Why France, Germany and the UK relate to their Muslim communities so differently

The way we perceive and talk about Islam varies greatly from one European country to the next. While this may be easy enough to intuit by glancing over different national headlines, I backed this up with hard data in my PhD research on public discourses on Islam in Germany, France and the United Kingdom.

The pursuit of German identity

In Germany, how you approach Islam hinges onto which side of the political debate you stand. On the one hand, the majority of the political elite defends a German identity that is no longer based on traditional culture but on support toward the constitution (Verfassungspatriotismus). On the other hand, a media and political minority defends the return of a monocultural vision of German identity (Leitkultur).

In this narrative struggle, elites see the country’s far right, led by the AfD (Alternative für Deutschland) party, as enemy number one, far more than they do radical Islam. Security concerns over Muslims are therefore limited to the former players and to a handful of figures in the media such as Alice Schwarzer or Birgit Kelle.

Shades of liberalism

Meanwhile, in the United Kingdom it is liberalism that calls the shots, with two strands of thought. On the one hand, ideological liberalism aims to protect the British way of life in the face of terrorism and “preachers of hatred”. In 2011, then–Prime Minister David Cameron put forward his brand of “muscular liberalism” that “actively promoted… certain values… [such as] freedom of speech, freedom of worship, democracy, the rule of law, equal rights regardless of race, sex or sexuality”. But that current of thought is also claimed by hard Brexiteers such as Nigel Farage, who’s ardently opposed to what he portrays as a pro-immigration EU led by Germany.

Inherited from the British empire, the other liberal current, multiculturalism, seeks to manage differences and face off both populist and nationalist threats. Advocates of “muscular liberalism” view this approach as passive and neutral, merely contenting itself with demanding citizens obey the law. Here again, champions of multicultural liberalism in Westminster and the media tend to focus their energies on the European Union – albeit this time to defend it – rather than on Islam.

Islam and laïcité

In France, narratives about Islam are articulated in relation to religion, opposing two conceptions of French secularism, or laïcité: on the one hand, what other academics and I refer to as axiological laïcité, or values-based laïcité, frames secularism as a refuge against a real or perceived “Islamic threat”. Constitutional secularism, by contrast, aims to regulate all religions, the French Muslims of the Republic included.

Although it is not based on any legal text, axiological secularism has managed to become the dominant force in French secularism since concerns over headscarves at school first erupted in 1989. Paradoxically, constitutional secularism, which is based on the 1905 law on the separation of church and state and on the preamble of the 1946 constitution, is struggling to make itself heard in the public debate.

In sum, the way Islam is represented across Germany, the UK and France reveals a struggle between two interpretations of political liberalism. The proponents of Leitkultur, muscular liberalism, and axiological secularism understand political liberalism as a set of “common values”, to which the newcomers have to assimilate.

By contrast, proponents of Verfassungspatriotismus, multiculturalism or constitutional secularism, insist on “common rules of the game” for de facto multicultural societies.

These European narrative battlefields show what is politically acceptable or costly in the national public debate.

Did you say “islamophobia”?

In Germany and the United Kingdom, pointing out (Muslim) culture as a threat is more acceptable than it is in France, where political players rarely venture to explicitly target a culture. On the contrary, denouncing (Muslim) religion as a threat is more acceptable in the French context, where religion is seen as an opinion. Doing so carries a high political cost in the UK and Germany, where religion is seen as part of one’s identity.

For example, there is no consensus across countries on the use of the term of Islamophobia, which is not officially recognised in France. This is partly because Islam is not protected by the Constitution or the law as a religion. On the other, many would argue against the concept of phobia on the grounds that it is legitimate to oppose Islam amid increased fundamentalism.

In Germany, the phenomenon is well recognised, but there is an ongoingdebate over whether the term ought to be used in official language. Since the German Islam Conference in 2011-2012, the state has favoured the word Muslimfeindligkeit (hostility toward Muslims), while academics and journalists refer to Islamophobia and its Germanic version, Islamfeindligkeit.

However, UK residents have extensively referred to the concept ever since the “Report on Islamophobia” by Runnymede Trust was published in 1997. And, since 2017, an All Party Parliamentary Group has been working toward the adoption of a legal definition of Islamophobia.

These narrative and conceptual variations from one European context to another reveal country-specific historical traumas.

The weight of national history in contemporary discourses

In the United Kingdom, continental Europe is more polarising than Islam for two historical reasons. On the one hand, continental Europe, sometimes Catholic, sometimes absolutist, sometimes imperialist, has always been perceived as the main threat to the country’s elites. On the other hand, Islam has been part of UK history since the colonisation of India through its trading posts in 1600, and all Muslim subjects of the Empire became full citizens through the Nationality Act 1948. Designating Islam as a threat is therefore of little value, at least from an electoral point of view, even on the far right of the political spectrum. This is evidenced by the defeat of the UKIP party in the 2019 European parliamentary elections after Eurosceptic Nigel Farage was replaced by the aggressively Islamophobic Gerard Batten as party leader in 2018, triggering the departure of some of its founding members.

The ambivalence of German public discourse toward Islam is linked to the traumatic legacy of Nazism and Germany’s division during the Cold War. This dual legacy shaped the emergence of a unified, democratic and liberal state around constitutional patriotism. The former Chancellor Angela Merkel’s decision to welcome more than one million refugees (“Wir Schaffen Das”) in 2015, however, has precipitated the return of an authoritarian and nationalist movement German Leitkultur, with cracks increasingly appearing within the consensus.

In France, the narrative victory of axiological secularism over constitutional secularism also expresses a double legacy. On the one hand, the secular tradition, either through anticlericalism or attachment to a Catholic secular tradition, expresses a reluctance to the visibility of Islam in the public space. On the other hand, the colonisation of North Africa, and with it the trauma of the decolonisation of Algeria, made the Muslim Other the figure that still structures French identity to a large extent today.

French identity thus continues to be constructed in opposition to Islam, while British identity hangs in opposition to continental Europe, and German identity, against Nazi Germany. If the future of the European Union rests, in part, on a greater convergence of interest and vision, acknowledging the weight of national histories in contemporary discourses is a necessary precondition for the construction of a European imagined community.