Regulating the Poor through Internal Borders: The EU in Historical and International Perspectives

Tensions surrounding internal migrants’ access to welfare and the associated politicisations about who should shoulder the ‘fiscal burden’ are not unique to the European Union (EU). Based on a Most Different Systems Design and following an institutionalist approach, this article analyses the developments associated with freedom of movement and access to poor relief/social assistance in four economically and politically diverse jurisdictions. It also considers the implications of these developments for the EU. The four cases analysed are industrialising England, contemporary China, Germany, and the United States. Although economic integration was a necessary, it was not a sufficient condition for the abolishment of residence requirements for internal migrants in all four jurisdictions. Moreover, it took political power, various coalitions, or the leadership of actors to overcome the barriers and hurdles on the path to social citizenship in the wider territorial jurisdictions. Solidarity as a precondition did not play a significant role.