When it comes to free movement, people usually refer to the right to work and reside in different countries of the European Union. But there is a lesser-known free movement agreement between Nordic countries, the Nordic Passport Union.
This was established at about the same time of the European Economic Community, but it works in a slightly different way.
Nordic governments have also set up a Freedom of Movement Council, a “politically appointed but independent body” tasked to identify problems and work with national authorities to resolve them.
History of free movement
“The Nordic free movement was established at the beginning of 1950s to create a common labour market. But after the Second World War we also wanted to cooperate more, keep our values and preserve peace between our countries. That was the origin of the idea. We are quite similar countries so it was natural to start this cooperation early on,” says Siv Friðleifsdóttir, who is an Icelandic-Norwegian national and chair of the Nordic Freedom of Movement Council.
In 1952, Denmark, Norway, Sweden and Finland agreed to abolish the passport requirement for their citizens crossing the border. In 1954, the agreement was extended to allow citizens to move, reside and work within the four countries without a residence or work permit. Then in 1958, passport checks at the border were also abolished for citizens of other countries.
Today, the Nordic free movement area covers Denmark, Finland, Iceland, Norway and Sweden, as well as the Faroe Islands and Åland. Greenland is not part of the Passport Union but is in practice subject to some of its provisions.
In comparison, the European Economic Community, which later became the European Union, was established in 1957. Denmark joined in 1973, Sweden and Finland in 1995. Norway and Iceland are not EU members but apply EU free movement rules.
“The idea of the European Union is also integration and free movement, for the same reasons. If you were to be outspoken, you could say that the EU is the biggest free movement Council ever,” Friðleifsdóttir continues.
The difference between the two, Friðleifsdóttir explains, is that the EU uses directives that countries are supposed to follow, while the Nordic cooperation was conceived as a soft cooperation.
So while the EU uses legislation to promote free movement, the Nordic Freedom of Movement Council looks at what needs to change in the existing national legislation.
How the Nordic Passport Union works
Under the Passport Union, Nordic citizens can move freely within the region, for instance to study or work, without a passport, or any other type of travel document or residence permit. Nevertheless, they should hold some type of identification document in case it is necessary for other reasons, for example for air travel, hotel stays and police checks.
Border controls within the Nordic countries have also been abolished, although large parts of these arrangements have now been replaced by the Schengen agreement, that the Nordics have joined.
This is similar to the EU. But the rights of Nordic citizens under the Passport Union are more far-reaching than those of EU citizens under the Schengen regulations, Sandra Forsén, senior advisor to the Nordic Freedom of Movement council explains.
For example, EU citizens travelling within the Schengen area and other parts of the EU must hold a valid travel document (passport or national identity card), while Nordic citizens travelling in the Passport Union or Greenland only need a valid identification document, such as a driving license, to prove their identity and citizenship.
Do non-EU citizens benefit?
For non-EU citizens these free movement rules do not apply completely. They may be able to travel without border checks as tourists, but it is national legislation that determines their right to work or residence, and each country has different rules.
“In general, societies which are quite open, where it is easy to move around to work and study, are stronger and that is beneficial for everybody,” says Siv Friðleifsdóttir.
But when it comes to the practicalities of moving, non-EU citizens need a work permit and that does not give them the automatic right to work in another Nordic country.
Council advisor Forsén says there is a lot of misinformation among non-EU citizens about the integrated labour market in the Nordics, because it does not apply to them. If a non-EU national lives in Malmö, Sweden, and takes a job in Copenhagen, Denmark, commuting daily, they requires having a residence permit in one country and a work permit in another. Many non-EU citizens aren’t aware either of this, Forsén says, or that failing to obtain them could lead to fines or even prison, as well as sanctions for their employer.
“This is one of the obstacles we have identified to really benefit from a common labour market. There are many non-EU citizens in the Nordic countries and they would, as well as businesses in need of labour, benefit from a more generous approach,” Forsén argues.
Removing the obstacles in future
The Council has identified over 100 obstacles to free movement. Thirty are prioritised for action.
Digitalisation. A key one is the digitalisation of the public sector. Interacting with institutions across borders is complicated, Friðleifsdóttir says, and in some cases still relies on the post. “It is a dinosaur environment, especially difficult to navigate for people with disabilities and the elderly. Young people [who are digitally native] will not accept the authorities don’t do something about this problem,” she argues.
Tax. The tax system can also be problematic, especially considering that many people in the Nordic countries are cross-border commuters and more people are working from home after the pandemic.
“When authorities closed the borders at the height of Covid-19, problems related to the affiliation to different social insurance systems were solved with countries closing their eyes on where people were working from, and finally through an exemption from the EU regulation on social insurance. This, however, was not accepted for taxation,” she continues.
The Freedom of Movement Council is pushing for the negotiation of a new tax agreement which would make it easier for people and businesses to work and recruit across borders. It would also take remote work into consideration, as well as the fact that people sometimes reside in one country and work in another, or more than one other.
Registration. Another priority is the cooperation between national registration authorities to facilitate life events, such as moves, marriages, the registration of children or citizenships. Cross-border pensions are another area of concern.
Border controls. Countries’ decision to reintroduce border controls, as it happened in Sweden and Denmark following the 2015 migration crisis, also represents a major obstacle to free movement, especially for the cross-border communities, frequent travellers between capitals, and border regions.
Over the years, the Council has managed to remove 65 obstacles to free movement, Friðleifsdóttir explains.
The Council has been vocal about Sweden reimposing border controls with its neighbours because of the problems this causes to commuters and businesses.
“We asked the authorities to take a better look at the issue and argued that if new border controls were considered necessary for criminality reasons, they should be set up in a way that would not dramatically increase commuting time,” Friðleifsdóttir continues.
Most integrated region in the world
Free movement is part of the ‘Vision 2030’ agreed by Nordic prime ministers, which aims to make the Nordics “the world's most integrated and sustainable region by 2030”. It is considered part of the competitiveness objectives and the Council members have to contribute to the removal of 5-8 border obstacles each year.
The Freedom of Movement Council is made of 10 members, including former politicians, civil servants, members of parliament and business representative. It operates with two staff from the Nordic Council of Ministers’ secretariat in Copenhagen.
The Council works closely with information centres in the Nordic countries. People can contact information services Info Norden, the Norway-Sweden Border Service, Øresunddirekt, the Sweden-Finland-Norway Border Service, as well as cross border committees, to highlight the problems they face. These would then pass the relevant information to the Council, which will contact the responsible ministry to seek a solution.
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