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Students or internationals? Divergent patterns of governing international student mobility in Germany and the United Kingdom


This article investigates how Germany and the United Kingdom (UK) have governed international student mobility (ISM) over the last two decades. While both are among the most popular destinations for international students and have experienced similar political trajectories during this period, they have pursued divergent education and immigration policies in regulating ISM. Driven by a mix of educational universalism and fear of future labor shortages, Germany offers financial benefits and generous right to stay opportunities. The UK, by contrast, combines high tuition fees with restrictive immigration policies, favoring students who will leave the country upon graduation. Drawing on a variety of parliamentary reports, policy documents, and interviews with politicians and civil servants, I argue that this divergence is rooted primarily in the different politicizability of ISM: international students are discursively treated as students (belonging to the non-politicized field of education) in Germany but as internationals (belonging to the hyperpoliticized field of immigration) in the UK.


Within only a few decades, the topic of international student mobility (ISM) has moved from the margins of mobility research to the mainstream, with more international students (defined as those “who [leave] their countries of origin and [move] to another country for the purpose of study”; see OECD, 2020: 235) appearing on the higher education scene each year (e.g., Riaño et al., 2018b; Van Mol, 2014). Many move between the popular student destinations of the Global North, others from South to North, North to South, or within the South.Footnote 1 More than 5.6 million students, the OECD estimated in its 2020 Education at a Glance report, are enrolled at tertiary institutions in a country that is not their own.Footnote 2 Their reasons and motivations for doing so (e.g., De Winter et al., 2021; Maringe & Carter, 2007; Netz, 2015) are as varied as their post-graduation plans (for an overview, see Alberts, 2018), which has brought government strategies to manage this particular form of transnational mobility (neither traditional labor migration nor the result of war or persecution) increasingly into focus.

Although popular fiction such as Noah Gordon’s The Physician reminds us that ISM has been subject to a complex interplay of permissiveness and restrictiveness for centuries (e.g., De Ridder-Symoens, 1992), the twentieth and early twenty-first centuries, with their rising knowledge societies (Stehr, 1994; see also Gürüz, 2011), have witnessed unprecedented debates about the implications of mass student mobility: brain drain and global war for talent are just two of many buzzwords that have become increasingly popular in recent years.Footnote 3 Especially in Europe and the United States (US), governments combine different education and immigration policies to steer ISM in their preferred direction, regulating the admission of international students as well as their employment opportunities upon graduation. But while one might expect countries in a similar position to pursue similar strategies, ISM policies are often paradoxically divergent. This article examines the reasons for this divergence in the case of Germany and the United Kingdom (UK). It first provides a conceptual overview, then outlines the reasons for comparing these two particular cases, and finally analyzes and discusses their policy trajectories over the past two decades. In the end, it concludes that institutional constraints alone are an insufficient explanation and instead emphasizes the contrasting politicizability of international students. While they have remained students in Germany, they are seen as internationals—and therefore as objects of controversy—in the UK.

Conceptual background

While ISM has existed since the early days of higher education, two macro developments in particular have contributed to its spectacular ascent. The first is educational expansion, which can be defined as a political strategy to increase tertiary enrollment across society. Historically, the need to allow mass access to higher education and dismantle traditional entry barriers arose in part from the major transformations of the 1960s and 1970s, when the emergence of advanced service economies changed the structural demands of the labor market, but more so from the spread of an educational ideology built around notions of progress and human development (e.g., Fiala & Lanford, 1987; Meyer & Schofer, 2007). Both fostered the scientification and technification of society, contributed to a homogenized view of the world (Schofer et al., 2021), and upended the centuries-old relationship between social status and educational attainment. No longer the privilege of a select few, attending a university or college became the “expectable thing for one’s children, just as a high school education […] has in the past” (Trow, 1962: 236). Needless to say, it was this expansionary impetus that turned higher education into a bona fide welfare issue—governments soon realized they had to make considerable financial investments to ensure the future competitiveness of their citizens.

However, this expansion was only a necessary but not a sufficient condition for the rise of ISM; its impact would have been limited without a parallel trend toward internationalization, that is, the growing embeddedness of learning in educational contexts beyond the national sphere (e.g., Altbach & Knight, 2007; Knight, 2008). Ranging from the establishment of satellite campuses abroad (Healey, 2015) to elaborate exchange programs, and advocated by policymakers and university administrators in equal measure,Footnote 4 it has become a core element of higher education strategies around the world. While in some cases a truly global approach is taken, it is the regional level that stands out in others—in Europe, for instance, a dominant element of internationalization is Europeanization, with national ISM policies largely shaped by the Bologna Process and European Union (EU)-driven harmonization efforts (e.g., Bache, 2006; Papatsiba, 2006; Teichler, 2012). But unlike educational expansion, which emerged from a specific moment of isomorphic pressure, and intra-European student mobility, which was a longstanding prestige project of European integration supporters,Footnote 5 the rationale for allowing non-European student mobility is by no means self-evident. In fact, one may argue that a state has no a priori interest in providing education to students who are neither its citizens nor its residents, let alone an interest in promoting an industry that serves no purpose other than to advertise its universities to them (e.g., Altbach, 2013; Beech, 2018; Lomer et al., 2018). As the logic of public welfare revolves around the dichotomy of give and take, one would expect those who take without giving to be shunned rather than courted.

What could be possible reasons to court them regardless? The first and most obvious one that comes to mind is reciprocity: If two countries have roughly similar numbers of incoming and outgoing students, both could benefit from ISM without one taking advantage of the other. However, there is clearly no such balance in the real world, with many more Asian or African students moving to North America and Europe than the other way around.Footnote 6 A second and perhaps more pragmatic reason is the pursuit of foreign policy goals (e.g., Kuptsch, 2006; Lomer, 2017; Metzgar, 2016). A third reason is the cultural capital and institutional prestige that international students can bring to their host universities (e.g., Lee, 2015; Shkoler & Rabenu, 2020). Yet, most relevant seems to be a fourth reason: the expectation that they can be integrated into the welfare state’s give-and-take logic, whether by contributing financially or by meeting local labor market demands (e.g., Beechler & Woodward, 2009; Bolsmann & Miller, 2008; Cantwell, 2015; OECD, 2020). That most are solicited “for the competitive edge they offer” has indeed long been a “received wisdom in ISM studies” (Riaño et al., 2018b: 283; see King & Raghuram, 2013).

Still, this does not explain the diversity of approaches to ISM policy, which generally encompasses two key aspects of nation-state openness. First, there is educational openness, of which tuition fees are an excellent indicator. They have the potential to either attract or deter international students and—in cases in which others pay less or nothing at all—cement a visible hierarchy between privileged domestic insiders and non-privileged international outsiders (Table 1).

Table 1 Tuition fees in OECD countries

At the same time, there is also migratory openness, which can be conceived in terms of admission (studying abroad is conditional on entering the country), but also as the period of time that students are allowed to stay after completing their studies (Table 2).

Table 2 Right to stay in OECD countries

Both tables point to a wide range of policy options, with two observations appearing particularly striking. First, there is considerable variation among countries considered top destinations for international students (e.g., Australia, Canada, UK) but no geographical clusters: Canada and the US are neighbors, but the former is more generous in its right to stay approach than the latter; likewise, Denmark and the UK are separated only by the North Sea, but seem miles apart in terms of tuition fees. Second, ISM policies significantly diverge from the three worlds of educational welfare (Willemse & de Beer, 2012) when it comes to the right to stay. In fact, some liberal education regimes (less stratification but more commodification) are among the most restrictive in this regard, whereas some conservative regimes (more stratification but less commodification) are relatively flexible. Since one would normally expect most OECD members to face similar internationalization pressures, such a discrepancy is all the more puzzling. Why do policy paths branch out in this case when they should run alongside each other?

Case selection and materials

Although the puzzle presented is of a more general nature, it seems prudent to limit the scope of this article to two countries that have much in common but champion different ISM policies: Germany and the UK. Perhaps their most obvious similarity is that both are exceptionally popular destinations for non-EU students and direct competitors in the battle for global talent. As of 2020, the UK accounted for close to 8 percent of the international student market, placing it second only to the US. Germany, however, was not too far behind, ranking number one outside the Anglosphere at 6 percent (OECD, 2020). In either country, the absolute number of international students has also risen sharply in recent years. To give but one example, 24,675 Chinese first-year studentsFootnote 7 were enrolled in British universities in 2007–08. A decade later, this number had already more than tripled to 76,425 (Universities UK 2020), with Indian, Indonesian, and Pakistani students also flocking in.Footnote 8

Moreover, the two countries have experienced a similar political history over the past two decades, beginning with popular Third Way politicians who set out in the late 1990s to overcome what many perceived as stagnation and scleroticism (Boswell & Hampshire, 2017). In Germany, Gerhard Schröder’s SPD-Greens coalition convinced many first-time voters with a bold commitment to reform: Ich bin bereit (I am ready), his campaign posters read. At the same time, in the UK, Tony Blair’s 1997 landslide victory appeared as the embodiment of Cool Britannia, with the new prime minister's youthful optimism mirroring the reform-minded zeitgeist of the era. Like Schröder, Blair had promised voters a “program of change and renewal” (Labour 1997: Ch.1) to meet the demands of the dawning twenty-first century (e.g., Coates, 2000; Newman, 2001) and inject innovation into an inflexible political system. In light of these parallels, this comparison begins with Schröder and Blair’s first election victories and concludes with the British withdrawal from the European Union (more colloquially known as Brexit). It only considers the situation of non-EU students, however, as neither country was allowed to restrict the rights and movement of EU students in a way that would have resulted in meaningful policy differences.

In both cases, I draw on an array of written materials, including legal provisions, policy reports, and parliamentary speeches.Footnote 9 To complement them and learn more about their background and practical relevance, I also conducted a series of semi-structured interviews (N = 13) with politicians, civil servants, and policymakers. In an inductive process, I usually took inspiration from a speech or report I had read to bring up a certain point in an interview and, in turn, received advice from interviewees on what to read and which leads to follow. This was greatly facilitated by the diverse backgrounds and perspectives of those I spoke with, among whom were current and former parliamentarians from the main political parties in both countries (Germany: CDU/CSU,Footnote 10 SPD, FDP; UK: Conservatives and Labour), civil servants, senior officials of the German Academic Exchange Service (DAAD) and the British Council, as well as a former member of the Schröder cabinet.Footnote 11 As it was not possible to hold in-person meetings due to the COVID-19 pandemic, all interviews were conducted via phone or video conferencing. In general, they ranged from forty minutes to three hours and were recorded. If recording an interview was not permitted, notes were taken and later transcribed.

Germany: Universalism and Fachkräftemangel

A country with a long academic tradition, Germany’s post-war higher education policy was characterized by efforts to reconcile the Humboldtian ideal (unity of research and studies; comprehensive acquisition of knowledge) with the need for highly specialized degrees that would prepare students for future employment (see Reihlen & Wenzlaff, 2016). While applied Humboldtianism initially had elitist connotations (e.g., Ringer, 1969), the core idea that higher education should provide Bildung as a cultivation of the whole person was quickly appropriated by progressive forces after the end of the Second World War. Throughout the 1960s and 1970s, new ‘reform’ universities were established, academic institutions democratized, and the Humboldtian legacy combined with a commitment to educational expansion. The result was (and is) a quasi-universalist concept designed to minimize the impact of income and social status. Access to higher education is supposed to be based solely on one's ability and potential, which means that anyone talented enough to pursue a post-secondary degree should be given the opportunity to do so.Footnote 12 This spirit is further reinforced by the fact that there are no elite universities (in the Anglo-American sense) and only slight differences in quality: Different universities and Hochschulen may have different areas of strength, but they are all meant to ensure a solid academic foundation. Private higher education, by contrast, is usually confined to business schools and a few highly specialized fields.

For all its advantages, this approach also entailed a certain degree of insularity, and the higher education landscape that Schröder’s coalition inherited was neither particularly dynamic nor outward-looking. Instead, low levels of ISM and a provincial attitude made one wonder whether the Land der Dichter und Denker (country of poets and thinkers) would soon lose its technological edge. Mindful of these concerns, Schröder’s SPD included the slogan Hochschulen modernisieren (Modernize universities!) in its 1998 platform, proclaiming that “Germany’s universities need more autonomy and competition […] research and teaching must be internationally oriented” (SPD, 1998: 31). While this reformist vision was shared by Bündnis 90/Die Grünen as the SPD's junior coalition partner,Footnote 13 both education and immigration policy were placed in Social Democratic hands: Edelgard Bulmahn, the SPD parliamentary group’s spokeswoman for education policy, and Otto Schily, a militant lawyer turned center-left pragmatist, were tasked with implementing the new government’s ambitious agenda. Both would remain in office (Bulmahn as Minister of Education and Schily as Minister of the Interior) for the entirety of Schröder’s seven-year tenure.

Once in government, they soon began drafting legislation to make Germany more attractive to international students. Since the federal government has very limited authority over education policy (which is primarily the responsibility of the states, a principle known as Bildungsföderalismus), most legislative efforts focused on reforming the immigration system. In 2004,Footnote 14 the Bundestag passed the Zuwanderungsgesetz (Immigration Act), which included a new Aufenthaltsgesetz (Residence Act) that modernized a wide range of immigration provisions. Among other things, it reaffirmed residence rights for students at German universities (§16b, 1 AufenthG), facilitated family reunification (§32, 1 AufenthG), and allowed university graduates to stay for up to eighteen months (§20, 3 AufenthG), shifting the prevailing paradigm from “a study and go to a study and stay approach” (Griesbeck & Heß, 2016: 55).Footnote 15 At the time, these measures were not without controversy, however, as the dethroned CDU/CSU was still committed to familialism and immigration skepticism. In 2000, Bulmahn’s predecessor Jürgen Rüttgers had famously called for Kinder statt Inder (‘Children instead of Indians’), and even toward the end of Schröder’s time in office, some more right-wing CDU/CSU MdBs continued to polemicize against “immigration through the backdoor” (Grindel, 2005: 16931).

This dismissive attitude only began to change when Schröder was bested by then CDU leader Angela Merkel in 2005. Forced into a grand coalition with the SPD, the CDU/CSU leadership showed little ambition to roll back the higher education strategy of the previous government. Instead, it succumbed to pragmatism, opted for policy continuity, and softened its hardline opposition to immigration. Its only major reform in higher education, the introduction of tuition fees made possible by a 2005 ruling of the Federal Constitutional Court, turned out to be an costly political mistake. While most CDU-led state governments soon passed legislation to charge around 500 euros per semester,Footnote 16 the public vehemently opposed the fees. It was not long before they were seen as electorally damaging and abolished again, in at least one case by the same state government that had introduced them in the first place. “This was a big mistake by the CDU back then,” recalled a long-time SPD MdB (#4). “Our universities may not be […] Champions League [level] yet, but at least we can do without this tuition fee madness. I think people were afraid that studying would become unaffordable for many.” After some time, even the CDU/CSU’s federal leadership could no longer ignore the writing on the wall: Preoccupied with the European sovereign debt crisis and fearful of further controversy, it came to terms with the status quo ante and agreed to a policy reversal. Not to burn its fingers again, it subsequently adopted the Social Democratic internationalization script and paved the way for a broad and lasting pro-ISM consensus.Footnote 17

Both the change in the CDU/CSU's position and the emergence of this consensus were fostered by the narrative of a looming Fachkräftemangel, which must be prevented at all costs. Showing just how big an impact ideas can have on social policy (Béland, 2005), this term, commonly translated as labor shortage, denotes a lack of skilled labor as a result of demographic change. “Fachkräftemangel became a really big thing […] we started to realize that we could lose our economic edge if we didn’t recruit workers from abroad. Preventing that has been the consensus ever since, and nobody in parliament wants to question it, except perhaps the AfD,”Footnote 18 a former FDP MdB (#3) noted. In fact, “there has hardly been an issue [in the recent past] which has dominated the debate in the areas of economic and labor market policy in a similar way” (Rahner, 2018: 12), with economists, demographers, employers’ associations, and even trade unions all spreading the message that millions of Fachkräfte are needed if Germany is to maintain its competitiveness (e.g., Menz, 2016; Oesingmann, 2016; for Asia, see also Mayer, 2014). In one of his many speeches on the subject, the CDU/CSU’s Peter Aumer argued, for example, that in his electoral district “you won’t find a 48-year-old tradesman unemployed. There is Fachkräftemangel! [And we have to solve it] urgently” (2019: 14233). Neither the SPD nor any of the other mainstream parties would disagree.

It must be noted, however, that despite this appetite for foreign labor, all German governments of the last twenty years have carefully avoided the impression that they are participating in the exploitation of developing countries or advocating brain drain. Efforts to attract international students have therefore always been accompanied by a commitment to educational cooperation and humanitarian aid. When several hundred thousand refugees arrived in Germany in 2014–15, government agencies provided funding for integration courses and made sure that all new arrivals could apply for BAföGFootnote 19 grants and KfWFootnote 20 loans (e.g., Ashour, 2022; Streitwieser & Brück, 2018). Even though most of these refugees did not meet the usual Fachkräfte criteria, they were still given the same access to the “generous German educational support mechanisms as all domestic students” (Streitwieser & Brück, 2018: 41), furnishing proof that the universalist tendencies in German higher education are still alive and well.

United Kingdom: Searching for the ideal student

As was the case with Schröder and his SPD, modernizing higher education and bolstering Britain’s international reputation were essential to Blair’s agenda. Supported by Jack Straw at the Home Office and David Blunkett as Secretary of State for Education and Employment, he wasted no time in devising a comprehensive internationalization strategy that eventually culminated in the Prime Minister’s Initiative (PMI) of 1999 (e.g., Dodds, 2009; Geddie, 2015; Lomer et al., 2018). Encompassing different strategies to raise the UK’s international profile, the PMI set out to “increase the number of international students [within five years] by 100 per cent”, “market education abroad more professionally”, and develop “a new UK education brand” (Blair, 1999: n.p.) under the auspices of the British Council. What the new government had planned, in other words, was nothing less than a complete overhaul of the country’s internationalization agenda, pursued aggressively and with specific numbers in mind. Initially, there was also much support for Blair’s idea—many liked the boldness of his approach, were convinced of its benefits,Footnote 21 or feared the prospect of dwindling competitiveness, especially in the face of heightened international marketing efforts in the US, Australia and Canada. As a result, the initiative was extended in 2006 (PMI 2)Footnote 22 with additional emphasis on quality management and transnational education (Lomer, 2018).

Considered “the first coherent British policy” (Lomer, 2018: 312) on ISM, most PMI measures focused on promoting the UK as an attractive student destination. But there were also immigration provisions aimed at facilitating educational access for foreigners: Student visas were made easier to obtain, and the labor market was opened to “undergraduates in sectors where we need extra skills [because they] will be able to work in the UK for up to 12 months after graduating” (Blair, 2006: n.p.). However, this shift toward a selective but nonetheless expansive study and stay approach came to an abrupt halt when David Cameron’s Liberal-Conservative coalition took the reins after the 2010 general election. The Tories had previously campaigned on the promise of regaining control over immigration, pointing, inter alia, to the abuse of student visa regulations by migrant workers (Carey & Geddes, 2010). While these fears were not new,Footnote 23 they were now stoked in a particularly drastic way. The PMI’s portrayal of international students as a valuable resource did not completely disappear, but this counter-narrative tarnished their image and cast them in a dubious light. Increasingly, they were accused of living off welfare benefits and placing an additional burden on already strained public services (Lomer, 2018), with Partos and Bale noting that “the ‘bogus’ asylum seekers of the 1990s/2000s [were replaced] in the [popular] imagination by ‘bogus’ students who attend ‘bogus’ colleges” (2015: 174).

Over time, this discrepancy between the official appreciation of skilled foreigners and the desire to reduce immigration numbers became ever more apparent:Footnote 24 During Cameron’s first years in 10 Downing Street, border interviews and additional language requirements were introduced, while the post-study work visa program was discontinued (e.g., Levantino et al., 2018; Lomer, 2018; Trevena, 2019).Footnote 25 Still, these efforts neither reduced the number of international student applications nor did they alleviate the financial dependence of British universities on them. In fact, since Margaret Thatcher’s decision to impose full fees on international students,Footnote 26 they have become quintessential “customers in a higher education marketplace” (Findlay et al., 2017: 27; see also, e.g., Bolsmann & Miller, 2008; Lomer, 2014; Marginson, 1997; Tannock, 2018), whose tuition is not subsidized and thus far in excess of what is charged to domestic students.Footnote 27 “I consider higher education one of our most thriving industries,” explained a Conservative MP (#11), before adding that “an industry, even a thriving one, is no immigration scheme. We are more than happy to welcome international students. […] But as students. Not as immigrants.”

Such positions are symptomatic of the paradoxical post-2010 logic, which continues to encourage ISM to keep British universities afloat, but at the same time pursues “the curtailing of net migration by the tens of thousands” (Levantino et al., 2018: 372).Footnote 28 The ideal student, it seems, would be someone who contributes to the economy, pays lots of fees, and becomes an ambassador for British culture, but is not physically present in the country. This trend has only intensified in recent years, especially in the wake of the Brexit referendum; an event whose consequences cannot yet be fully assessed but whose anti-mobility message is hard to overlook. Although it does not directly affect students from non-EU countries, its political dimension—how proponents of the isolationist regain control line triumphed over supporters of intra-European mobility—suggests that the needs of higher education are considered less important than the fears of being overwhelmed by immigration (e.g., Weimer & Barlete, 2020). Some, of course, also hope that Brexit will prove beneficial in the long run and allow the UK to build a truly global Britain (Kleibert, 2023), which is also what new student exchange programs such as the Turing scheme aim to achieve.Footnote 29 In any case, however, the current impression is that deep-seated immigration fears and a self-centered outlook could ultimately prevail.

Discussion: What can explain the divergence?

In summary, both Germany and the UK set out to attract more international students and open up their higher education systems at the beginning of the new millennium. But only two decades later, they seem to have parted ways. An entrenched universalist legacy, the pervasive narrative of Fachkräftemangel, and the CDU/CSU’s shift in immigration policy have given rise to a strong pro-mobility consensus in Germany: international students can benefit from the system now but are expected to contribute to it later. Conversely, a commodified higher education landscape and growing anti-mobility prejudice have turned this strategy on its head in the UK, where international students are asked to contribute now but promised that they will later benefit from their prestigious degree. Yet the reasons for this divergence are still not intuitively clear. After all, both countries could be similarly affected by future labor shortages—why then is there policy continuity in one case but a back-and-forth of permissive and restrictive measures in the other? Why has the UK changed its strategy but Germany has not?

There are several possible explanations for this, the first of which stems from the reality of coalition politics.Footnote 30 Coalitions between two or even three parties are quite common in the German political system, and with the exception of the period between 2009 and 2013, Merkel’s CDU/CSU always governed in grand coalitions with the post-Schröder SPD. One could thus assume that the Unionsparteien simply lacked the political capital to enforce restrictive policies against the will of a coalition partner on which they were so dependent.Footnote 31 By contrast, the British Conservatives governed alone most of the time, and the majoritarian Westminster system allowed them the luxury of not having too much regard for others when implementing their program. The only time when this was not the case—after the 2010 general election had resulted in a hung parliament—substantial differences over education policy led to conflict within the newly formed Conservative-Liberal alliance and severely damaged its credibility (Griffiths, 2015).

Related to this is the argument that divergent policies may arise from institutional differences. When there is, as in the UK, a propensity for “[m]inisterial and civil servant short-termism, reshuffles […]” and “political hyperactivity” (Barber, 2016: 1; see also Herman, 1975; Berlinski et al., 2007), one is well advised not to think too much about the possible long-term consequences of one’s decisions. With cabinet members coming and goingFootnote 32 and reforms often carried out for the sake of doing something, there is little incentive for those in power to pursue a consistent ISM strategy. Consider also that the Bundestag places more emphasis on committee work than the House of Commons, that it has additional consultative and conflict resolving bodies such as the Ältestenrat (Council of Elders), and that there is no leader of the opposition constantly seeking the limelight. “It is a parliament designed and programmed for rational debate among sensible people,” Paul Lever acknowledges, “rather than for the rough and tumble” (2017: 77) of Westminster. As such, it is geared toward incremental change and consensus, especially when there are no deep ideological divides.

While these differences provide helpful insights and must be taken seriously, I argue that there is yet another crucial element: the discursive status of international students, which entails varying degrees of politicizability, that is, how easily something can be made the object of politicization. In Germany, they have always been considered students (and future workers), who belong to the non-politicized field of education. But in the UK, they were gradually turned into internationals, who instead belong to the hyperpoliticized field of immigration. In one case, they are absent from immigration debates, while in the other, these debates are rife with imagery that portrays them as takers rather than givers; as hostile intruders who take advantage of the system and diminish the life chances of native youth. In the popular press, this narrative has become manifest in the dualism of foreign applicants who jump “the queue: Overseas candidates offered uni places with lower grades than UK teenagers” (Bains & Gayle, 2012) and local applicants who consequently feel “betrayed:Footnote 33 Top UK universities take foreign students with poor grades over Brits so they can rake in four times as much in fees” (Burnip, 2017), a juxtaposition that would probably fare rather badly in the German context. So too would complaints that “brilliant” domestic students are rejected from top medical schools while British hospitals are “plundering staff from the Third World” (Adams, 2018) for short-term gain.Footnote 34

Still, in the UK, such stories seem to work well, not least because they are ultimately less about international and domestic students than about foreigners and citizens, about those privileged by virtue of their nationality and those who challenge this privilege from the outside.Footnote 35 It must be said, however, that this different politicizability is neither the result of fate or coincidence, nor a mere byproduct of British tabloid culture. Rather, if we depart from the notion that social and political institutions are embedded in a broader framework of discursive practices, abilities, and potentialities (e.g., Schmidt, 2008), we soon encounter two sharp discursive contrasts. The first is between integrationist openness and sovereigntist insularity in immigration policy, whereas the second is between little commodified universalism and highly commodified particularism in education policy. Both are, at least to some extent, also rooted in national cultures and can be found in a range of related phenomena, from the British tendency to politicize intra-European movement more generally (Roos, 2019) to the historical reluctance of post-war Germany to restructure its education system (Baldi, 2012).Footnote 36 In the present case, once international students had become salient enough to be relevant objects of controversy, these contrasts led to different degrees of politicizability—low in Germany and high in the UK—which prompted political and media actors to react and engage with them accordingly. “I would definitely say that there is such a difference […] the German debate has been considerably less ambiguous,” agreed a leading DAAD official (#6). “Many people have been worried about asylum seekers. But no one, really no one, has expressed concerns about international students so far.”

Concluding remarks

In conclusion, although the politico-institutional background may have contributed to policy continuity in Germany and discontinuity in the UK, it is the politicizability of international students that best explains the policy divergence between the two countries. German legislators were able to build on a coherent universalist foundation and a pro-mobility consensus once the narrative of Fachkräftemangel had become hegemonic and the traditional immigration skepticism of the CDU/CSU had begun to wane. Meanwhile, their British counterparts had to contend with both a more wary public and more popular anti-mobility demands. As neither German enthusiasm for recruiting talent from abroad nor British reservations about immigration are likely to disappear soon, this divergence can be expected to persist for the foreseeable future. In Germany, the CDU/CSU suffered defeat in the 2021 federal election, losing the Ministries of the Interior and Education to the SPD and FDP,Footnote 37 but the fear of Fachkräftemangel is as present as ever, and cross-party support for pro-mobility policies continues unabated.Footnote 38 If anything, the Scholz government could push for even greater internationalization; its culturally liberal profile would certainly allow for it.

On the other side of the Channel, the fact that neither Brexit nor the COVID-19 pandemic has led to a decline in the number of international applicants does not bode well for those hoping for policy change in the UK.Footnote 39 The system adapts to its environment, the international students keep coming, and the British public may continue to favor self-sufficient universities and tough immigration measures. Thus, the forking paths of ISM are unlikely to reconverge any time soon, which opens up numerous possibilities for future research. These include ethical questions that transcend simple critiques of ‘neoliberalism’ in British higher education (Yang, 2020), as well as possible strategies for recruiting international students without giving the impression of admitting immigrants. In view of the pandemic and its repercussions, the promotion and diffusion of online education should be examined more closely in this context (see, e.g., Bennell, 2022).

Availability of data and materials

Data sharing is not applicable to this article as no datasets were generated or analyzed during the current study.


  1. In fact, the fastest growth is in “students enrolled in non-OECD countries” (OECD 2020: 228).

  2. Data from 2018. In view of an average annual growth rate of 4.8% since 1998, the current number is likely higher.

  3. There is a large body of literature on both; notable examples include Baruch et al. (2007) and Rizvi (2005) for the former and Beechler and Woodward (2009) for the latter.

  4. See, for example, the Lisbon Declaration of the European University Association and its commitment to facilitating long-term student mobility: “In particular, national authorities are urged to adapt immigration laws and visa regulations to enable this strategy to succeed” (2007: 4).

  5. A Dane studying in Greece or a Latvian studying in France are also international students, but any restriction of their right to study, live, and work abroad would run counter to the EU’s Citizens’ Rights Directive (2004/38/EC).

  6. In Canada, Australia, and the US, the ratio between incoming and outgoing students even exceeds 10:1.

  7. Mainland China, without the Special Administrative Regions of Hong Kong and Macau.

  8. While the UK attracts more international students, annual growth rates tend to be higher in Germany. They regularly exceed 7 percent (DAAD, 2020b).

  9. The German Bundestag offers a comprehensive online archive of speeches, as does the House of Commons.

  10. Technically, the CDU and CSU are two distinct parties with separate structures, platforms, and leadership bodies. My interviewee (#2) was a CSU politician and member of the joint CDU/CSU parliamentary group.

  11. Nine interviewees were from Germany and four from the UK. A complete list can be found in the appendix.

  12. Despite this universalist approach, Germany exhibits a lower higher education participation rate than almost all other OECD countries—at least in part because Ausbildung (vocational training) is considered an acceptable alternative, and professions such as nursing or hospitality management are usually non-academic. This German peculiarity has withstood much pressure in recent decades (Powell & Solga, 2011), but now seems to be crumbling: Since 2000, the university entrance rate has risen from 33.3% to 54.8%.

  13. In the following referred to as ‘the Greens’ or ‘Greens’.

  14. While the law was passed on July 30, 2004, and promulgated on August 4, 2004, it did not enter into force until January 1, 2005. Since then, it has been revised three times (2007, 2013, 2016) and further modified by other laws and directives (e.g., the Fachkräfteeinwanderungsgesetz of 2019). Originally, the SPD-Greens coalition had introduced the proposal in 2001 on the advice of the Unabhängige Kommission Zuwanderung (‘Independent Commission on Immigration’) (Griesbeck & Heß, 2016).

  15. There have also been efforts to allocate more resources to the development of recruitment strategies and internationalization of higher education, often via the DAAD (see Bode & Davidson, 2011; DAAD, 2020a).

  16. Tuition fees were introduced by the state governments of North Rhine-Westphalia (CDU/FDP; 2006), Lower Saxony (CDU/FDP; 2006), Baden-Württemberg (CDU/FDP; 2007), Bavaria (CSU; 2007), Hamburg (CDU; 2007), Hesse (CDU; 2007), and Saarland (CDU/FDP; 2007). Today, neither first-time nor international students must pay any fees, except in Baden-Württemberg, where the latter are charged €1,500 per semester. Special regulations apply for refugees, students from developing countries, and those who obtained their Abitur at a German school (Bildungsinländer).

  17. As the same SPD MdB argued, “Germany’s internationalization agenda was and is a Social Democratic project. Merkel’s achievement is that she just left things as she found them.”

  18. In fact, the AfD has no clear position on international students. In its most recent platform, they are not mentioned once.

  19. BAföG is a law regulating federal student grants and loans.

  20. KfW is a state-owned development bank that offers low-interest student loans.

  21. Particularly popular was the promise that international students would cross-subsidize poorer domestic students by paying higher fees: “British exports of education are worth eight billion pounds a year. Money that feeds into our institutions and helps our goal to open up more people to study” (Blair, 1999: n.p.).

  22. PMI 2 came to an end in 2011. Its de facto successor, the Coalition’s International Education Strategy, did not set any recruitment targets.

  23. In the context of PMI 2, the Blair government had already announced that it would step up its efforts to exclude “anyone who intends to abuse the system” (2006: n.p.).

  24. International students in the UK are also statistically categorized as immigrants (Lomer, 2018); admitting fewer students may have seemed like a relatively easy way to keep migration numbers down.

  25. This was changed again in the wake of Brexit; see the legend to Table 2.

  26. Means-tested tuition fees for domestic students had been abolished in 1962, but were reintroduced via the Teaching and Higher Education Act of 1998 on the recommendation of the Dearing Report. Maintenance grants were also replaced by student loans. Due to devolution, that is, the delegation of power from Westminster to the subnational level, different arrangements were introduced in Scotland.

  27. According to Tannock, tuition fees during the 2016–17 academic year were “on average between 50% and 172% higher” (2018: 125) for international undergraduate students.

  28. This conflict also plays out at the intra-governmental level, where, for example, the Business and Education departments develop strategies to attract international students and the Home Office others to deter migrants.

  29. Touted as a “cheaper and more global” (Daily Express) alternative to the ERASMUS program (from which the UK has withdrawn), the Turing scheme supports British students who want to go abroad for up to twelve months.

  30. Levantino et al. (2018) stress the importance of party politics in the British case.

  31. Between 2013 and 2017, the SPD, the Greens, and Die Linke had a majority in parliament and could have toppled Merkel at any time. It was only the relative tameness of the CDU/CSU and the foreign policy radicalism of Die Linke (as well as Merkel’s popular mandate) that prevented the SPD from reaching for the chancellorship.

  32. In the twenty years between 1998 and 2018, there were not only twice as many UK Prime Ministers as German Chancellors (4–2) but also almost three times as many cabinet members dealing with education issues (11–4): first as Secretary of State for Education and Employment, then as Secretary of State for Education and Skills, then as Secretary of State for Innovation, Universities and Skills, and finally as Secretary of State for Education.

  33. The term ‘betraying’ is a quote from Conservative life peer Andrew Adonis (a former Parliamentary Under-Secretary of State for Education).

  34. See also Riaño et al. (2018b), who list international students as immigrants of doubtful value (D) as one of five prevalent ISM discourses. Obviously, international students as sources of income for the higher education sector (B) and international students as part of soft power (E; see also Lomer, 2017) exist as well.

  35. This link between international students and immigrants has not always been there. For instance, Enoch Powell, in his famous Rivers of Blood speech, remarked that “aliens [who came] into this country for the purposes of study or improving their qualification […] are not, and never will be, immigrants” (Powell, as cited in Acton, 2011: 3).

  36. The importance of national cultures has also been underscored in research on ISM policies; see Riaño et al. (2018a).

  37. Since December 2021, the SPD has been governing with the Greens and the FDP in a traffic light coalition headed by Merkel’s former vice chancellor Olaf Scholz.

  38. This is not necessarily the case for refugees, but it is undoubtedly for international students.

  39. Although many had predicted a decline due to mounting uncertainty, the Universities and Colleges Admission Service announced in September 2020 that the number of international (i.e., non-EU) students newly admitted for the 2020–21 academic year had reached an all-time high.



Alternative for Germany/Alternative für Deutschland


Federal Training Assistance Act/Bundesausbildungsförderungsgesetz


Christian Democratic Union of Germany/Christlich Demokratische Union Deutschlands


Coronavirus disease


Christian Social Union in Bavaria/Christlich-Soziale Union in Bayern


German Academic Exchange Service/Deutscher Akademischer Austauschdienst


European Union


Free Democratic Party/Freie Demokratische Partei


International student mobility


Credit Institute for Reconstruction/Kreditanstalt für Wiederaufbau


Member of the Bundestag


Member of Parliament


Organisation for Economic Co-Operation and Development


Prime Minister’s Initiative


Social Democratic Party of Germany/Sozialdemokratische Partei Deutschlands


United Kingdom (of Great Britain and Northern Ireland)


United States (of America)


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I thank my interviewees for their time, commitment, and insights. Moreover, I am grateful to Jean-Thomas Arrighi, Pieter Bevelander, Gianni D’Amato, J. A. Douglass, Dominik Hangartner, Swen Hutter, Anne MacLachlan, Annique Lombard, Philipp Lutz, Anita Manatschal, Yvonne Riaño, Robin Stünzi, Maria Thürk, Daniela Vintila, Nelson Zavale, and the anonymous reviewers for their comments on previous versions of this article.


This work was supported by the NCCR - on the move [Grant Number 51NF40-182897].

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Appendix: List of interviewees

Appendix: List of interviewees

The names on this list have been anonymized for reasons of confidentiality.


Case: Germany.

Date: November 3, 2020.

Type: Written.

Position: Head of Division (Federal Ministry of the Interior).

Party: N/A.


Case: Germany.

Date: November 9, 2020.

Type: Online.

Position: Member of the Bundestag.

Party: CSU.


Case: Germany.

Date: November 12, 2020.

Type: Phone.

Position: Former Member of the Bundestag, now at a major Trade Association.

Party: FDP.


Case: Germany.

Date: November 26, 2020.

Type: Phone.

Position: Member of the Bundestag.

Party: SPD.


Case: Germany.

Date: November 30, 2020.

Type: Online.

Position: Head of Division (DAAD, Marketing).

Party: N/A.


Case: Germany.

Date: December 2, 2020 (together with #7).

Type: Online.

Position: Head of Division (DAAD, Strategy).

Party: N/A.


Case: Germany.

Date: December 2, 2020 (together with #6).

Type: Online.

Position: Expert for Statistics (DAAD).

Party: N/A.


Case: Germany.

Date: December 9, 2020, and December 17, 2020.

Type: Online.

Position: Former Member of the Federal Cabinet.

Party: SPD.


Case: Germany.

Date: December 16, 2020.

Type: Online.

Position: Head of Department (Hochschulrektorenkonferenz, International Affairs).

Party: N/A.


Case: UK.

Date: December 14, 2020.

Type: Online.

Position: Member of the House of Commons.

Party: Labour.


Case: UK.

Date: January 12, 2021.

Type: Online.

Position: Member of the House of Commons.

Party: Conservatives.


Case: UK.

Date: January 15, 2021.

Type: Phone.

Position: Former Member of the House of Commons.

Party: Labour.


Case: UK.

Date: January 27, 2021.

Type: Online.

Position: Head of Department (British Council, Global Network).

Party: N/A.

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Bitschnau, M. Students or internationals? Divergent patterns of governing international student mobility in Germany and the United Kingdom. CMS 11, 24 (2023).

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