Scala Civium : citizenship templates post-Brexit and the European Union’s duty to protect EU citizens

Brexit opened the way for the ‘restoration’ of British sovereignty and, if an EEA model (or an EEA‐like model) is not chosen following the activation of Article 50 TEU, EU citizens settled in the UK will be requested to apply for either UK nationality or permanent leave to remain. The same applies to UK nationals residing in other Member States who will lose their EU citizenship status. Unexpectedly, 3.9 million EU citizens have been transformed into ‘guests’ or ‘foreigners’ in communities they call ‘their own’. Although naturalization in the state of residence might be seen to furnish a secure and fully recognized status for EU citizens, I argue that it is not an adequate policy option. The conceptual differences between national and EU citizenships are immense. In this article I explore the advantages and disadvantages of possible citizenship templates and propose an ‘EU protected citizen’ status for EU citizens