A major study reveals how five Western nations handle religious diversity in radically different ways — and Muslims often bear the brunt of the toughest rules.
The Core Question: One Region, Two Very Different Playbooks
When a Muslim woman walks down a street in Birmingham, Paris, Berlin, Brussels, or Sydney, her legal rights are not identical. In some cities, she can wear a headscarf almost anywhere. In others, a single piece of fabric can trigger a ban in schools, parliaments, or public offices. The reason lies not in theology, but in politics.
A comprehensive 2022 study by Thomas Sealy and Tariq Modood from the University of Bristol examines how five countries — Belgium, France, Germany, the United Kingdom, and Australia — govern religious diversity. Their conclusion is striking. All five share a common foundation of political secularism and freedom of conscience. However, they diverge sharply on one critical issue: how much religion belongs in public life.
The research introduces two distinct modes of governance. The first, moderate secularism, treats religion as a public good worth supporting. The second, secularist statism, treats religion as a private matter to be tightly controlled. Four countries lean toward the first mode. France stands apart, embodying the second.
This distinction matters enormously for ordinary people. It determines whether faith schools receive public funding, whether headscarves appear in classrooms, and whether mosques face surveillance. Therefore, understanding these models helps explain daily headlines about religious freedom across Europe.
Moderate Secularism: Religion as a Partner, Not a Problem
The United Kingdom, Belgium, Germany, and — to a lesser extent — Australia operate under what the authors call moderate secularism. In this model, the state maintains formal connections with religious institutions. Moreover, those connections extend benefits, recognition, and cooperation rather than control.
Germany offers a clear example. The Basic Law separates church and state formally. Yet religious groups can achieve “corporation under public law” status. This status brings tax privileges and allows cooperation in education and welfare. Methodists, Jews, Greek Orthodox, Baptists, and Jehovah’s Witnesses have all gained this recognition over decades. Consequently, religious diversity receives institutional acknowledgment rather than suspicion.
Belgium follows a similar path. Although no formal constitutional separation exists, the state recognizes multiple religious groups officially. Strong ties between state and Catholic institutions persist in education and public life. Furthermore, newer religious communities have gradually gained official status too.
The UK presents another variation. The Church of England remains weakly established, with bishops holding reserved seats in the House of Lords. Nevertheless, other religions operate freely and receive support. Under the Charities Act 2011, “advancement of religion” counts as a charitable purpose. This status unlocks tax relief for religious bodies. Additionally, state welfare would struggle severely without partnerships with churches and faith-based organizations. In short, religion functions as a public good, not a private hobby.
Australia: Multicultural Accommodation With Constitutional Limits
Australia’s approach blends moderate secularism with a distinctive constitutional framework. The Australian Constitution treats religious beliefs largely as voluntary and private matters. Consequently, positive protection for religious rights is weaker than in Germany, Belgium, or the UK. Some scholars describe this arrangement as “liberal separationism.”
Despite this constitutional restraint, Australia has built a robust multicultural tradition. The country maintains a list of Registered Religious Institutions through the Australian Tax Office. These institutions may access various tax benefits and concessions. Additionally, state and territory governments fund religious and cultural groups, sometimes specifically targeting minority ethno-religious communities.
The 2018 Religious Freedoms Review marked a significant national development. In response, the Australian government declared that freedom of religion is not subordinate to other freedoms. A new Religious Discrimination Act subsequently passed the lower house. However, it has stalled in the Senate owing to tensions with sex and sexuality discrimination rights. At state level, Victoria has moved to restrict religious organizations’ ability to discriminate on grounds of sexuality, gender, and marital status in staff recruitment. This creates potential conflict with the federal bill should it become law. Therefore, Australia’s model remains contested and evolving.
Two Modes of Governing Religious Diversity
| Feature | Moderate Secularism | Secularist Statism |
|---|---|---|
| Countries | UK, Belgium, Germany, Australia | France |
| View of religion | Public good | Private matter, potential problem |
| State-religion ties | Cooperative, supportive | Controlling, restrictive |
| Faith schools | Publicly funded | Funded with heavy state oversight |
| Religious symbols | Generally tolerated with some limits | Heavily restricted in public sphere |
| Recognition process | Accessible, multiple groups recognized | Difficult, state reviews purposes |
| Autonomy of religions | High in doctrine and appointments | Low, state interferes in appointments |
France: The Exception That Proves the Rule
France operates under secularist statism, a mode rooted in a specific interpretation of laïcité. The country is the only EU state that explicitly defines itself as secular in its constitution. This commitment stems from a form of civic nationhood that rejects group differences. Consequently, religious expression is confined more strictly to the private sphere than elsewhere in the region.
The French state maintains significant control over religious institutions. For instance, the Minister of the Interior reviews the values of proposed bishops before the pope appoints them. The state also plays a major role in deciding employees and curriculum in religious schools it funds. Moreover, churches built before 1905 remain state-owned and largely state-maintained. These arrangements reveal a relationship defined by supervision rather than partnership.
One exception exists: the Alsace-Moselle region. There, four faiths — Catholicism, Calvinism, Lutheranism, and Judaism — receive public recognition and greater financial support. This anomaly stems from the region having been part of Germany when the 1905 separation law passed. Therefore, it represents a historical footnote rather than a model for the rest of France.
The 2021 anti-separatism bill expanded state powers considerably. It restricted religious freedoms and implicitly targeted Muslims. Numerous mosques and Muslim organizations were shut down. Furthermore, an inter-ministerial committee on laïcité now ensures “respect and promotion of laïcité by all public institutions.” These measures illustrate how secularist statism translates into concrete policy.
Headscarves and the Geography of Banning
Few issues illustrate the divide between moderate secularism and secularist statism more clearly than religious dress. France banned ostentatious religious symbols in public schools in 2004. Subsequently, it banned full-face coverings in public in 2011. These laws applied generally, but their primary target was Muslim women. Sikh students wearing turbans and Jewish students wearing yarmulkes were also expelled under the 2004 law. Therefore, the ban affected multiple faiths while disproportionately impacting Muslims.
Germany took a different route. The Federal Constitutional Court ruled that a blanket ban on religious symbols was unconstitutional. Instead, individual Länder could introduce their own legislation. As a result, bans appeared unevenly across the country. Left-leaning Länder favored general bans on all religious symbols. Right-leaning Länder selectively targeted the Islamic headscarf, distinguishing it from Christian symbols. The legal debate centered on teachers as public servants expected to maintain neutrality. Consequently, German bans focused on specific roles rather than blanket public prohibitions.
Belgium introduced a criminal ban on face-covering in public. However, a general headscarf ban never materialized. Some schools and municipalities imposed restrictions, but these remained ad hoc and inconsistent. A recent Constitutional Court ruling stated that universities may introduce bans if they choose. Nevertheless, many universities declared they would not. Some existing bans in Wallonia were even revoked. Thus, Belgium’s approach reflects moderate secularism’s uneven, negotiated character.
Meanwhile, the UK and Australia have not introduced such bans at all. In Britain, bans of this kind have never garnered serious political attention. This contrast underscores how differently countries treat the same religious practice.
Religious Dress Rules Across Five Countries
| Country | Headscarf in Schools | Full-Face Covering in Public | Teachers’ Religious Symbols | Overall Approach |
|---|---|---|---|---|
| France | Banned (2004) | Banned (2011) | Banned | Strict, centralized |
| Germany | Varies by Land | Partial bans in some regions | Restricted for public servants | Uneven, federalized |
| Belgium | Ad hoc, varies by school | Banned nationally | Depends on institution | Inconsistent, negotiated |
| UK | No ban | No ban | Generally permitted | Permissive |
| Australia | No ban | No ban | Generally permitted | Permissive |
Muslims: The Central Test Case
Across all five countries, Muslims have become the primary focus of debates about public religion. The authors note that fears of radicalization and extremism have intensified scrutiny of Muslim institutions. Mosques face greater surveillance than other places of worship. Foreign influence has become a particular concern.
Belgium terminated Saudi Arabia’s lease on the Grand Mosque of Brussels over concerns about radicalism promotion. In Flanders, mosques seeking recognition must prove their commitment to using Dutch as their working language. They must also demonstrate respect for the constitution and basic rights. Furthermore, they must show they are not involved in terrorist activities. These conditions illustrate how institutionalization can become a tool for regulation.
The study observes that Muslim representative bodies have struggled to gain legitimacy. This difficulty stems partly from the diversity of Muslim communities — ethnically, nationally, and doctrinally. Unlike Protestantism or Catholicism, Islam lacks a centralized authority structure. Therefore, states demanding a single representative body create their own obstacles. Additionally, transnational influences can aggravate these challenges.
Despite these pressures, the authors argue that moderate secularism still offers better accommodation than secularist statism. In moderate secularism, regulative aspects have increased without questioning religion’s public good function. The tension between support and control remains prominent but balanced. In France, by contrast, state control crowds out more moderate forces. Consequently, the qualitative difference between the two modes persists.
Why This Matters for Ordinary People
These governance models affect daily life in concrete ways. They determine whether a Muslim student can wear a headscarf to class. They shape whether a Sikh can wear a turban in school. They influence whether faith-based charities receive public funding. Moreover, they affect whether religious leaders can operate freely or face state interference.
The study also reveals something important about democracy. Moderate secularism treats religion as one voice among many in the public square. Secularist statism treats it as a voice that should remain largely silent in public. Both approaches claim to protect freedom. Nevertheless, they produce very different outcomes for religious minorities.
Public opinion remains divided. Some citizens support stricter secularism as a safeguard against extremism. Others view accommodation as essential for social cohesion. Consequently, these debates will continue shaping elections, legislation, and community relations for years to come.
A Region Still Negotiating
Sealy and Modood conclude that Western Europe and Australia share common foundations. Freedom of conscience and moral individualism underpin all five countries. However, the extent and quality of state-religion connections vary significantly. Therefore, the region cannot be characterized by a single approach.
Moderate secularism itself should be understood as an ongoing project. Its parameters remain under constant negotiation. Countries currently characterized by moderate secularism could shift toward secularist statism. Such a shift would require much wider changes, but it remains possible. Alternatively, they could move toward deeper multicultural accommodation. The direction depends on political choices, demographic changes, and public debate.
The authors suggest that future research should compare other European countries. Nations such as Italy, Spain, and the Netherlands also have moderate secularism as their dominant norm. However, they qualify it in different ways. Examining these variations could illuminate additional pathways.
Ultimately, the question lingering over the region is this: Will governance of religious diversity lean toward accommodation or toward muscular liberalism? The answer will determine not only the fate of religious minorities but also the character of liberal democracy itself.
