Comparative legal analysis shows disparities in roma integration and rights in France and Germany, suggesting targeted approaches are needed.
This paper investigates the integration and rights of the Roma minority in France and Germany, two countries with distinct historical trajectories and policy frameworks concerning national minorities. Drawing on Ager and Strang’s theoretical model of integration and grounded in a comparative legal and socio-political analysis, the study evaluates the implementation and effectiveness of the Framework Convention for the Protection of National Minorities (FCNM) and the National Roma Integration Strategies (NRIS) within both contexts. The research highlights systemic disparities in housing, education, healthcare, and employment, compounded by entrenched discrimination and administrative exclusion. Through qualitative analysis of state practices and legal instruments, the study demonstrates that while both countries have adopted EU-aligned frameworks, Germany exhibits a more structured approach through formal recognition and targeted measures. France, by contrast, upholds a republican model that resists ethnic categorisation, thereby limiting tailored policy interventions.
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Suchismita Panda (2025) studied this question.
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