Transnational mobility presents fundamental challenges to nationally-bounded welfare states, which historically have tended to be organised according to territorial principles of solidarity among permanent residents / nationals. By developing legislation to create welfare benefits encouraging the durable return of specific groups of older migrants to their countries of origin, the Dutch and French governments have taken recent unusual steps to break this link between national solidarity and territorially-bounded consumption of welfare.

This presentation asks what motivated policymakers to initially develop these very specifically-targeted policy proposals which contradict the territorial logic of the welfare state. Based on interviews and available official documents, we follow the subsequent ‘biographies’ of the two policies, explaining why the revised Dutch scheme has entered into force, while the implementation of the French proposal (although passed by parliament) continues to be blocked. What is noteworthy about the Dutch discussions is that the territoriality principle was not at issue; rather the political debate focused primarily on the utilitarian wish to save the welfare state money. By contrast in France, the dynamics of the debate have been precisely the contrary, with concern for the territoriality of the welfare state trumping any financial considerations. However, in both country cases the concern not to transgress anti-discrimination clauses in the EU treaties was a major preoccupation. We conclude by exploring the extent to which policymakers and other stakeholders in the respective countries have engaged in mutual ‘policy learning’.