With the Freedoom of Movement being essential within the EU – it being exactly what has allowed me to stay and work in Austria as a UK national, another issue was alerted to me, which may affect fewer people, but which until recently would have affected someone no less prominent in the Brexit referendum than Boris Johnson.
Mentioning he-who-shall-not-be-named in a blog that remains strongly on the “in” side of the fence, even conceding my previously Eurosceptic self was bound to happen sooner or later. Without wanting to consider “what exactly the hell is he playing at?” Boris presents an interesting case. Granted that it is clear that he is firmly anchored in the UK, but there are others in a similar situation to his in terms of being dual nationals – with US-British joint citizenship (as an aside – in researching this fact I was amazed to learn that Johnson is ancestrally a veritable “Heinz 57” – as my grandmother referred to mongrels, whereas Johnson’s self-attribution is that of being a “one-man melting pot”) who find themselves in a difficult position. On a further aside, it should be noted that prior to his more publicly known time at Eton College, Johnson was schooled at the European School of Brussels I.
The issue for US-British citizens is a difficult one. Many have said that without their British citizenship the hurdles towards permanent residence, or the right to directly access the employment market in the EU would be vastly more difficult. A number of my friends are in the boat of having used their UK citizenship (usually held through having one parent who was a British national), although they have never actually lived in the UK, or some who did briefly, seeing America as the country that was more the centre of their vital interests, did not register to vote in the UK.
As previously mentioned, UK voting is different to many countries – there are a number of countries (regardless of EU members or not) that have overseas voters voting at their embassy – the list of countries where this is the case extends geographically from Russia to South Africa. A UK citizen continues to be registered to their last constituency (one friend recently said how he is eligible to vote in the Tiverton constituency, where he was last registered, although he has no links to the area any more). If you don’t have a last constituency (e.g. you had a brief spell in the UK prior to coming to Austria between elections) then you are unable to vote.
Having started to publicise this blog on linkedin, I was alerted to another circumstance that affects American-UK dual nationals, for whom the ludicrous 15 year rule has less effect than the fact of not having been registered to vote, and
[The 15 year rule] doesn’t apply in my case as I’ve only been gone 8 years; it’s rather the fact that I didn’t register while still living in the UK. However it also seems crazy that I can’t register now, from abroad, to vote in this referendum that is really the only UK ‘election’ that has an impact on me.
As a dual US-UK citizen, I would note that in spite of all the terrible things one can say about US elections and how they’re run, at least the US allows its expat citizens to vote forever (of course, we have to pay US taxes forever, too, so they have to give us something in return…).
The situation also affects dual citizens of other nationalities holding British and a non-EU nationality (now following the lapsing of the transitional agreements that restricted the intitial access of nationals of the newer (post-EU-15) accession countries the playing field is somewhat more level in the EU among its 28 members), who like those falling foul of the 15 year rule might also fall foul of the consequences of a Brexit.
To return to the title of this post in conclusion, it seems that there is a stratification of citizenship. I would draw a tangential parallel from the world of cricket. In 2001 Italy withdrew from cricket’s ICC Trophy, held in Canada, due to issues surrounding the the eligibility of some of its players. The grounds for its withdrawal, stated eloquently by Simone Gambino, the FCA’s President, was the fact that players of “acquired citizenship” were treated detrimentally in comparison to “citizens from birth” (sometimes also calls “natives”). Ultimately it has lead to the old qualification criteria for national teams being changed – as under Italian Law and many others it is not acceptable to differentiate between those have acquired citizenship and those who have held it from birth.
Sadly in the UK, those who have held British citizenship from birth, but who have chosen to further their career within the EU under the freedom of movement, or who hold a citizenship which is pivotal to their ability to live and work in the EU, are not being treated equally. I am sure that the Daily Mail readers out there (I know who you are, you share inane stories on Facebook!) will denounce me as an opportunist or as someone “who left the UK to go to Austria and steal an Austrian’s job!” but such attitudes are ante-diluvian.