Across the major countries of Europe, there are plenty of ongoing debates about to how to reform democracy, but these national-level debates are often disconnected from each other and there is little attempt to learn from another’s system. Instead, the tendency is to think the grass is greener on the other side, with other countries’ systems being seen as better without a proper examination, and the focus being on their advantages rather than disadvantages.
But a proper comparison of democratic institutions and processes across Europe – as a Chatham House research project has been doing – helps foster a better understanding of the dilemmas and tensions in liberal democracy as a concept, and identifies the true challenges of reform.
In the UK, further devolution and reform of both the House of Lords and the electoral system – particularly to move away from first-past-the-post towards a more proportional system – have long been discussed, while in France radical parties such as La France Insoumise have called for a ‘sixth republic’ to reduce the power of the presidency.
There is less dissatisfaction with the actual system in Germany but there are calls to reduce the size of the Bundestag which has gradually grown to 736 seats and is one of the largest legislatures in the world. But comparing these three countries is a good starting point because they have such contrasting systems.
Majoritarian, consensual, and semi-presidential
The UK is Europe’s leading majoritarian democracy – one in which power is concentrated – whereas Germany lies towards the other end of the spectrum as a much more consensual democracy in which power is shared, dispersed, and restrained. France lies somewhere in between but has a ‘semi-presidential’ system with a directly-elected president alongside a prime minister dependent on the legislature as in a parliamentary system.
Debates about reform show a striking contrast between France and the UK on the one hand and Germany on the other. France and the UK are extremely centralized, especially in comparison to Germany with its federal system and powerful independent institutions such as the constitutional court. But France and the UK are centralized in slightly different ways – in France, power is concentrated around the presidency – the executive – whereas in the UK it is around the House of Commons – the legislature, or at least the cabinet.
When considering proportionality in electoral systems, the Netherlands is the most proportional electoral system in Europe as essentially it has one single constituency, and the UK is one of the least proportional because of the first-past-the-post system. France and Germany are in between, with France closer to the UK and Germany closer to the Netherlands.
The advantages of proportionality are clear in terms of representation but there is also a major disadvantage in that the more proportional the system, the weaker the link tends to be between representatives and the represented – one strength of the UK system is the relatively strong link between MPs and their constituents.
In addition, the more proportional the system, the more likely it is to produce coalition governments – and again, there are clear advantages to this but also disadvantages. Accountability is less clear as government policies emerge out of coalition negotiations rather than simply implementing manifesto commitments, and coalition partners can blame each other for failures. It can also produce a tendency towards a permanent ‘grand coalition’ – between 2005 and 2021 Germany had three grand coalitions in four electoral periods – which creates a perception that voters cannot kick out those in power.
Better systems or less demanding electorates
However, overall there seems to be greater satisfaction with democratic processes and institutions in Germany than in France or the UK. But in many ways Germany is a more constrained democracy with the ‘constitutional’ pillar of liberal democracy being dominant relative to the ‘popular’ pillar. Therefore, if German citizens really are happier with their democratic system than British or French citizens, it could either be because their system is better, or they are less demanding. Or, to put it in terms used by Irish political scientist Peter Mair, they may be happier with a less responsive form of government because they value ‘responsible’ government more.