The Dynamics of Citizenship Politics in Democracy: Challenges of Dual Citizenship Regulation in Indonesia

1. Introduction

Citizenship is the fundamental foundation of the relationship between individuals and the state, encompassing civil, political, and social rights (Sosnowski & Klem, 2023). In the context of dual citizenship, tension arises between an individual’s right to remain connected to their country of origin and the state’s principle of single loyalty (Peters & Vink, 2024). This research is necessary because it highlights the unequal recognition of diaspora identities that feel alienated from their citizenship rights. In the era of globalization, an increasing number of Indonesians live, work, or marry across borders (Dewansyah, 2019). They experience the reality of multiple citizenships, while the Indonesian legal system still adheres to the principle of single citizenship.

This research problem concerns fundamental issues in the relationship between the state and its citizens. In the Indonesian context, the recognition or rejection of dual citizenship is not merely an administrative issue, but reflects the dynamics of power, identity, and political loyalty (Lazuardi, 2020). Empirically, millions of Indonesian diasporas live abroad and face citizenship dilemmas due to regulatory limitations that do not accommodate social realities (Antikowati et al., 2023). They desire to remain connected to their homeland, but are hampered by a legal system that adheres to the principle of single citizenship (Andriani & Prasetyo, 2023). This situation highlights a gap between the needs of citizens and the state’s stance, which often prioritizes maintaining the status quo in the name of national sovereignty and security.

The theoretical approach of recognition and redistribution in this study enriches the study of citizenship politics by demonstrating that the struggle for citizenship recognition is not solely a matter of legal rights, but also concerns identity, loyalty, and social justice (Fraser, 2020). Within the framework of Pancasila Democracy, the study also examines the extent to which the principles of deliberation and social justice are able to address the differing interests of citizens (Basit, 2023). Thus, it has theoretical and practical significance for encouraging more inclusive and democratic policy reforms in citizenship management in Indonesia. This situation suggests that negotiations between the state and its citizens remain incomplete, particularly in the case of the Indonesian diaspora.

This study makes a theoretical contribution, particularly by combining Honneth’s theory of recognition (Honneth, 2004) and Fraser’s theory of redistribution (Fraser, 2020) to explain socio-political conflicts over citizenship rights. This is crucial for broadening the concept of citizenship politics in the context of developing countries, which possess unique characteristics such as the Pancasila ideology and a long history of debates over citizenship (Dewansyah, 2019). The study also has a close relationship with various previous studies in the field of citizenship, particularly those focusing on the issue of dual citizenship, while also presenting significant differences and developments in terms of location, approach, and theoretical focus.

The aim of this study is closely related to efforts to understand and explain citizenship politics in the context of the push for recognition of dual citizenship in Indonesia, based on the theory of recognition and redistribution. This objective stems from the theory of political recognition, which views citizenship as a form of social relations that demands recognition of identity, and the theory of redistribution, which emphasizes the importance of economic justice and access to fundamental rights. By examining conflicts and differences in position between groups, this study explains how efforts to recognize dual citizenship are not only a legal matter, but also involve socio-political struggles over recognition and social justice.

Most previous studies, such as those by Gustafson in Sweden (Gustafson, 2002), Yanasmayan in Western Europe (Yanasmayan, 2015), and Kovács in Hungary (Kovács, 2006), have focused more on dual citizenship in the context of immigration, the integration of minority identities, or state responses to ethnic diasporas, with a focus on European countries. Knott examines the case of Moldova as an extreme case of dual citizenship. In Moldova, the majority of the population can acquire (or reacquire) Romanian citizenship based on descent from former Romanian citizens (Knott, 2019). Poethig conducted research in Cambodia on the debate surrounding the 1996 Dual Citizenship Law. Opponents of dual citizenship argued that it would undermine cultural purity, that dual loyalty was detrimental to fragile democracies, that it threatened political stability, and that it eroded a clear national identity (Poethig, 2006). Research in Africa was conducted by Whitaker, for example, who examined dual citizenship in Senegal, Ghana, and Kenya. The results showed that the drivers of dual citizenship can come from both society (bottom-up) and the state (top-down). This condition is driven by political, economic, and security reasons (Whitaker, 2011). Sejersen collected data from 115 countries and found that nearly half now recognize dual citizenship, compared with only a handful in the 1950s. This study highlighted regional differences, with acceptance of dual citizenship lower in Asia and higher in Europe and the Americas (Sejersen, 2008). These studies tend to view dual citizenship as a logical consequence of global mobility and multiculturalism, as well as a more adaptive and liberal strategy for socio-political integration. In contrast, this study positions Indonesia as a prime case, empirically demonstrating that a Southeast Asian country that has not experienced large waves of immigration, yet has a significant and politically active diaspora, is the primary actor in pushing for the recognition of dual citizenship.

Previous research in Indonesia is generally focused on the legal and formal aspects of citizenship (Nurmawati & Suantra, 2020). Yet, this study specifically examines the political dimension of citizenship, focusing on how various social groups namely, globalists, nationalists, and primordialists interact and negotiate in their efforts to either fight for or reject the recognition of dual citizenship. In this way, this research broadens the approach from one that is primarily legal and administrative to one that is critical-political and socio-philosophical.

Furthermore, the main development in this study is the time and its political context. This research focuses on the period after Law No. 12 on Citizenship in 2006, which marked a significant milestone in the history of Indonesian citizenship regulation (van Klinken, 2018). Overall, this study not only fills the gap in citizenship studies in Indonesia but also develops a richer conceptual approach to understanding citizenship politics as an arena for contestation of identity, power, and justice amidst the currents of globalization and demands for democratization.

Practically, this study has strategic value as input for policymakers, particularly in developing regulations that are more responsive to the needs of the Indonesian diaspora. The findings regarding various social groups that support and oppose dual citizenship can inform the government and the House of Representatives (the national parliament) in designing fair, realistic, and sustainable policies. It also provides a deeper understanding of diaspora groups and civil society organizations, enabling them to develop effective advocacy strategies, craft compelling narratives, and establish constructive communication with decision-makers.

Furthermore, the study can be utilized to enhance public understanding of the importance of citizenship as a fundamental aspect of human rights and political participation. By systematically presenting facts and analysis, it encourages the public to understand better that the debate over dual citizenship is not merely a legal issue, but also reflects a struggle over fundamental values in national life. The study is expected to contribute to the advancement of science as well as the strengthening of democracy and the development of inclusive public policies in Indonesia.

2. Method

This study employs a qualitative approach to understand the dynamics of citizenship politics in the push for the recognition of dual citizenship as a legal status in Indonesia. Data collection was conducted through documentation studies and content analysis of various sources, such as laws and regulations, official government documents, speeches by political figures, mass media coverage, archives of diaspora congresses, and interview results related to citizenship issues. Additionally, the study reviews relevant academic literature and journal articles to compare the Indonesian context with other countries in terms of dual citizenship policies. Data validity was maintained through source triangulation, comparing data from various types of documents and information sources to ensure the consistency and credibility of the findings (Wiltshire & Ronkainen, 2021). The analysis was conducted in stages through a process of issue categorization, actor mapping, and identification of political narratives developing in the debate on dual citizenship (Guest et al., 2014).

3. Results

Following the enactment of Law No. 12 of 2006 on Citizenship, a new dynamic emerged in Indonesian citizenship politics. This regulation reinforced the principle of single citizenship and only provided limited opportunities for dual citizenship for children of mixed marriages (Lazuardi, 2020). However, with increasing global mobility and the number of Indonesians living abroad, demand for recognition of dual citizenship has grown (Antikowati et al., 2023). This issue has created tension between the individual’s right to remain connected to their country of origin and the state’s concerns about dual loyalties (Wulansari et al., 2021).

The constellation of three social groups on the issue of dual citizenship does not reflect the political dynamics emerging in the legislative realm. The dominant groups emerging to negotiate are globalists and nationalists, while primordialists have not significantly responded to the dual citizenship issue. Empirically, these three groups have different perspectives on citizenship. First, the globalists represent the Indonesian diaspora living abroad. They advocate for the recognition of dual citizenship as a form of recognition of human rights, global mobility, and emotional attachment to the homeland. Their primary rationale is to facilitate contributions to national development without having to relinquish legal and economic rights in the country of residence. For them, citizenship is a form of legitimate dual membership in both the global and national communities (Harijanti et al., 2018). Second, the nationalists emphasize the importance of single loyalty to the state. They reject dual citizenship because they believe it can weaken sovereignty, open up opportunities for legal abuse, and create problems in defense and political leadership. This view reflects concerns about the state’s weak control over citizens who hold two national affiliations simultaneously (Afifi Elfinur, 2021). Third, primordialist groups are rooted in local ethnic, customary, and cultural ties. They view dual citizenship as a threat to national identity and ownership of local resources, particularly land rights. They believe that recognizing dual citizenship will facilitate foreign domination of local land and the economy, which has historically led to inequality and social conflict (Permana, 2021).

Amid differing views from various social groups, the national parliament has taken steps to discuss the issue in legislative forums and include it in the National Legislation Program. However, there has been no significant progress in the regulatory process. Weak political commitment, competing interests among factions in the House of Representatives, and the dominance of security and nationalist discourse have contributed to the stagnation of this issue. The parliament has not yet functioned as a deliberative arena capable of inclusively absorbing citizen aspirations as idealized in democracy. This situation demonstrates the difficulty in establishing new agreements and the tendency to prioritize the status quo, due to the minimal potential for conflict (Dator, 2001).

Within the unique democratic framework of Indonesia, known as Pancasila Democracy, state decisions should be made through deliberation and prioritizing consensus (Wisnaeni & Herawati, 2020). However, in practice, the dual citizenship policy has become an arena for ideological debate that struggles to find common ground (Bauböck, 2021). Democracy, which should offer a compromise, has instead become mired in differing views between groups defending their respective views (Eckersley, 2020). This demonstrates that deliberative democracy in the Indonesian context still faces serious challenges in responding to the diversity of civic aspirations.

Other findings indicate that diaspora groups face gaps in two primary dimensions: identity recognition and the redistribution of citizenship rights (Banting, 2023). Although the diaspora plays a significant role in remittances, cultural diplomacy, and Indonesia’s international image, they remain denied full recognition as citizens if they choose or hold another citizenship. This inequality highlights the limited application of the principle of social justice, which is integral to the state ideology (Fedina & Povalena, 2023). However, suppose the state provides access to dual citizenship recognition. In that case, this situation will impact the redistribution of citizenship rights that already apply under the principle of single citizenship, leading to an ideological and cultural shift in the understanding of nationality and statehood (Dean, 2024).

The research findings show that citizenship politics in Indonesia, particularly regarding dual citizenship, is an arena for negotiating interests between social and political groups. The policy-making process is not merely a legal or administrative matter, but also involves values, identity, and perceived threats to the nation (Hoffmeyer-Zlotnik, 2024). In this context, dual citizenship is not merely a legal status, but a symbol of the struggle between global openness and national protectionism.

4. Discussion

This study found that citizenship politics in Indonesia, related to the issue of dual citizenship, occurred during negotiations between social groups, specifically globalists, nationalists, and primordialists. Although the primordialist group paid less attention to the issue of dual citizenship, negotiations occurred. These three groups have different constructions of meaning regarding the concept of citizenship and national interests, which in turn influence their positions in the dual citizenship discourse.

Globalists, largely drawn from diaspora communities, advocate dual citizenship based on human rights, global mobility, and the desire to continue contributing to Indonesia while maintaining their civil and economic rights in their home countries. Globalists in Indonesia share a similar view to those in Britain, they want the state to adopt a more flexible and transnational approach to citizenship to recognize the changing identities of citizens in the global era (J. Scotto et al., 2018). Meanwhile, nationalist groups reject the concept of dual citizenship, deeming it detrimental to political loyalty, defense, and the integrity of the nation’s sovereignty (Kozyrev, 2016). They believe that citizens must have a single commitment to Indonesia and consider dual citizenship a form of identity uncertainty, as well as a potential threat to domestic policy, particularly in the political, legal, and agricultural sectors. Primordialist groups, on the other hand, are based on traditional values and local tribal or ethnic identities. They tend to view dual citizenship as a threat to cultural heritage, customary lands, and the social structure of rural communities. In their view, dual citizenship policies could open up opportunities for foreigners to access exclusive rights of local communities, such as land ownership and economic resources (Hutton, 2022).

This study finds that parliament, as a democratic arena, has not been able to effectively act as a deliberative space in responding to calls for the recognition of dual citizenship (Irving, 2019). Although dual citizenship has been included in the National Legislation Program for over a decade, formal discussions on revising the Citizenship Law have not yet resulted in a decision, due to the intense tug-of-war between factions and the weak political will of state actors. From a theoretical perspective, this study demonstrates that recognition and redistribution cannot stand alone in explaining the dynamics of citizenship politics in Indonesia. Recognition of the diaspora’s identity as citizens is not always accompanied by a fair redistribution of rights (Wulansari et al., 2021). On the other hand, demands for economic justice from the diaspora often clash with nationalist concerns about losing control of national resources. This reflects the limitations of Western theory, which needs to be contextualized within the political and ideological realities of the Indonesian state (Saraswati, 2021).

The political reality of citizenship, driven by calls for recognition of dual citizenship legal status in the legislature, demonstrates that the principle of deliberation and consensus has not been able to substantively resolve differing views. Rather than providing a space for consensus, citizenship politics has become an arena for resistance and policy deadlock (Lee & Romano, 2013). This demonstrates that democracy in Indonesia still faces challenges in managing the diversity of citizens’ aspirations in a deliberative and inclusive manner, particularly on sensitive issues that touch on identity, loyalty, and constitutional rights.

5. Conclusion

This study demonstrates that the issue of dual citizenship in Indonesia is part of a complex dynamic of citizenship politics, marked by competing interests. In a democratic context, the push for dual citizenship recognition is not merely an administrative or formal legal issue; rather, it reflects a conflict of values, identities, and political orientations among social groups. Three leading opposing positions exist: globalists, who push for recognition based on the principles of human rights and global connectivity; nationalists, who reject it on the grounds of sovereignty and single loyalty; and primordialists, who view this issue as a threat to the collective identity and rights of local communities. This suggests that citizenship is not a neutral concept, but a contested political terrain. In practice, the state has not been able to bridge these differences in a deliberative manner. Parliament, as a representative of democracy, has yet to produce a substantive policy on dual citizenship. Yet, the need to respond to the reality of an increasingly globally connected diaspora is becoming increasingly urgent.

The study also reveals the inequality in recognition and redistribution of rights for the Indonesian diaspora. Despite their significant economic contributions and international reputation, they remain on the fringes of the citizenship structure because the state has not fully recognized their status. This suggests that the principle of social justice in democracy has not been fully realized in citizenship policy. However, granting dual citizenship has the potential to change the legal structure, cause social unrest, and shift national identities. Therefore, recognition and redistribution in the context of dual citizenship pose a dilemma. This situation indicates that citizenship politics in Indonesia still faces challenges in managing the plurality of citizens’ aspirations democratically. Recognition of dual citizenship requires not only regulatory changes but also a shift in political paradigm, from an exclusive and defensive approach to one that is inclusive, deliberative, and oriented towards social justice.

Author Contributions: All authors contributed to this research.

Funding: Not applicable.

Conflicts of Interest: The authors declare no conflict of interest.

Informed Consent Statement/Ethics approval: Not applicable.

Acknowledgments: This research is fully supported by grants from the Faculty of Social and Political Sciences, Universitas Gadjah Mada, and the Research and Community Service Institute, Universitas Siliwangi.  The opinions expressed here are those of the authors and do not necessarily reflect the views of funding agencies.

Declaration of Generative AI and AI-assisted Technologies: This study has not used any generative AI tools or technologies in the preparation of this manuscript.