Microstates and the European Union

There are a number of microstates in Europe. While there is no clear consensus on which political units qualify as "microstates", most scholars view Andorra, Liechtenstein, Monaco, San Marino and the Vatican City as examples of such states.[1][2][3] At the same time, some academics dispute even qualifying Vatican as a state arguing that it does not meet the "traditional criteria of statehood" and that the "special status of the Vatican City is probably best regarded as a means of ensuring that the Pope can freely exercise his spiritual functions, and in this respect is loosely analogous to that of the headquarters of international organisations."[4] According to the qualitative definition of microstates suggested by Dumienski (2014), microstates can also be viewed as "modern protected states, i.e. sovereign states that have been able to unilaterally depute certain attributes of sovereignty to larger powers in exchange for benign protection of their political and economic viability against their geographic or demographic constraints."[5] And indeed, all of the European microstates are sovereign states that function in a close (and voluntary) association with their respective larger neighbour. Currently, all of the European microstates have special relations with the European Union.[6]

Andorra, Liechtenstein, Monaco, San Marino, and the Vatican City remain outside the Union, some because of the cost of membership as the EU has not been designed with microstates in mind. Andorra is, by population, the largest of the 5 microstates with 78,115 according to a census taken in 2011. Two other small countries, Luxembourg and Malta, are full members of the European Union and both inhabited by populations over 400,000. Iceland is considered a microstate by some, because of its small population of 320,060 per April 2012.[7] It is a member of the European Economic Area (EEA), and is recognized as an official candidate for accession to the Union, though the negotiations have been suspended. If Iceland accedes to become an EU member state, it would enter as the smallest EU state measured by population, although twelfth largest by geographical size.

Status of relations

Andorra, Monaco, San Marino, and the Vatican City use the euro through monetary agreements with the EU, and have been granted the right to issue a limited number of euro coins. They were allowed to do so as they had used or been tied to the old eurozone currencies. Liechtenstein, on the other hand, uses the Swiss franc.

Liechtenstein is a full member of the Schengen Agreement and Dublin Regulation on asylum and is negotiating an agreement to participate in the Prüm Decisions , while Monaco has an open border with France and Schengen laws are administered as if it were a part of France. San Marino and the Vatican City have an open border with their neighbouring Schengen Area state Italy. No microstates can issue Schengen visas. None of them have any airport, but all have heliports. Monaco has the only seaport. Arrival from outside the Schengen Area is allowed in Monaco,[8][9] but not in San Marino and the Vatican City as they have no border controls.[9]

Monaco is a part of the EU customs territory through an agreement with France, and is administered as part of France. San Marino and Andorra are in a customs union with the bloc. Liechtenstein, as a member of the EEA, is within the EU internal market and applies certain EU laws. All of the microstates are also part of other organisations such as the Council of Europe and the Organisation for Security and Co-operation in Europe (the Vatican is member only of the OSCE).

Andorra, Monaco, and San Marino have all stated their desire to deepen relations with the EU. San Marino had considered joining the EEA in the past,[10][11] and held a referendum on submitting an application for EU membership.[12]

Future of relations

In November 2012, after the Council of the European Union had called for an evaluation of the EU's relations with these microstates, which they described as "fragmented",[13] the European Commission published a report outlining options for their further integration into the EU.[12] Unlike Liechtenstein, which is a member of the EEA via the European Free Trade Association (EFTA) and the Schengen Agreement, relations with these three states are based on a collection of agreements covering specific issues. The report examined four alternatives to the current situation: 1) a Sectoral Approach with separate agreements with each state covering an entire policy area, 2) a comprehensive, multilateral Framework Association Agreement (FAA) with the three states, 3) EEA membership, and 4) EU membership. The Commission argued that the sectoral approach did not address the major issues and was still needlessly complicated, while EU membership was dismissed in the near future because "the EU institutions are currently not adapted to the accession of such small-sized countries." The remaining options, EEA membership and a FAA with the states, were found to be viable and were recommended by the Commission. In response, the Council requested that negotiations with the three microstates on further integration continue, and that a report be prepared by the end of 2013 detailing the implications of the two viable alternatives and recommendations on how to proceed.[14]

As EEA membership is currently only open to EFTA or EU members, the consent of existing EFTA member states is required for the microstates to join the EEA without becoming members of the EU. In 2011, Jonas Gahr Støre, the then Foreign Minister of Norway which is an EFTA member state, said that EFTA/EEA membership for the microstates was not the appropriate mechanism for their integration into the internal market due to their different requirements than large countries such as Norway, and suggested that a simplified association would be better suited for them.[15] Espen Barth Eide, Støre's successor, responded to the Commission's report in late 2012 by questioning whether the microstates have sufficient administrative capabilities to meet the obligations of EEA membership. However, he stated that Norway was open to the possibility of EFTA membership for the microstates if they decide to submit an application, and that the country had not made a final decision on the matter.[16][17][18][19] Pascal Schafhauser, the Counsellor of the Liechtenstein Mission to the EU, said that Liechtenstein, another EFTA member state, was willing to discuss EEA membership for the microstates provided their joining did not impede the functioning of the organization. However, he suggested that the option direct membership in the EEA for the microstates, outside of both the EFTA and the EU, should be given consideration.[18]

On 18 November 2013 the EU Commission published their report which concluded that "the participation of the small-sized countries in the EEA is not judged to be a viable option at present due to the political and institutional reasons", but that Association Agreements were a more feasible mechanism to integrate the microstates into the internal market, preferably via a single multilateral agreement with all three states.[20] In December 2014 the Council of the European Union approved negotiations being launched with Andorra, Monaco and San Marino on such an agreement,[21] and they began in March 2015.[22] Andorran ambassador to Spain Jaume Gaytán has said that he hopes that the agreement will include provisions to make the states associate members of the Schengen Agreement.[23]


Integration Level

This table summarises the various components of EU laws applied in the microstates. Some territories of EU member states also have a special status in regard to EU laws applied as is the case with some European Free Trade Association members and their sovereign territories.

Microstates Association Agreement Eurozone[24] Schengen Area EU single market EU customs territory[25] EU VAT area[26] Dublin Regulation Prüm Decisions
 Andorra (relations) Negotiating[22] Yes[Note 1] No[Note 2] No Partial[Note 3] No No No
 Liechtenstein (relations) Yes[Note 4] No[Note 5] Yes Yes[Note 6] No[Note 7] No Yes Negotiating[34]
 Monaco (relations) Negotiating[22] Yes[Note 1] de facto[Note 8] Partial[Note 9] Yes[Note 10] Yes[Note 11][Note 12] No No
 San Marino (relations) Negotiating[22] Yes[Note 1] Open border[Note 13] No Partial[Note 3] No[Note 14][Note 15] No No
  Vatican City (relations) No Yes[Note 1] Open border[Note 13] No No No No No


  1. 1 2 3 4 Monetary agreement with the EU to issue euros.
  2. No visa is required, but entry is only possible via the Schengen area.[27]
  3. 1 2 Customs Union Agreement that eliminates barriers in trade between the country and the EU, as well as the adoption of the EU acquis on imports in regards to third countries; however there are certain exceptions and standard customs procedures still apply between the country and the EU.[28][29][30][31][32]
  4. Agreement on the European Economic Area.
  5. Uses the Swiss franc.
  6. Member state of the European Economic Area.
  7. Customs union with Switzerland.[33]
  8. Although not a contracting party to the Schengen Agreement, has an open border with France and Schengen laws are administered as if it were a part of France.[29][35]
  9. Through an agreement with France.[36]
  10. Through an agreement with France. Part of the EU Customs territory, administered as part of France.[29][37][38][28]
  11. Also part of the EU excise territory.[28]
  12. Through an agreement with France. Administered as a part of France for taxation purposes.[26][29][39][28]
  13. 1 2 Although not formally part of the Schengen area, has an open border with Italy.[29]
  14. Partially participates in the EU excise territory.[28]
  15. Through an agreement with Italy. Administered as a part of Italy for taxation purposes.[26][39]

Size Comparison

This table provides a comparison between major statistics of the microstates to the smallest EU member states.

Microstates Relationship Population Area GDP (nom) HDI
 Andorra Agreements 85,458 467 km2 $4.510 billion 0.845
 Liechtenstein EEA State 37,340 160 km2 $5.155 billion 0.908
 Luxembourg EU State 562,958 2586 km2 $57.9 billion 0.892
 Malta EU State 445,426 316 km2 $10.582 billion 0.839
 Monaco Agreements 37,800 2 km2 $5.424 billion n/a
 San Marino Agreements 32,576 61 km2 $1.44 billion n/a
  Vatican City Agreements 842 44 ha n/a n/a


  1. Catudal, H., 1975. The plight of the Lilliputians: An analysis of five European microstates. Geoforum, 6, pp.187–204
  2. Duursma, J.C., 1996. Fragmentation and the International Relations of Micro-states: Self-determination and Statehood, Cambridge University Press.
  3. Eccardt, T.M., 2005. Secrets of the Seven Smallest States of Europe: Andorra, Liechtenstein, Luxemborg, Malta, Monaco, San Marino, and Vatican City, Hippocrene Books.
  4. Mendelson, M., 1972. Diminutive States in the United Nations. The International and Comparative Law Quarterly, 21(4), pp.609–630.
  5. Dumienski, Zbigniew (2014). "Microstates as Modern Protected States: Towards a New Definition of Micro-Statehood" (PDF). Occasional Paper. Centre for Small State Studies. Retrieved 2014-07-06.
  6. "EU relations with the Principality of Andorra, the Republic of San Marino and the Principality of Monaco" (PDF). Council of the European Union. 2011-06-14. Retrieved 2012-09-12.
  7. Herbertsson, Tryggvi Thor; Zoega, Gylfi (December 2002). "A Microstate with Scale Economies: The Case of Iceland". Institute of Economic Studies Working Paper. University of Iceland. W02:10.
  8. Both by sea and helicopter
  9. 1 2 Update of the list of border crossing points referred to in Article 2(8) of Regulation (EC) No 562/2006 of the European Parliament and of the Council establishing a Community Code on the rules governing the movement of persons cross borders (Schengen Borders Code) (OJ C 316, 28.12.2007)
  10. "The Secretary of State for Foreign Affairs has met the European Commissioner for External Relations and European Neighbourhood Policy". 2009-07-17. Retrieved 2013-04-01.
  11. "San Martino to participate to the EEA". 2009-07-21. Retrieved 2013-04-01.
  12. 1 2 "Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee of the Regions - EU Relations with the Principality of Andorra, the Principality of Monaco and the Republic of San Marino - Options for Closer Integration with the EU". 2012.
  13. "Council conclusions on EU relations with EFTA countries" (PDF). Council of the European Union. 2010-12-14. Retrieved 2013-04-01.
  14. "Council conclusions on EU relations with the Principality of Andorra, the Republic of San Marino and the Principality of Monaco" (PDF). Council of the European Union. 2012-12-20. Retrieved 2013-04-01.
  15. "Norge sier nei til nye mikrostater i EØS". 2011-05-19. Retrieved 2013-04-06.
  16. "Innlegg på møte i Stortingets europautvalg". Ministry of Foreign Affairs of Norway. 2013-01-28. Retrieved 2013-04-01.
  17. "Eide: Bedre blir det ikke". 2012-12-21. Retrieved 2013-04-01.
  18. 1 2 Aalberg Undheim, Eva (2012-12-08). "Regjeringa open for diskutere EØS-medlemskap for mikrostatar" (in Norwegian). Retrieved 2013-04-06.
  19. "La Norvegia chiude le porte a San Marino" (PDF). La Tribuna Sammarinese. 2013-01-03. p. 7. Retrieved 2013-04-06.
  20. "EU Relations with the Principality of Andorra, the Principality of Monaco and the Republic of San Marino: Options for their participation in the Internal Market". European Commission. 2013-11-18. Retrieved 2013-11-20.
  21. "Council adopts mandate to negotiate association agreement(s) with Andorra, Monaco and San Marino" (PDF). Council of the European Union. 2014-12-16. Retrieved 2014-12-22.
  22. 1 2 3 4 "RECORDED HRVP Federica MOGHERINI host the ceremony on the occasion of the launching of the Association Agreement(s) negotiations with the Principality of Andorra, the Principality of Monaco and the Republic of San Marino". European Commission. 2015-03-18. Retrieved 2015-03-18.
  23. Rubio, Alberto. ""En un par de años Andorra podrá formar parte del Espacio Schengen"". Retrieved 2015-10-26.
  24. "The euro outside the euro area". Europa (web portal). Retrieved 26 February 2011.
  25. "EU Customs Union". European Commission. Retrieved 2015-06-18.
  26. 1 2 3 "Taxation and Customs Union - Within the EU". European Commission. Retrieved 2012-09-09.
  27. "Travel to Andorra". Government of Andorra. Retrieved 3 October 2014.
  28. 1 2 3 4 5 "Annex 1: Overview of European Union countries" (PDF). European Commission.
  29. 1 2 3 4 5 "Obstacles to access by Andorra, Monaco and San Marino to the EU's Internal Market and Cooperation in other Areas". 2012. Retrieved 2013-03-30.
  30. "Part 2 - The European Community and accession of new member states" (PDF). Government of the United Kingdom.
  31. "Andorra : Customs Unions and preferential arrangements". European Commission. Retrieved 2012-09-12.
  32. "San Marino : Customs Unions and preferential arrangements". European Commission. Retrieved 2012-09-12.
  33. "Switzerland and Liechtenstein: December 2000". World Trade Organization. 2000-12-06. Retrieved 2012-09-16.
  34. "OUTCOME OF THE COUNCIL MEETING - 3473rd Council meeting - Justice and Home Affairs". Council of the European Union. 2016-06-10. Retrieved 2016-07-04.
  35. "The Schengen acquis - Decision of the Executive Committee of 23 June 1998 on Monegasque residence permits". Official Journal of the European Union. 2000-09-22. Retrieved 2012-09-09.
  36. EU relations with the Principality of Andorra, the Republic of San Marino and the Principality of Monaco: "If France adopts internal legislation transposing EU directives in certain areas covered by bilateral Agreements with Monaco, the Principality directly applies the French legislation in certain areas"
  37. "Taxation and Customs - FAQ". European Commission. Retrieved 2012-09-12.
  38. "Council Regulation (EEC) No 2913/92 of 12 October 1992 establishing the Community Customs Code". Official Journal of the European Union. 1992-10-19. Retrieved 2012-09-12.
  39. 1 2 "COUNCIL DIRECTIVE 2008/118/EC of 16 December 2008 concerning the general arrangements for excise duty and repealing Directive 92/12/EEC". Official Journal of the European Union. 2009-01-14. Retrieved 2012-09-10.

See also

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