A multilevel citizenship puzzle: Residence and citizenship in national and local elections

In contemporary democracies, the franchise in national elections has been largely separated from territorial residence by extending it to voters residing permanently abroad, but not from citizenship status, which remains a fundamental requirement in all but a few countries, with New Zealand as the most significant exception that confirms the rule. Conversely, the local franchise has been separated from national citizenship requirements in a significant number of (mostly European) states but remains – with only few exceptions – reserved for those who reside in the municipality. These observations can be condensed into a testable hypothesis: The national franchise is separable from territorial residence but not from national citizenship; the local franchise is separable from national citizenship but not from territorial residence. Stated differently, voting rights are increasingly differentiated according to the criteria of residence and citizenship, and there is an interaction between the vertical differentiation of voting rights in multilevel polities and the horizontal differentiation of the franchise in contexts of international migration.

In the first part of the paper we discuss findings from a European and American survey of voting rights and focus on exceptions to the two non-separability claims and examples for resistance against actual separation. Our aim is to show that the exceptions confirm the rule and that resistance against separation can be explained contextually rather than by some inherent features of the democratic franchise in national and local elections. In the second part of the paper, we try to make sense of these observations from the perspective of democratic theory.