Introduction

Talk of citizenship beyond state borders is not new. To the contrary, we find competing conceptions already in ancient Greek and Roman political thought. When asked which was his country, Socrates insisted that he was a citizen of the world, rather than an Athenian or a Corinthian. Likewise, when asked where he came from, Diogenes answered that "I am a citizen of the world". Their notion of citizenship beyond the city-state did not include any legal rights beyond borders. In contrast, Athenian citizens - that privileged set of free men -- enjoyed active rights to political participation. Yet for Socrates and Diogenes, citizenship of the world seemed to replace traditional citizenship rights and duties. In comparison, the Roman Empire recognized and even encouraged dual citizenship, with loyalty both to the local community and to Rome. This arrangement allowed citizens of Rome freedom of movement and trade within the Empire. Still, the Roman notion of dual citizenship had its drawbacks, both for the individual and for the political order. To be a citizen of Rome usually only provided status or passive citizenship in the form of protection, rather than active citizenship rights to political participation enjoyed only by the patrician class. Dual citizenship also created dual loyalties in the populations of the Empire, causing unresolved conflicts (Toynbee 1970, Clarke 1994).

European Union Citizenship is closer to this Roman practice than to the Greek vision of cross-border citizenship - for better and worse. Union citizenship carries clear legal implications fostering freedom of movement and trade, and is intended to supplement, rather than to replace, national citizenship. Dual citizenship also means that the European Union must come to grips with challenges of institutionalisation and multiple loyalties. Reflection on the roles and challenges of Union citizenship may teach lessons for global citizenship. Both forms of citizenship create aspirations to a democratic political order with a scope beyond existing states, and face challenges regarding institutions and political culture aspiring to treat all affected individuals as equals.

Section A provides a brief overview of the content of Union Citizenship. Section B discusses the need for trust among individuals creating and sharing European-level institutions. Section C explores how trust can be secured by Union citizenship based on shared commitments rather than on common history and broader culture. Section D draws lessons for the roles and preconditions of global citizenship.

A Union Citizenship

Union Citizenship was a conceptual innovation of the 1993 Maastricht Treaty, reaffirmed most recently in the Treaty of Nice (December 2000). Every person who is a national of a Member State of the Union is also a Union citizen. Union citizenship confers four main rights (EC Treaty 1992 Art. 17, 21). They include both protections - passive rights - and political control - active rights:

1. The right to move freely among, and stay in, other Member States;
2. The right to vote and run in local and European Parliament elections in the Member State where one resides. The European Parliamentarians are elected directly by citizens of the various Member States, forming a representative body across state borders. Through successive treaties, its power over Union legislation has gradually increased. Union citizenship enhances the political rights to the European Parliament of those who have exploited the opportunities for mobility.
3. Protection in a non-EU country, by the diplomatic or consular representatives of other Member States if one's own Member State is not represented;
4. The right to petition the European Parliament, and to petition the European Ombudsman.
The Amsterdam Treaty (1999) clarified the relationship between national and Union citizenship, insisting on the supplementary role of Union citizenship. Union citizenship does not replace national citizenship, but was intended to complement it. One reason for introducing Union Citizenship was the perceived need to facilitate free movement and residence within the Union. Citizens of Member States were no longer foreigners when travelling and living elsewhere in the Union (Preuss 1996: 139).

B Citizenship as a source of trust

The label 'citizenship' hints at another important reason why governments agreed to these rights; namely to foster a sense of European identity among those belonging to the same political unit. Union Citizenship was introduced to foster trust among citizens of the Union, and to engender popular support and allegiance to Union institutions and policies (Closa 1992: 1155; Shaw 1997; Wiener 1997).

The need for popular support has increased with the expansion of EU activities and powers. Community-level institutions increasingly shape the lives, circumstances and aspirations of Europeans. Union law enjoys status as a new legal order, exercising direct legal authority over Europeans (Weiler 1991; MacCormick 1997). Many citizens and organisations were critical of the increased powers of Union-level institutions, particularly because they appear to be beyond the control of any single accountable government. This legitimacy deficit hindered trust among Europeans and prevented compliance with common rules.

Mutual trust is central to ensuring a stable political order over time, in several ways.

B1 The need for Trust among Individuals - Impersonal Reciprocity

One possible role for Union Citizenship is to foster and maintain the mutual, legitimate trust required among Europeans. Trust is important when individuals must co-operate, but when they will only do so if they expect the others to do their part. Suspicion that others will exploit rather than reciprocate one's efforts can easily prevent or unravel complex practices of co-operation. Trust is therefore crucial for 'social capital' - 'social connections and the attendant norms and trust' (Putnam 1995: 665; Loury 1987; Coleman 1990).

Robert Putnam argues that the operative norm in trust is what he calls 'generalised reciprocity', fostered in civil society:

(N)ot 'I'll do this for you, because you are more powerful than I,' nor even 'I'll do this for you now, if you do that for me now,' but 'I'll do this for you now, knowing that somewhere down the road you'll do something for me'. (Putnam 1993, 182-83)

To prevent suspicion and ensure stable cooperation, actual compliance is not enough: each must also appear trustworthy, so that others can count on their compliance (Hardin 1996). I submit that institutions such as those of the European Union can be an important means for fostering trust and trustworthiness even among strangers, by engendering impersonal reciprocity, of the form:

I'll do this for you, knowing that somewhere down the road someone else will treat me in the appropriate way.

B2 Shaping institutions that in turn shape us

Such impersonal reciprocity is fostered by confidence in the general compliance with social institutions - including abstract, aggregated political systems (Inglehart 1970; Giddens 1995). Institutions can monitor and sanction defection, thus reducing the temptation to free ride. In turn, this reduces the likelihood of defection by those who do not mind co-operating as long as they are assured that others do likewise. These arrangements are especially important when establishing practices, as in the European Union at present, where institutions are crucial for facilitating co-operation.

Social practices and institutions rely on norms of impersonal reciprocity, but can also foster them - though slowly (Putnam 1993: 184; Rawls 1993: 168). Institutions not only enable cooperation and shape individuals' strategies, but they can shape our identities: How we conceive of ourselves, our values, norms and interests. This is another way that institutions can create and sustain trust. They shape individuals' interests and perceptions of alternatives, and can foster trust in others' benevolence (Becker 1996). Trustworthiness is further enhanced if individuals do not act on the basis of calculations, but instead are socialised to regard certain behaviour as obvious and appropriate (Stinchcombe 1986, March and Simon 1993, Olsen 2000).

B3 Increased Need for Compliance in the European Union

As the Union increases its influence, individuals and government representatives are required to adjust or sacrifice their own interests for the sake of other Europeans. Several aspects of Union law make trust in other Europeans more important. One feature of the European Union that makes compliance especially dependent on trust is that it is national governments that implement EU decisions and directives. If Union legislation is perceived as 'interference' or an improper imposition on domestic government, and this becomes widely known, it will be difficult to secure compliance.

Veto powers intended to protect vital interests easily lead to deadlock in the absence of trust. No one must suspect that others will veto extensively to their own advantage - otherwise veto easily turns into a bargaining chip. Majority voting also requires trust. The minority that loses in decisions is required to act contrary to their own interests, possibly against the majority of their fellow domestic citizens, out of respect for the majority decisions made in European institutions (Scharpf 1997: 21). The minority that submits must trust that future minorities will do likewise (Taylor 1969; Barry 1991). Minorities must also be confident that the majority will take their interests into account. Legislators must be trusted by each other, and by the populations, to consider the impact on all Europeans when making law.

The population at large must trust the legislators and executive branch. For instance, if the population perceives that the Commission abuses trust, acceptance and compliance with its decisions are at stake (Wessels 1999: 268). Another source of mistrust could be whether the domestic government officials attending Commission committees shift their loyalties, from government representatives towards evoking roles as supranational, pro-integrationist agents (Egeberg 1999; Egeberg and Trondal 1999; Trondal 2000).

B4 Willing support for institutional change

Trust is also important when institutions are created or modified in (quasi-)constitutional conventions. The Intergovernmental Conferences of the European Union regularly recast institutions in such ways, most recently in Nice December 2000. These institutions are important both because they give the decision-rules for the Union, and because the long-term role that institutions may have in shaping Europeans' motivations and values (Checkel 1999; Checkel and Moravcsik 2001). Given these high stakes, citizens and their representatives must be reasonably secure that their interests are considered and respected by other participants. Individuals must not believe that others will change institutions guided by shared values or ideals, e.g. concerning the proper allocation of tasks between the Member States and the Union.

If the Union remains a 'polycentric' political order with competences split and shared between Member States and Community institutions, the question of institutional stability becomes even more important. Historically, the institutions of such multinational federations have been less stable than those of unitary states. (Kymlicka 1998; Lemco 1991) A central challenge will be to maintain trust in the co-operation of others in the face of protests concerning the appropriate allocation of powers between the central unit and sub-unit, all the while maintaining loyalty both to the particular group and to the state. (cf. Lijphart 1977: 81-83; Mason 1999: 282)

Subsidiarity as a solution?

An important challenge, then, is to agree to the proper allocation and use of such powers. Within the European Union, the so-called Principle of Subsidiarity shall serve this role. This principle holds that Community action is appropriate only if 'the objectives of the proposed action cannot be sufficiently achieved by Member States'' action in the framework of their national constitutional system and can therefore be better achieved by action on the part of the Community.' The Principle of Subsidiarity faces several challenges (Follesdal 1998).

Firstly, there are various conceptions of subsidiarity. Some versions hold that larger-scale institutions shall support the smaller scale institutions in carrying out their tasks, while other versions hold that smaller-scale institutions must enjoy immunity from interference. The conception of subsidiarity of the EU Treaty is reasonably clear on such issues. The aim of the principle is to limit but also warrant actions by the Community to those necessary to secure the objectives of the Treaty. Decisions shall not go beyond what is necessary to achieve the objectives of the Treaty, and this must be substantiated. A global principle of subsidiarity awaits a clear interpretation. David Held, for one, suggests a similar standard of comparative efficiency for deciding whether to allocate powers to the global level (Held 1995, 236).

Secondly, the application of the Principle of Subsidiarity requires agreement on the ends of the political order, and the appropriate tasks of each level. This is currently not in place in Europe, and certainly not regarding global level institutions.

Thirdly, and related, a particular problem arises insofar as the multi-level political order is asymmetric, in the sense that some sub-units will enjoy certain competences, while others will not. In Europe today this finds expression in the Monetary Union, uniting some but not all Member States. States will disagree about the proper tasks and responsibilities of the Union, and some citizens and their politicians may plausibly claim a larger say in matters monetary. This is even more so if the future holds 'multiple Europes' of asymmetric federal arrangements where Member States have different bundles of competences.

These remarks suggest that a fundamental challenge to the future European Union is to ensure that Europeans develop and maintain trust in one another and in their common institutions, particularly if the Union increases its power and remains a polycentric, asymmetric political order. Europeans must have reason to believe that they all comply with common laws, and that their new institutions and rules deserve compliance.

One important function of Union Citizenship can be to bolster such trustworthiness.

C. The Basis of Citizenship

An immediate objection to Union citizenship as a facilitator of trust might be that this is implausible. It is unrealistic to believe that Europeans will act on feelings of solidarity and charity across hundreds of miles (Preuss 1995: 275). The shared culture and common heritage of Europeans seems too thin to support the required trust, especially when compared to the national heritages bolstering compliance within the European welfare states. There is no 'demos' in Europe (Preuss 1995), no shared sense of destiny or broad set of common values.

However, a 'thick' common basis of shared beliefs, values and traditions is not needed. There are states without 'thick' shared values and sense of community. Indeed, the search for a common ethnic or cultural base for 'belonging' worries many Europeans, due to the memory of past wars based on such grounds.

Instead, I submit that a satisfactory account of Union citizenship need not build on a broad base of common identity, culture and history. It can build on a shared sense of justice and more limited commitments to the equal dignity of all Europeans, motivated by a 'desire ... to arrange our common political life on terms that others cannot reasonably reject.' (Rawls 1993: 124; and see Ackerman 1980:69ff.; Weiler 1995; Preuss 1996: 275; MacCormick 1996: 150; MacCormick 1997: 341; Habermas 1998).

On this view, the motivating force is not a feeling of altruism, but a sense of justice, a preparedness to comply with those institutions that apply to us that are just (Rawls 1980: 540). Day-to-day compliance with laws and other commands is required by the duty to honour others' legitimate expectations, and the sense of justice as it binds us to the institutions that surround us. This is a different motivation for individuals' compliance than 'sentiments of affinity', the emotional bonds between individuals. A central question to this account is whether this inherently 'abstract' sense of solidarity based on universalistic principles of social justice can motivate, and be sustained over time (Preuss 1995, 275). However, even existing nation states are usually too large to foster empathy and sympathetic concern for the wellbeing of all others (Calhoun 1996: 3; Goodin 1988). And still they seem to enjoy support from their citizens - at least for the time being. The account I sketch below assumes this more 'impersonal' motivation: a sense of justice, an interest in doing our moral duty and expressing respect for others, rather than from a sense of community, 'thick' identity, or empathy.

C1 Citizenship: Commitment to Institutions and to a Political Theory

For trust among citizens, it seems that they must be habituated to three sets of commitments.

Firstly, citizens must be committed to their institutions and the decisions and rules that their officials make. In practice, this means that they must generally be prepared to abide by the laws and other rules that apply to them. In this way they respect the legitimate expectations of those around them who depend on their compliance.

Citizens must also have reason to believe that others will continue to comply in the future. Such trustworthiness, essential for stability, can be maintained by a publicly known, generally shared commitment to comply for what each person regards as good reasons. The second commitment is therefore to principles of legitimacy for institutions.

Such principles of legitimacy, duly worked out for polycentric polities, serve several roles in accounting for stability. One is to provide critical standards for assessing existing, concrete institutions. Another is to secure some shared bases for compliance with just institutions, since these principles provide justification for such existing institutions.

The third common commitment is to the immediate premises for such principles, for instance in the form of a conception of citizens as equal members of the polycentric political order. To illustrate this commitment, consider John Rawls' suggestion that the social institutions should be regarded as a system of co-operation among individuals regarded for such purposes as free and equal participants (Rawls 1971). That particular conception is insufficient for the challenges facing the European Union, since the Member States and Community institutions split and share sovereignty. A shared conception of the proper responsibilities of Member States and the Union seems necessary to allocate powers between them, for instance by specifying the Principle of Subsidiarity further.

There are two reasons for this third kind of commitment. A consensus on institutions and principles of legitimacy is insufficient to convince others of one's trustworthiness regarding future compliance with these procedures. Others' present compliance does not by itself give us reason to trust that they will continue to respect the principles of legitimacy - we also need assurance that they regard themselves as having reasons to continue to comply in the future. Moreover, the trust needed in the European Union now also concerns the creation of institutions. Such tasks must be guided and seen as guided by a sense of justice, including a commitment to a shared conception of the equal standing of Europeans within the polycentric European political order.

C2 Talk of Citizenship may erode Trust in the Union

The label 'Union Citizenship' indicates that the future European order must satisfy democratic principles harking back at least to Jean-Jacques Rousseau and Immanuel Kant. Equal respect requires that those subject to laws should also have an equal say in legislation and other matters European.

By invoking the notion of citizenship, the European Union commits itself to the normative ideals and requirements developed over centuries in Europe. Long-standing European theories of political legitimacy insist, for instance, that a legitimate political order must provide terms for living together that in some sense could secure the consent of all (Locke 1963; Rousseau 1978; Kant 1970). Constitutional democracy has come to be seen as one such condition, where citizens can hold their rulers accountable on the basis of unconstrained common debate and deliberation.

However, many observe that the European Union falls short of such conditions for legitimate rule: there are few opportunities both for deliberation and for accountability. Insofar as talk of 'Union Citizenship' highlights these deficits, it may serve to reduce, rather than enhance the support and trust Europeans exhibit towards each other and their common institutions. So Union Citizenship destabilises rather than consolidates the European political order.

In response to this worry, it seems clear that talk of citizenship may fail to provide the desired support for existing institutions. However, the conclusion is not automatically that the normative political ideals and standards of democratic governance should be scrapped. This would run counter to the traditional critical function of normative political theory in the Western tradition.

The need to enhance democratic control appears unavoidable given the political impact of the Union. Talk of 'Union Citizenship' does not create these tensions, nor do the tensions disappear by abolishing the term - for that, institutional reforms are required. And it remains to be seen whether there is political will and resources for such political craftsmanship (Olsen 2000; Joerges, Mény, and Weiler 2000).

In response to this worry, I submit that pessimism on the basis of current absence of trust is premature (Follesdal 2000). The development of a European sense of commonness can be a dynamic process. Given that institutions can shape citizens, common institutions may help create the requisite commitments and will to live together, thus building trust (Preuss 1995: 277-8; Preuss 1996; Streeck 1996: fn64 and 74; cf. Putnam 1993: 184; Rawls 1999: 112; Habermas 1998; MacCormick 1997: 353).

The arenas for public debate may also emerge with time. The lack of a common language may be less severe insofar as the agenda can be limited to political issues, and among them only those that are of common European concern (La Torre 1998; Habermas 1992: 7).

Nevertheless, the relatively feeble European public sphere and weak socialisation to a common European sense of justice may warrant caution about a premature reliance on majoritarian decision-making (Grimm 1995: 293-94). Institutions should economise on trust while at the same time fostering the means for credible commitments among Europeans.

C3 The Challenge of Multiple Citizenship - Conflicting loyalties?

Historically, citizenship has often been regarded as exclusive. One is hopefully a citizen of one state - but only of one. Many states have traditionally prohibited multiple citizenships. One long-standing worry about multiple citizenships is that individuals will suffer from conflicting loyalties and split identities. Union citizenship is explicitly a second citizenship, supplementing rather than replacing citizenship in a Member State. This would lead to a fear that instead of bolstering trust, Union Citizenship will foster split loyalties.

In response, we can note that the basis of citizenship sketched above is not exclusionary. It does not rely on a broad cultural basis or a thick sense of national identity and pride. It is thus - at least in principle -- compatible with other, concurrent commitments and loyalties. Conflicts may still occur, of course, insofar as the Member State government and Union institutions issue conflicting orders or legislation and there is no final judicial authority. Such occasions can be drastically reduced insofar as Courts with European jurisdiction have the final word, on the basis of a clear delineation of authority and competences.

I have suggested that one important task that Union Citizenship can play is to facilitate trust and trustworthiness, required for stable compliance and support of Union institutions. To secure such trust, all Union citizens must share some common grounds that include the commitment to existing institutions, and to shared principles of legitimacy. Moreover, citizens must also share the immediate grounds for principles, for instance conceptions of the ends of the political unity, and some conception of the proper relationship between individuals and non-unitary European political order, where Member States and Community institutions split and share sovereignty. These three commitments would seek to avoid contested parts of specific religious or philosophical world-views. At the same time, the shared basis goes beyond "Constitutional Consensus" or a "Constitutional Patriotism", that require consensus on procedures for making and interpreting authoritative decisions (Baier 1989; Habermas 1998). Agreement on procedures seems insufficient for maintaining the mutual trust necessary for constitutional changes and institutional development.

Critics will point out that there are broad discrepancies between the institutions of the European Union, including Union Citizenship, and the requirements of normative political theory. But such deviations are not necessarily a flaw of the theory. They may equally well be weaknesses of the institutions, highlighted by a normative theory. That talk of citizenship may increase conflicts, and not only induce support, should come as no surprise: governments have often discovered that citizenship rights have "the potential for exacerbating, as well as diminishing the conflict of classes" (Goodin 1988).

D European and Global Citizenship

Union citizenship may help clarify the notion and possible political roles of global citizenship.

Union citizenship invokes the notion of citizenship. This commits the European political order to the equal standing of all individuals, including democratic control over the institutions that shape their lives. We may call this underlying normative commitment Normative Cosmopolitanism. It is universal in scope, insisting that if someone is affected, they should receive equal consideration regardless of race, gender, social status or citizenship.

Normative cosmopolitanism does not in itself require global institutions. But those equally affected by practices and institutions should also have an equal say in how the institutions should be shaped. Such arguments apply at the European level: Europeans are now so interdependent due to their common institutions that they must also have an equal say in how they are governed (Follesdal 1997b). The institutions of the Union, including Union citizenship, must be shaped to ensure such democratic accountability.

This line of argument can serve as a model with regards to claims to institutionalise global citizenship. Globalisation reduces the significance of state borders, due largely to the digital and trans-national economy. Our decisions increasingly affect others across borders, increasing the interdependency of foreigners. Insofar as global regimes have global implications, normative cosmopolitanism requires that they must also be under political control where all have an equal say. The fact of globalisation, if indeed a fact with drastic implications on individuals' life chances, supports a normative requirement to address the global democratic deficit.

The requisite legal protections and controls may take at least two forms, reminiscent of the classical distinction between passive and active citizenship. Firstly, there may be institutional arrangements that provide immunity to individuals and communities against severe damage wrought by others. A wide range of human rights and practices of sovereignty are examples of such protections. Secondly, individuals may enjoy institutionalised influence in the form of political rights over the institutions and regimes. National citizenship typically provides both forms of controls. Europeans also enjoy both forms of controls: Passive rights are expressed in the form of European human rights regimes - including the recent Union Charter on Fundamental Rights. Active rights are enjoyed in the form of voting rights of two kinds: through democratic control over domestic governments represented in the EU Council; and secondly regarding directly elected representatives to the European Parliament. Union citizenship ensures the latter political influence to Europeans residing in Member States other than their own.

Hitherto, insofar as global citizenship is institutionalised it primarily consists of passive rights in the form of universal human rights standards. Elements of the United Nations may be enhanced to provide equal political influence over various regimes, but such global political rights are not well developed - yet.

The discussion of Union citizenship indicates that institutionalising active global citizenship faces several challenges.

Global political authorities do not automatically alleviate the problems of globalisation - to the contrary, they can easily be abused to the further detriment of the powerless. To ensure that a global political order expresses respect for all on a footing of equality, the institutional design is of utmost importance. Moreover, if these decision-making bodies are to enjoy compliance and support, they must be trusted to make just decisions. If they are to be representative, this entails that most global citizens must be committed to a common normative basis. The account of Union citizenship sketched above suggests that such a basis need not draw on a broad shared history and culture. Nevertheless, several commitments must be broadly shared, including a conception of the proper tasks of state governments, regional bodies such as the EU, and global institutions. Such a shared political culture must be fostered, and maintained. The risks of abuse of such global institutions are obvious, particularly in the absence of global arenas for political deliberation and habituation. But gradual development in this direction may still be feasible - and the alternatives may be even worse, judged from the point of view of normative cosmopolitanism.

Conclusion

The present reflections have focussed on the role of Citizenship in securing trust, and thereby contributing to compliance with legitimate institutions. This concern for trust seems to have fuelled the call for Union citizenship. Similar needs arise at the global level in the wake of globalisation, and global citizenship might be considered a solution.

If Union citizenship is to secure trust and trustworthiness in the population, a common normative basis is required. I have suggested that this basis need not primarily focus on a common history and culture and a broad sense. Instead, three commitments may suffice; to the institutions and hence the legislation they engender, to principles that justify these institutions; and to a political theory that grounds these principles in a conception of the proper role of individuals, of member states and of the Union. Such common grounds may suffice to ensure trust and stable compliance.

Talk of Union citizenship sets standards of legitimacy for such a shared basis, but the actual institutions and shared commitments fall short of these standards. Insofar as Union Citizenship highlights these deficits it may reduce rather than enhance the support and mutual trust of Europeans.

The response should not be to dismiss the normative political ideals and standards of democratic governance. Given the impact of the Union, the need to enhance democratic control is unavoidable. Long-term trust among Union citizens depends on resolving the legitimacy deficit of the Union. However, it remains to be seen whether there is political will and resources for such changes.

Similar considerations appear to hold concerning institutions for global governance. Present global regimes regarding issues such as trade, environment and human rights fall short of the normative standards of global justice. These conflicts cannot be resolved by dismissing any attempt at bringing normative political theory to bear. Resources, competence and political will are required to increase the legitimacy of the political orders both in Europe and globally. Reflections on Union citizenship and global citizenship might motivate and guide such changes.

Notes

1. The research for this paper was funded by ARENA - a program of Advanced Research on the Europeanisation of the Nation State, under the Research Council of Norway, and by the EU TSER program (SOE 2973056) on European Citizenship and the Social and Political Integration of the European Union.
I have benefited from comments by Stefan Gosepath, Jos de Beus, Carlos Closa, Hans Petter Graver, Pablo De Greiff, John Erik Fossum, Percy Lehning, Neil MacCormick, Johan P. Olsen and Ulf Sverdrup. This paper explores further some themes addressed in earlier works, particularly Follesdal 1997a and Follesdal 2001.

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