Borderless Europe: Seven Decades of Free Movement

Europe is host to a unique free-movement area in which barriers to international migration and mobility are lower than anywhere else in the world. Citizens and permanent residents of 27 European Union Member States along with Iceland, Lichtenstein, Norway, and Switzerland may choose to relocate without hindrance for work, education, or pleasure across an area spanning from Scandinavia to the Mediterranean, and from the Black Sea to the Atlantic Ocean.

After years of expansion, however, the free-movement zone has come under tremendous strain over the last decade. The United Kingdom’s withdrawal from the European Union, which was sparked largely by concerns about intra-European migration, and border restrictions imposed amid the COVID-19 pandemic have profoundly tested the notion of barrier-free European movement.

The area emerged over 70 years of bureaucratic and political wrangling, in response to economic needs and citizens’ desires, and free movement has been widely regarded as one of Europe’s biggest successes post-World War II. Given its current challenges, how was it that such an area of free movement, with more than 460 million inhabitants, came into being? Why did the sovereign states of Europe give up the fundamental right of being able to decide which fellow Europeans can cross their borders and settle within their countries? And who are these intra-European migrants, who as of 2020 amounted to more than 15 million people?

This article provides a short overview of the development of Europe’s free-movement regime, including the European Union and Schengen Area . It discusses how different types of people have embraced this freedom and reviews recent challenges that have prompted questions about Europe’s future.

Origins: Post-War Economic Growth Fuels Demand for Mobile Labor

After World War II, Europe shifted from a region of net emigration to one of net immigration. Following the devastation of the war, Western European states suffered labor shortages and needed to recruit millions of workers to rebuild their economies. Laborers were most in demand in jobs that were dirty, dangerous, and dull—the so-called 3D—in the sectors of agriculture, building, mining, and transportation, and also later industrial work. Labor recruitment was mainly arranged via bilateral guest-worker agreements with Southern European countries, former colonies, and peripheral countries such as Turkey.

To reap these economic benefits, free movement for workers was included in the treaties founding the European Coal and Steel Community in 1951 and the European Economic Community (EEC), whose establishing document was known as the Treaty of Rome, in 1957. These communities were predecessors of the current European Union.

More than 8 million work permits were issued to foreigners by the original six EEC members of Belgium, France, Italy, Luxembourg, the Netherlands, and West Germany during the guest-worker period of 1958 to 1972. One-third of foreign workers came from elsewhere within the EEC, mainly from Italy, parts of which were less industrialized and had experienced high unemployment.

Rights of free movement for all EEC workers took several years to be fully realized, and finally came into effect in 1968. However, only a few years later, the 1973 oil crisis ground Europe’s economy to a halt and states no longer needed large numbers of migrant workers. Still, the seeds of free movement had been sown, and the economic and political collaboration would deepen in years to come.

Expansion of Free Movement: From Workers to All

The right of free movement was initially intended for workers who could support themselves in the destination country. Only the worker was to be welcomed, not their family members. However, founding treaties and follow-on legislation of the EEC left room for interpretation, and from the 1970s onwards Europeans have actively tested the limits of the law. Over decades, individuals have taken their cases to the European Court of Justice and filed challenges to deportation orders, denials of entry, refusals of access to benefits, and other national administrative decisions. Through its rulings, the court gradually began to shift the interpretation of the free-movement right from “workers” to “persons.”

Proactive legal changes also played a role. In what was the first major revision of the Treaty of Rome, the Single European Act of 1986 promised the creation of an internal market in which goods, persons, services, and capital could move unhindered. In 1990, additional regulations extended freedom of movement to students, pensioners, and the unemployed, as well as for their families, with certain limitations.

The right to free movement finally reached its pinnacle of applying to all Member State nationals in 1992, with the signing of the Maastricht Treaty creating the European Union and introducing the concept of a common European citizenship. The 1994 enactment of the Agreement on the European Economic Area (EEA) brought into the single market the members of the European Free Trade Association (EFTA): Iceland, Liechtenstein, and Norway. Switzerland, which is also an EFTA member, has its own bilateral agreements with the European Union.

These measures abolished restrictions on individuals moving between countries in the bloc, but they did not reduce bureaucracy at Europe’s internal borders or transform travel between Member States into the seamless process that it has become. This was the result of a separate intergovernmental initiative called the Schengen Agreement, which intended to promote mobility, tourism, and trade. When it went into effect in 1995, the agreement was separate from other European frameworks, and created a common area only between Belgium, France, Germany, Luxembourg, the Netherlands, Portugal, and Spain. However, two years later its rules were incorporated into the European Union’s Treaty of Amsterdam, and by 1999 most EU citizens were free to cross the bloc’s internal borders without showing their passports.

Border controls have been eliminated under Schengen for EU citizens as well as non-EU nationals living in or visiting the bloc, but intermittent challenges have arisen. In 2011, France tried to block Tunisian migrants coming from Italy, in a prelude to the border checks that emerged in multiple Member States amid the arrival of more than 1 million asylum seekers and other migrants in 2015. Total border closures were temporarily imposed in 2020, in the midst of the COVID-19 pandemic (discussed in more detail below).

Still, the bloc has persisted. As of this writing, the Schengen Area encompasses 26 countries: 22 EU Member States and four EFTA countries (see Figure 1). Five states are members of the European Union but not Schengen; Ireland has chosen not to be included in the zone, and Bulgaria, Croatia, Cyprus, and Romania are expected to join once they meet the full slate of requirements on external border control, data protection, and other areas such as cooperation against organized crime.

Citizens and permanent residents have the right to move to and settle anywhere in this 31-country free-movement area. Border checks still exist for those traveling from a non-Schengen Area country such as Romania or Ireland to a country within the Schengen zone, but citizens simply need to show their passport.

Enlargements of the European Union

As the legal freedom of movement has expanded over time, so too has the number of nations whose citizens have access to it. From its original six founding members, the EEC expanded first to include Denmark, Ireland, and the United Kingdom in 1973, followed by Greece in 1981, and Spain and Portugal in 1986. There had been anxieties particularly that inclusion of the latter three Southern European countries would prompt mass migration of workers to higher-income Member States. But this did not occur, partly due to six-year restrictions on labor migration imposed on new members as part of the transition.

Further expansion opened doors for intra-bloc migration for millions more Europeans. After formal establishment of the Maastricht Treaty, Austria, Finland, and Sweden joined the European Union in 1995, and in 2004 ten new Member States were welcomed in the bloc’s largest expansion to date. Among these new members were seven from the other side of the former Iron Curtain: the Czech Republic, Hungary, Poland, Slovakia, and the three Baltic states of Estonia, Latvia, and Lithuania. Membership was also granted to Slovenia and the island states of Cyprus and Malta.

The 2004 enlargement was controversial, due to estimates that between 5 million and 40 million economic migrants could move to some of the wealthier countries of the free-movement area. Some officials and media figures in older Member States worried that unlimited migration would cause serious problems for their labor markets. Similar fears that immigrants would undermine market wages and strain welfare systems recurred when Bulgaria and Romania joined the European Union in 2007, and to a lesser extent upon Croatia’s accession in 2013.

In part to alleviate these concerns, the bloc imposed transitional periods of seven years allowing historic Member States to determine when they were ready to open their borders to newer ones. (These restrictions did not apply to citizens of Cyprus and Malta upon their accession.) Free movement between all Member States was guaranteed by 2011 at the latest for citizens of the countries joining in 2004, by 2014 for citizens of Bulgaria and Romania, and by 2020 for Croatia.

At the time of the 2004 enlargement only three Member States—Ireland, Sweden, and the United Kingdom—immediately opened their borders to the newcomers. In Sweden, politicians believed their regulated labor market could absorb migrant workers without wages dropping. In the United Kingdom, officials expected relatively few migrants—a miscalculation that would play a role in the country’s decision to leave the European Union just over a decade later.

Prior to the early 1990s, there had been heavy controls on migration from these new Central and Eastern European Member States (also called the EU-11, for all post-2004 members excluding Cyprus and Malta). However, visa restrictions for Eastern Europeans traveling to pre-2004 Member States (known as the EU-15) had been lifted by the time these more recent states joined the European Union and well before transitional periods ended, so some large-scale labor mobility was already taking place before.

Who Are Intra-European Migrants?

There were 15.4 million citizens of the 31-country free-movement zone living elsewhere in the area as of 2020, according to Eurostat. This is a reduction from 19.8 million in 2019, before the United Kingdom’s withdrawal from the bloc, but the number of intra-area migrants has generally increased over time (see Figure 2). According to estimates, there were also 1.5 million cross-border workers and 3 million workers posted abroad within the zone in 2019. However, many forms of cross-border movement within this area remain uncounted by official statistics, as Europeans cross borders unregistered and often remain essentially invisible in their destination countries. The true number of migrants is likely to be larger.

When the free-movement regime was initiated 70 years ago it was intended to encourage blue-collar workers to cross borders for temporary employment in the industrial sector. Now, a wide variety of Europeans utilize this right.

Not all laborers move looking for work or to accept a job offer abroad. Many cross borders to commute to work on a daily or weekly basis. Workers are also sometimes posted by their employers to bridge short-term skill and labor shortages, and self-employed workers can choose the best market for their trade.

Laborers are not the only ones moving. Retirees and other so-called lifestyle migrants may freely relocate to whichever climate, culture, and country they wish. Many students earn parts of their degree abroad via the popular Erasmus+ program. Recent graduates can find trainee placements or seasonal jobs in other countries. And family members follow migrants or join loved ones wherever they live.

Mobile Europeans are privileged in comparison with those arriving from outside the free-movement zone. Yet there are also exploited and underpaid groups of migrants, including seasonal workers in agriculture, caretakers in private households, and posted construction workers, who are paid according to the salary level of their country of origin, not where they work. The EU Agency for Fundamental Rights has documented cases of employers exploiting intra-European migrants by withholding pay, deducting money for food and housing without notice, and forcing them to work excessive hours, among other actions. And in some cases, such as for Roma who face poverty and discrimination in Romania and Bulgaria, the free-movement regime has only opened the opportunity to beg in the streets of foreign cities.

Where Migrants Go

The most significant patterns of movement are from newer, Eastern Member States to those in the West, as well as regional migration flows between neighboring countries such as Germany and Austria, Denmark and Sweden, and Latvia and Lithuania.

The number of EU-11 citizens living in other EU Member States increased approximately five-fold between 2004 and 2019, to 8.7 million, according to Eurostat estimates, although this number dropped to 6.9 million in 2020, largely due to the United Kingdom’s withdrawal from the European Union. This change shows the importance of the United Kingdom as a migration destination. The largest numbers of EU-11 migrants in 2020 resided in Germany (2.6 million), Italy (1.3 million), and Spain (872,000); the largest number originated from Romania (nearly 3.1 million) and Poland (1.5 million), which are the most populous EU-11 countries.

Among migrants from the overall free-movement area, Germany has generally been a primary target; the country hosted 29 percent as of 2020 (see Table 1). More than two-thirds of migrants from across the European free-movement zone lived there or in Spain, Italy, France, or Switzerland. At the other end of the spectrum, Croatia, Liechtenstein, Bulgaria, Lithuania, and Latvia combined hosted less than one-half of 1 percent of migrants from other members of the free-movement area.

Meanwhile, the largest sending countries across the free-movement area, including to non-EU Member States, were Romania (3.2 million), Italy (1.8 million), Poland (1.7 million), Portugal (1.2 million), and Bulgaria (812,000) as of 2020. Citizens of these five countries accounted for 57 percent of all intra-regional movers that year.

Brexit, COVID-19, and the Future of Free Movement

In Eurobarometer surveys, Europeans often rank freedom of movement as the greatest achievement of the European Union, ranking above the euro, economic prosperity, or even peace. Yet this freedom has been under threat. Europe recovered from the Eurozone fiscal crisis which threatened to tear the union apart, but it may be permanently scarred by the fallout from the United Kingdom’s departure and the COVID-19 pandemic.

After decades of simmering Euroskepticism, the 2016 Brexit decision was backed particularly by voters expressing concerns about immigration and multiculturalism, among other issues. In some cases these voters, who tended to be less educated, poorer, and older, might not be considered to have benefitted from EU integration. As result, the 1 million British citizens legally residing in the European Union became “third-country nationals,” as citizens of non-EU Member States are known. Although they will continue to have broadly the same rights as before, due to the Withdrawal Agreement, UK citizens in EU Member States faced months of uncertainty before their situation was finalized, during which many had serious concerns about the future of their health care, pensions, and other services. The same was true for more than 3 million EU citizens living in Britain.

Brexit was arguably the largest shock to intra-European mobility in decades. Britain had been a key migrant destination, but new migrants now face barriers moving there. Au pairs, students, seasonal workers, and highly skilled migrants from other European countries wishing to live in Britain are subject to the same immigration rules as those arriving from outside Europe. The same applies for British citizens who can no longer freely move to study in Amsterdam, work in Paris, or retire to sunny Spain. However, citizens of the United Kingdom and Ireland can continue to freely move and reside between both countries, due to a longstanding Common Travel Area that was unaffected by Brexit.

Meanwhile, Member States have made their own decisions on responding to the COVID-19 pandemic since it arrived in early 2020, often initially acting alone instead of in coordination. Temporary unilateral restrictions on cross-border mobility, permitted under the Schengen Borders Code, were swiftly imposed.

From the perspective of the European Union as a whole, the situation has been a balancing act between protecting public health and preserving the integrity of the internal market. To safeguard the right to free movement and the economy dependent on it, EU officials created a list of exceptions to travel restrictions, including for critical and essential workers, returning nationals, and those traveling due to a family emergency. The European Commission has also begun rolling out a Digital Green Certificate proving someone has been vaccinated against COVID-19, received a recent negative test result, or recovered from the disease, in order to begin resuming free movement once the worst of the crisis ends. Yet the fact that national borders were closed so quickly suggests that countries may feel free to do the same in future public-health emergencies or other crises, potentially undermining the previously seemingly inviolable nature of free movement.

Furthermore, while many Europeans appreciate free-movement rights, anti-immigration sentiments have been on the rise in many countries. Nationalist leaders in countries including France, Greece, Hungary, Italy, and Sweden have linked COVID-19’s spread to migration, and pressures to impose border restrictions in the name of public health or state security are likely to persist in the post-pandemic era. It remains to be seen how these sentiments will impact free movement.

A more recent blow to free movement came in May 2021, when Switzerland abandoned negotiations to replace the 120 bilateral treaties governing its access to the European Union’s single market with a new framework. Among the sticking points were free-movement directives offering permanent residence to intra-bloc migrants and extending social security benefits to residents without employment. The current agreement governing free movement has no expiration date, so it is unclear if or how the situation on the ground will change. 

Recent years have posed challenges to the European regime, but what is clear is that neither freedom of movement nor the Schengen system are static concepts. The political, economic, and intergovernmental relationships upon which they are predicated will continue to evolve, as they have since the region’s inception. Brexit and the pandemic are just the latest developments to test Member States’ solidarity and mutual trust, but there will surely be more to come.

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