Introduction
In June 2023, the Parliamentary Assembly of the Council of Europe recognised that transnational repression is a growing concern that undermines the rule of law and human rights in Europe.Footnote 1 From Chinese unofficial police stations to the assassination attacks perpetuated by Russian or Iranian secret agents on their citizens and diaspora communities residing abroad, authoritarian states are becoming increasingly emboldened and assertive in projecting their power onto their population across borders. The sociologist Dana Moss defines this phenomenon as transnational repression. In such context, as argued by Moss,Footnote 2 ‘the population abroad cannot fully exit from authoritarianism, and those with domestic opportunities for protest remain constrained in the exercise of their rights, liberties, and “voice”’. As observed in the scholarly literature, such practices form an extension of the pursuit by authoritarian governance of regime security and represent an extension of domestic political control and governance, which spans across territorial borders.Footnote 3 As the emerging literature on transnational repression demonstrates, authoritarian states have quickly adapted to changes induced by globalisation and technologies to ensure their survival. Dictators are becoming increasingly flexible in using their repression tools to contain new forms of dissent and security challenges arising from their population abroad. Through tactics such as physical threats, Interpol arrest warrants, and digital surveillance, authoritarian states are not shying away from silencing their critics abroad, even in democracies.
So far, the emerging literature on transnational repression has examined the contours of the transnational repression phenomenon, and its tactics and strategies,Footnote 4 and has explained conditions that drive authoritarian states to engage in the transnational repression phenomenon.Footnote 5 Scholars have also reflected on the effects of transnational repression on human rights and state sovereignty.Footnote 6 Yet, we still lack knowledge on how European democracies respond to such forms of authoritarian interference. The question is important to investigate, given Europe’s strong stance against foreign interferences in democracies, at least at the rhetorical level. In its January 2024 Conclusions on the European Union’s (EU) priorities in United Nations (UN) human rights fora, the Foreign Affairs Council committed to considering measures to prevent and tackle transnational repression and encouraged actions at the UN to address this increasingly concerning global phenomenon.Footnote 7 Similar echoes resonated in the recent G7 Statement, where members of the group, including the EU, have committed to ‘building resilience against malign foreign interference and acts of transnational repression that seek to undermine trust in government, society and media, reduce civic space and silence critical voices’.Footnote 8
This article explores the EU’s responses to the authoritarian transnational repression phenomenon by using the analytical framework of securitisation. The study demonstrates that transnational repression has not been securitised according to the Copenhagen School’s strict formulation of existential threat. In doing so, the article makes several contributions. First, it contributes to the emerging literature on transnational repression by examining how democracies respond to transnational repression phenomenon. Second, it advances securitisation theory applied to the level of regional and multilateral institutions and the processes involved in the collective construction of, and responses to, the challenges of perceived transnational threats. Finally, the analysis further helps us to advance our understanding of failed securitisation cases – how ‘the appeal of security is rejected or resisted’Footnote 9 and why some threats take a societal salience and others not.Footnote 10 Therefore, this study reflects on what the failure to securitise transnational repression within the EU tells us about security construction and importantly about (in)securitisation processes taking place in a multilateral governance system. The article is structured in three parts. First, the theoretical framework of securitisation is outlined and applied to the EU as a case study. The second section offers a discussion on methods. The third section presents the analysis of key findings. The article concludes with a discussion on the findings in relation to securitisation theory.
Theoretical framework: Securitisation
The original formulation of securitisation theory is associated with the Copenhagen School (CS) of security studies, which has revitalised the international security theory in the post–Cold War environment and inspired a burgeoning literature that applied its insights on a range of topics and contexts. At the heart of securitisation theory is the idea that security issues are socially constructed by political actors through the process of speech act.Footnote 11 In the words of Ole Wæver ‘by uttering “security”, a state-representative moves a particular development into a specific area and thereby claims a special right to use whatever means are necessary to block it’.Footnote 12 Under these circumstances, a problem would become a security issue whenever so defined by power-holders. Such a philosophical approach to securitisation thus emphasises on the language of security and explains how through the process of speech acts and political discourse an issue is lifted from ordinary politics to a security issue that requires urgent attention or extraordinary measures.Footnote 13 Schematically, the core concept of securitisation proceeds as follows: an issue becomes a security issue through the ‘securitising speech act’ voiced to a ‘specific audience’ by a ‘securitising actor’ who designates an issue as ‘fundamentally threatening to something’ and which requires ‘extraordinary’ urgent security measures. Securitisation becomes successful when the securitising agent and the audience reach an acceptance of the common threat perception and the extraordinary measures to be taken.Footnote 14
Since its original formulation, nearly all aspects of the securitisation theory have been revisited and redefined. While recognising its major contribution to security studies, scholars have pointed out the weaknesses of the CS, particularly in relation to the ‘elite rhetoric’, the role of securitising actor(s) and the audience. In the following, I review these critiques in relation to our present study.
First, the original formulation of the CS assumes that the securitising actor is a political state entity who has the authority to speak of power because it occupies government office and can thus claim to act on behalf of the state.Footnote 15 Yet, as noted by Sperling and Webber,Footnote 16 the rise of new transnational security challenges, such as climate change, terrorism, and health pandemics, has required a collective response from states.Footnote 17 Increasingly, states rely on international and regional organisations to deal with transnational security challenges.Footnote 18 State representatives can delegate their authority to international organisations which, through the proclamations and actions of designated agencies, might in turn engage in the practice of securitisation.Footnote 19 Such an approach necessitates viewing a securitisng actor beyond the state level and instead situates actorness in terms of collective securitisation.Footnote 20 Sperling and Webber define collective securitisation as ‘a security process in which the actor in question acts on behalf of other empowered actors who themselves may have individual securitizing imperatives’.Footnote 21 In the EU context, EU actorness is ‘a consequence of particular legal and political prerogatives which provide it with authority to speak and to act in the security field in its own right’.Footnote 22 Such rights, however, are circumscribed by Member States’ preferences. This implies that the EU actorness derives directly from the Member States’ interactions over the meaning of security and how policies are formulated in response to perceived threats. In this sense, the actorness of the EU is also bound up with the relationship it enjoys with its Member States, all of which are security actors in their own right but also constitute simultaneously the audience through the process of recursive interactions.Footnote 23 Accordingly, the securitising actor is the agent who explicitly links together the social construction of the threat with socially acceptable governance or policy measures.Footnote 24
Second, the initial formulation of the CS lacks precision in defining the audience and who constitutes the audience in practice.Footnote 25 According to the CS, security threats are constructed through intersubjective processes between securitising actors (socially authorised security ‘speakers’) and audiences, and the issue is securitised only if and when the audience accepts it as such.Footnote 26 The audience forms an essential aspect of the intersubjective character of securitisation theory, the creation of shared security meanings, and the justification of security policies.Footnote 27 Yet, its nature and its role in securitisation, as pointed out by some scholars, are weakly defined.Footnote 28 In this view, more recent scholarship has focused on the impact of the audience on the securitising move. The study by Adam Côté, for instance, reveals that actions and the influence of the audience vary significantly across cases.Footnote 29 In a similar vein, Balzacq and colleaguesFootnote 30 suggest that multiple audiences may exist within a single securitisation process, and those audiences often possess different powers and influence, leading to differing effects on securitisation outcomes.Footnote 31 In line with this, in the context of the EU, Member States are security actors in their own right but also constitute simultaneously the audience. In such an instance, securitisation is produced through the process of recursive interaction and intersubjective interaction.Footnote 32 In this setting, the distinction between actor and audience is consequently blurred. As observed by Sonia Lucarelli, securitisation results from both a securitising move by the EU institutions (i.e. the European Commission, European Council) and the interaction between its Member States (audience and securitising actors).Footnote 33 This has been visible in the securitisation of the Schengen area or European energy security, when securitisation was initiated by Member States acting as security actors who have guided the Council in the iterative securitisation process with the Commission.Footnote 34
Third, the construction of the ‘threat’ may take different forms, which include not just discourses but also certain social practices.Footnote 35 Balzacq and colleagues, for instance, argue that ‘scholars need not only to account for the performative nature of utterances, but also to examine the (perlocutionary) effects of these words, as well as the conditions of possibility of security practices’.Footnote 36 , According to these authors, the original formulation of the CS is theoretically weak and methodologically restrictive, as discursive practices and speech acts provide little understanding of how security operates.Footnote 37 In his seminal work, Thierry Balzacq and others associated with the so-called Paris School advocate for a ‘sociological approach of securitization’,Footnote 38 where securitisation occurs through social practices, context, and power relations that characterise the construction of the threat image.Footnote 39 Such an approach promotes a ‘pragmatic’ view of securitisation as a ‘kaleidoscope of practices’Footnote 40 and includes non-discursive practices where invocation of security is not reducible to a linguistic form only but occurs through day-to-day bureaucratic practices and routines, as well as diffuse forms of power in decentralised networks.Footnote 41 In the context of the EU, for instance, Balzacq suggests that practices of securitisation can be studied by examining the ‘empirical referents of policy’ – policy tools or instruments – that the EU utilises to alleviate public problems defined as threat.Footnote 42 Analytically and in the context of the present paper, such an alternative formulation of securitisation is particularly relevant, given the multifaceted identity of the EU, where authority and policy-making influence are shared across multiple layers of governance and institutions. It allows us to examine the interaction between securitising actors, audience, and context and further sheds light not only on how security is constructed but also where it plays out in terms of processes, and practices – such as policy tools, configurations, and bureaucratic and technocratic rationalities, among others.Footnote 43 That said, understanding how security issues are framed through speech acts still remains highly relevant. In the case of the EU, as argued by Lucarelli, the speech act is articulated through official policy documents addressed to the audience and actors already embedded within the structure of the EU governance.Footnote 44
Finally, although securitisation theory provides us with important analytical insights to study the securitisation process, the theory does not offer satisfactory explanations for why certain issues fail to be securitised. As rightly pointed out by Salter, failed securitising moves are not desecuritising moves, which entail a reversal of a previous successful securitisation.Footnote 45 Instead, failed securitisation is instances where securitisation moves did not occur or were rejected.Footnote 46 Jan Ruzicka speaks of ‘case selection bias’ in securitisation studies that ‘privilege[s] successful cases (and hence outcomes in general) [and] leads to a rather impoverished understanding of failed processes of securitization’.Footnote 47 According to Mark Salter, this is because the ‘Copenhagen School (CS) interprets all successful securitizing moves as a failure of normal politics’.Footnote 48 In the original formulation of the securitisation framework, securitising moves can fail because of faults in the grammatical structure of the securitising move, the inherent characteristics of the issue, or a rejection by the audience.Footnote 49 Additionally, proponents of the broader sociological approach to the securitisation framework argue that to assess the success or failure of securitisation one needs to take into account certain conditions (e.g. political, historical, material) that further impact the construct of (in)securitisation moves.Footnote 50 As noted by Salter,Footnote 51 securitisation is a sociological and political process that manifests in language, but also in the complex effect of power, interest, intersubjectivity, bureaucratic position, and processes. In this view, the sociological approach to studying securitisation helps us to explain the failure of securitisation and therefore further advances our knowledge of the processes of security construction viewed as a causal process rather than viewing it merely through actors’ pronouncements.Footnote 52
Methods
To analyse the process of (in)securitisation of the transnational repression issue and to increase confidence in the findings, I rely on multiple data sources. These consist of: (1) selected text readings, (2) observations and informal discussions, (3) interview analysis, and (4) descriptive statistics. This analysis was further complemented by secondary sources and relevant literature. Such a research strategy was adopted to promote a more comprehensive understanding of the research question under investigation and to enhance the rigour of the research study overall.
Discourse analysis was performed on a range of official documents produced by the European Parliament and the European Commission as well as official statements delivered by the Union’s representatives on the topic of transnational repression. This analysis helped to identify themes associated with transnational repression and trace whether or not policy responses have been adopted. Discourse analysis provides an appropriate method of analysis to explore the relationship between language and policy in the securitisation process and the representation of the threat image put into circulation by security actors as well as to consider the wider implications of the policy discourse.Footnote 53 In this process, questions from the European Parliament Plenary Database were also used for examining questions raised on topics pertaining to transnational repression. Data was further collected from the online workshop organised by Human Rights Watch in 2024 in which the researcher took part. Additionally, observations and informal discussions on transnational repression with EU official policy representatives were collected during the ‘Global State of Human Rights Conference’ on 24–5 May 2024 in Venice. The paper further draws on 12 semi-structured interviews conducted online and in Brussels with EU policymakers, civil society organisations, and political exiles. Interview methods followed a snowball strategy. The interviews took place between July and October 2023 in Brussels and online. The conclusions were reached based on data saturation. Given the sensitivity of the topic and to facilitate conversations, the researcher offered the option of full anonymity to all interviewees. Questions were focused on EU institutional responses to the transnational repression phenomenon, current policies, and tools available to fight such forms of authoritarian interference, and the implications of transnational repression attacks on European democracies. To examine interview data, the researcher relied on thematic analysis to inductively identify themes and patterns that emerged on the topic of transnational repression. Patterns and practices associated with the theme ‘transnational repression’ were thematically clustered to interpret specific dimensions and themes addressing the research question under investigation. This led to the production of a thematic framework categorising participants’ responses as follows: (1) interpretation of transnational repression, (2) political mobilisation on transnational repression, (3) policy responses. These themes were then used to structure the presentation and analysis of the findings below. Additionally, the study further relies on the Freedom House Database on Transnational Repression (version 2023) and uses descriptive statistics to demonstrate transnational repression incidents in the EU.
Securitising moves on transnational repression
As argued by Floyd, securitising actors ‘do not exist in a political vacuum; rather they are influenced by a variety of actors, including political advisors, opposition politicians, public intellectuals, newspaper editors, and ordinary people’.Footnote 54 According to Floyd, these ‘securitizing requesters’ are actors who seek to influence the initiation of the securitisation process and persuade others to securitise an issue.Footnote 55 In a similar way, Diez and colleaguesFootnote 56 discuss the significance of ‘discursive entrepreneurs’, individually or collectively, in conducting securitising moves, whereby they pave the way for the legitimate securitisation of an issue, setting a new ‘norm’ for policy agendas. In the present study, we can identify several securitising setters who have paved the way for the securitisation of transnational repression in EU institutional fora.
In the aftermath of the Arab Spring, a handful of academic scholars scattered across the disciplines of political science in Europe and in the United States looked at a new way to make sense of evolving trends in authoritarian states and their engagement with their populations across borders. Increasingly, as they note, authoritarian engagement with their populations abroad carried a repressive character.Footnote 57 In this sense, although the phenomenon of transnational repression is not new, it gained new momentum with the renewal of authoritarian politics globally.
At the same time, this intellectual effort drew the attention of civil society actors such as Freedom House, who similarly observed a rising trend in authoritarian transnational repression practices.Footnote 58 The joint mobilisation of Freedom House with academics, practitioners, and policymakers around the topic generated a series of round-table discussions and debates around transnational repression. In 2018, in the aftermath of the killing of the Saudi journalist Jamal Khashoggi, transnational repression gained new momentum. The event represented a critical point in generating new paths of institutional development towards securitisation of the issue in the United States. The Biden administration made transnational repression one of the key priorities across agencies, with attention given by the National Security Council.Footnote 59 Transnational repression became a key component of US foreign policy diplomacy. From 2021, the Biden–Harris administration, in the words of Uzra Zeya, secretary of state for civilian security, democracy, and human rights in the Biden administration, made ‘combating transnational repression a global human rights priority’ and urged its allies to join its efforts to ‘drive a global response’ to it.Footnote 60
US attempts to externalise its concerns about transnational repression spilled across international organisations, such as the UN,Footnote 61 and other informal intergovernmental fora such as the G7. The United States played an influential role in the establishment of the G7 Rapid Response Mechanism Working Group on Transnational RepressionFootnote 62 and has helped coordinate emergency responses with partners when individuals have been targeted for transnational repression abroad.Footnote 63 Several interviews mentioned that the United States is actively promoting a security narrative on transnational repression on an international level. The aim is to drive a policy diffusion on the topic, as explained by an EU officer: ‘the more we talk about the topic, the more states in the EU will become socialised and will see [transnational repression] as a salient issue to be addressed’.Footnote 64
This international narrative about transnational repression as a security concern has thus started to pervade the European context. Events and media reports on high-profile cases, such as the diversion of the Ryanair flight carrying the Belarusian activist and blogger Roman Protasevich and his girlfriend in 2021 or the discovery of unofficial police stations by Safeguard Defenders in 2022, have contributed to increasing the visibility of the issue in the EU. Additionally, the mobilisation of individual diaspora actors and the civil society sector on the topicFootnote 65 further shaped debates and raised the visibility of transnational repression within EU fora. The ability of human rights organisations to collect, disseminate, mobilise, and frame information about transnational repression as a human rights and a security issue played a significant role in attracting the attention of some of the Members of the European Parliament (MEPs). In this view, transnational repression has been further championed by individual MEPs who took part in the joint events organised by these advocacy actors. For example, in 2024, the Human Rights Watch branch in Europe held its first joint session on the topic with Hannah Neumann MEP (Greens, Germany), academics, and exiles after the release of their influential report on transnational repression in Europe, ‘“We will find you”: A global look at how governments repress nationals abroad’.Footnote 66 It portrayed transnational repression as a security threat affecting human rights and destabilising democracies in Europe.
Alongside these efforts, independent organisations in Europe such as the Council of Europe – the European benchmark for human rights, democracy, and the rule of law – played an important role in further increasing the political awareness on the topic. In his report ‘Transnational repression as a growing threat to the rule of law and human rights’ submitted to the Parliamentary Assembly of the Council of Europe (PACE) in June 2023, Sir Andrew Chopes notes that ‘the number and gravity of acts of transnational repression committed in Europe, including on the territory of some member States, are a matter of concern’. He further observes that acts of transnational repression ‘not only violate numerous individual human rights but are also a threat to the rule of law and democracy and undermine the values of the Council of Europe’.Footnote 67 Chopes’s report further urged the Council of Europe, its members, and observer States to recognise that ‘transnational repression is a global phenomenon attacking the foundations of democratic societies and the rule of law’ and asked them to adopt stronger and more co-ordinated actions to prevent and fight transnational repression.Footnote 68
In this context, transnational repression has entered the EU internal institutional fora. References to transnational repression in the EU can be found in the activities of the European Parliament and its specialised committees, such as the Special Committee on Foreign Interference in All Democratic Processes in the EU, Including Disinformation (INGE1 and ING2) and the PEGA Committee. The Special Committee on Foreign Interference was set up in June 2020, with the task of combating meddling by third countries in the democratic processes of EU member states. It was created as a result of tensions between Europe, Russia, and China.Footnote 69 The final report was adopted in plenary on 9 March 2022 by an overwhelming majority. The report maps the threat of foreign interference: disinformation, manipulation of social media platforms and advertising systems, cyberattacks, threats against and the harassment of journalists, covert political funding, and elite capture and co-optation.Footnote 70 The report notes that ‘malicious foreign actors’ such as Russia, China, and Iran use information manipulation and other tactics to interfere in democratic processes and aim to weaken the democratic governance of the targeted countries.Footnote 71 The report further acknowledges that foreign interference presents a threat to European security and affects fundamental freedoms as well as democracy and the rule of law. The second report (ING2) follows a similar line of argument, with the added mandate to address issues of transparency, integrity, and accountability within the European Parliament in relation to the alleged attempts by Qatar and Morocco to influence Members, former Members, and staff of the European Parliament.Footnote 72
Despite a strong focus on election interference, disinformation campaigns, media manipulation, and cyberattacks on EU critical infrastructure, both reports raise the issue of transnational repression and highlight different transnational repression strategies used by authoritarian states to target journalists, human rights activists, academics, government officials, and politicians.Footnote 73 The reports further recommend the EU and its Member States co-ordinate a strategy on interference and develop cross-sectoral targeted sanctions mechanisms including diplomatic sanctions, travel bans, asset freezes, and the stripping of EU residence permits from foreign individuals and their family members associated with foreign interference attempts.Footnote 74
In a similar vein, the PEGA Committee report,Footnote 75 which investigates infringements and maladministration in the application of EU law about use of Pegasus and equivalent spyware, makes annotations regarding transnational repression. The report, written by Dutch MEP Sophie in’t Veld (Renew Europe) describes how the governments of Morocco and Rwanda targeted with spyware high-profile Union citizens, including the political exiles and critics of the regime.Footnote 76 It further highlights the vulnerability of individuals targeted by online cyber threats in Europe.
Transnational repression has been further raised in various parliamentary resolutions. In 2022, the European Parliament adopted a recommendation regarding the negotiation of a cooperation agreement between the EU and Interpol, highlighting that the abuse of Interpol by authoritarian regimes to target critics abroad constitutes a ‘threat to the integrity of the EU’s cooperation with Interpol’.Footnote 77
In March 2023, the European Parliament report on the EU guidelines on human rights defenders (HRDs) (2021/2204[INI]), written by the German rapporteur, Hannan Neumann (Verts/Ale), called on the Commission to tackle the increasing phenomenon of transnational threats against HRDs and on Member States to facilitate reporting, investigations, and attribution of these transnational attacks. It explicitly asked the Commission to investigate cases of unlawful foreign interference that persecute human rights advocates in EU Member States.Footnote 78 The resolution further called for the Commission and Member States to ‘to identify and tackle these threats within the EU as a priority’.Footnote 79
Furthermore, following China’s crackdown on human rights activists and the systematic repression of people of Uyghur ethnicity, notably in the Xinjiang region, the resolution on the ‘Chinese Government crackdown on the peaceful protests across the People’s Republic of China’ (2022/2992[RSP]) called on the Commission and its Member States to ‘identify and close down any avenues facilitating China’s campaigns of transnational repression, in particular against members of its diaspora’.Footnote 80 The resolution further urged the introduction of sanctions against those responsible for crimes against humanity and better co-ordination regarding Chinese overseas police service stations.
More recently, the resolution on Iran’s unprecedented attack against Israel, the need for de-escalation and an EU response (RC-B9-0235/2024), adopted in April 2024, called for the European Commission to launch ‘a broad strategy to address transnational repression by the Iranian regime in the EU’ and take measures to ‘prevent any harassment or intimidation of the Iranian diaspora in the EU, including on campuses’.Footnote 81
As noted by Maurer, ‘initiative reports and resolutions reflect MEPs awareness and interests in raising an issue with the public, with the Council and the Commission’.Footnote 82 In this view, the European Parliament (EP) constitutes an important arena where policy concepts are discussed and put forward, contributing to the formulation phase. Among the EU core institutions, the EP positions itself as a defender and protector of human rights within and beyond the EU.Footnote 83 The EP’s strength within the EU political system comes from the fact that it is the only directly elected institution. Accordingly, given that the electoral connection is stronger regarding global issues, parliamentarians often have greater incentives to put foreign policy issues on the agenda.Footnote 84 During international conflicts such as the Arab Spring, for instance, studies show how MEPs often used arguments about their special position as an institution representing citizens.Footnote 85 In this realm, the EP has been particularly active in holding debates or passing resolutions on human rights issues. At the national level, as noted by Szép, members of parliaments (MPs), whose political survival depends on the electorate, also have incentives to put human rights issues on the agenda, given that in some Member States the electorate and civil society have high standards and expectations in these policy domains.Footnote 86 Krotky also notes that MEPs are agents of two principals – their national party and their European political group – and often favour their national party position on sensitive topics.Footnote 87 In this view, individual MEPs have contributed to debates on nurturing the issue of transnational repression through parliamentary questions or resolutions. In 2024, MEPs explicitly tabled a question on ‘transnational repression’ for the first time.Footnote 88
As we can see from the above analysis, transnational repression has entered EU agenda-setting and has been channelled by the EP, which has initiated a securitising narrative on the topic. The aim is to convince Member States, the Commission, and the Council of the social and collective threats posed by transnational repression and the need for extraordinary measures. However, despite calls from the Parliament to securitise transnational repression in the EU, the analysis below demonstrates that there have been no efforts to do so in the face of what was articulated as a common threat to the Union and its democracy. As argued by securitisation scholars, securitisation is an ‘explicitly political choice and act’.Footnote 89 This implies that securitisation depends on political factors which require political mobilisation.Footnote 90 What are then the political factors that affect a wider securitising move on transnational repression?
Conditions explaining the failure to securitise transnational repression in the EU
Extraordinary measures?
In its February 2023 Conclusions, the Foreign Affairs Council stressed that the EU would ‘pay special attention to … transnational repression’.Footnote 91 Although a reference was made to transnational repression, beyond such declarations, no emergency or policy measures have been taken to respond to it. As shown in earlier sections, securitisation implies a shift from a ‘normal’ political process into an ‘emergency mode’ generating the adoption of specific policy measures.Footnote 92
At present, the EU’s efforts to tackle transnational repression, as stated by the High Representative/Vice-President Borrell i Fontelles on behalf of the European Commission, are addressed via multilateral platforms and human rights dialogues, as well as through various EU instruments such as the emergency fund, Protectdefenders.eu, which is addressed to HRDs at risk, including HRDs in exile subject to transnational repression. It also coordinates its approaches with ‘like-minded partners’.Footnote 93 The Commission’s recommendations on the Defence of Democracy Package further acknowledge that ‘surveillance and spyware tools should not interfere with the democratic debate, notably by targeting political actors and journalists’.Footnote 94
It becomes clear from the above observations that the Council and the Commission have acknowledged the thematic issue of transnational repression without invoking extraordinary measures. It further becomes evident that responses to transnational repression at the EU level have been very limited at best and have been mainly addressed through diplomatic and multilateral frameworks within the EU external actions. In this sense, transnational repression is largely treated in the domain of external threats. Indeed, interviews conducted in Brussels for this article further show that transnational repression is embedded within different agencies of the European External Action Service (EEAS). Discussions with policy officers from the Directorates-General for Human Rights, Defence Industry and Space (DEFIS), and the Hybrid Threat Unit all acknowledge transnational repression as part of their workflows. However, as the interviews revealed, because of its broad indeterminate framing and the fact that transnational repression is not in itself a defined policy area, the topic has become a playing field among these different entities. Experts in these entities generate their own meaning and interpretations of transnational repression.Footnote 95
Additionally, there has been little policy discussion on the topic. Although the EU has not yet defined transnational repression, interviews with policy officers and the review of EU policy documents reveal a common understanding of how the EU conceptualises transnational repression. In the current context, transnational repression has been largely viewed and aggregated with a range of hybrid threat concerns but has been rarely mentioned, if defined at all.Footnote 96 The European official communication issued by the Commission and the European Centre of Excellence for Countering Hybrid Threats defines hybrid threats as ‘unacceptable foreign interference in sovereign states’ internal affairs and space’.Footnote 97 The EU’s policies to counter hybrid threats are outlined in two major documents: the 2016 ‘Joint Framework on countering hybrid threats’ and the 2018 ‘Joint Communication on increasing resilience and bolstering capabilities to address hybrid threats’.Footnote 98 In these communications, the EU identifies hybrid threat activities carried out by state and non-state actors as being a ‘serious and acute threat’ to the Union and its Member States. The communications further outline actions to build resilience in areas such as cybersecurity, critical infrastructure, protecting the financial system from illicit use, and efforts to counter violent extremism and radicalisation. In 2018, the EU issued a new communication on the threat of disinformation and foreign information manipulation.Footnote 99 The articulation of hybrid threat and disinformation as a threat to the Union’s collective security and its citizens has been further emphasised in the EU’s new strategic agenda for 2019–24: ‘we must protect our societies from malicious cyber activities, hybrid threats and disinformation originating from hostile states and non-state actors’.Footnote 100 Perhaps more authoritatively, the EU Security Strategy further stresses the building of EU resilience and mainstreaming hybrid considerations into broader policy-making.Footnote 101 Such concerns have been further reflected in the Strategic Compass for Security and Defence document, which sets out the EU’s security and defence ambitions for the next 10 years. In this document, the EU further acknowledges its role as a security provider and the need to build collective resilience against hybrid threats: ‘threats we face around the world are intensifying and the capacity of individual Member States to cope is insufficient and declining’.Footnote 102
There is thus a clearly articulated sense of ‘vulnerability’ to hybrid threats from authoritarian states, and unless the EU enhances its resilience and its ability to counter hybrid threats, such threats will risk undermining the Union’s security order and the safety of its citizens, society, and institutions. Yet, despite such claims, current policy formulations lack reference to transnational repression. The emphasis on the Union’s policy work on hybrid threats is largely centred on issues related to increasing situational awareness, cybersecurity, election manipulation, and disinformation campaigns against the EU’s critical infrastructure and democratic processes. There has been little effort and discussion to problematise transnational repression as a prime challenge to individual security and its ramifications for societal and political referent objects. None of the above-mentioned policy documents make explicit reference to transnational repression or make efforts to distinguish it from other forms of hybrid threats. Indeed, when efforts have been made to bring the issue of transnational repression onto the EU agenda through questions for written answer, they have received responses from the High Representative/Vice-President of the Commission (Josep Borrell i Fontelles) stating that the EU had no competence in this area but recognised that hybrid threats, including information manipulation and foreign interference, are a challenge to the EU’s security.Footnote 103 We can therefore further argue that the current understanding of the EU on transnational repression relates to the idea that the threat of transnational repression is external and part of a ‘basket of threats’ belonging to the category of hybrid threats.
Securitising power and audience acceptance?
As we can observe, there is an awareness of transnational repression among the EU institutions, but this process does not mean the acceptance of transnational repression as a security threat by the EU’s key decision-makers. From the European Commission’s perspective, transnational repression is viewed as a localised issue within national borders, which in most instances does not pose a significant threat to the security of the Union and its Member States. The official written answer on Chinese illegal police station incidents in Europe, provided by the European Commission and the High Representative for Foreign Affairs and Security (who also presides over the Foreign Affairs Council), clearly illustrates this position:
Member States, which are responsible for the maintenance of law and order and for safeguarding internal security on their own soil, are entitled to investigate any alleged violation of their laws or transgression of their competences in internal security occurring on their territory, and any violation of human rights.Footnote 104
In this sense, the EU’s resilience agenda to counter transnational repression from authoritarian states is based on the assumption that Member States are central actors in resilience building against such forms of authoritarian interference. Such an understanding implies that transnational repression is subject to national assessment and response. However, at the national level, there has been little interest from Member states in addressing transnational repression. Although some European countries have demonstrated some awareness – the signing of the Declaration of Principles to Combat Transnational RepressionFootnote 105 which includes Germany, the Baltic states, and Slovakia, is an illustrative example – overall, however, Member States have refrained from taking actions and initiating a securitisation response. Interviews with different EU stakeholders reveal an apparent lack of interest among the Member States on transnational repression issues.Footnote 106 Several interviews mentioned that transnational repression is not on the radar of most Member States’ representatives, which in turn reflects a low level of visibility on transnational repression at EU institutional levels.Footnote 107 As a civil society officer explains: ‘we brief Member States and EU institutions like the Commission, they listen to our reports and observations, but without further interest’.Footnote 108
In this view, as argued by scholars of securitisation, for a securitisation move to be successful the audience must accept the securitisng actor’s claims and be convinced that the issue poses an ‘existential threat’.Footnote 109 Securitisation is ultimately a process of shared agreement or attitudes.Footnote 110 As noted by BalzacqFootnote 111 and Léonard and Kaunert,Footnote 112 audiences often possess differential powers and influence, leading to differing effects on securitisation outcomes. They are defined by the connection to the legitimisation and authorisation of security speech,Footnote 113 by their position within different phases or ‘settings’ of securitisation processes,Footnote 114 or by their potential to authorise security action.Footnote 115 In the present EU context, the issue of transnational repression fails to resonate among its Member States, the European Commission, and the Council, who appear to be unwilling to securitise transnational repression and have expressed no sense of urgency in tackling the issue. Therefore, in the absence of common views and threat resonance, the issue of TR fails to find salience. Furthermore, one should also consider the capacity of actor(s) to securitise an issue, as an actor ‘needs sufficient institutional and political authority for their statements to contribute to the shaping of political and social relations’.Footnote 116 In this view, further consideration should be given to power relations between securitising actors and audiences. From this perspective, despite the Parliament’s calls to act against authoritarian transnational repression, its institutional power in decision-making is limited. The European Parliament’s resolutions have no binding effect, and do not necessarily reflect the views of the EU Member States or other EU institutions, such as the Commission or the Council, which have a greater influence on EU policy.
Political environment and threat perception
The challenge to securitising transnational repression can be further explained by the political environment of the EU and security threat perception. First, the EU is a regional institution encapsulating a range of individual nation-states with different cultures, norms, and interests. Such diversity poses a challenge to the strategic formulation of common threat perception. The current EU post–Cold War security environment has been subject to new security threats such as terrorism, migration, territorial conflicts in the EU neighbourhood, and energy security, among others. In the midst of such tensions, giving attention to transnational repression, viewed as isolated sub-state violence, may be a luxury that EU institutions and some Member States cannot afford.Footnote 117 Looking at the Freedom House database, only 82 out of 854 incidents recorded in the world between 2014 and 2023 take place in the EU; this means that only 10 per cent of incidents of transnational repression are happening on EU soil. This signals a relatively low level of incidents in comparison to other regions in the world. As suggested by Michaelsen and Ruijgrok,Footnote 118 authoritarian states engaging in transnational repression find it more difficult to conduct direct cross-border attacks in democracies due to the established rules and laws that democracies provide.Footnote 119 Given the low level of incidents, one might assume that transnational repression is not considered in the domain of immediate threat and is rather viewed as a distant threat. As argued by the scholars of securitisation, frequency of activities and severity of outcomes have an impact on whether an issue is framed as a threat or acquires a societal salience.Footnote 120 Buzan and colleagues further contend that the success of securitising moves requires that features of the alleged threat must be ‘generally held to be threatening’.Footnote 121 In relation to collective securitisation, Lucarelli also notes that the perception of a common threat frequently leads to enhanced cooperation (or at least coordination).Footnote 122 In her words, ‘when the security stake is perceived to be high, multilateral security governance is enhanced’.Footnote 123 In the current context, transnational repression is not viewed as a threat to the Union and its Member States but rather is treated as an isolated diplomatic incident, and not as a unified pattern or a phenomenon that requires emergency measures.Footnote 124 Additionally, the phenomenon of transnational repression within the EU context is perceived as a relatively new security issue.Footnote 125 As an EU policy officer observes: ‘we are aware of transnational repression and its implications on human rights and democracy, however, in the past such incidents were mostly situated outside the EU. It is only recently that we have encountered instances of transnational repression within the EU context.’Footnote 126 As argued by Balzacq,Footnote 127 the success of a securitisation move is contingent upon a perceptive environment and rests with whether the historical conjuncture renders the audience more sensitive to the vulnerability of a given issue.Footnote 128 This point has been also raised by Barry Buzan, who notes that ‘threats that are specific, close in time and space, and amplified by historical circumstances, are more likely to become security issues than threats that are diffuse, distant in time and space, and historically neutral’.Footnote 129 In the current European context, transnational repression incidents are perceived as low-intensity threats, and given their low level of incidence, Members States do not appear to be much concerned.
Second, transnational repression can be perceived as a sensitive political issue for the EU and its Member States, which may share strategic partnerships with authoritarian perpetrator states. Here, the prioritisation of economic and broader geopolitical interests and the desire to avoid political conflict with strategic partners means that the EU and its Member States may turn an ‘a blind eye’ on incidents related to transnational repression and prioritise strategic interests over normative human rights dimensions.Footnote 130 In this respect, geopolitical dynamics and strategic interdependencies condition the (in)securitisation of transnational repression. The accession of Sweden to NATO illustrates this point. In 2022, when Sweden asked to join NATO after Russia’s full-scale invasion of Ukraine, Turkey withheld its approval amid a row over what it called Sweden’s support to Kurdish separatists and the country being a refuge for political refugees who took part in the 2016 alleged coup attempt in Turkey.Footnote 131 Turkey also demanded that they lift the arms embargo imposed as a result of the former’s military operations in Iraq and Syria. After a long negotiation process (leading to a 20-month delay), Turkey was able to extract some concessions which led to the accession of Sweden to NATO membership.Footnote 132 In response to Turkey’s demands, Sweden introduced tougher anti-terrorism laws, making it illegal to give financial or logistical help to banned groups classified as ‘terrorists’.Footnote 133 An estimated 50,000–100,000 Kurds, including people from Turkey, Syria, Iraq, and Iran, live in Sweden.Footnote 134 Shortly after the NATO agreement, some Kurdish charities closed their bank accounts. Kurdish people living in Sweden were also subjected to surveillance by Säpo, the Swedish security police.Footnote 135 A Swedish court jailed a Kurdish man for crimes including attempting to finance terrorism and told him he would be deported upon release.Footnote 136
Additionally, bilateral relations between the host state and the authoritarian perpetrator state can further explain Member States’ reticence to securitise transnational repression. Recent studies examining the geopolitics of transnational repression demonstrate how trade leverages and geopolitical ties, among other factors such as geographical proximity and weak rule of law, facilitate transnational repression in host countries.Footnote 137 As Figure 1 illustrates, a significant number of individuals residing in the EU were faced with physical violence, including assault (15%) and assassination attempts (2.5%) as well as assassination (6%).Footnote 138 A large proportion of them have also experienced detention (46%). Additionally, an increasing number of individuals have also been unlawfully deported (15%) or have been subject to rendition (6%).
Percentage of types of transnational repression incidents in Europe.
The observations related to ‘detentions’, ‘deportations’, and ‘renditions’ demonstrate that some European states are complicit in perpetuating transnational repression incidents. This can be illustrated with the case of Turkey and Bulgaria. In addition to the geographical proximity, the two countries share important bilateral economic relations, particularly in the sectors of energy, trade, and tourism. Turkey is among Bulgaria’s the top five trade partners, representing an 8 per cent trade share in the overall foreign trade of the country.Footnote 139 Following the failed military coup in 2016, Turkey launched a witch hunt against Muhammed Fethullah Gülen and the Gülen movement but also against leftists and any critics of the regime. Just one month after the coup, at the request of Turkish authorities, Bulgaria extradited Gulenist businessman Abdullah Büyük, who had sought political asylum in Bulgaria.Footnote 140 The extradition came into force even though the City Court of Sofia and the Court of Appeal refused extradition over the lack of guarantee of a fair trial. This event further demonstrates that, despite adopting legal and institutional reforms associated with EU membership, Bulgaria’s judicial system is still prone to politicisation.Footnote 141 In total, the Freedom House database shows that out of seven incidents recorded in Bulgaria, six originated in Turkey, with incidents ranging from detention to deportation and rendition (see Figure 2). Turkey is also ranked as the second main perpetrator of transnational repression incidents in Europe after Russia (see Figure 3).
Transnational repression incidents in individual EU member states, 2014–2023.
Transnational repression incidents counted by perpetrator state, 2014–2023.
What actions could the EU take in response to the threat of transnational repression?
As seen earlier, securitisation of an issue derives from the language discourse and from the different capacities of various actors to engage in speech acts. As demonstrated in this study, although the European Parliament has initiated a securitising move on transnational repression, its claims have failed to find resonance with the audience and produce a securitisation move. In this respect, as this study shows, it is important to view securitisation as a three-stage process: stage 1 where one identifies an issue to be called ‘security’, stage 2 of acceptance, and stage 3 of response mobilisation, where policy measures are adopted to counter the designated security issue. As this study demonstrates, the invocation of transnational repression as a security issue by the European Parliament did not produce its acceptance by the audience, and neither did it lead to emergency measures. Nevertheless, the European Parliament’s position on transnational repression is substantial, and offers interesting insights into how parts of the European policy community approach transnational repression.
One of the key challenges of securitising transnational repression is related to its inherent characteristics. Because of its hybrid and complex nature, transnational repression has been associated with different themes and security implications. Transnational repression issues are broad and heterogeneous, and they intersect national and human rights security dimensions. Additionally, they have broader global implications. Moreover, because of their murky nature it is very often difficult to establish the rules of liability and hold perpetrators accountable for their actions. For these reasons, securitising transnational repression represents a challenge. As this study reveals, transnational repression is characterised by the presence of multiple actors with different perspectives and understandings of what transnational repression represents and how and whether it needs to be securitised.
In the current EU context, there are two divergent interpretations of transnational repression. One way of thinking about transnational repression is causal – transnational repression leads to human insecurity and violation of human rights across international borders and represents a threat to democratic values and the Union, and this is the reason why it needs to be treated as a security issue at the supranational EU level. The approach is largely ‘human-centred’, where transnational repression is not about (national) security but about people and their needs. Such views have been advocated by human rights scholars, NGOs, and the European Parliament. According to this approach, the European Union institutions and its Member States would formulate policies to protect its residents from external sources of repression by developing policy solutions, working with law enforcement agencies and facilitating legal redress, and establishing special institutions that would monitor transnational repression and provide support to affected individuals and communities.Footnote 142
However, another way of looking at transnational repression is to view it as a national security issue embedded within larger frame categories of hybrid threats.Footnote 143 This is the approach adopted by the EU decision-making institutions and its Member States. From this perspective, transnational repression is articulated within the broader discursive framework of hybrid threats without necessitating the use of exceptional measures. Such understanding further implies that transnational repression is country specific and does not require supranational measures at the EU level.
These findings have relevant implications for what is understood as security and how it needs to be addressed. In this view, the problematisation of a security issue depends on the meanings that security language implies, and the framing of a problem thus guides policy responses. From this perspective, in the words of Jeff Huysmans, ‘the meaning of security does not primarily depend on the kind of threats one includes but on the nature of the framing that security practice applies’Footnote 144 – thus, the conceptual and political rationality that security language invests in defining and interpreting a problem. In the current context, there are different perspectives on the meaning and policy responses to address transnational repression. These divergent interpretations are causing friction in the development of a common approach to tackle transnational repression within the EU’s overarching political spectrum and are as a result symptomatic of non-acceptance of the securitisation process. Additionally, the securitisation of transnational repression has been further subject to actors’ interests, preferences, and different security perspectives, further demonstrating a more complex reality that lies behind the (in)securitisation of transnational repression.
For the EU to securitise transnational repression, one would need to consider a more comprehensive approach. At present, there is a lack of reflection by the EU Commission and its Member States to distinguish between different forms of hybrid threats. The current definition of hybrid threats and what it means is problematic in the sense that it (1) remains vague and broad and (2) sheds little light on what constitutes authoritarian interference, and even less on policy responses to tackle it. As a result of such interpretation, transnational repression has been associated with other security narratives, connected to a more general master frameFootnote 145 on hybrid threats. Consequently, it has not been recognised as a security issue for which exceptional measures are needed. Such a narrow understanding obscures the complexity of the transnational repression phenomenon and fails to recognise the nuances involved in responding to the issue effectively.
To recognise transnational repression as a distinct threat category one needs to differentiate it from other forms of hybrid threats. Transnational repression raises a unique set of violations both at the human rights and state’s national security levels. Therefore, a clear definition of transnational repression needs to integrate these two security dimensions and in doing so bridge the conceptual divide between internal and external security dimensions tied to transnational repression. This is an essential first step for the creation of standardised common understanding of transnational repression and the moulding of Member States’ interpretation of the phenomenon. Such an approach would then entail a clear policy formulation of transnational repression and its labelling as an ‘existential threat’ to the Union’s security and its values. This would further require a unified and coordinated response from the EU institutions and its Member States, as well as cross-sectoral cooperation. This is because transnational repression gives rise to a complex interagency issue that requires collaboration between authorities responsible for areas as diverse as foreign policy, security, migration, police and justice, and human rights, among others.Footnote 146 It would further necessitate tools to prosecute acts of transnational repression. Here, one could consider an expansion of law enforcement powers to criminalise and prosecute acts of transnational repression. The United States can be used as an illustrative case here. In the aftermath of the killing of Jamal Khashoggi, the country has initiated a series of policies and legislative measures aiming to counter transnational repression. Those include the so-called Khashoggi Ban, the Protection of Saudi Dissidents Act of 2021, and the Transnational Repression Accountability and Prevention (TRAP) Act, mandating twice-yearly reports on the abuse of Interpol red notices. Additionally, law enforcement agencies launched a series of criminal cases against alleged perpetrators of transnational repression. The FBI website further provides a helpline and guidance for victims of transnational repression.
At the EU institutional level, the EU can further expand its current punishment mechanisms and tools. Here, targeted sanctions, as the EU Global Human Rights Sanctions Regime, may be used to bring the perpetrators of transnational repression to justice. In this way, the EU can play an important role as a transmitter of best practice, advancing solutions to transnational repression and establishing itself as a leading authority for tackling transnational repression. Yet, to achieve all this, the EU needs to ensure that such initiatives receive broader support among its Member States and resonate with European citizens.
Conclusion
This article set out to investigate the extent to which transnational repression has been securitised in the EU. To recall, the theoretical argument given by securitisation theory is that an issue becomes securitised when it is taken out of normal politics, which in turn amounts to exceptional measures.Footnote 147 It seems therefore uncontroversial to conclude that the designation of threat associated with transnational repression did not enable the pursuit of emergency measures in the EU. As demonstrated in this study, securitisation is an intersubjective process between different actors, institutions, and their power interests. Therefore, one has to look beyond the role of securitising actors and observe the processes and factors that shape the political agenda to understand why certain issues rise in security prominence while others do not. In this respect, the study reminds us that securitisation needs to be understood as a dynamic process conditioned by a variety of factors which include securitising power, political context, audience preferences, and the inherent nature of the securitisation issue. The analysis demonstrates that competing views between and within the EU institutions and actors, and the multiple framings and therefore interpretation of transnational repression, as well as a lack of political will from the Member States and EU core decision-making institutions, prevent the securitisation of transnational repression. In this perspective, the study reminds us to consider the role of audiences and their relationship to actors in the securitisation process. Therefore, even though transnational repression has penetrated the EU institutional agenda, it has not led to a securitisation move. The case of transnational repression, as such, is an example of how security issues fail to find resonance and be securitised in EU institutional fora.
Acknowledgements
I would like to thank the journal’s editors and the two anonymous reviewers for their comments and suggestions. I am also grateful to Alexander Dukalskis, Marlies Glasius, Fiona Adamson, Patricia Correa Vila, Huseyn Aliyev, Francesca Loparco, and Irene Fernandez Molinas for their support and feedback on the earlier drafts of this manuscript.
Saipira Furstenberg earned her PhD from the University of Bremen in 2017. From 2018 to 2019, she was a postdoctoral researcher at the University of Exeter. After completing her postdoctoral project, she worked as a lecturer at Oxford Brookes University. From 2022 to 2024, she was a Marie Curie Cofund Fellow at Ca’ Foscari, University of Venice. Her research interests are in International Relations with a particular focus on the international dimension of authoritarian states.
Appendix A: List of questions raised on transnational repression topic in the EU Parliamentary Plenary
Appendix B: Interviews
Notes on interviews
Data were gathered from a dozen interviews and several other informal discussions with EU policymakers, civil society organisations, and political exiled activists. Interviews were conducted in Brussels in July 2023. A large proportion of interviews were also conducted online on Zoom from June–October 2023. Below are the details of the interviews used in this study.
Interviews
Interview 1: Representatives of Safeguard Defenders, June 2023 and October 2023 (Online)
Interview 2: Representative of ProtectDefenders.eu, October 2023 (Online)
Interview 3: EEAS Policy Officer 1, October 2023 (Online)
Interview 4: UNPO, July 2023 (Brussels)
Interview 5: Exiled political activist 1, July 2023 (Brussels)
Interview 6: EEAS Policy Officer 2, August 2023 (Online)
Interview 7: MEP 1, September 2023 (London)
Interview 8: MEP 2, September 2023 (Online)
Interview 9: Representatives of Freedom House, October (Online)
Interview 10: Exiled political activist 2, March 2021 (Online)
Interview 11: EEAS Policy Officer 3, July 2023 (Brussels)
Interview 12: Civil society activist from Dutch Foreign Interference Alliance (Alliantie tegen Buitenlandse Inmenging), 27 February 2024 (Online)
Descriptive statistics
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incident
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