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24 Eur. J. Soc. Sec. 3 (2022)

handle is hein.journals/eujsocse24 and id is 1 raw text is: Article                                                         EJSS
European Journal of Social Security
2022, Vol. 24(1) 3-20
Regulating          the     Poor through                              ©TheAuthor(s)2021
Internal Borders: The                    EU     in                    Article reuse guidelines:
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Historical and             International                       DOI:10.1177/13882627211064637
journals.sagepub.com/home/ejs
Perspectives                                                                *SAGE
Martin Seeleib-Kaiser
Institute of Political Science, University of Tibingen, Germany
Abstract
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 coali-
tions, 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 signif-
icant role.
Keywords
China, England, EU, freedom of movement, Germany, social citizenship, social rights, USA
Introduction
Increased migration and mobility within the European Union (EU) have led to a politicisation of
freedom of movement and highly contested debates about 'unreasonable burdens' caused by
'welfare tourism' (Roos, 2019; Verschueren, 2014). EU citizens have the right to freedom of move-
ment and to take up residence in any Member State; but this right to residence does not

Corresponding author:
Martin Seeleib-Kaiser, Institute of Political Science, University of Tubingen, Germany.
E-mail: martin.seeleib-kaiser@uni-tuebingen.de