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. 2023 Jan 13;2:133. Originally published 2022 Dec 6. [Version 2] doi: 10.12688/openreseurope.15042.2

A timeline of freedom of movement in the European Economic Area

Emily Barker 1,a
PMCID: PMC10446036  PMID: 37645342

Version Changes

Revised. Amendments from Version 1

The updated version of this paper features a new Section 2 that describes the methodology employed in this piece of qualitative research. Specifically, there are short descriptions of the Study Design; Source Selection; Data Collection and approach to Analysis. The details that were in Section 2 of the previous version have been combined with Section 3. Other minor changes include the update of Table 1 to include the countries: Moldova and Ukraine as Candidate Countries (CC), with Georgia as a Potential Candidate Country (PCC) following the result of their applications made shortly after Russia’s invasion of Ukraine in February 2022. Additionally, Bosnia and Herzegovina status change from PCC to CC in December 2022.

Abstract

The European Economic Area (EEA) provides a common market for goods, labour, services, and capital. Promoting integration between countries through the free movement of labour, or more generally persons, pre-dates the previous forms of the EEA. However, during the Southern and Eastern Expansions of the European Union, there have been transition agreements on persons, designed to restrict immigration. Opening up labour markets to the new member states with signifcantly lower GDP per capita than existing states, has been contentious. This is why the use of transition agreements have permitted periods which existing members can limit immigration. Not all existing member states impose restrictions, and during the Eastern Enlargements, the restrictions were imposed for varying lengths of time by different existing members up to a maximum of seven years. During the transition agreement, the economies of new members and existing members can converge, which is ultimately designed to limit the pull factor of migration. In this note, we provide a concise resource of the timeline of the expansion of full free movement of persons for countries in the EEA and Switzerland.

Keywords: European Union, Migration, Freedom of Movement, EU Expansion, Single Market, European Economic Area, Migration Restrictions

Plain language summary

In this research we answer: What year were citizens of the countries within the European Economic Area (EEA) able to move to another country in the EEA without any restrictions? Immigration is a controversial topic in most developed economies, but the EEA is a unique group of countries which offers its citizens the ability to live and work anywhere in its member countries. Political issues have risen when there are new members who have significantly lower GDP per capita than existing member states. To satisfy some of the existing members, they are able to limit migration from the new members for up to seven years. This research brings together many sources to detail when restrictions were lifted if this differed to the country joining the EU or EEA.

1 Introduction

The European Single Market includes the 27 countries of the European Union (EU) and the European Free Trade Association (EFTA) countries of Iceland, Liechtenstein, Norway, plus Switzerland. 1 Until 2020, the EU included the United Kingdom. The Single Market is for the free movement for goods, labour (alternatively persons), services, and capital. However, joining the Single Market has not always been as simple as joining and assuming equivalent status as Existing Member States (EMS). This prime example of international co-operation and international integration can come with caveats. Transition agreements on free movement of labour have been implemented on the countries joining the EU in 1981, 1986, 2004 (except Cyprus and Malta), 2007, and 2013. The transition agreements are in place to stop large shocks to the labour markets and population of EMS. The transition periods can last up to seven years, in which time it is probable that the economies of New Member States (NMS) have improved to be closer to EMS. As a result, there should be reduced incentive to migrate. The expansion, exit of the UK, candidate and potential candidate countries of the EU is shown in Table 1.

Table 1. Expansion of the European Union.

Expansion of the EU Brexit CC PCC
1958 1973 1981 1986 1995 2004 2007 2013 2020
BEL DNK GRC PRT AUT POL BUL HRV -UK ALB GEO
FRA IRE ESP FIN CZE ROU BIH KOS
DEU UK SWE EST MKD
ITA HUN MDA
LUX LVA MNE
NED LTU SRB
SVK TUR
SVN UKR
CYP
MLT
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CC: candidate countries ; PCC: potential candidate countries. The development of the European Union and the possible future members. In June 2022, Moldova and Ukraine were granted Candidate Country status, while Georgia was granted Potential Candidate Country, which will become a Candidate Country once some key priorities have been addressed. Their applications were made soon after Russia invaded Ukraine in February 2022. Bosnia and Herzegovina were given full CC status on 15 December 2022. Source: European Union and European Commission

This paper provides a concise resource as to which years single market entry and freedom of movement was first obtained to enable researchers to easily access the information. Section 2 describes the methodology employed; Section 3 presents the expansion of the common market, and other relevant unions; and contains the years freedom of movement was gained; and Section 4 discusses possible future expansions and challenges.

2 Methodology

Study design

The most suitable approach for this research is a multiple case study, as we are analysing the same question across 32 countries of the EU+ in 2019. Further, in the Eastern Expansions since 2004, there has been differing results across the EMS. The primary method used is document analysis the exact sources are detailed in the next sections. To formulate a timeline of freedom of movement, we proceed with two main questions: (i) what date did a country join the common market and (ii) was that country granted immediate freedom of movement for persons. If the answer for the second question is negative, we are required to explore further sources to find the years which full access was granted. Early research stages required creating a timeline of the evolution of the EEA (as detailed in Section 3).

Source selection

To gather information for the timeline on the expansion of the European Common Labour Market, we begin by researching the timeline of what is currently known as the EEA. The EU provides a record of legal agreements on EUR-Lex which the majority of treaties included in this research are available. For information not available from EUR-Lex, we source from other government sources, academic literature or reports from official organisations.

Data collection

The analysis of the downloaded documents took place in July and August 2021. The conclusion of the research occurred when Table 2 and Table 3 were complete. The full list of sources by country is available in the data accompanying this research ( Barker, 2022). The treaties covered most of the details, however, some were details that could be subject to change. 2 The treaties were chosen as they are the legal documents and available from credible sources. Important treaties included in this investigation were the Benelux Economic Union Benelux Union (1958); the Treaty establishing the ECSC Publications Office of the European Union (1951); the Treaty establishing the EEC The six Member States: Belgium, Germany, France, Italy, Luxembourg, Netherlands (1957); Treaties of Accessions European Communities (1972); European Communities (1979); European Communities (1985); European Communities (1994), European Union (2003); European Union (2005); European Union (2012); the establishment of the EEA Council of the European Union, European Commission (1993); and the withdrawal of the UK European Union (2020).

Table 2. Expansion of Freedom of Movement (1).

Sending
Country		 Receiving Country
AUT BEL BGR HRZ CYP CZE DNK EST FIN FRA DEU GRC HUN IRL ITA LVA
AUT NA 1994 2007 2020 2004 2004 1994 2004 1994 1994 1994 1994 2009 1994 1994 2004
BEL 1994 NA 2007 2015 2004 2004 1973 2004 1994 1968 1968 1988 2009 1973 1968 2004
BGR 2014 2014 NA 2013 2007 2007 2009 2007 2007 2014 2014 2009 2009 2012 2012 2007
HRZ 2020 2015 2013 NA 2015 2013 2013 2013 2013 2015 2015 2015 2013 2013 2015 2013
CYP 2004 2004 2007 2015 NA 2004 2004 2004 2004 2004 2004 2004 2004 2004 2004 2004
CZE 2011 2009 2007 2013 2004 NA 2009 2004 2006 2008 2011 2006 2004 2004 2006 2004
DNK 1994 1973 2007 2013 2004 2004 NA 2004 1954 1973 1973 1988 2009 1973 1973 2004
EST 2011 2009 2007 2013 2004 2004 2009 NA 2006 2008 2011 2006 2004 2004 2006 2004
FIN 1994 1994 2007 2013 2004 2004 1954 2004 NA 1994 1994 1994 2006 1994 1994 2004
FRA 1994 1968 2007 2015 2004 2004 1973 2004 1994 NA 1968 1988 2008 1973 1968 2004
DEU 1994 1968 2007 2015 2004 2004 1973 2004 1994 1968 NA 1988 2009 1973 1968 2004
GRC 1994 1988 2007 2015 2004 2004 1988 2004 1994 1988 1988 NA 2006 1988 1988 2004
HUN 2011 2009 2007 2013 2004 2004 2009 2004 2006 2008 2011 2006 NA 2004 2006 2004
IRL 1994 1973 2007 2013 2004 2004 1973 2004 1994 1973 1973 1988 2004 NA 1973 2004
ITA 1994 1968 2007 2015 2004 2004 1973 2004 1994 1968 1968 1988 2006 1973 NA 2004
LVA 2011 2009 2007 2013 2004 2004 2009 2004 2006 2008 2011 2006 2004 2004 2006 NA
LTU 2011 2009 2007 2013 2004 2004 2009 2004 2006 2008 2011 2006 2004 2004 2006 2004
LUX 1994 1960 2007 2015 2004 2004 1973 2004 1994 1968 1968 1988 2007 1973 1968 2004
MLT 2004 2004 2007 2018 2004 2004 2004 2004 2004 2004 2004 2004 2004 2004 2004 2004
NLD 1994 1960 2007 2018 2004 2004 1973 2004 1994 1968 1968 1988 2007 1973 1968 2004
POL 2011 2009 2007 2013 2004 2004 2009 2004 2006 2008 2011 2006 2004 2004 2006 2004
PRT 1994 1992 2007 2013 2004 2004 1992 2004 1994 1992 1992 1992 2006 1992 1992 2004
ROU 2014 2014 2007 2013 2007 2007 2009 2007 2007 2014 2014 2009 2009 2012 2012 2007
SVK 2011 2009 2007 2013 2004 2004 2009 2004 2006 2008 2011 2006 2004 2004 2006 2004
SVN 2011 2009 2007 2018 2004 2004 2009 2004 2006 2008 2011 2006 2004 2004 2006 2004
ESP 1994 1992 2007 2015 2004 2004 1992 2004 1994 1992 1992 1992 2006 1992 1992 2004
SWE 1994 1994 2007 2013 2004 2004 1946 2004 1954 1994 1994 1994 2004 1994 1994 2004
ISL 1994 1994 2007 2015 2004 2004 1952 2004 1954 1994 1994 1994 2009 1994 1994 2004
LIE 1995 1995 2007 2018 2004 2004 1995 2004 1995 1995 1995 1995 2009 1995 1995 2004
NOR 1994 1994 2007 2014 2004 2004 1952 2004 1954 1994 1994 1994 2009 1994 1994 2004
CHE 2004 2004 2009 2024 2006 2006 2004 2006 2004 2004 2004 2004 2006 2004 2004 2006
UK 1994 1973 2007 2018 2004 2004 1973 2004 1994 1973 1973 1988 2004 1923 1973 2004
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Notes: Notes: Years that free movement of persons was granted. The column shows the host country, with the row identifying the citizens of sending country.

The UK ceased to be a member of the common labour market in 2020, though the original years are detailed here. Only Ireland and the UK have free movement.

Table 3. Expansion of Freedom of Movement (2).

Sending
Country		 Receiving Country
LTU LUX MLT NLD POL PRT ROU SVK SVN ESP SWE ISL LIE NOR CHE UK
AUT 2004 1994 2004 1994 2007 1994 2007 2004 2006 1994 1994 1994 1995 1994 2007 1994
BEL 2004 1960 2004 1960 2007 1992 2007 2004 2006 1992 1994 1994 1995 1994 2007 1973
BGR 2007 2014 2014 2014 2007 2009 2007 2007 2007 2009 2007 2012 2012 2012 2016 2014
HRZ 2013 2015 2018 2018 2013 2013 2013 2013 2018 2015 2013 2015 2018 2014 2024 2018
CYP 2004 2004 2004 2004 2004 2004 2007 2004 2004 2004 2004 2004 2004 2004 2007 2004
CZE 2004 2007 2004 2007 2004 2006 2007 2004 2004 2006 2004 2009 2009 2009 2014 2004
DNK 2004 1973 2004 1973 2007 1992 2007 2004 2006 1992 1945 1955 1995 1954 2007 1973
EST 2004 2007 2004 2007 2004 2006 2007 2004 2004 2006 2004 2009 2009 2009 2014 2004
FIN 2004 1994 2004 1994 2006 1994 2007 2004 2006 1994 1949 1955 1995 1954 2007 1994
FRA 2004 1968 2004 1968 2007 1992 2007 2004 2006 1992 1994 1994 1995 1994 2007 1973
DEU 2004 1968 2004 1968 2007 1992 2007 2004 2006 1992 1994 1994 1995 1994 2007 1973
GRC 2004 1988 2004 1988 2006 1992 2007 2004 2006 1992 1994 1994 1995 1994 2007 1988
HUN 2004 2007 2004 2007 2004 2006 2007 2004 2004 2006 2004 2009 2009 2009 2014 2004
IRL 2004 1973 2004 1973 2004 1992 2007 2004 2004 1992 1994 1994 1995 1994 2007 1923
ITA 2004 1968 2004 1968 2006 1992 2007 2004 2006 1992 1994 1994 1995 1994 2007 1973
LVA 2004 2007 2004 2007 2004 2006 2007 2004 2004 2006 2004 2009 2009 2009 2014 2004
LTU NA 2007 2004 2007 2004 2006 2007 2004 2004 2006 2004 2009 2009 2009 2014 2004
LUX 2004 NA 2004 1960 2007 1993 2007 2004 2006 1993 1994 1994 1995 1994 2007 1973
MLT 2004 2004 NA 2004 2004 2004 2007 2004 2004 2004 2004 2004 2004 2004 2007 2004
NLD 2004 1960 2004 NA 2007 1992 2007 2004 2006 1992 1994 1994 1995 1994 2007 1973
POL 2004 2007 2004 2007 NA 2006 2007 2004 2004 2006 2004 2009 2009 2009 2014 2004
PRT 2004 1993 2004 1992 2006 NA 2007 2004 2006 1992 1994 1994 1995 1994 2007 1992
ROU 2007 2014 2014 2014 2007 2009 NA 2007 2007 2009 2007 2012 2012 2012 2016 2014
SVK 2004 2007 2004 2007 2004 2006 2007 NA 2004 2006 2004 2009 2009 2009 2014 2004
SVN 2004 2007 2004 2007 2004 2006 2007 2004 NA 2006 2004 2009 2009 2009 2014 2004
ESP 2004 1993 2004 1992 2006 1992 2007 2004 2006 NA 1994 1994 1995 1994 2007 1992
SWE 2004 1994 2004 1994 2004 1994 2007 2004 2004 1994 NA 1955 1995 1954 2007 1994
ISL 2004 1994 2004 1994 2007 1994 2007 2004 2006 1994 1945 NA 1995 1954 2007 1994
LIE 2004 1995 2004 1995 2007 1995 2007 2004 2006 1995 1995 1995 NA 1995 2007 1995
NOR 2004 1994 2004 1994 2007 1994 2007 2004 2006 1994 1945 1955 1995 NA 2007 1994
CHE 2006 2004 2006 2004 2006 2004 2009 2006 2006 2004 2004 2004 2004 2004 NA 2004
UK 2004 1973 2004 1973 2004 1992 2007 2004 2004 1992 1994 1994 1995 1994 2007 NA
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Notes: Years that free movement of persons was granted. The column shows the host country, with the row identifying the citizens of sending country.

The UK ceased to be a member of the common labour market in 2020, though the original years are detailed here. Only Ireland and the UK have free movement.

Analysis

The data analysis method employed is basic qualitative content analysis, in which we search the required documents for the dates to answer the questions outlined in our study design. The dates gathered from this research are used to create Table 2 and Table 3. In addition, the exact dates (not only years) Barker and Bijak (2021) to create a variable for the effective labour market size for EEA states and Switzerland for the purpose of the investigation of the effects of net immigration or net emigration on the macroeconomy. As there has been considerable expansion of the EEA since the start of the sampling period (2002), this needed to be reflected as an exogenous variable in that model. It was important to identify the dates that countries joined the bloc (and exited in the case of the UK) to reflect the joining of new members and their labour force size. For example, when the A8 countries joined in 2004, there was a significant increase in migration to Ireland, Sweden and the United Kingdom because those countries didn’t place any limitations on movements. The other member states did impose limits, but for varying lengths of time which meant reflecting the changes was important. While it was necessary to the research to find the changes from 2002, to complete the research we backdated the start of the study to have an understanding of the origins and development of the European Common Market as of today.

3 Results

Expansion of the Common Market

For each country we detail the year that they gained access to another country’s labour market. In finding these years, we have several policies to extract analysis from which we gather the joining dates between two (or more) countries. Below we list the main treaties and evolution of the common (labour) market.

European Coal and Steel Community (ECSC) The founder members were Belgium, France, Italy, Luxembourg, the Netherlands, and West Germany. The Treaty establishing the European Coal and Steel Community Treaty came into force on 23rd July 1952 ( Publications Office of the European Union, 1951). This covered workers from only certain industries, thus not enabling full freedom of movement.

European Economic Community (EEC) The EEC succeeded the ECSC which aimed to establish a common market for the freedom of movement for goods, people, capital and services. This came into force 1st January 1958. Only by 1968 were any barriers to free movement of persons fully abolished, as preceding agreements still permitted countries to impose restrictions on foreign workers ( Condinanzi et al., 2008).

Treaty of Accession (ToA) There were Treaties of Accession where new member countries joined the EU: 1972 for Denmark, Ireland and the United Kingdom, 1979 for Greece, 1985 for Spain and Portugal, and 1994 for Austria, Finland, and Sweden. The Treaties of Accession of 1979 and 1985 permitted transitional agreements which lasted until 1986 and 1992 respectively. There was not the expected large movements of people following during (or after) the transition period for Spain and Portugal, due to the improved economic (and political) conditions ( Royo, 2007), as such the transition period was reduced to six years ( Council of the European Union, 1991). The countries in the 2003 ToA included Cyprus, Czech Republic, Estonia, Latvia, Lithuania, Malta, Poland, Slovakia, and Slovenia. Citizens of Cyprus and Malta were allowed immediate access to all EU15 labour markets, but the remaining eight countries were not guaranteed this. Only Ireland, Sweden, and the United Kingdom fully opened their markets. Nations could impose restrictions on workers being able to access the welfare state. The transition agreements permitted the NMS to employ reciprocal restrictions, which only Hungary, Poland and Slovenia did ( Goldner Lang, 2008).

European Economic Area (EEA) EEA includes the EU countries, Iceland, Liechtenstein, and Norway the agreement came into force on 1st January 1994. Austria, Finland and Sweden joined the EEA before subsequently joining the EU in 1995. The agreement brought the countries into the Single Market for the four freedoms. Not all of the EU policies were included in the agreement. EFTA today consists of Iceland, Liechtenstein, Norway, and Switzerland.

Nordic Passport Union A membership of Denmark, Finland, Iceland, Norway and Sweden made in 1954 enabling free movement between the nations with members implementing it at different dates.

Switzerland There are a number of safeguard agreements which applied to all countries when it came into force. Free movement in to Switzerland was suspended for a period under the safeguard agreement. The Eastern Expansion are subject to further delays on accessing the Swiss labour market beyond the seven years they are constrained to elsewhere in EU.

Liechtenstein The small country in the centre of Europe is an anomaly. A member of the EFTA, and a population of less than 40,000. 3 Working in the country is unrestricted for EEA and Swiss citizens but gaining a residence permit is more difficult due to the limitations allowed ( Cassis, 2012).

The Withdrawal Agreement In 2016, the United Kingdom voted to leave the EU. The terms of agreement were finalised in 2020. In the results, we have included the years which access were granted by the United Kingdom to its labour markets, and given to citizens of the United Kingdom in other European countries. Only citizens of the Republic of Ireland have free movement to the labour market of the United Kingdom and reciprocally to satisfy the Good Friday Agreement.

As a summary, Figure 1 shows the different economic groupings within Europe.

Figure 1. Groupings of Europe 2021.

Figure 1.

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Table 2 and Table 3 show the year in which a country gained full access to the labour market of another country. The column heading is the country that the row applies to. The row shows what year citizens of that country gained access to the labour market of the country in the column heading. For example, cell B4 of Table 2 shows that Bulgarian citizens gained full access to the labour market in 2014, whereas in D2 Austrian citizens were able to access the Bulgarian labour market in 2007 as no reciprocal measures were in place.

Notes

Spain allowed access to Bulgarian and Romanian citizens in 2009, but Spain reintroduced restrictions for Romanian citizens on 22 July 2011, which were removed in 2014. Switzerland has a safeguard clause in their agreements, such that they are able to suspend free movement or introduce quotas on permits. They introduced quotas for category B permits in June 2013 for EU-15, Cyprus and Malta, and activated this safeguard clause in April 2012 for the EU-8 countries 4 which were both removed in 2014. The original years for the United Kingdom remain as it is important to the history of the EU. The freedom of movement to and from the United Kingdom ends in 2020, except for Ireland.

4 Discussion

We have looked the evolution of the Single Market with a focus on the free movement of persons. This case study provides a resource for researchers looking at the history of the Europe and future paths. In light of the results presented in Table 2 and Table 3, it is clear that simply assuming that freedom of movement of persons was granted in the years of accession is not possible. Only in the case of the founding members of the EEC and the 1972 and 1994 accession countries was this correct. For researchers studying migration in Europe, and to the wider European labour market, this gives a timeline of major changes. When future expansions of the EU happen, researchers will now be able to look back to see how previous NMS dealt with the restrictions on freedom of movement. Briefly, we look at potential future expansions and the challenges.

Future expansions of the EU

The CC and PCC listed in Table 1 have varying degrees of likelihood. Some of the countries have a significant length to go to so that their politics aligns with EU directives, and in some cases the country to be fully recognised as an independent state by all current member countries. Noteworthy examples include Cyprus, Greece, Romania, Slovakia, and Spain not recognising Kosovo; and the issues of Turkey and Cyprus over the Turkish Republic of Northern Cyprus, and absence of Turkish-Cypriot diplomatic relations. Expansion of the EU with CC and PCC is unlikely in the short-term, alongside opposition of founder EU members to further expansion as evidenced when a group of countries led by France blocked the opening talks with Albania and North Macedonia to the accession process in October 2019 citing the need for review and reform of the EU before any expansions can take place. 5

For any future (Eastern) expansions, transitional agreements on persons would likely be imposed. These agreements, designed to allow the closing of the gap of NMS to EMS, are likely to be minimal due to the existing GDP per capita gap that exists. The real GDP per capita of Montenegro, North Macedonia, Serbia, Bosnia and Herzegovina, and Kosovo for 2019 was less than 25% of that of the EU-15, with Turkey at 37%. 6 The small closing of this gap will leave a pull factor to EMS, in particular the EU-14 and EFTA states, and possibly Slovenia. The inclusion of Slovenia towards EU-14 and EFTA states is due to their relatively high GDP per capita than other Eastern European countries, where wages and salaries are close to the levels of Greece, Italy, Portugal and Spain.

Georgia, Moldova and Ukraine applied to join the EU following the invasion of Russia into Ukraine ( Gehrke, 2022), which resulted with Moldova and Ukraine being granted CC status and Georgia as a PCC. The likelihood of membership for any of these countries of the EU in the short-term is unlikely. Particularly since there is a war happening in Ukraine, and for similar reasons as discussed above.

In addition, the fallout from Brexit within the United Kingdom cannot be ignored with support for independence in Scotland increasing, and the troubles associated with the Brexit agreement in Northern Ireland creating problems there. Scotland and Northern Ireland cannot be treated in the same way, with Northern Ireland’s requirements to satisfy the Good Friday agreement with the Republic of Ireland could see a reunified Ireland as one member of the EU, whereas Scotland would be an entirely separate state with no immediate right to be in the EU/EEA. 7

Challenges of Integration

Countries joining the EU must align their social, economic and political factors with that of the EU. Further economic convergence is considered when a NMS joins the Euro currency. However, as shown in Figure 1, there are eight countries who have not adopted the Euro. Denmark negotiated an opt out and Sweden has no plans to, whilst the remaining six will join when they have met the necessary conditions. 8 From the perspective of a migrant, international migration is more challenging than domestic migration. The introduction of a common labour market has benefited millions of people, however, there are some issues that migrants encounter. One such struggle is a language barrier there are 24 official languages of the EU with more languages in use in the common labour market such as Icelandic, Norwegian, and regional ones. Having a poor command of the host country’s language can be a barrier to employment or fully integrating into the community. Where a country has a positive attitude towards migrants, they are more likely to integrate ( Naveed & Wang, 2021), however, with the rise of populism in Western Europe in particular, negative attitudes are likely to increase.

Acknowledgements

I would like to thank Jakub Bijak, Mathias Czaika, and Peter Smith for their suggestions on an early draft of this paper. This research is part of the QuantMig research project that is funded by the European Union’s Horizon 2020 research and innovation programme under grant agreement No. 870299. All the remaining errors and inaccuracies are mine. This document reflects the author’s view and the Research Executive Agency of the European Commission are not responsible for any use that may be made of the information it contains.

Funding Statement

The QuantMig research project is funded by the European Union’s Horizon 2020 research and innovation programme under grant agreement No. 870299.

The funders had no role in study design, data collection and analysis, decision to publish, or preparation of the manuscript.

[version 2; peer review: 1 approved, 2 approved with reservations]

Footnotes

1Switzerland does not participate in the European Economic Area, though agreements are in place that allow access to the single market.

2For example, Spain and Portugal had restrictions lifted earlier. This is explained in more detail later.

3Source: Eurostat.

5Source: Reuters. 28 July 2021

6Source: Author’s calculations using Eurostat tables nama 10 gdp and demo pjangroup

7A separation of Scotland from the Union has the potential to be more fractious than Brexit negotiations due to Scotland’s desire to keep the GBP currency, whilst the UK Government was strictly against this. Previous separation proposals by the Scottish National Party made when the UK was a member of the EU argued that Scotland would be able to continue EU membership, that is no longer the case.

8Source: European Union, 16 September 2021

Data availability

Underlying data

Zenodo: A timeline of freedom of movement in the European Economic Area. https://doi.org/10.5281/zenodo.7225880 ( Barker, 2022).

This project contains the following underlying data:

  • Full list of sources by country

Data are available under the terms of the Creative Commons Attribution 4.0 International license (CC-BY 4.0).

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Open Res Eur. 2023 Jul 10. doi: 10.21956/openreseurope.16694.r33353

Reviewer response for version 2

Mario Munta 1,2

The article “A timeline of freedom of movement in the European Economic Area” written by Emily Barker represents a valuable resource for all scholars interested in the topic of freedom of movement, and particularly labor mobility within the EU/EEA. The empirical contributions in Table 2 and Table 3 can serve as a starting point for qualitative and quantitative research into a variety of topics, including determinants of variation in the duration of labor market access restriction by countries (or country groups), conditions for using reciprocal measures etc. Whilst this version of the manuscript is mostly well-written and sound, I am of the opinion that there are still some minor issues which need to be addressed before this paper becomes the final version. These smaller interventions would improve the manuscript even further.

- First, a note on this sentence from the intro: ‘’However, joining the Single Market has not always been as simple as joining and assuming equivalent status as Existing Member States (EMS)’’. From this sentence, it is not entirely clear whether the author considers all four freedoms in the single market to be equally difficult to access for new Member States (NMS) or does this only apply to free movement of labor. Please clarify accordingly.

- in the first sentence of the methodology, the paper claims to conduct a multiple case study. I strongly advise against this claim because it does not reflect the reality and doesn’t do justice to what case study methodology and research look like. Multiple case studies are in-depth, qualitative investigations. I believe you can leave this claim out and refer to document analysis of all countries observed in this paper as a data collection method, and quantitative content analysis as the method of data analysis.

- related to the previous point, it also seems to me from the description of the methodology and the presented results that the author actually conducted ‘quantitative content analysis’ instead of ‘qualitative content analysis’ as argued in the Analysis section. I suggest the author further looks into the differences between the two methodological approaches, and cites the relevant literature. Given the fact that this article observed documents and coded explicit dates in various documents (accession treaties, safeguard agreements etc.), this approach differs from qualitative content analysis in which latent meanings are extracted from the text to generate categories.

- the paragraph which discusses the Treaty of Accession leaves out (without an explanation why) a discussion of the 2007 and 2013 enlargement cycles. In the same paragraph, the author forgets to mention that Croatia also applied reciprocal restrictions, which is also evident from Table 2 and Table 3.

- Given how controversial the topic labor mobility has been in Swiss-EU relations, a broadening of that specific paragraph on p 7/11 is warranted. An explicit reference to the Agreement on the Free Movement of Persons from 2002 is needed. This agreement foresees a gradual opening of the Swiss labor market and a quota system. In the case of Croatia, the European Commission and Croatia repeatedly asked for restrictions to Croatian citizens to be lifted after Croatia’s entry into the EU in 2013, however a ban applied until 2021, only to be reapplied/reintroduced in 2023. Please see for Croatian case: https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-91561.html. Also, for a general overview: https://www.lexology.com/library/detail.aspx?g=958a571f-06a9-4322-a411-16024aeb0975

- in Table 2 and Table 3, change acronym for Croatia from HRZ to either HRV, HR or CRO as the internationally recognised versions.

- please clarify in the note or in the title of Table 2 and Table 3 whether they show the years in which the treaties/agreements foresaw a lifting of restriction, that is, the granting of free movement or do they reflect the actual years when the free movement was granted. Look at the case of Croatia – the table writes that Croatian citizens could access the Swiss labor market only from 2024 – which is inaccurate. Please see previous point for reference. Formally, the Swiss safeguard clause for Croatian nationals can be applied until 2024, however free movement was granted already in 2022. The fact that new quotas were reintroduces for Croatians starting 2023 does not deny the fact that restrictions were lifted at the end of 2021. Please clarify and if needed, include separate figures in brackets for cases where there is a discrepancy in the theoretical and actual revocation of mobility restrictions on the labor market.

- Figure 1 should be updated to reflect the fact that Croatia entered the Eurozone starting 1 January 2023. Equally, the number of EA countries should be updated to 20. Related to this point, please also correct the numbers in the final section on ‘’Challenges of integration’’ – seven countries have not adopted the euro, and five are still to join (excluding Denmark and Sweden).

If applicable, is the statistical analysis and its interpretation appropriate?

Not applicable

Is the study design appropriate and is the work technically sound?

Yes

Is the work clearly and accurately presented and does it engage with the current literature?

Yes

Are the conclusions drawn adequately supported by the results?

Yes

Are sufficient details of methods and analysis provided to allow replication by others?

Yes

Are all the source data and materials underlying the results available?

Yes

Reviewer Expertise:

European integration, Economic and Monetary Union, Social Europe, EU employment policy, Europeanisation of Public Policy, European Green Deal

I confirm that I have read this submission and believe that I have an appropriate level of expertise to confirm that it is of an acceptable scientific standard, however I have significant reservations, as outlined above.

Open Res Eur. 2023 Jul 10. doi: 10.21956/openreseurope.16694.r33358

Reviewer response for version 2

Dion Kramer 1

By providing a clear overview of the opening of labour markets to new (EEC/EU/EEA/EFTA) Member States, this article offers a useful addition to the literature on the history of free movement and will be a useful resource for scholarship on free movement and migration. I have three main points for improvement.

- My main point is a lack of engagement with the (mostly legal) literature pointing at such phenomena as posted work and self-employed work. While workers are typically restricted from entering the labour markets of other Member States during transition agreements, there are typically no restrictions on the free movement of services and establishment. The famous Rush Portuguesa judgment is an example of this: while Portugal was still subjected to transition arrangements, Portuguese companies could already provide services and bring their Portuguese workers to other Member States for that purpose. Same goes for establishment: e.g., Polish citizens could set up a company and start economic activities as self-employed workers in other Member States. In other words: restrictions were merely imposed on the the free movement of workers and not all forms of migration itself (as suggested in the paper). For a comprehensive understanding of (the effects of) transition agreements, the difference between these forms of labour mobility seem pertinent to address. 

- The discussion/conclusion does not seem to follow necessarily from the findings/results of this paper. One could arguably reflect on the prospect of free movement after (future) accession(s), but could one really reflect on the prospect of accession itself based on the findings? I am not saying that the discussion in its present form is not interesting, but how do your findings specifically add to the wider debate around accession? For one, the Russian war against Ukraine has accelerated the potential and the process of accession, of both Ukraine and other CC and PCCs. Additionally, I struggle to see the relevance of the final subsection on integration in light of the contribution of the article. This brings us to the main point: what is the added value of such a timeline? Perhaps this could be explicated better.

- Stylistic: There are some typo's and informal use of language ("aren't"). Additionally, I would personally refrain from using abbreviations, especially since there are so many. The article is relatively short and the reader will not benefit from reading abbreviations like CC, PCC, ToA, NMS, EMS, etc.

If applicable, is the statistical analysis and its interpretation appropriate?

Not applicable

Is the study design appropriate and is the work technically sound?

Yes

Is the work clearly and accurately presented and does it engage with the current literature?

Partly

Are the conclusions drawn adequately supported by the results?

Partly

Are sufficient details of methods and analysis provided to allow replication by others?

Yes

Are all the source data and materials underlying the results available?

Yes

Reviewer Expertise:

EU citizenship, free movement of persons, internal market law.

I confirm that I have read this submission and believe that I have an appropriate level of expertise to confirm that it is of an acceptable scientific standard, however I have significant reservations, as outlined above.

Open Res Eur. 2023 Jun 20. doi: 10.21956/openreseurope.16694.r31761

Reviewer response for version 2

Francesco Paolo Mongelli 1

In my view, the article “A timeline of freedom of movement in the European Economic Area” by Emily Barker provides a very useful support in the discussion and analysis of an indispensable plank of the Single Market: the freedom of mobility within the European Union but also across EFTA and the wider European Economic Area. On one hand, this might support further research into the actual transposition of EU/EEA legislation into national law and the adoption of national decrees to support freedom of movement. On the other hand, it might support research into actual labour mobility across EU/EEA member states. My prior is that freedom of movement might be higher among EU member states, but should still be significant among EEA states: this is an empirical question.

Major points:

  • Would be helpful to clearly distinguish between ratifications, adoption into national law, transposition with help of implementation decrees, enabling provision(s), and so on.

  • Concerning Table 2, I am perplexed by the NA: keep blanks instead? Figure 1 is about the EMS (nice figure by the way). 

  • In the end implementation of the SM is a matter of degrees and modulation: what might subsequent empirical analysis show in terms of effective labor mobility?

  • In the discussion: vague language when mentioning "...align their social, economic and political factors." Which factors?

Minor points:

  • The Single Market aims at/promotes....

  • It should be “member states”.

  • I am not sure that Liechtenstein would appreciate being labelled as an "anomaly", may be unique case?

  • Please take out or redraft Footnote 7: not sure UK might appreciate. 

If applicable, is the statistical analysis and its interpretation appropriate?

Partly

Is the study design appropriate and is the work technically sound?

Yes

Is the work clearly and accurately presented and does it engage with the current literature?

Yes

Are the conclusions drawn adequately supported by the results?

Yes

Are sufficient details of methods and analysis provided to allow replication by others?

Partly

Are all the source data and materials underlying the results available?

Yes

Reviewer Expertise:

Economic integration and monetary policy

I confirm that I have read this submission and believe that I have an appropriate level of expertise to confirm that it is of an acceptable scientific standard.

Associated Data

    This section collects any data citations, data availability statements, or supplementary materials included in this article.

    Data Availability Statement

    Underlying data

    Zenodo: A timeline of freedom of movement in the European Economic Area. https://doi.org/10.5281/zenodo.7225880 ( Barker, 2022).

    This project contains the following underlying data:

    • Full list of sources by country

    Data are available under the terms of the Creative Commons Attribution 4.0 International license (CC-BY 4.0).

    Articles from Open Research Europe are provided here courtesy of European Commission, Directorate General for Research and Innovation

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