Microstates and the European Union

Relationship overview

Andorra Flag of Andorra.svg
Flag of Liechtenstein.svg Liechtenstein
Monaco Flag of Monaco.svg
Flag of San Marino.svg San Marino
Vatican City Flag of Vatican City.svg
The third-country European microstates[a]

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 true 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] Iceland is sometimes considered a microstate,[5] because of its small population of 376,248 as of 2022.[6]

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."[7] And indeed, all of the European microstates are sovereign states that function in a close (and voluntary) association with one or two of their respective larger neighbours. Currently, all of the European microstates have some form of relations with the European Union (EU).[8]

Andorra, Liechtenstein, Monaco, San Marino, and the Vatican City remain outside the Union, because the EU has not been designed with microstates in mind.[citation needed] Andorra is, by population, the largest of the five microstates with 78,115 citizens according to a census taken in 2011.[needs update] Two other small countries, Luxembourg and Malta, are full members of the EU and both inhabited by populations over 600,000 and over 500,000 respectively.

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 in its own right of the Schengen Agreement, European Free Trade Association (EFTA) and Dublin Regulation on asylum and has signed 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, both enclaves within Italy, have open borders with Italy and are de facto part of the Schengen Area. No microstates can issue Schengen visas.[citation needed] None of them have any airport, but all have heliports. Monaco has the only seaport; the others are landlocked. Arrival from outside the Schengen Area is allowed in Monaco,[9][10] but not in San Marino and the Vatican City as they have no border controls.[10]

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 European Single Market and applies certain EU laws. All of the microstates are also part of other organisations such as the Council of Europe (except Vatican City) and the Organization for Security and Co-operation in Europe.

Iceland and Liechtenstein are members of the European Economic Area (EEA) through the EFTA. San Marino had considered joining the EEA in the past,[11][12] and held a referendum on submitting an application for EU membership, which was approved by its electorate; however, not enough votes were cast for the result to be considered valid.[13] Iceland and was previously an official candidate for accession to the European Union and if Iceland had acceded to the Union, it would have entered as the smallest EU state measured by population, although twelfth largest by geographical size. The Icelandic government withdrew its application for membership in 2015.[14]

Future of relations

Andorra, Monaco, and San Marino have all stated their desire to deepen relations with the EU. 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",[15] the European Commission published a report outlining options for their further integration into the EU.[13] Unlike Liechtenstein, which is a member of the EEA via the 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.[16]

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.[17] 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.[18][19][20][21] 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.[20]

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.[22] In December 2014 the Council of the European Union approved negotiations being launched with Andorra, Monaco and San Marino on such an agreement,[23] and they began in March 2015.[24] 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.[25] In January 2016, Andorran minister of foreign affairs Gilbert Saboya stated that he believes the agreement could be signed by 2018.[26]


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[27] Schengen Area EU single market EU customs territory[28] EU VAT area[29] Dublin Regulation Prüm Decisions
 Andorra (relations) Negotiating[24] 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 Agreement signed[38]
 Monaco (relations) Negotiating[24] Yes[Note 1] De facto[Note 8] Partial[Note 9] Yes[Note 10] Yes[Note 11][Note 12] No No
 San Marino (relations) Negotiating[24] 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. ^ a b c d Monetary agreement with the EU to issue euros.
  2. ^ No visa is required, but entry is only possible via the Schengen area.[30][31]
  3. ^ a b 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.[32][33][34][35][36]
  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.[37]
  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.[33][39]
  9. ^ Through an agreement with France.[40]
  10. ^ Through an agreement with France. Part of the EU Customs territory, administered as part of France.[33][41][42][32]
  11. ^ Also part of the EU excise territory.[32]
  12. ^ Through an agreement with France. Administered as a part of France for taxation purposes.[29][33][43][32]
  13. ^ a b Although not formally part of the Schengen area, has an open border with Italy.[33]
  14. ^ Partially participates in the EU excise territory.[32]
  15. ^ Through an agreement with Italy. Administered as a part of Italy for taxation purposes.[29][43]

Size comparison

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

Microstates Relationship Population Area (km2) GDP (nom) HDI
 Andorra Agreements 85,458 467 $4.510 billion 0.845
 Iceland EEA State 376,248[6] 102,775[44] $20.8 billion[45] 0.959[46]
 Liechtenstein EEA State 37,340 160 $5.155 billion 0.908
 Luxembourg EU State 562,958 2,586 $57.9 billion 0.892
 Malta EU State 445,426 316 $10.582 billion 0.839
 Monaco Agreements 37,800 2 $5.424 billion n/a
 San Marino Agreements 32,576 61 $1.44 billion n/a
  Vatican City Agreements 842 0.44 n/a n/a

See also


  1. ^ Malta, despite being considered one of the European microstates is not highlighted on this map because it is a full member of the European Union. Iceland is also excluded due to its geographical size.

Further reading

  • Butler, Graham (2022). "The Legal Relations of the European Union with the Vatican City State and Holy See". European Foreign Affairs Review. 27 (2): 263–282.


  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, Luxembourg, 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. ^ 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. SSRN 444040.
  6. ^ a b "Statistics Iceland: Overview". Statistics Iceland. Retrieved 17 August 2022.
  7. ^ Dumienski, Zbigniew (2014). "Microstates as Modern Protected States: Towards a New Definition of Micro-Statehood" (PDF). Occasional Paper. Centre for Small State Studies. Retrieved 6 July 2014. {{cite journal}}: Cite journal requires |journal= (help)
  8. ^ "EU relations with the Principality of Andorra, the Republic of San Marino and the Principality of Monaco" (PDF). Council of the European Union. 14 June 2011. Retrieved 12 September 2012.
  9. ^ Both by sea and helicopter
  10. ^ a b "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)".
  11. ^ "The Secretary of State for Foreign Affairs has met the European Commissioner for External Relations and European Neighbourhood Policy". 17 July 2009. Retrieved 1 April 2013.
  12. ^ "San Martino to participate to the EEA". 21 July 2009. Retrieved 1 April 2013.
  13. ^ a b "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.
  14. ^ Timeline of events – Iceland's application for membership of the EU, Icelandic Ministry for Foreign Affairs Archived 3 September 2011 at the Wayback Machine
  15. ^ "Council conclusions on EU relations with EFTA countries" (PDF). Council of the European Union. 14 December 2010. Retrieved 1 April 2013.
  16. ^ "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. 20 December 2012. Archived from the original (PDF) on 17 May 2013. Retrieved 1 April 2013.
  17. ^ "Norge sier nei til nye mikrostater i EØS". 19 May 2011. Retrieved 6 April 2013.
  18. ^ "Innlegg på møte i Stortingets europautvalg". Ministry of Foreign Affairs of Norway. 28 January 2013. Retrieved 1 April 2013.
  19. ^ "Eide: Bedre blir det ikke". 21 December 2012. Archived from the original on 13 April 2013. Retrieved 1 April 2013.
  20. ^ a b Aalberg Undheim, Eva (8 December 2012). "Regjeringa open for diskutere EØS-medlemskap for mikrostatar" (in Norwegian). Retrieved 6 April 2013.
  21. ^ "La Norvegia chiude le porte a San Marino" (PDF). La Tribuna Sammarinese. 3 January 2013. p. 7. Archived from the original (PDF) on 7 March 2014. Retrieved 6 April 2013.
  22. ^ "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. 18 November 2013. Retrieved 20 November 2013.
  23. ^ "Council adopts mandate to negotiate association agreement(s) with Andorra, Monaco and San Marino" (PDF). Council of the European Union. 16 December 2014. Retrieved 22 December 2014.
  24. ^ a b c d "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. 18 March 2015. Retrieved 18 March 2015.
  25. ^ Rubio, Alberto. "En un par de años Andorra podrá formar parte del Espacio Schengen". Retrieved 26 October 2015.
  26. ^ "We don't pretend to be a full member of the EU, but the association agreement with the EU will provide Andorra with access to the European market, says minister of foreign affairs of Andorra Gilbert Saboya • ALL ANDORRA". 26 January 2016.
  27. ^ "The euro outside the euro area". Europa (web portal). Retrieved 26 February 2011.
  28. ^ "EU Customs Union". European Commission. Archived from the original on 19 June 2015. Retrieved 18 June 2015.
  29. ^ a b c "Taxation and Customs Union - Within the EU". European Commission. Archived from the original on 11 November 2012. Retrieved 9 September 2012.
  30. ^ "Travel to Andorra". Government of Andorra. Retrieved 3 October 2014.
  31. ^ "Obstacles to access by Andorra, Monaco and San Marino to the EU's Internal Market and Cooperation in other Areas". 2012. Retrieved 30 March 2013.
  32. ^ a b c d e "Annex 1: Overview of European Union countries" (PDF). European Commission. Archived from the original (PDF) on 4 May 2014.
  33. ^ a b c d e "Obstacles to access by Andorra, Monaco and San Marino to the EU's Internal Market and Cooperation in other Areas". 2012. Retrieved 30 March 2013.
  34. ^ "Part 2 - The European Community and accession of new member states" (PDF). Government of the United Kingdom.
  35. ^ "Andorra : Customs Unions and preferential arrangements". European Commission. Archived from the original on 26 October 2012. Retrieved 12 September 2012.
  36. ^ "San Marino : Customs Unions and preferential arrangements". European Commission. Archived from the original on 26 October 2012. Retrieved 12 September 2012.
  37. ^ "Switzerland and Liechtenstein: December 2000". World Trade Organization. 6 December 2000. Retrieved 16 September 2012.
  38. ^ "Agreement details". Council of the European Union. Retrieved 19 July 2019.
  39. ^ "The Schengen acquis - Decision of the Executive Committee of 23 June 1998 on Monegasque residence permits". Official Journal of the European Union. 22 September 2000. Retrieved 9 September 2012.
  40. ^ 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"
  41. ^ "Taxation and Customs - FAQ". European Commission. Archived from the original on 8 June 2012. Retrieved 12 September 2012.
  42. ^ "Council Regulation (EEC) No 2913/92 of 12 October 1992 establishing the Community Customs Code". Official Journal of the European Union. 19 October 1992. Retrieved 12 September 2012.
  43. ^ a b "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. 14 January 2009. Retrieved 10 September 2012.
  44. ^ "Ísland er minna en talið var" (in Icelandic). RÚV. 26 February 2015. Archived from the original on 15 March 2015. Retrieved 10 March 2015.
  45. ^ "Iceland". International Monetary Fund.
  46. ^ "Human Development Report 2021/2022" (PDF). United Nations Development Programme. 8 September 2022. Retrieved 8 September 2022.

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