The current rules for “free movement” in the European Union (EU) facilitate unrestricted intra-EU labour mobility and equal access to national welfare states for EU workers. Free movement is thus a case of “exceptionalism” in the view of longstanding theory and research which alleges the incompatibility between open borders and inclusive welfare states. The sustainability of this EU exceptionalism has recently been threatened by highly divisive debates between EU member states about the need to restrict some welfare benefits for EU workers. This paper develops a theory for why the current free movement rules might present particular challenges for certain EU member states. It focuses on the potential roles of three types of national institutions and social norms in determining national policy positions on free movement in the EU15 countries: national labour markets (especially their regulation and “flexibility”); welfare states (especially their “contributory basis”); and citizenship norms (with a focus on the “European-ness” of national identities). I show that these institutions and norms vary considerably across member states and explain why we can expect these differences to contribute to variations in the scale and effects of EU labour immigration, and to divergent national policy preferences for reforming free movement. Although focused on intra-EU labour mobility, the paper contributes to broader research and debates about institutional variations across EU member states, the potential tensions between national institutions/norms and common EU regulations, and the implications for the design and sustainability of different types of EU policies on migration and mobility.
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