In this article we explore how constitutionally enshrined and historically conditioned conceptions
of membership in Germany have continued to frame citizenship debates over the
last two decades. These debates have been revived both by domestic developments, such as
mass migration, and by external factors, such as European integration. The larger question
examined is the extent to which, at least in the European Union, conceptions of “ citizenship
” now evolve in reaction to “ internal ” or “ external ” factors, and how the balance of such
factors shapes the outcome of particular changes in policy. In our inquiry, we look fi rst at the
evolution of policy on access to full citizenship in Germany and then at that of its attendant rights
and obligations. Finally, we draw certain general conclusions from the German example for
European integration and for possible scenarios of coexistence of the national and European
citizenship models
