms of migration – such as visa-controlled labour migration or refuge due to war. Despite a few restrictions, an EU citizen decides on his/her own if he/she wants to stay in another country, for example, as an employee, a student, self-employed, a family member or for retirement. The freedom induced diverse short-term, long-term and circular patterns of migration and mobility within Europe. In 2019, 17.9 million EU28 citizens lived in another EU member state (Fries-Tersch, Jones and Siöland 2021).¹ According to European law, they have equal rights as nationals. However, their position as an (EU) citizen and migrant challenges the multi-level European institutional setting.

From the local to the European level, a complex landscape of institutions is involved and interwoven to develop policies and strategies as responses to the freedom of movement. Their actions shape the conditions under which EU citizens work in another member state, how they arrive – for example, in terms of (good) housing – how they access support systems and social services and how they return or settle in another member state. The scope ranges from supporting intra-EU migrants in emergencies to motivating young citizens to gain experience abroad.

However, different institutions at diverse levels have varying goals and challenges. Stakeholders at the local level can make use of new opportunities and have to deal with the consequences that result from freedom of movement (Scholten 2018; van Ostaijen and Scholten 2018). In German cities, for example, there is discussion of how governmental actors can react to precarious living conditions of intra-EU migrants (e.g. Bruzelius 2020). In Romania, the debate considers local networks to ensure the welfare of children whose parents work abroad (e.g. Balaban and Huţuleac 2021). At the same time, companies and agencies have recruitment strategies for skilled workers for care and crafts, which may be lacking in their home country (e.g. Bermudez and Brey 2017). European institutions support migration and mobility by funding schemes like Erasmus+ and by cooperation through, inter alia, the EURES network (e.g. Heimann 2021). Moreover, within European multi-level governance, challenges exist due to the different legislative competencies and national institutional path dependencies – examples of which are the different welfare systems in Germany and Denmark (Martinsen and Werner 2019).

Against the backdrop of the European integration process, this article sets out to gather together discussions on this complex landscape of institutions and their interactions across levels and policies. Here, institutions are understood in the narrow sense as organisations (Hodgson 2006). These include formal social actors – such as authorities, courts and schools – and actors whose organisational form contributes significantly to social life, such as companies and associations. Taking historical and discursive institutionalist perspectives, these institutions’ actions result from specific contextual conditions within and outside of the institutions (Thelen 1999) and are reasoned by a set of ideas as policies, programmes and philosophies (Schmidt 2008). Context and ideas (re-)produce and are (re)produced in communicative and coordinative discourses and, thus, induce specific institutional logics leading to certain policy outcomes. While the communicative discourse concerns the necessity and appropriateness of policies (see, e.g., Roos and Westerveen 2020; van Ostaijen 2017), ‘the coordinative discourse consists of the individuals and groups at the center of policy construction who are involved in the creation, elaboration, and justification of policy and programmatic ideas’ (Schmidt 2008: 310).

The article puts the coordinative discourse at centre stage and presents key findings from the scientific literature regarding the logics of institutional action in different policy fields. The aim is to better understand current policies existing at the intersection of migration, social inclusion, the labour market and regional development provoked by the EU right of free movement and to deduce implications for the European integration process. For the methodological approach, a systematic literature review was used to map the state of knowledge on institutional action. Various academic disciplines studied the institutional arrangements across levels and policies in different thematic areas. This review contributes to an interdisciplinary discussion and does not pay special attention to particular disciplinary debates such as European citizenship, minority studies or labour relations.

Analysis of the scientific publications identified organisations decisively shaping policies in the context of intra-EU migration and mobility and revealed what is discussed about the institutional logics that induce current policy outcomes. Thus, this article’s institutionalist (and interdisciplinary) approach shows crucial ambivalences within the European integration process. Different institutional logics in the coordinative discourse surrounding the intra-EU migration and mobility enable the rejection of responsibility, enhance the neoliberal migration and integration paradigm, put vulnerable groups at risk and hinder the development of policies for the benefit of all EU citizens.

The following section explains the methodological approach of the systematic literature review. The results are then presented from both quantitative and qualitative perspectives. The article closes with a discussion of the results.

Methodological approach

The literature review was carried out according to the guidelines provided by Xiao and Watson (2019), aiming primarily at a description of the research field (narrative review, Xiao and Watson 2019: 95). The study was conducted in 3 steps: Defining the criteria; Searching in the databases and Analysing the publications (see Figure 1).

Figure 1. Schematic procedure of the literature review

Defining the criteria

The first step was to determine the thematic scope of the field. The mapping of relevant terms in scientific databases revealed a broad field of national and international publications concerned with various types of migration and mobility (e.g. high-skilled workers, student mobility, seasonal workers, poverty migration, transnational and lifestyle migrants) and different territorial levels (local, national, European) deemed helpful to the discussion. However, a systematic literature review on intra-European migration and mobility and their institutional negotiation was not found.

Inclusion and exclusion criteria for the sample were defined. The review includes scientific literature from journals, monographs, edited volumes and reports published from 1997 onwards.² It excludes newspaper articles, contributions with purely informational content, political position papers and the like. It also excludes academic publications that generally focus on migration (in Europe) or institutional practices. As a result of the preview mapping, it should be noted that many aspects of intra-EU migration and mobility are described in practice-oriented publications and the journalistic field.

Searching in the databases

For the search, combinations of the following search terms were used: ‘intra-eu*’, ‘EU citizen’, ‘European citizen’, ‘euro*’, ‘in the EU’, ‘mobility’, ‘migration’, ‘freedom of movement’, ‘EU’, ‘institution*’, ‘integration’ and ‘local’ (for example the combination: ‘intra-eu*’ AND ‘mobility’ OR ‘migration’ AND ‘institution*’). The search was conducted mainly in April and May 2021 (databases: Web of Science, Google Scholar) and supplemented in July 2023 (database: Web of Science) covering publications until the end of June 2023. The publications’ titles and abstracts were reviewed regarding the defined criteria and their relevance to the research question. In this process, many publications were excluded. In particular, many contributions were not considered because no explicit reference to the actions of specific institutions was discernible (for example, ethnographical studies on the arrival processes from the perspectives of migrants) or because intra-EU migration/mobility played no or only a subordinate role (for example, publications about general considerations of institutional negotiation processes at the European level). Challenging, here, was the different use of the term institution, as some scholars used a broad term – for example, the legal system as an institution. The boundary could not be clearly drawn due to the lack of definitions in the publications. Publications about the role of intra-EU migration (and the changed framework) when the UK left the EU were also not considered for this review since the case is particular in Europe. Eighteen contributions could not be included due to a lack of availability.³ Bibliographies of single sources were scanned for publications that fit the review but were missing and this backward search added 15 publications to the study. Finally, this study includes 84 highly relevant publications.

Analysing the publications

The quantitative analysis refers to the forms of publication, the publication year, the author’s location, and the European cities and countries surveyed. This gives an overview of the scope of the publications considered. The qualitative analysis followed the principles of inductive content analysis. The first step was grouping according to the topics discussed. Secondly, against the background of the institutionalist perspective described in the introduction, the following questions guided the interpretation: What institutions are described? What findings do scholars present about how these institutions develop and elaborate on policies and programmes? What institutional logics arising from internal and external contexts and/or ideas are discussed in the publications as being important for developing and elaborating on policies and programmes? Thirdly, this study intertwined the central results within the topics and concluded indications for the European integration process.

Quantitative analysis

Of the publications included, more than two-thirds are articles published in one of 43 different journals (see Figure 2). Most journals have a social and political science background. It should be noted that many journals have an interdisciplinary understanding, especially in migration research. Assignment to social and political science is primarily based on information provided by publishers but often invokes interdisciplinarity. The review included 12 chapters of 4 edited volumes. The most important volumes in the field of research were Lafleur and Stanek (2017a), Magazzini and Piemontese (2019), and Scholten and van Ostaijen (2018). Furthermore, the study comprises 10 research reports and 3 dissertations as monographs.

The overview of publication periods (Figure 2) shows that the number of publications on the research question increased from 2013 onwards. Most of the publications appeared between 2017 and 2019, including the volumes mentioned.

Figure 2. A quantitative overview: Type of publication, background of the journals and year of publication

The authors were employed in 17 (exclusively European) countries at the time of publication, mainly in Germany, the Netherlands and the UK. Six authors, each with more than 3 publications included, worked on an EU-funded project and, in addition to an edited volume (Scholten and van Ostaijen 2018), also published several articles and reports on the topic under consideration here. At least 9 publications in the sample result from this research cooperation.

Researchers primarily examined local (n=33) and national (n=49) institutions or institutional arrangements as levels of practice. Eighteen publications looked at the European level, 21 analysed cooperation and interaction across various levels (multi-level governance, MLG), and 26 analysed more than one level.

The map shows the locatable case studies identified in 68 publications (Figure 3). More than half the research activities worked comparatively.³ Thirty-four different cities were examined. Berlin, Brussels, Dublin, Gothenburg, Madrid and Stockholm are the most frequent subjects of analysis, with 3 studies each. The Western and Northern European countries also stand out: Germany (n=16), the UK (n=11), Sweden and Denmark (n=9 each), Austria, Spain and the Netherlands (n=8 each). Only 13 publications looked at Eastern and South-Eastern European countries.

Figure 3. Cities and national states studied by the included publications

To sum up, the research on the interface of freedom of movement within Europe and institutional action is anchored in the broad migration and policy studies field. Scholars from various academic disciplines participate, especially in social and political sciences. Researchers from economics, geography, ethnology and law were less concerned with analysing institutional action. Research has increased significantly, especially since the mid-2010s, which coincides with an increasing number of mobile and migrating Europeans and highlights a growing academic interest in the subject. The research focused on cities and countries of arrival, with researchers mainly working in large cities and institutional action in rural areas and smaller towns mostly ignored. Researchers were primarily employed in Western and Northern Europe and, to a lesser extent, in Southern Europe. To date, the ways in which institutions in sending countries adjust to or support intra-European migration and mobility movements has been poorly covered in the English-language literature. The high number of different journals is a consequence of the diverse angles from which this subject is addressed. However, except for a few project consortia and volumes, there is no recognisable interdisciplinary collaboration among authors working on the topic based on the information available in the literature.

Qualitative analysis

The wide range of migration and mobility patterns within the EU is reflected by the broad spectrum of topics examined in the academic community. The majority of publications discussed aspects of social inclusion. This includes the debate on social policy at the European level, welcoming policies at the local level, access to social services, support for those facing precarious housing and homelessness, enforcement of labour and social rights and policies for the Roma minority. Concerning labour migration, the authors analysed the recruiting practices, working conditions and role of unions. A small portion of the sample addressed questions on migration regarding (higher) education, emigration and remigration policies and the political representation of intra-EU migrants. Horizontal and vertical governance patterns as forms and problems of cooperation and coordination between and within action levels are cross-sectional topics.

The following sections present key results regarding the 3 topics: social inclusion, labour migration and governance patterns. The results consider actors, policies and guiding principles for action (of different actors) as discussed in the publications. The number of publications concerned with higher education (e.g. Teichler 2009, 2019), representation and emigration (e.g. Ciornei 2016), retirement migration (e.g. Calzada, Páez, Martínez-Cassinello and Hervás 2023) and remigration policies (e.g. Kirch 2018) is too small to provide a meaningful overview. Single findings are highlighted in the social inclusion and labour migration sections.

Social inclusion

Two starting points for the academic discussion on social inclusion (mainly of foreign EU citizens) can be identified. Firstly, between 2013 and 2015, 4 research reports on the order of European institutions described policies for the socio-economic inclusion of intra-EU migrants (Cancedda, Curtarelli, Hoorens, Vierelhauzen and Hofman 2015; Eurofound 2015; EY 2014; Piemontese, Plainer, Bianconi, Stefanova and Förschner 2013). The reports encouraged further political science research in migration studies (e.g. Bousiou, Bucken-Knapp and Spehar 2016; van Ostaijen 2017), which focused on vertical and horizontal governance and their roles in moderating intra-EU migration and mobility, which will be discussed below. The contributions also discussed the crucial role of specific national and European actors in framing policies for social inclusion. The main actors depicted are the European Court of Justice (ECJ) (e.g. Blauberger and Schmidt 2014; Thym 2015a) and the national institutions responsible for the implementation of the welfare system (e.g. Mullan 2017).

Secondly, researchers – mainly with backgrounds in social sciences, social work and anthropology – critically discussed local institutional practices concerned with highly vulnerable EU citizens – above all, migrated Roma and homeless people (e.g. Minas and Enroth 2015; Mostowska 2011, 2014; Parker and López Catalán 2014). The literature described the policies implemented when foreign EU citizens need support in arriving countries, for example, the provision of basic needs, counselling regarding housing, access to the labour market and financial support for return (e.g. Minas and Enroth 2015; Mostowska 2014; Zelano 2018a). From the perspective of sending countries, 2 publications dealt with policies to address local challenges in care systems for children and older people resulting from the number of family members working abroad (Balaban and Huţuleac 2021; Kindler 2018). One recent publication asked about the access conditions of retired intra-EU migrants to local social services in Spain (Calzada et al. 2023). The main actors described are the municipality, seen as responsible or at least the first contact to provide basic needs (e.g. shelter) and NGOs as social workers and intermediary actors with (language) skills to inform and support. Many authors contributed to this academic discussion, with perspectives from urban studies and political sciences included (e.g. Persdotter 2019).

Both discussion lines analysed and criticised the ways in which social inclusion policies serve to control and select the migration and mobility of foreign EU citizens. Studies argued that, due to the abolition of border controls and the difficulty of consistently monitoring free movement rights, the local level is taking over migration control through street-level/front-line bureaucrats of national or local authorities, police and social workers (mostly working at NGOs). Border techniques and exclusionary practices were diverse – for example, the eviction of homeless camps (Parker and López Catalán 2014; Persdotter 2019) or conditions for registration (e.g. Bruzelius 2019; Parker and López Catalán 2014; Scheibelhofer 2022; Spehar, Hinnfors and Bucken-Knapp 2017).

The publications showed problematic linkages between NGOs and authorities in the context of these exclusionary practices (e.g. EY 2014; Manca and Vergnano 2019; Tervonen and Enache 2017). NGOs and social workers are highlighted as being the main contact point and mediator in many cases and the authors concluded that there had been a transfer of responsibility from the municipality to the NGOs (e.g. Minas and Enroth 2015). As a rule, the NGOs are funded with public money (mainly from the EU) for regulated tasks for a certain period. They are bound (at least financially) and, thus, may act as middlemen through their direct contact with communities. For example, Manca and Vergnano (2019) described this in the context of a rehousing project for Roma in Torino (Italy): social workers checked individual suitability for participation in the project and, where it was lacking, encouraged applicants to return to their home country.

Authors also described exclusionary policies regarding the enforcement of national law at the local level, primarily through strategies to restrict access to welfare benefits (e.g. Lafleur and Stanek 2017b; Martinsen and Werner 2019). Kramer, Sampson Thierry, and van Hooren (2018) noted that national institutions mainly regulate access through practical and administrative instructions rather than legal changes. Authors concluded that front-line bureaucrats (representing national authorities) are caught between two different logics – the European endeavour of equal rights and national protectionist welfare regimes (Thierry and Martinsen 2018). The lack of guidelines opens up substantial power for bureaucrats to act according to their personal principles (Ratzmann 2022) and they are hardly legally bound and controlled. Likewise, according to Blauberger and Schmidt (2014), the burden of proof is increasingly being reversed, to the disadvantage of migrants. Thus, the institutional setting was described as being rather arbitrary (e.g. Dwyer, Scullion, Jones and Stewart 2019; Ratzmann 2021). Moreover, Lafleur and Mescoli (2018: 490) write about a ‘schizophrenic welfare state’ – while NGOs are mandated to support migrants, applications for social benefits are rejected by front-line bureaucrats.

Access to welfare benefits also depends on European law. The authors analysed the legal design of the right of free movement as it is negotiated by the European Court of Justice (ECJ) on a case-by-case basis (e.g. Eigmüller 2013; Heindlmaier and Blauberger 2017; Parker and López Catalán 2014). They concluded that, while legal decisions have led member states to revise their national policies, the patchwork of unclear regulations and instructions described above remains. Also, Mantu and Minderhoud (2023) argue that the legal decisions support the restrictive and conditional access to the welfare services in the member states (see also Mantu and Minderhoud 2019; Mantu, Minderhoud and Grütters 2021; Thym 2015b). Ultimately, the ECJ’s legal decisions were too small in scope to initiate uniform implementation across the different member states. Major differences in the political and administrative systems of the member states hinder, for example, the transferability of entitlements in the social system (unemployment benefits, pensions) and have not yet been resolved by European laws (Grabbe 2023).

The scholars showed findings on new associations and initiatives by intra-EU migrants to represent their interests (Lafleur and Stanek 2017b) and these initiatives can be traced back to community building in many ways (Barnard and Fraser Butlin 2020). The authors emphasised that intra-EU migrants (or mobile workers) succeed in exercising their social and labour rights through their own institutions, at times using these institutions to claim their rights with greater vehemence.

This process is seen as necessary by many authors due to their very critical opinion of the institutional logics that shape the actions toward (vulnerable) intra-EU migrants and mobile persons. The authors found that the restrictions on social benefits for foreign EU citizens and the conditionality of free movement in various member states in recent years are a response to the rise of right-wing populists (e.g. McMahon 2013; Mullan 2017; Roos 2019). This also applies to the latest decisions at the European level (Roos and Westerveen 2020). According to Dølvik and Eldring (2017), a (renewed) normative positioning has primarily been taken by the ECJ (as described above) but not by European political institutions.

At the local level, in the sample, 4 discussion strands of institutional logics with adverse effects on social inclusion can be identified:

1. The institutions’ reactions to the needs of foreign EU citizens resulted from (previous) experiences with migration. Institutions reactivated strategies for social inclusion but their policies did not consider changed conditions and action was thus trapped in a cognitive lock (e.g. Bousiou et al. 2016; van Ostaijen and Scholten 2018; Ulceluce, Bock and Haartsen 2021; Zelano, Bucken-Knapp, Hinnfors and Spehar 2016).
2. The mobility lock is a specific aspect of the discussion on EU freedom of movement (e.g. Bruzelius 2020; Mostowska 2014; Persdotter 2019). Short-term, circular migration and, if applicable, the associated multi-locality of foreign EU citizens are not part of the institutional logic. This leads to a lack of access to these people. Closely linked is the research on (urban) European citizenship (e.g. Bouali 2018; Simola 2018; Vrăbiescu 2019).
3. Different institutions act according to normative and neoliberal integration paradigms (e.g. Kostka 2018). This is illustrated, for example, by front-line bureaucrats who make language skills a prerequisite (Ratzmann 2021; see also Carmel and Sojka 2021). Above all, it is in the social work of NGOs that neoliberal integration paradigms, such as the individualisation of responsibilities, are analysed and criticised by the authors (e.g. Magazzini, Chiozza and Rossi 2019; Manca and Vergnano 2019; Vrăbiescu and Kalir 2018).
4. Decisions and basic features of host-country migration regimes were at least partly shaped by racism and resulted in the exclusionary policies described above (e.g. Kostka 2018; Persdotter 2019; Raithelhuber 2019; Ratzmann 2021, 2022).

To sum up, the literature described the front-line bureaucrats of public authorities and NGOs as the actors and institutions responsible for social inclusion at the local level. Authors criticised the institutional logics at the local level leading to the (intended or unintended) exclusion of (vulnerable) intra-EU migrants and mobile persons. However, their decision-making competence is highly dependent on the national (mainly legal) and European levels (mainly legal and financial), whose institutional logics are shifting towards more restrictions and conditionality. It is striking that hardly any specific organisations are named at the national level. Instead, the term institution is used in a broad sense here – for example, welfare system. Only when looking at the European level is the ECJ clearly mentioned as crucial for elaborating policies and programmes that are further discussed in the coordinative discourses at the local and national levels. The findings pointed to distortions between institutions at the local, national and European levels, which are discussed in depth below.

Labour migration

In the research field of labour and production, institutions and the right of free movement are less relevant as topics. Authors worked at different intersections of economics, industrial relations, social sciences, demography and law. The contributions in the sample are more related to singular aspects, yet two strands of research are still visible. Firstly, there is a discussion of working conditions. In this context, publications discussed the role of trade unions, the emergence of temporary staffing agencies and governmental responses. Secondly, the recruitment of skilled workers and the local, regional and national actors involved is increasingly the focus of research.

In the publications, the changed role of trade unions and the fulfilment of the right to also represent foreign EU citizens (as workers) can be traced back: Heimann (2021) stressed the fact that trade unions opposed protectionist positions during the debates on eastward enlargement (approx. 1997–2012). In 2015, Cancedda et al. (2015) noted that, in their four case studies, each city had some form of counselling service or information campaign (co-)initiated by trade unions to counteract the abuse and exploitation of migrant workers. Refslund (2016) observed increased cross-border cooperation between trade unions.

In the mid-2010s, authors described postings and temporary staffing as significant challenges for trade-union action and the enforcement of the labour rights of foreign EU workers (e.g. Refslund 2016; Zelano et al. 2016). During Eastern enlargement, temporary staffing agencies emerged as new transnational actors (Friberg and Eldring 2013). Authors criticised new, atypical forms of employment and the profits of the companies involved through their undermining of collective labour agreements and minimum wage laws in receiving countries (Refslund 2016; Wagner and Hassel 2017). The publications highlighted the ambivalence in enforcing the labour rights of all workers as the challenging rationale for trade unions’ actions in the complex system of free movement (Dølvik and Visser 2009; Friberg and Eldring 2013; Refslund 2016; Wagner and Hassel 2017). Refslund (2021: 331) concludes, for the Danish case, that ‘institutional embedded unions’ and their ‘effort to engage with the migrant workers’ contributed significantly to improving the situation and bridging the gap between workers.

The recruitment of skilled workers is rarely discussed critically. Authors presented different strategies (e.g. Cancedda et al. 2015). Kovacs, Girasek, Kovacs, Aszalos, Eke, Ragany, Cserhati and Szocska (2017) showed both an increasing professionalisation and a binational networking of chambers and recruitment agencies. Given the shortage of skilled workers, recruitment strategies seem to increasingly aim at accompanying social inclusion (e.g. individual support to find a job or housing; Cancedda et al. 2015; Zelano et al. 2016). Authors described regional networks of companies, chambers and agencies as well as cultural and social actors for coordinating offers (e.g. Heimann and Wieczorek 2017). As Heimann (2021) points out, this is complemented by diverse European actors (e.g. the EURES network) and policies (e.g. the European Higher Education Area). The institutional logic of these actors is the possible benefit of the deregulated (labour) market within the European Union. This is subject to the logic of competition between regions in the EU. So, publications from sending countries discussed how authorities cooperate in setting up financial support and other incentives to enhance the remigration of skilled workers (Croitoru 2021; Genelyte 2017; Kirch 2018; Soltész 2019).

To summarise, contributions which were included dedicated less of their discussion on the coordinative discourses and the responsibilities or decision-making opportunities of institutions in the field of the labour-market participation of intra-EU migrants and mobile workers. The thematic proximity to social inclusion issues is noticeable (e.g. trade unions and working conditions). A new publication by Bruzelius and Seeleib-Kaiser (2023) crosses the bridge between labour-market-centred analyses and social rights. The authors discuss hypermobility and the precarious employment of seasonal workers and point at ‘institutionalised exploitation’ (ibidem: 12) as national and European institutions are not effectively enforcing labour standards. In this review, results are lacking when it comes to presenting a larger or more nuanced picture of the institutional role in labour migration and policy outcomes (e.g. the Posting Workers Directives, wage regulation, see Dølvik, Marginson, Alsos, Arnholtz, Meardi, Müller and Trygstad 2018).

Horizontal and vertical governance patterns

The research on governance in the context of intra-EU migration and mobility is about the forms of cooperation and distortions between actors or levels. Contributions mainly came from political-science scholars researching migration but most studies concerned with social policy discussed particular facets. Some aspects, especially horizontal collaboration, have already been mentioned in the previous sections.

In the publications, it is notable that the ways in which policies were shaped within different governance environments depend on whether migration and mobility are recognised and which patterns are considered (e.g. Eremenko, El Qadim N. and Steichen 2017; Lafleur and Stanek 2017b; van Ostaijen 2017). In this context, the authors emphasised the complex collection and interpretation of statistical data by authorities (Bruzelius, Chase and Seeleib-Kaiser 2016; van Ostaijen and Scholten 2017). In particular, it is striking that many authors wrote about the ignorance of various institutions towards intra-EU mobility and migration as one key feature of the institutional logics at play here (e.g. Dwyer et al. 2019; Eurofound 2015; Lafleur and Mescoli 2018 Shaw and Miller 2012).

Against this background, cooperation was described differently for cities, member states and policy fields (e.g. van Ostaijen and Scholten 2018). Authors emphasised the formation of new networks and improved cooperation at the local level to meet the challenges posed by an influx of intra-EU migrants or a shortage of skilled workers (e.g. Cancedda et al. 2015; Scholten, Engbersen, van Ostaijen and Snel 2018; horizontal governance).

Still, capacity at the local level seems to remain restricted. Most authors criticised the lack of interaction between different levels and its negative impacts on local governance. For example, the authors described the way in which responsibility for social inclusion is delegated to municipalities (see also above, e.g. Bucken-Knapp, Hinnfors, Spehar and Zelano 2018); nation states provided few or no guidelines (or financial support) and tried to circumvent European social legislation (e.g. Kramer et al. 2018). The EU level is described as absent from discussion and policy development apart from minority policies (Bucken-Knapp et al. 2018; van Ostaijen and Scholten 2018). However, also, according to the publications in the sample, European institutions finance most efforts for social inclusion within the minority policies and investment funds of European institutions (especially for Roma and other vulnerable groups; e.g. Kramer et al. 2018; Piemontese et al. 2013; Vermeersch 2013). The authors criticised the temporal limitation and the lack of coordination regarding needs at the local level (Vermeersch 2013; Zelano 2018b). A lack of cooperation and uncertain division of competencies leads to the formation of ‘dispersed, contested or even incongruent policies’ (van Ostaijen and Scholten 2018: 255; also, e.g. Shaw and Miller 2012; Spehar et al. 2017; vertical governance).

Looking at the background of these institutional logics at play, scholars explained the lack of action and cooperation across the levels as resulting from competing interests. Engbersen, Leerke, Scholten and Snel (2017) even argue that the paradigmatic conflict of free movement cannot be resolved – the local level bears the consequences and has few opportunities to act pre-emptively. The EU is interested in enforcing the law and striking a balance between regions as essential parts of European integration policies (also Roos and Westerveen 2020). In between, the national level wants to keep its sovereignty. To finish, European values are negotiated in this process. Balch, Balabanova and Trandafoiu (2014: 1168) concluded that European values are ‘lofty rhetoric which can be adopted and adapted when it suits, and usually not for the benefit of the marginalised’ (also Barbulescu and Favell 2020; van Ostaijen 2020).

On the whole, the researchers draw a negative picture of current governance. To date, authors have mainly noted the rejection of responsibility and ignorance towards both intra-EU migrants and mobile persons as well as actors at other levels as institutional logics in the coordinative discourse. Researchers found that significant contributors to the inaction of a wide range of entities are a lack of knowledge of the legal framework, uncertainties regarding migration and mobility patterns and inconclusive competencies (this also refers to cognitive and mobility lock, see above).

Conclusion

Based on a systematic literature review, this article has explored the state of knowledge regarding the complex landscape of institutions involved in moderating intra-EU migration and mobility. Diverse scholars’ research, mainly in Western and Northern Europe, examined institutional action regarding the arrival (or recruitment) and social as well as labour-market inclusion of foreign EU citizens. Three core topics could be identified in debate about the institutions moderating intra-EU migration and mobility: social inclusion, labour migration and governance patterns.

The literature on social inclusion described in greater detail the institutional practices at the local level, with local actors mainly responding to new problems. NGOs and front-line bureaucrats are central to the enforcement of policies that promote social inclusion. Publications discussing the European level and the ECJ as decisive actors underlined the rejection of responsibility and the non-action of many actors that could be involved. Discussion of labour migration refers to trade unions and temporary working agencies but it cannot be deduced from the included publications whether these (alone) are the decisive institutions. Policies (non-)moderating intra-EU migration and mobility are inconclusive across the nation states and the EU. This has adverse effects on (mostly vulnerable) citizens and dedicated actors.

Institutional logics at play refer to changes in the past years – for example, the right-wing shift in Europe – but also to path dependencies such as cognitive and mobility lock, as described for the local level, an uncertain division of competencies and competing interest, as described for the multi-level governance. The synopsis of the elaborated institutional logics within the coordinative discourse presented in the review highlights some crucial ambivalences within the European integration process:

• The freedom of movement is a prime example of disorganised deregulation. While the EU pushes the opening of markets for economic and wealth growth, it does not take political responsibility for negotiating in socially divided and capitalist societies. In extreme cases, this results in disastrous working and living conditions and racist harassment towards foreign EU citizens. Readjustments are only made through juridical (case-by-case) decisions.
• The proclaimed legal equality of migrating and mobile EU citizens supports a neoliberal integration paradigm in arrival cities and nations. Institutions hand over the social and political responsibility for the living situation to the individuals – ignoring the question of the extent to which social and labour market participation is possible. Front-line bureaucrats and local NGOs deal with inconclusive policies that should support intra-EU migration and mobility (e.g. as part of recruitment strategies) and still restrict access when it is not clear that the person is contributing a societal value.
• The different interests between the policy-making levels and the competition between regions hinder a joint discussion about the potentials (and necessities) of the freedom of movement. There is no negotiation about the migration/mobility paradigms and the development of policies for the benefit of all EU citizens.

Surprisingly, institutional action on many migration and mobility patterns is not discussed in the English-language literature, at least within the range of the search terms used. For example, there is hardly any literature on students or the mobility of young people, while the EU supports this with many financial resources and narratives of a common European space. The search terms here also cover the area of labour markets only inadequately. So, it remains unclear who the key players are in the recruitment of skilled workers. The role of companies and their benefits through intra-EU migration and mobility is analysed and discussed to a very limited degree. The introduction of free movement took place in the context of creating the single European market. However, intra-EU migration and mobility are hardly the subjects of economic development. The sample lacks analysis of non-funded short-term mobility (exceptions, inter alia, Bruzelius and Seeleib-Kaiser 2023) and its impact, i.e. new opportunities and challenges, on the regional and urban development of receiving and sending regions.

In the scientific debate, there is a need for a stronger (interdisciplinary) link between the social issues of free movement (including working conditions) and its economic relevance, especially in the context of ambiguous opportunities for regional development. Due to demographic changes, EU regions are in fierce competition with each other for the recruitment of (qualified) workers through ‘soft’ immigration strategies (e.g. incentives, image) as well as remigration policies. Research should critically examine policies in terms of adverse consequences for mobile people and its implications for the European integration process. In particular, perspectives on institutional action in sending countries are missing.

It should be noted that the criteria set by the author limited this study. For instance, a search in German-language literature revealed a more intense debate within the field of labour migration. Furthermore, the disciplines use different terms and not all could be covered. Therefore, a linguistically broader review might reveal an even more complete picture. This could also apply to research from non-Western European countries. However, other (urgent) issues, a different positionality of the institutions as considered here and a lower funding of the sciences could also be reasons why these countries are so little present here in the review.

Funding

This work was supported by the Federal Ministry of Education and Research, Germany [grant number 01UG2118].

Acknowledgements

Thanks to my colleagues Katharina Kullmann, Maria Budnik and Katrin Großmann for the discussions.

Conflict of interest statement

No conflict of interest was reported by the author.

ORCID ID

Jenny Kunhardt  https://orcid.org/0000-0002-9350-0359

Notes

1. There are significant difficulties statistically mapping the movements of EU citizens (Marchand, Fajth and Siegel 2019). For example, authorities often do not register postings, seasonal workers and students. This article considers the wide range of patterns by discussing the mobility and migration of EU citizens. These data still include citizens of the UK and EU citizens in the UK. The UK left the EU on 30 January 2020.
2. In 1997, the European Council granted candidate status to 7 countries of the former Eastern Bloc, starting a political and media debate on the EU right of free movement.
3. Unfortunately, two volumes were also unavailable for checking contributions: Amelina, Carmel, Runfors and Scheibelhofer (2021) and Arnholtz and Lillie (2021).
4. Norway and Iceland were part of the comparative studies. Therefore, these countries are marked on the maps even though they are not members of the EU.

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