This article examines the evolving dynamics of migration control in the European Union, where traditional state borders are being redefined. As governance shifts to private and local actors, healthcare access increasingly serves as a tool of internal bordering, regulating migrant mobility and social rights within different welfare state models. Focusing on the experiences of free-moving EU migrants in Germany, Sweden, and the UK (an EU member at the time of this study), the research shows how healthcare provision selectively includes or excludes migrants. The findings reveal that these bordering strategies vary by welfare state model: the liberal welfare state model, as seen in the UK, aligns more closely with the EU’s ideal of free mobility, while the social-democratic model, exemplified by Sweden, struggles to accommodate this type of mobility, highlighting significant tensions in the EU’s commitment to universal access.

This article tackles the question of how bureaucratic structures condition frontline implementers’ use of European Union (EU) migration law. Adopting an organisational perspective, the study expects that only under discretion do implementers draw independently on original EU law. Empirically, the article draws on qualitative interviews with migration law implementers in the Netherlands and the German Bundesland of North Rhine-Westphalia. The analysis reveals that in the nondiscretionary Dutch structure, frontline implementers only rely on EU law when receiving instructions from higher administrative levels. The use of EU law is more diverse in the German discretionary structure. Under legal tension, several German frontline implementers use EU law parallel to national law. However, not all German respondents feel comfortable in interpreting original EU law and jurisprudence. Although structural discretion conditions uses of EU law, the variation of the German case suggests that microlevel factors complement explanations for frontline uses of EU law.