Dmitry Karateev

Regulation and Reform: Analysis and Policy

Analytical Essay. Dmitry Karateev

TOPIC

'Decentred' Regulation Concept in the Framework of Migration NGO Activities in Germany

INTRODUCTION

The history of German migration policy dates back to the time when Germany as such

did not exist. After numerous religious wars in the 16th and 17th centuries, the German

principalities and duchies became one of the first lands in Europe which recognized their

need for labor resources. Given the devastating effect of the wars that Germany waged after

imperial unification, the prerequisites of various requests for the need to attract labor from

abroad became more obvious. After World War II, which left Germany not only destroyed,

but also divided by two ideologies, politicians from both sides tried to retrieve a way out of

their predicament. Many people died in battles and concentration camps, therefore the work

on the restoration and further progress required colossal capacity. The genuine precursor of

modern migration policy in Germany was apparent at the period between 1955 and 1968,

when BRD (Federal Republic of Germany) decided to make a bunch of special labor

agreements with several countries. The first of them were assigned with Italy (1955), Spain

(1960), Greece (1960) and Turkey (1961) (BPB, 2005). This kind of treaties was named

Anwerbeabkommens zwischen der Bundesrepublik Deutschland und anderen Staaten

(Recruitment agreements between the Federal Republic of Germany and other states) and it

was given a start to develop the real policy in migration sphere for BAMF (Federal Office for

Migration and Refugees). This institute was founded in 1953 mostly for the reasons of the

repatriation of Germans from the lands previously occupied by the Third Reich, the
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acceptance of refugees from DDR (German Democratic Republic) and the regulation of the

massive inflows of former German and foreign aresteers of prisons and stalags both in

Germany and in former occupied countries (BAMF, 2018). This period between 1953 and

1989 was considered by German scholars of migration processes as the time of labor

migration to the country.

After the Warsaw Pact dissolution and reunion of two Germanies, another direction of

migration policy was clearly outlined on the agenda - the repatriation of Germans from the

countries of the socialist bloc. Very soon the number of ethnic German resettlers increased

significantly in the Federal Republic of Germany in the late 1980s and the early 1990s.

Returnee immigration reached its first climax in reunified Germany in 1992 and continued to

be relevant until the end of the decade. The period between 1985 to 1999 is usually called the

time of reunion migration (BPB, 2018).

The third major wave of migration in the German history fell on the period of the

European Union formation and the Dublin Agreements’ adoption, which later became the

main direction of the general migration policy in Europe. Since 2010, the inflow of migrants

has been increasing again. In 2015, immigration was at its highest in the history of the

Federal Republic of Germany, especially due to the large inflow of asylum seekers. The cause

of these statistical shifts is considered to be the aggravated internal conflicts in North and

Central Africa (Libya, Sudan and South Sudan, DR Congo, Somalia, Rwanda), ‘Arab spring’,

the war in Syria, the turbulent situation with Turkey, Iraq, Afghanistan and Pakistan. One

way or another, these events have drawn the migration policy of Germany and BAMF

particularly into two new regulatory currents. The first is the growing tendency in asylum

seeking from the poorest (and necessary to mention, radically islamized) countries. The

second is acting together and within the supranational migration agenda dictated by the EU,

the European Commission and the Dublin Agreements (BBC, 2015).

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These three described waves of migration and four directions of migration policy

form the general kinds of common migration policy in Germany these days, which does not

suit many political and societal groups in society. It is possible to hear from the different sides

of it a request for a special reaction and plans that will mitigate the negative effect on the

country. Not finding answers in state institutions, the particular NGOs begin to arrange, the

essence of which is to promote their own vision of regulating migration relations. This study

will present an attempt to analyze the reforms of policy practices of the German

Bundesministerium des Innern, für Bau und Heimat (Federal Ministry of the Interior,

Building and Homeland) and the BAMF over the past five years since the crisis of the Dublin

Agreements appeared and to investigate an attempts to form a ‘decentred’ approach to

regulation migration processes in Germany (‘regulation from below’). We will try to consider

these aspects through the prism of Decentring Regulation Concept of J. Black,

Meta-regulation of P. Grabosky and Transnational Non-Government Approach of Natasha

Tusikov.

THEORETICAL FRAMEWORK OF REGULATION PRACTICES

Julia Black in the article “Decentring Regulation: Understanding the Role of

Regulation and Self-Regulation in a 'Post-Regulatory' World’ and ‘Critical Reflection on

Regulation” defines the regulation as ‘the act of controlling by government through a

separate agency with respect to business using rules’. However, given the current

post-regulatory era, the concept of ‘decentred’ or polycentric governance is gaining

popularity nowadays. This concept does not imply that the nation state withdraws itself from

the process of control and command. Due to democracy growth around the world, it only

steps aside, hence considers only as a particular actor with a sufficient variety of levers on

specific policy, but NOT absolute. The most important aspects, explaining these changes in
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policy process identified by J. Black as follows: fragmentation and construction of

knowledge; fragmentation of the exercise of power and control; autonomy of social actors;

interconnection between government and particular social actors; the collapse of the

public/private distinction. This composition of facets formulates a general tendency to limit

the extent of government influence on any of the political events. 'Decentring' regulation, thus

refers to changing (or differently recognized) capacities of the state and limitations on those

capacities (Black, 2001).

Paul Grabosky in his works propose not a ‘decentred’ model, but rather a polycentric

model of regulation, where the state is not on the sidelines. The state, as well as other actors,

influence regulation, but at the same time it has a greater number of capacities than in the

‘decentred’ understanding. He highlights the most common criticism of the ‘decentred’

model, which appears as a lack of strategic coherence and lack of accountability. Despite the

availability of procedural safeguards and economic disincentives to frivolous and vexatious

private actions, they are hardly a regulatory panacea. It is activity upstream, that is prior to

the occasioning of harm, which is likely to be more productive, and to which mankind turns

now (Grabosky, 1994). Grabosky repeats after Black that the main issues of CAC model

decrease lie in the withdrawal of state regulatory activities, the increase in the number and

activity of non-governmental participants (NGOs and transnational companies) and the

growth of technology influence on the policy processes. Nonetheless, he prefers to call it not

so much as decentrism, but as a model of meta-regulation. This distinction should be

explained by the significant contribution to the development of electronic protest and targeted

elaboration with certain social groups seeking to control the process from below (Grabosky,

2017). Therefore, in addition to weakening the state’s might and NGOs’ amplification, it

must be noticed that the huge role of the Internet and social networks gave the tangible

impetus to the era of meta-regulation.

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Natasha Tusikov (2017) reflected on the interpretation of transnational non-state

regulation; subsequently, she comes to the inference that it is necessary to draw attention to

moral, technical or discursive power are used by state and non-state actors, and grasp to how

they exploit their resources to gain structural authority and influence from below to get an

input, which would be able to satisfy as much social actors amongst as possible. Given the

diversity of actors and activities, making up this type of regulation, there is no standard

definition of transnational non-state regulation. It can be broadly understood as non-state

actors making, implementing and/or enforcing rules and standards across national borders.

Transnational non-state regulation connects with theories of globalization - most obviously

regulatory globalization. As transnational non-state regulatory regimes comprise a broad

array of actors, rules, arrangements, strategies and interests, it is important to examine each

regime’s constituent components (Tusikov, 2017). In the case of Germany, global trends in

regulation (especially migration regulation) are very noticeable. Since Germany is now a kind

of trendsetter of European unity, it remains important, how the state interacts with

supranational institutions, and how the state engages NGOs in the triple dialogue.

However, before finding out whether the current system of migration policy in

Germany can be designated as a particular model, it is worth primarily to examine the latest

regulatory initiatives developed after the migration crisis in Europe.

MIGRATION POLICY FROM THE ‘CENTRE’.

As was stated previously, Germany's migration policy at the federal level is

governing, operating and regulating by several actors: Federal Ministry of the Interior,

Building and Homeland (BMI); Federal Government Commissioner for Migration,

Refugees and Integration (Bundesbeauftragter für MFI); The Federal Office of Migration

and Refugee (BAMF); Federal Office of Administration (BVA). The first two bodies have
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more executive and regulatory powers, while the last two are operational and

practice-oriented. Nevertheless, all these institutions are endowed with initiative and advisory

functions.

It is always emphasized in the institutional documentation that the migration policy of

the Federal Republic of Germany is ‘intended to manage, control and limit the immigration

of foreigners to our country’. It pays attention to the ability of our society to take in and

integrate new arrivals and to our economic and labour market interests. Migration policy also

serves to meet agency humanitarian obligations before the migrants and refugees (BAMF,

2019). However, the German migration policy has hardly changed since the recent laws that

regulate immigration in a period of relative stability were involved in the general agenda. It is

about such laws as Migration Act (2005), Immigration Law (2005), Labor Law (2007),

Citizen Regulation Law (2008), Meselberg Cabinet Decision (2008). Basically, this package

of laws unites by the general tendency of the state to take responsibility for immigrants’

integration into German society and standardization of common migration regulation for all

EU members. Among the most important innovations are: simultaneous issuance of residence

and work permits, financing language and legal courses with government subsidies,

mitigation of restrictions for several work places, introduction of the ‘golden visa’ practice

for foreign investors, standardization of the citizenship test for all German states, the surcease

of ‘domestic worker preference’ practice for scientists and academic workers with a tertiary

degree (Suessmuth, 2009).

The general practice of regulation of the movement and activities of migrants in

Germany has also not changed much since 2012. Federal Ministry of Interior with the BAMF

and BVA consultation adopted six basic ordinances and acts for foreigners: Residence

Ordinance (AufenthV), Employment Ordinance, Employment Procedure Ordinance,

Ordinance on Integration Courses, Asylum Procedure Act and the Asylum Seekers’ Benefits
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Act. The last two of them only introduced the peculiar changes to German migration policy,

namely, a reference to full compliance with the requirements of the Dublin II Regulation and

the sanctions for local authorities in the event of their violation (e. g, the refusal of authorized

body/placeman to consider an application for asylum in a certain Federal land) (Schneider,

2012).

On 1 August, 2012, the law implementing the Blue Card Directive in German national

legislation took effect. It modified the former Aufenthaltsgesetz (Residence Act) and

included a new residence title for highly qualified workers. The goals of the new law were to

make Germany more competitive to attract more qualified employees, contribute to reducing

labour shortages and thus benefit the German economy and society. For these ends, the

German government embraced the EU Blue Card. In 2014, Germany issued almost 90

percent of all Blue Cards while most other member states rely on their own national schemes

to admit highly qualified workers. Hence, the Commission looks carefully at Germany in its

efforts to recast the Blue Card Directive in 2016 as the first step to implement its new policy

on migration regulation after the Dublin III Regulation setback (Mayer, 2017). In this case,

the initiative to introduce the national Blue Card can be considered as a kind of illustrative

example for those EU countries that turned out to be neither physically nor mentally prepared

for the uncontrolled growth of refugees and illegal immigrants.

The latest amendment to the German migration framework entered into force on 6

August, 2016. The Integration Act and the Regulation on the Integration Act were aimed to

facilitate the integration of refugees into German society. The basic idea behind the

legislation is a continuation of the policy of “support and challenge”, which had been

introduced in 2005 in the Migration Act. Refugees who show the potential to integrate and

have a good chance of staying permanently in Germany are provided with easier and faster

access to integration classes and employment opportunities, while refugees who refuse to
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cooperate face a reduction in benefits (Gesley, 2017). The difference, albeit small, but is still

present in the new actions. For the first time since 2005, the state has thought about certain

restrictions for migrants and refugees who refuse to undergo the standard procedures. It was

related to re/settlement permission and, foremost, the labor market priority (The Federal

Government, 2016).

In 2018, a new Familienzusammenführungs Gesetz (Family Reunification Law) of

refugees was developed and adopted at the initiative of BAMF and BVA, which caused a lot

of controversy in Germany. In the regulatory plane, the law did not introduce anything new,

its essence was only to resettle an additional 1000 migrants per month, provided they are the

direct relatives of refugees already living in Germany. The main contradiction was that the

German government promised to regulate illegal migration and smuggling of illegal

immigrants, but there was no real progress in this direction (Kazaryan, 2019). In March 2016,

the German government introduced a two-year suspension of family reunification for

migrants only eligible for subsidiary protection. The bill was introduced just after the

migration crisis in 2015 and aimed to slow down the influx of refugees from besieged regions

of the Middle East. In February 2018, the Bundestag voted to extend the suspension of

powers by six months, but BAMF and BVA arranged on the terms of the new bill (Deutsche

Welle, 2018).

The latest major change in the regulatory practice of German migration policy was a

return to legislative reforms as part of the recruitment of highly qualified foreign workers. On

20 August, 2019, the Skilled Workers’ Immigration Act (Perma, 2019) and the Act on

Temporary Suspension of Deportation for Training and Employment were published by the

Federal Ministry of the Interior, Building and Homeland (Perma, 2019). These acts amended

the Residence Act and implemented several European Union directives (e. g., Council

Directive 2009/50/EC, Directive 2014/36/EU, Directive 2014/66/EU, and Directive (EU)

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2016/801). Sufficient to emphasize in these actions that they continue to maintain an EU

common vision on controlling migration and refugees. This is confirmed in the paragraph,

which says about the complete abolition of any preference in relation to citizenship for “labor

market priority check”. A skilled worker now may not undergo the national vocational test as

long as he/she will provide a domestic certificate or university diploma. The second law also

refers to the aforementioned EU directives, since here the ban on deportation in any form by

the national institutions is already strictly indicated here. The Act on Temporary Suspension

of Deportation for Training and Employment regulates toleration for the purposes of

employment and training, and provides the possibility of receiving a residence permit for two

years after successfully completing vocational training or being employed for 30 months

(Gesley, 2019). Taking into account the changes regarded with the COVID-pandemic, this

period can be extended for a long time, which will further reduce the influence of migration

institutions in the country.

REGULATION FROM GERMAN BOTTOM

Despite the openness of German society and government structures on a number of

issues, migration policy is continuing to be an occupational area of the federal government,

its own bodies and the EU. Nevertheless, according to the National Integration Plan adopted

in 2007, the German government announced the development of a dialogue with society and

non-governmental organizations, which will be able to present their own expert opinion and

further vision in the regulatory practice evolution of migration policy (BVA, 2007). The

National Integration Plan of 2007 and the National Action Plan for Integration of 2012 were

the first attempts of executive bodies to involve experts and those people for whom it was

actually necessary to develop a feasible migration policy in the dialogue. In 2016, 50 active

migrant organisations gathered to come up with concrete proposals on how to make public
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institutions more diverse. One of the main issues of the last discussion was the absence of

migrant voices and civil society influence when federal bodies are making various decisions

and adopting acts and ordinances (European Commission, 2017). For instance, Refugee

Welcome and Immigration-2-Germany insist that Germany in accompany with EU policy

give rise to the following problems for proper integration: the lack of transparency and

accountability in the national migration policy making, the securitization of the migration

challenge by focusing security concerns about the negative sides of new populations to the

host society and integration and the use of research methodologies in investigating migration

related topics from theoretical and expert academic positions (Boswell, 2016).

The main document that many NGOs in Germany operate now with is the one

adopted in the same 2016 Impulspapier der Migrant*Innenorganisationen zur Teilhabe in der

Einwanderungsgesellschaft (Impulse paper from the migrant organizations on participation in

the immigration society). Migrant*innenorganisationen are understood as initiatives or

associations that were predominantly founded by people with an immigrant background or

that are involved in migration and integration-specific topics. The members of migrant

organizations usually have migration experience themselves and can therefore help other

people who are new to Germany to settle in in Germany. Tasks and goals, the composition of

the association members and the degree of organization of the migrant organizations can be

very diverse: in addition to religious, cultural or political associations, there are associations

of certain immigrant groups, student associations, professional associations, sports clubs,

business associations or educational institutions. In their composition, migrant organizations

can also consist exclusively of women, mothers, men, fathers, parents, senior citizens or

young people. The offers of the migrant organizations are diverse, including interpreting

services, advice (migration, social, legal), events, cultural offers, courses and trainings, offers

in the field of education, parent education and other integration projects (Berlin.de, 2018)
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This paper reveals the vision of integrated German migrants to revise the approaches

to migration policy in Germany. Of the specific measures, four main goals can be

distinguished: to legislatively encourage the national diversity in public participation, to

aspire for diversity participation in the intercultural openness, to provide equal participation

in decision-making functions and in federal services. For these purposes the several NGOs

offered an inclusion of a new state goal in the Basic Law as Art. 20b: “The Federal Republic

of Germany is a diverse country of immigration” which should promote equal participation,

equal opportunities and integration of all people, despite race and nation” and “Adoption of a

new joint task within the meaning of Art. 91a GG “Equal participation, equal opportunities

and integration” which ensures that the federal government supports the federal states in the

framework planning and financing of these goals, also in terms of improving living

conditions”. In addition to this, the anti-discrimination agenda was strengthen by the next

measures’ proposition: the extension of legal anti-discrimination rules to include ethnicity

and positive discrimination; joint voluntary commitments to develop a model; the

introduction of a check of the intercultural opening in legislative processes (IKÖ check); The

inclusion of the laws, maintaining confidentiality in legislative proposals and executive

bodies for mitigation of racist tendencies. As for results, contributions of this cooperation are

following:

- It provided confidants for ombudsman offices. This lowered the obstacles for concerned

migrants and ensured better communication. They are also able to participate in the process

of establishing ombudsman offices;

- It supported research processes by ensuring that research could be carried out

"group-specified";

- It became stronger service providers in the field of refugee aid or to expand existing

commitments;
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- It tested offers and services for intercultural sensitivity and reports on them (basing on the

instrument of 'mystery shopping') (Impulspapier der Migrant*Innenorganisationen, 2016).

Apart from this agenda Bundesnetzwerk TANG - The African Network of Germany,

Paritätischer Wohlfahrtsverband and MIGRANET-MV add that it is no less important in

current migration policy to discuss issues of maintaining a professional level among migrants

and maintain transparency in the adoption of annual quotas. The importance of allocating

funds for training, testing and courses from both federal and regional budgets is emphasized

Interested migrant organizations should be able to be certified as carriers of intercultural

organizational development and anti-discrimination measures, analogous to the process of

certification of institutions of political education. This certification process is supported with

three-year start-up funding. In 2017, it is to develop an implementation strategy with the aim

of realizing the representation of people with an immigrant background in the federal

administration in proportion to the population share. In this context, Section 5 of the General

Equal Treatment Act (AGG) must be further developed, also to ensure that target quotas are

met (BKMO, 2018).

Generally speaking, the most of these initiatives have not yet been considered by the

federal authorities and, in fact, the legal field was influenced only by the recommendation to

improve conditions for skilled migrant workers and the allocation of budgetary funds from

both the federal and the regional treasury (Perma, 2019).

CONCLUSIONS

‘Decentred’ regulation in migration policy of Germany can be traced rather weakly,

since the federal authorities and its accountable operational institutions willingly let NGOs

into dialogue, but at most as experts and practitioners who are faced with a solitary problem

of the system. At the same time, we are able to oversee the growing dependence of the
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German government on the initiatives and directives of the EU and the European

Commission, since each subsequent law adopted in the framework of migration policy was

increasingly linked to the agenda of a supranational institution in Europe. In this regard, the

German federal authorities seem to be trying to maintain a balance between NGOs and

supranational formation, since officials understand that the agenda of the former is too radical

to allow these organizations to take part in real regulatory processes. Meanwhile, the EU

itself is a rather flexible instrument that allows you to gradually reduce the level of radicalism

on the part of NGOs and influence other members of the union in order to more evenly

distribute new migrants. Within the framework of this situation, we understand that the

approach of Grabosky and Tusikov is more competently described the German model than

Black, since the state continues to keep its top position above the social actors and

contemporary acts on a par with transnational entities represented by the European Union.

But despite fairly good progress over the past decade, German legislation, just like the

regulatory practices of German government institutions, did not allow to avoid the negative

influence of the crisis that happened in 2018. We can assume that some of the problems with

this are due to the lack of a genuine fragmentation of the exercise of power and autonomy of

social actors in German society. Apparently, within the framework of the German case,

Grabosky is right, arguing that the modern system of meta-regulation is characterized by

spontaneity, which inevitably causes certain desires to control the process from below (P.

Grabosky, 2013). As we can see, the regulation of the current migration policy is

characterized by some consistency, but at the same time, it is logical, which pursues not so

much to solve certain problems, but to maintain a certain balance between the actors. This

keeps the state afloat, since NGOs have enough instruments of influence, but do not know

how to use them and whereas it is more profitable for transnational organizations to cooperate

with the state than to contact not quite stable NGOs.

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