Abstract
This paper examines competing liberal and multiculturalist theories on the state’s recognition of religion to address the accommodation of transnational religious diversity in the liberal democratic context. The three liberal theories examined include nonestablishment, minimal secularism, and liberal establishment. While coherent within liberal political thought, these theories encounter persistent limitations when addressing the complex realities of transnational religious diversity. The Bristol School of Multiculturalism (BSM) provides a necessary but insufficient corrective by emphasizing multicultural citizenship, multiculturalized secularism, and the recognition of religion as a public good. This paper, however, argues that both liberal secularisms and the BSM overlook the significant role that transnationalism plays in shaping religious identities and belongings. This neglect of transnational dimensions of religious diversity undermines their ability to address the lived realities of cross-nationally connected religious communities. Accommodating transnational religious diversity involves more than domestic struggle for recognition, it also encompasses transnational religious identities, engagements and attachments that shape contemporary religious minority subjectivities. The paper offers a critical multiculturalist intervention that expands BSM’s framework to include the role of transnational religion in liberal democratic contexts, which retains BSM’s strengths while transcending its nation-state-bound limitations.
Keywords
Introduction
Despite the continuing process of secularization (e.g., decline in belief in God, church attendance, religious identification) in western liberal democracies, religion remains a potent force (Shah and Toft, 2006; Toft et al., 2011) in different forms–e.g., “belief without belonging” (Davie, 1994) or “implicit religion” (Bailey, 2009). While some have emphasized a crisis of secularism in Western Europe, citing a slowdown in the process of secularization (Bhargava, 2010; Habermas, 2006; Roy, 2007), the challenge to political secularism, however, is essentially related to the new religious diversity, a product of post-war migration flows (Modood, 2019). Since the early 1990s, a significant scholarly corpus emerged on the governance and/or accommodation of this new religious diversity. This paper examines competing liberal and multiculturalist theories on the state’s recognition of religion in the context of the accommodation of the new transnational religious diversity, 1 arguing that despite their robust engagement with identity and recognition both liberal secularists and multiculturalists have failed to recognize and theorize transnational identities and belongings, overlooking transnational dimensions of religious diversity.
Liberalism has had an ambivalent relationship with religion, best manifested by liberal democratic countries, as some of them embrace some form of religious establishment (e.g., the UK, Finland) while others favor varying degrees of separation (e.g., the USA) or exclusion (e.g., France). Liberal tradition emphasizes that religion is a matter of the private realm, implying that when citizens enter the public realm their personal convictions should be left at the door. However, some religious traditions (e.g., Judaism, Islam, and some forms of Christianity including some conservative Protestant traditions) might desire to bring their visions of good life into the political sphere and demand respect, recognition, accommodation, and representation. This is where the tension arises for the liberal state. Some have argued that the liberal state is ill equipped to meet the demands of faith groups except labeling such demands as illegitimate, illiberal, or extremist (e.g., Fish, 2010; Milbank, 2010), whereas others have tried to address issues concerning minority faith groups within the liberal philosophy of cultural diversity (e.g., Miller, 1995 and 2021; Tamir, 1993). 2 Still, liberal tradition overlooks the transnational dimensions of religious diversity, identities and belongings. It fails to recognize individuals/communities whose religious connections, practices, authorities, belongings, etc. not necessarily confined to the territory of their settled country but embedded in transnational social fields (see below). A liberal conception of religion and how it should relate to the state, 3 thus, has been only partially addressed, specifically in the context of transnational religious diversity.
As with liberals, multiculturalists have also culturalized and/or ethnicized religion. However, multiculturalism, specifically the Bristol School of Multiculturalism (BSM) (Levey, 2019; Uberoi and Modood, 2019), has provided a necessary but insufficient corrective to the liberal predicaments by emphasizing multicultural citizenship, multiculturalized secularism, and the recognition of religion as a public good. Despite its robust engagement with issues of recognition, identity and belonging, the BSM also overlooks religious identities and belongings that are not confined to national boundaries. Both liberal secularists’ and BSM’s neglect of transnational dimensions of religious diversity undermines their ability to address lived realities of cross-nationally connected religious communities.
Religion is inherently transnational. Post-war religious diversity is no longer, if ever, containable within the boundaries of a single nation-state. Accommodating religious diversity, therefore, is not only about domestic struggle for recognition but also transnational religious identities, engagements and attachments that shape contemporary religious minority subjectivities. Transnational religious diversity refers to religious plurality as constituted through cross-border religious institutions, practices, and belongings that go beyond the boundaries of the nation-state. It involves in and operates through (1) institutions and authorities (e.g. overseas-trained imams, transnational religious bureaucracies such as Turkiye’s Diyanet issuing Friday sermons), (2) practices and networks (e.g. diverging moonsighting practices for Ramadan/Eid, participation in religious networks such as the Deobandi tradition), (3) legal-political infrastructures (e.g. dual citizenship or counter-extremism regimes shaping transnational ties and activities), (4) belonging and affective attachments (e.g. identification with a global ummah, solidarities with co-religionists), and (5) digital mediation (e.g. cross-border religious guidance from scholars “elsewhere”, online sermons and fatwas).
Taken together, these clearly challenge the underlying theoretical assumptions, of both liberal secularisms and the BSM models of accommodation, that religious diversity can be recognized and governed within nationally bound political space. Drawing on the growing field of transnationalism studies, this paper argues that there is a need for conceptual shift in religious diversity studies and that theories on the accommodation of religious diversity must include the transnational dynamics present/inherent in the experiences of religious minorities. In doing so, it contributes to the existing scholarship not simply highlighting transnational religious practices but more importantly showing how normative frameworks of accommodation (i.e. liberal secularism and the BSM) operate strictly within the nation-state framework (even though, for example, affirms dual citizenship rights). The paper, therefore, brings transnational religion into direct conversation with political theory debates on recognition, secularism and governance, instead of treating it merely as a sociological phenomenon.
The paper is divided into three parts. The first part discusses liberal and multiculturalist theories of the accommodation of the religious diversity, secularism, establishment, and public role of religion. The second part discusses the possibility of a “transnational turn” in religious diversity studies, highlighting some of the shortcomings of liberal secularisms and multiculturalism and emphasizing the necessity of re-framing religious diversity beyond the nation-state. The third part discusses the importance of transnational identities and belongings. The Conclusion sums up the discussion.
Liberal secularisms and the BSM: Religion in public life and the accommodation of religious diversity
Liberal secularisms: Nonestablishment, minimal secularism and liberal establishment
Classical liberal thinkers such as John Locke (2010) argued that religious or spiritual issues must remain within the realm of individual space and the state must not involve itself in religious matters. Consistent with this, in the twentieth century, political philosophers like John Rawls (1971) and Jürgen Habermas (2002) argued that democratic deliberation of citizens requires them to leave their religion at the door before entering the public realm, implying that religion has no role in public life. Later, both Rawls (2005) and Habermas (2006 and 2008) revised their positions and underscored the importance of religion in democratic deliberation and public life. Rawls’ political liberalism, for example, affirms religion’s role in public life on two fundamental grounds: (1) religious freedom “is a constitutional essential and a matter of basic justice”; and (2) “constitutional essentials and principles of justice must be justifiable to all citizens by appeal to public reasons.” (Laborde, 2013: 70). Both scholars, however, insisted that a secular vocabulary must prevail for the sake of accessibility. For example, Habermas’s (2006) concept of institutional translation proviso allows citizens to use religious reasons in informal public spaces such as media and civil society yet insisted that such religious arguments must be translated into secular language when it comes to formal democratic domains such as laws and courts.
Multiculturalists such as Bhikhu Parekh (2000: 324) opposed this “secularist requirement”, arguing that “it discriminates against religious persons and violates the principle of equal citizenship.” Liberal democracies offer respect for believers, but they do so by detaching them from their distinctive faith traditions. Although the liberal state is not fully unequipped in addressing religious diversity, identities, and practices, it continuously falls into controversies (e.g., from the 1980s French headscarf and the British Rushdie Affair to 2000s Danish cartoons and the Sharia council controversies) (Dikici, 2022a). It is further challenged by minority transnational religious engagements, identities, and belongings. In the face of increasing (minority) religious demands (e.g. claims for public recognition, religious dress, or faith-based institutions) as well as transnational religion, the liberal state is inclined to reassert its secular character via restrictive policies (e.g. the prohibition of headscarf), which only deepen its predicaments regarding the role of religion in public life and the accommodation of religious diversity. The following discussion unpacks three competing liberal theories that have attempted to address the role of religion in public life and the separation of the state and religion, which are instrumental for the accommodation of religious diversity.
The first theory is called nonestablishment – which essentially refers to a strict separation between the state and religion and the idea that any form of religious establishment violates fundamental principles of liberalism (Audi, 2000; Nussbaum 2007). These principles include the following: the state must ensure religious freedom of practice, with some constraints (libertarian); the state must not privilege any religious tradition (egalitarian); and the state should hold a neutral position towards faith (neutrality) (Audi, 2011; Nussbaum, 2007, 2008). According to Martha Nussbaum (2007: 339), “liberty of conscience is incompatible with any type of religious establishment, even one that is so gentle and benign as to escape most people’s notice”, insofar as any form of establishment, be it full or symbolic, imposed or otherwise, translates into “a statement that creates an in-group and an out-group.” She (2007: 347) claims that establishment is a kind of orthodoxy “imposed on the striving of individual conscience”. Therefore, for Nussbaum, religious establishment is intrinsically illiberal and undesirable in liberal democratic systems. Other liberal theorists such as Robert Audi (1997) have also supported a robust form of nonestablishment, arguing that nonestablishment is not only a legal/constitutional necessity but also a moral imperative ensuring the liberty of all citizens.
Nevertheless, the idea that liberal democratic states can/should be neutral is problematic in the sense that they are already historically linked to a particular culture or religion, thereby it is unrealistic to expect a state to strip itself of its past (e.g. institutions, legal systems) and be fully neutral. Relying on the idea of state neutrality, the nonestablishment theory strongly advocates for a secular public realm where (transnational) religious identities are overlooked. Moreover, some people, evidently some Christians, Muslims, and Jews, desire to enter the public realm as believers and bring some of the aspects of their faiths into the public realm (e.g. religious symbols). Nonestablishment theory has no choice but to reject any such demands and yet continue to advocate democratic deliberation on the grounds of equality. Since this approach leaves no room for religious identities in the public realm it has less chance to address the new transnational religious diversity seeking recognition, respect, and accommodation.
The second liberal theory is called minimal secularism developed by Cecile Laborde. Laborde (2013: 73) argues that state support for religious practices without the endorsement of any normative good that such religious practices aim to offer, merely based on freedom of religion and equality of citizens, can be justifiable within liberal political theory. Laborde (2017) argues that the liberal state does not need a strict state-religion separation as in the USA or France, but it requires some form of secularism, more specifically, what she calls, minimal secularism. Laborde’s minimal secularism does not expel religion from the public sphere in the name of Rawlsian public reason but seeks to “disaggregate” it to develop better understanding of different dimensions and complexity of religion.
Laborde (2017: 134-135) even goes as far to argue that symbolic religious establishment may be permissible if it does not breach “basic rights of religious freedom”, is not “incompatible with public reason”, and does not impede the liberal neutrality principle. Still, Laborde (2017: 135) argues, there is a problem with the symbolic establishment “when it communicates that religious identity is a component of civic identity— of what it means to be a citizen of that state—and thereby denies civic status to those who do not endorse that identity, who are then treated as second-class citizens.” She, therefore, considers formal connections between the state and religion as problematic, arguing that religious establishment risks alienating minority religious groups. She, thus, rules out the possibility of establishment potentially being an accommodative force. Equally important, Laborde’s religion and theory of minimal secularism is confined to the borders of the liberal nation-state. Transnational dimensions of religious diversity, such as how diasporic religious minorities sustain cross-border religious connections and engagements or how global Muslim, Sikh or Hindu religious networks and movements shape identity formation and belonging, is not even peripheral to her theory.
The third liberal theory is called liberal establishment. So far, we have seen that liberal theorists either strongly oppose any form of religious establishment or tolerate it up to a point; however, David Miller (2016 and 2021), a prominent liberal theorist, has proposed a form of religious establishment constrained by liberal principles or “liberal establishment”. Relying on David Hume, who argued that “ecclesiastical establishments […] prove in the end advantageous to the political interests of society” (cited in Miller, 2021: 79), Miller contends that state support for a national church is not inherently illiberal. He (2021: 80), for example, argues that a national church can act both as a moderating force against the dark sides of religion–which can be destructive and divisive–and as a legitimate voice in public discourse, contributing to “an open society where all manner of groups holding different world views feel free to comment on public affairs.” Thus, he suggests that liberals should not simply “tolerate but positively welcome to having a particular religious institution supported by the state.” (2021: 76).
Of course, this religion is the historically prevailing religion of the majority group. Miller defends a single formal institution as the national church, and not simply what is sometimes called multi-faith establishment, where different (minority) faith groups, organizations, etc. would ideally be granted recognition. The so-called liberal establishment goes “beyond merely symbolic recognition” via offering both symbolic (e.g., displaying religious symbols in national ceremonies, funerals) and material (e.g., the maintenance of church buildings) support for the officially recognized institution. However, Miller does not say whether and/or the extent to which the same state support will be extended to minority religions–e.g., paying imam’s salaries, financing synagogues and so on–or how minority religious identities might be incorporated. Moreover, Miller’s formulation of citizenship, identity and belonging presumes the nation-state as the primary locus of belonging and recognition, hence, overlooks the importance of transnational religion, identities, and belongings. His theory of liberal establishment is not only reluctant to extend some privileges to minority faith groups but, critically, it omits transnational dimensions of minority religious groups (e.g. implications of cross-border religious connections) or the continuing influence of transnational religious actors on the lives of minorities. The assumption that identities of religious minorities are territorially contained creates a significant flaw in his theory.
The Bristol school of multiculturalism: Multicultural citizenship, multiculturalized secularism and religion as a public good
Largely based on a critique of liberalism, the BSM has offered interesting insights into the state-religion relations, the role of religion in public life and the accommodation of religious diversity in secular democracies such as the UK. Among them, the three following BSM arguments provide a necessary, but insufficient, corrective that provides a promising basis for accommodating transnational religious diversity.
The first argument suggests that instead of state neutrality and liberal egalitarianism, multicultural citizenship should be prioritized as a normative basis, for which the presence of some forms of connections between the state and religion does not constitute a normative problem, on the contrary, such connections are compatible with liberal democracy and can help to address the multicultural challenge (i.e. post-war religious diversity). Unlike liberal theorists who focus on state-religion separation, BSM scholars (e.g. Modood, 2019; Modood and Sealy, 2021; Parekh, 2019) focus on strengthening multicultural citizenship that allows minorities to be able to participate in public life with their own identities, including religious identities. It is key for the BSM that religious identities are not viewed as less important or distinctively controversial. Modood (2019: 186) writes that “any political norm that excludes religious identities from the public space, from schools and universities, from politics and nationhood […] is incompatible with multicultural citizenship; and if religious identities face this kind of exclusion but not identities based on race, ethnicity, gender and so on, then there is a bias against religious identity and a failure to practice equality between identities or identity groups.”
The second argument emphasizes that multiculturalizing secularism, where religious establishment may be an integral part, can be a way forward in incorporating religious diversity as well as giving religion greater voice in public deliberation. BSM scholars have been strong proponents of positive engagement with religion in public and political life (Meer, 2010; Modood, 2013, 2019; Parekh, 2000, 2019). Parekh (2019: 216) writes that instead of excluding religion, we should give religion “a respectable but non-hegemonic place in political life and make it a responsible and disciplined partner in a generously designed secular political order.” Obviously, opposing rigid state-religion boundaries, radical secularist frameworks or welcoming positive relations between the two or engaging with religious pluralism are not uniquely multiculturalist ideas (e.g. see Smart, 1996). The BSM, however, offers a conceptual framework, namely multiculturalized secularism, that lays the ground for such a positive engagement with religion and religious establishment (Dikici, Modood and Sealy, 2026; Modood, 2017, 2019; Modood and Sealy, 2021; Parekh, 2019).
Multiculturalized secularism is defined as a form of secular governance that goes beyond liberal individualist and neutralist frameworks/conceptions of religion with the aim of actively accommodating “ethno-religious” identities into the shared national identity as part of the broader multicultural equality project (Modood and Sealy, 2021). It challenges the traditional liberal model by recognizing that religious identity is not simply a matter of individual conscience but of collective cultural belonging, hence affirms a public role for religion in pluralistic democracies. Multiculturalized secularism refers to a pluralirizing process that “adds to the national culture by not disestablishing the national church but bringing other faiths into relationship with it; by not taking religion out of schools but ensuring that commonality and diversity are both accommodated; by not emphasising a particular national religious identity that sees minority faiths as ‘other’ but developing an inclusive multicultural and multi-faith national identity” (Modood and Sealy, 2024: 141).
And the third argument proposes to consider religion as a public good, which will help mitigate secular bias and institutionalize religious pluralism. Unlike some of the liberal theorists such as Nussbaum and Audi, who essentially consider religion as part of the problem and religious establishment as an inherently alienating institution, BSM scholars consider religion as a public good, specifically emphasizing social services offered by the Church of England as well as it is being a voice for religion in public life in general. Modood (2022: 218-219), for example, writes that religion is not simply a private good for individuals or a source of harm, e.g. fostering division or conflict, it is a public good, generating wider benefits for the whole society, including “being social partners with the state in the delivery of education, health, and caring services.” Churches and faith communities, for example, support Trussell, which has run most of the food banks in the UK since the early 2000s, by running/supporting foodbanks, providing donations and volunteers and campaigning against food insecurity across the UK. 4
In sum, the BSM not just challenges liberal assumptions about, e.g., state neutrality, but also provides useful conceptual frameworks such as multiculturalized secularism that can help institutionalizing religious diversity. While the BSM effectively criticizes the limitations of liberal secularisms and offers a necessary corrective, its concentration on the national context creates an important blind spot insofar as religion is inherently transnational and that religious diversity is no longer, if ever, bound by national borders. The next part further discusses this blind spot, highlighting the importance of transnationalism and the necessity of a conceptual shift in religious diversity studies.
Re-framing religious diversity beyond the nation-state: Transnational religious diversity
Liberal secularisms’ and the BSM’s focus on the nation-state as the primary framework of identity and belonging obscures how religious communities operate within “transnational social fields” (Levitt and Glick Schiller, 2004). Without an explicit account of transnational religion, they risk misrecognizing minority religious identities and belongings as primarily nationally bound. Religious identity of Muslims across Europe, for example, is not only shaped by local/national contexts and dialogue but also by transnational religious actors (e.g., Turkish Directorate of Religious Affairs (Diyanet)’s oversight of thousands of mosques across Europe and beyond), transnational engagements (such as civic/political participation in the settled and origin countries simultaneously), participation in transnational solidarity activities (e.g. advocacy for Uighurs/Palestine causes) and a sense of transnational belonging (e.g. multiple, intersecting belongings) (Adamson, 2018; Dikici, 2021a, 2021b; Kaya and Drhimeur, 2022; Waldinger and Shams, 2023).
Overlooking these dynamics reflects methodological nationalism—the tendency to treat the nation-state as the natural unit of analysis (Wimmer and Glick Schiller, 2003). Studies on religious diversity (including liberal secularist and multiculturalist) must avoid methodological nationalism by considering cross-border phenomena as religion is inherently transnational. Research, for example, shows that religious identity among Muslim diasporas is not confined to the borders of a single nation-state (Birt, 2005; McLoughlin, 2010). Transnational state and non-state actors such as the Turkish Diyanet maintain institutional, doctrinal, and emotional ties with Turkiye, influencing religious education, civic engagement, and identity making processes of Turkish-speaking people in the UK (Dikici, 2021b). These networks do not operate merely in parallel to national frameworks of recognition but actively shape how individuals relate to institutions and policies.
In this regard, liberal secularisms and the BSM operate within a methodological nationalism that limits their conceptual reach. By taking the host nation as the only frame of normative reasoning, they risk under-theorizing the role of homeland politics, transnational networks, specifically religious movements, which significantly impact diasporic religiosity (Cesari, 2017). Transnationalism is not simply an empirical condition but a structural feature of the lives of contemporary religious minorities (i.e. Muslims) living in secular liberal democracies, and this requires theoretical accommodation.
Transnational turn in religious diversity studies
Scholars of transnationalism have demonstrated the diverse and complex ways people (e.g. minorities) traverse national borders to engage in a wide array of social, cultural, economic, political, and religious activities (Levitt, 2003; Levitt and Glick Schiller, 2004; Vertovec, 2009; Waldinger, 2013). Any attempt to understand and frame post-war (religious) minority groups, identities and belongings, would be incomplete without a transnational perspective. A transnational perspective encourages and enables looking at dynamics beyond the borders of the nation-state, in doing so facilitates a comprehensive view of the lived realities of minority communities (e.g. continued influence of the origin country on their lives).
The study of religious diversity, thus, requires a conceptual shift with the emergence of the “transnational turn” –a conceptual reorientation that challenges the nation-state framework that long dominated social sciences (Glick Schiller, Basch and Blanc, 1995; Waldinger and Shams, 2023). This conceptual shift can facilitate a better understanding of the fact that religious identities, engagements and institutions increasingly operate across national borders, creating complex networks and communities that are not confined to territorially bounded frameworks of governance and belonging. Unlike the liberal and multiculturalist traditions, which have undertheorized cross-border phenomena, transnational perspectives reveal how religious actors actively sustain “multidirectional connections” that transform both sending and receiving contexts simultaneously. As Levitt (2004: n.p.) observes, “The assumption that people will live their lives in one place, according to one set of national and cultural norms, in countries with impermeable national borders, no longer holds. Rather, in the 21st century, more and more people will belong to two or more societies at the same time”. This simultaneity of belonging constitutes one of the core challenges for theories of secularism and the accommodation of religious diversity.
Liberal theories such as nonestablishment, minimal secularism, and liberal establishment as well as the BSM’s multicultural citizenship and multiculturalized secularism work strictly within a geographically defined polity. These theories emphasize governing (religious) diversity within the nation-state, presupposing that identity formation, belonging and religious connections and engagements are all limited to receiving society. Transnationalism studies challenge this assumption at its core, calling for a “transnational turn” in diversity studies, highlighting the enduring relevance and influence of sending-states, supranational entities, non-governmental networks and so on (Dikici, 2021b). Thus, this paper suggests modifying the promising concept of multiculturalized secularism so that it no longer merely relies on a strict nation-state framework of recognition and recognizes that religious identities, solidarities, belongings, etc. are multi-scalar and transnational, with implications for how nation states engage with religious communities.
Levitt and Glick Schiller (2004) argue that immigrants are embedded in “transnational social fields”, which refers to multi-layered networks of relationships through which ideas, practices, resources, and identities circulate across national borders. Within these social fields, Levitt (2004) distinguishes between ways of being (participation in cross-border practices) and ways of belonging (deliberate identification with transnational communities), which is an important differentiation for understanding transnational religion where individuals may engage in practices without strong identification or vice versa. Research indicates that minorities are embedded in transnational social fields where experiences, identities, and belongings are shaped by sustained ties and engagements with multiple locations (Levitt, 2007; Nielsen and Otterbeck, 2016; Nordin and Otterbeck, 2023; Pasura, 2022). These ties and engagements, which can be real or imagined, are not residual but continuously re-built and sustained, challenging the nation-state’s ability to monopolize identity-formation and belonging (Waldinger and Fitzgerald, 2004). Thus, we need to focus on accommodating “transnational religious diversity” not simply “religious diversity”.
Sikh religious life, for example, is organized through transnational networks linking diaspora in the UK with religious institutions in Punjab, with gurdwaras operating as both local places of worship and hubs for transnational religious authority, charity, and political mobilization (Tatla 2013; Thandi, 2013). Hindu transnationalism likewise operates through global temple networks, spiritual movements, and digital infrastructures that connect diaspora to India. Organizations such as the Swaminarayan movement exemplify how Hindu religious practices, leadership, and moral authority move transnationally, shaping diasporic religious identities (Williams, 2016). Muslim communities across Europe, similarly, often work within dense networks of religious scholars, institutions, educational materials, and media (Allievi and Nielsen, 2003). Religious practices and interpretations at a local mosque in London can be informed or shaped by religious debates in Pakistan, Saudi Arabia, and Egypt, or by transnational religious movements like Deobandi, Tablighi Jamaat, Jamaa-t-e Islami, or Salafists (see Birt and Lewis, 2011). Therefore, transnational connections and engagements of Muslims across different countries and cultures cannot be ignored when framing the accommodation of Muslims. Such connections create transnational religious spaces where national borders have limited meaning. For example, Birth and Lewis (2011) demonstrate how Deobandi networks in the UK are embedded not just in British social-political contexts and multicultural policies but also strongly involved in South Asian Deobandi religious networks shaping religious identities and religiosity. State efforts to domesticate Islam through engaging solely with local representative bodies often fail to capture the complex, overlapping, and sometimes conflicting transnational sources of authority and legitimacy (Dikici, 2022a; Sunier, 2024).
One example demonstrating how domestication efforts have failed in capturing the transnational character of Muslim religious life in the UK relates how Muslims determine religious calendar. The beginning of Ramadan and Eid depends on the sighting of the lunar crescent, and this has been a matter of contestation in the UK (and globally) as Muslims do not follow a single, national calendar. Some Muslims follow the local calendar (or moon sighting), while majority follow either dates announced by Saudi Arabia or their country of origin (e.g. Pakistan, Morocco, Turkiye) (Bowen, 2012). 5
Similarly, transnational networks are reflected in religious authority and mosque affiliation. Scholars trained overseas are considered authoritative when they return to the UK, and mosques and seminaries affiliated with Deobandi maintain doctrinal and curricular ties to South Asian centres like Darul Uloom Deoband. 6 With its European centre in Dewsbury, the Tablighi Jamaat connects British mosques to a larger network of missionaries and authorities throughout the Middle East, Europe, and South Asia. Local practices of Muslims are also influenced by state-linked networks: Turkiye’s Diyanet provides Friday sermons straight from Turkiye and sends imams to mosques across Europe, ensuring that religious instruction and guidance are aligned with the ones in Turkiye (Carol and Hofheinz, 2022).
In sum, insofar as religion is intrinsically transnational, maintaining connections across borders or developing multiple belongings is inevitable for members of religious communities. Therefore, theories on the accommodation of religious diversity must consider key transnational dimensions of diversity such as transnational identities and belongings, which is the subject of the next part.
Transnational religious identities and belongings
Transnational identities and recognition
BSM rightly empahsizes that religious identity demands recognition within national frameworks (Modood, 2019; Parekh, 2019). However, its model assumes identities emerge primarily through domestic/national dialogue, ignoring how religious identities and belongings are shaped transnationally. For Muslims across Europe, origin countries’ diaspora engagement policies and practices, transnational religious networks, individual and group transnational religious practices and engagements (e.g. pilgrimage, relief works), diasporic solidarity activities (e.g. supporting Palestine) and digital religious spaces (e.g. fatwa platforms) sustain religious identities irreducible to local/national identities (Dikici, 2021b).
Research has long demonstrated, for example, that young generations of Muslims in Europe tend to blend local civic values with transnational Sunni identity, challenging both assimilationist and national models of integration (Østergaard-Nielsen, 2003), and that Muslim identities in Europe are often constructed and negotiated within transnational frameworks (Kaya and Drhimeur, 2022; Rosenow-Williams, 2012). These frameworks are informed by transnational religious movements, political dynamics from their homelands, and global Islamic discourses as well as connections to local communities. For example, Turkish Islamic organizations across Europe are strongly tied to civic, political, and religious networks based in Turkiye, such as the Diyanet or Suleymanli community (Sunier and Landman, 2015). Such border-crossing connections and sources of religious authority influence how community members understand and practice their religion and continuously shape their sense of religious identity and belonging.
Multiple identities developed by minority communities are rather multi-scalar. “British Muslim” identity, for example, is not solely developed within the boundaries of the UK. While “Britishness” is mainly understood, negotiated, accepted or challenged within the UK context, “Muslimness” is shaped by connections to the origin country (e.g. Pakistan) and negotiated in transnational social fields as well as within the context of the settled country. A study by Kapinga et al. (2022) shows how “places beyond the UK” (i.e. Pakistan and Bangladesh) shape some young British-born Muslims’ religious identity and belonging. Kapinga et al. (2022) argue that for UK-born young Pakistani and Bangladeshi British Muslims, “being Muslim” is not just influenced by local/national experiences but also simultaneously influenced by parental homeland, cultural heritage, pilgrimage destinations, and so forth. Thus, religious identity transcends mere local minority engagements or recognition within the host society; it is deeply embedded in a complex web of transnational relationships that shape both individual and collective identities.
This is also supported by the rich scholarship on global Islam. Roy (2004), for example, observes the “individualization” and “de-territorialization” of Islam, where young Muslims forge religious subjectivities in digital and diasporic spaces that transcend the nation-state. Mandaville (2001) similarly observes that the political agency of Muslims in diaspora is shaped by “translocal” modes of belonging, shaped as much by media flows and homeland engagement as by domestic policies. These insights complicate the nation-state-centric frameworks (such as liberal secularisms and the BSM), which largely assume that struggles for recognition exclusively occur within nationally bound public spaces.
While BSM’s analytical framework pays attention to the struggles for recognition by marginalized groups, it remains exclusively focused on the national context. Its primary concern is how minorities—often racialized or religiously identified—can be recognized as full and equal citizens within liberal democracies such as the UK. Although valuable, it is inherently limited. It risks essentializing minority identities as contained within the nation-state, overlooking how these identities are constantly reshaped by transnational flows of people, ideas, practices, and institutions. BSM’s nationally bound “recognition” framework, therefore, cannot fully capture layered identifications.
In sum, the BSM’s commitment to navigating the complexity of pluralism, its defense of inclusive nationalism (Modood, 2019), and its openness to state-supported religion (Modood and Sealy, 2021) are critical correctives to liberal secularisms. However, to avoid methodological nationalism, pathologizing legitimate transnational engagements (e.g. solidarities) and to remain relevant in an era of transnational religion, the BSM must develop a clearer account of how transnational religious formations interact with national models of diversity governance.
Transnational belongings
A key part of multicultural citizenship as re-defined by the BSM is belonging-in-the-nation, a sense of attachment to the national community (Modood, 2019). This overlooks the fact that religious minorities develop cross-border belongings through, e.g., civic and political engagements “here”, “there”, and “elsewhere” simultaneously (Dikici, 2021b; Shams, 2020). National belonging exists alongside and influenced by other types of belongings such as nonterritorial belonging (Kastoryano, 2025) or what we can call transnational belonging. The idea of transnational belonging refers to multiple belongings individuals and communities develop that span cultures and borders. These belongings manifest themselves in different ways, including, for example, a sense of attachment to the imagined global communities such as the Muslim ummah, emotional ties to their country of origin, a sense of belonging to a transnational religious network, and political participation in the origin country as well as a sense of attachment to their country of settlement and/or city. Therefore, insistence on “national” belonging alone as a kind of supreme principle may pathologize legitimate transnational solidarities as, for example, deficit of integration into the settled country. On the contrary, transnationalism is not a threat to integration but a constitutive part of Muslim religious and ethical subjectivity potentially facilitating integration (Dikici, 2021b).
Transnational connections, engagements, and belongings are enabled and sustained by various actors including immigration sending and receiving states and transnational religious movements and solidarity networks. These actors essentially facilitate and/or shape transnational social spaces. For example, such spaces are shaped by immigration-sending countries, which seek to generate benefits (e.g. transfer of finances, technologies and “know how”) and influence (e.g. diaspora governance). Many Muslims often connect with their countries of origin through various origin country institutional networks such as the Turkish Diyanet or Moroccon Makhzen. Such institutional networks not only offer community support, religious guidance, and cultural resources to help people in diaspora to stay connected to their origin culture, religion, etc. but also acts as a religious authority to strengthen cultural and spiritual bonds between co-nationals living abroad and their homeland (Bruce, 2019).
Immigration-receiving states have also facilitated, deliberately or otherwise, transnational social spaces by embracing dual citizenship practices. As Figure 1 indicates, while 20% of countries were affirming dual citizenship in 1960, as of 2024, 51% of countries, including most of the Western European countries such as France, Germany, the Netherlands and the UK, allow dual citizenship (see Vink et al., 2025). Dual citizenship in the world from 1960 to 2024 (in 191 countries).
Dual citizenship functions as a legal infrastructure for transnational ties, engagements, and activities as much as a catalyst for transnational identities and belongings. Dual citizenship can be considered as a formal recognition of transnational belongings. Dual citizenship has various benefits for the host and origin countries as well as individuals holding dual citizenship rights. Among them, its contribution to integration into the settled country has been specifically underlined in recent scholarship. It is argued that while restricting dual citizenship rights (e.g. not permitting it or making it conditional) hinder immigrant integration, as observed in Denmark (Midtbøen, 2015), Germany (Weinmann, 2021) and some Scandinavian countries (Jensen et al., 2017), affirming dual citizenship encourages immigrants to proactively participate in naturalization programmes and integrate into the settled country (Aker, 2019; Bevelander and Spång, 2014; Huddleston and Falcke, 2019; Dikici, 2025). In short, research suggests that whilst restricting dual citizenship impedes minority integration and naturalization processes, more permissive policies are likely to promote inclusion and belonging in both contexts.
Although dual citizenship facilitates transnational ties, activities, and belongings it does not necessarily resolve the puzzle that liberal secular and multicultural frameworks maintain conceptualizing religion, recognition, belonging, and accommodation within the nation-state framework–hence suffer from methodological nationalism. Dual citizenship rights co-exist with alongside regulatory and discursive practices that still aim to domesticate religion and pathologize transnational belonging.
Finally, transnational solidarity activities and networks further underpin transnational belongings. For example, transnational Muslim solidarity practices reveal the increasingly cross-border nature of Muslim belonging. Muslim communities across Europe (and beyond) engage in transnational political solidarity particularly with Palestinians, Kashmiris, and Uighurs, often through mass mobilizations, online (e.g. social media) campaigns, boycott movements, and public protest. A recent example is solidarity activism with Palestinians in Gaza. Muslims’ mass protests of the Gaza genocide or boycotts targeted at companies, such as Starbucks and McDonalds, that are believed to be supporting the genocide, 7 reflect both expressions of ethical/political protests and embeddedness of shared transnational religious imaginaries. As Kastoryano (2025: 4) observes, in their efforts to re-define identities to get recognition before nation-states and institutions, cultural, ethnic, and religious groups “rely increasingly on transnational solidarities expressing common identification, a sense of belonging to a constructed unity beyond nation-states”.
Such solidarity activities are often organized or supported by various transnational networks. Project Ummah, 8 for example, is a digital platform that tracks and publishes lists of companies, institutions, and brands with direct or indirect ties to Israeli state violence in Palestine, informing Muslims and activists globally. It functions simultaneously as a real-time boycott tool and a transnational solidarity network. Similarly, dozens of transnational Muslim relief networks, including Islamic Relief Worldwide, Muslim Aid, and Human Appeal, provide humanitarian aid in crisis zones like Gaza, Syria, and Rohingya camps. In doing so, they also sustain transnational social spaces, consolidate solidarity activities, and a sense of belonging among Muslims living across different national borders.
At the same time, Muslims living in Europe maintain integrating into and develop a sense of belonging in their countries of settlement. According to Muslim Council of Britain (MCB) (2025), for example, “94% of British-born Muslims in England and Wales have a strong sense of British identity.” This indicates that British Muslims cand develop and manifest multiple belongings simultaneously. They, however, face unique challenges as they try to negotiate their identities and belongings sometimes due to transnational factors. Some Muslims, as just mentioned, may feel a deep responsibility that goes beyond borders, urging them to engage with issues impacting their homeland or fellow Muslims experiencing hardships (e.g. in Gaza) or simply be part of the global Muslim community, which shares common beliefs, while at the same time contribute to the well-being of their country of settlement and engage with their fellow co-citizens and become an equal part of the wider society.
Overall, understanding these complex dynamics (and tensions) is vital for accommodating transnational religious diversity. Adopting a transnational perspective is not a set-back for national identity or inclusivity or respect for diversity, contrary it strengthens the BSM by recognizing identities, belonging as well as practice and authority are constituted across national borders. This modification enables the BSM to distinguish legitimate transnational religious life from problematic forms of exclusion rather than misrecognizing such ties as failures of integration. Theories on the accommodation of religious diversity must evolve beyond methodological nationalism to engage the transnational dimensions of religion and religious communities.
Conclusion
The accommodation of the new transnational religious diversity has been a potent challenge for secular liberal democracies. These groups seek recognition, respect and representation, and express a desire to bring some aspects of their faiths into the secular public space. To address such claims, liberal secularists have developed different responses that either overlook religious identities (nonestablishment) or approve a strictly limited space for religion in public life (minimal secularism) or unwilling to extend the same state support for minority faith groups that is granted to the historical/majority religious group (liberal establishment). This is where the BSM, as a tradition of thinking centered on equality and struggle for recognition, offers a necessary but insufficient corrective. The multiculturalist approach shows that the accommodation of religious diversity can best be addressed within the context of multicultural citizenship, not liberal egalitarianism or state neutrality. It illustrates that the presence of some forms of connections between the state and religion does not constitute a normative conundrum; multiculturalized secularism, where religious establishment may be an integral part, can play a facilitative role, thereby, it should not be automatically regarded as an alienating actor; and religion should not be regarded as a source of division, it can be a public good by producing public services such as education and contributing to national democratic deliberation.
While the BSM offers a necessary corrective to secular liberalisms, both traditions operate within methodological nationalism, that is, they neglect transnational religion, framing citizenship, identity and belonging strictly within a nation-state framework. Drawing on transnationalism studies, this paper argues that theories on the accommodation of religious diversity must include the transnational dynamics present/inherent in the experiences of religious minorities. Accommodating transnational religious diversity, then, inevitably requires us to consider transnational religious identities and belongings as well as mechanisms that facilitate cross-border experiences such as dual citizenship. Overall, a more comprehensive multiculturalist account that incorporates a transnational perspective is needed both to provide a more contextually grounded understanding of transnational religious diversity and the accommodation of religious identities and belongings.
Footnotes
Acknowledgements
I would like to thank Pier Luc-Dupont, Thomas Sealy, and three anonymous reviewers for their insightful comments on earlier versions of this paper.
Funding
The authors disclosed receipt of the following financial support for the research, authorship, and/or publication of this article: This work was supported by the University of the West of England; UHSW100. The author is grateful for the UWE Bristol for the New Starter and VC ECR awards, which provided the necessary time and resources to complete this work.
Declaration of conflicting interests
The authors declared no potential conflicts of interest with respect to the research, authorship, and/ or publication of this article.
Data Availability Statement
Data sharing not applicable to this article as no datasets were generated or analyzed during the current study.
