In May 2019, the US President Donald Trump gave a speech in which he outlined a possible extensive overhaul of the US immigration system. This push towards a new approach started a national conversation about what it means to have a “merit-based” immigration system. A particularly controversial suggestion was a requirement for immigrants to speak English before they were accepted by US authorities.

President Trump lauded other merit-based immigration programs such as Australia or Canada as models for what a US system could look like. The “Australian Immigration Model” was also recently used as justification to improve the UK immigration system after Brexit. These models are also known as points-based immigration systems.

Unfortunately, too often national conversations about merit-based immigration systems are rife with overly broad generalizations and misinformation about how these systems work and what they actually mean for a society. This leads to negative attitudes towards immigration policies. Therefore, we intend to contextualize these conversation and offer a discussion of what “merit” actually means and is measured by different countries.

The four countries often taken as examples of such points-based systems are Canada, Australia, New Zealand, and the UK. The misinformation already starts here, as these countries are nowhere near the only countries who apply a points system to immigration. They just happened to be the first countries to systematically apply these criteria to immigration. Almost every country in the EU as well as numerous other countries apply some version of a points-based system.

And this is the crux of the issue, some version of a points-based system. As I will explain below, our definition of merit, represented by points, makes all the difference. Every single country claims to only accept the best and the brightest into their midst.

Defining Economic and Non-Economic Migration

The first consideration of what “merit” means usually distinguishes economic and non-economic migration from each other. While I will discuss what economic means below, it is important to mention that each country generally allows for two categories of non-economic migration, namely family reunification and humanitarian obligations.

Nations all across the world usually recognize the importance of immediate family being allowed to join a migrant for a variety of reasons, such as productivity or compassion. Further, most nations have signed international treaties which recognize legitimate refugee claimants as non-economic migrants and are obligated to accept some.

This is where the first debates in a society start. These debates are framed by a number of questions: What should immediate family be? Children, Partners, and Parents are generally accepted definitions by some countries, while other countries may extend this definition to Grandparents, Uncles/Aunts, Cousins, or other members of a family.

The second debate is usually about the distribution of economic to non-economic migrants. How many refugees should be accepted? How many extended family members? For example, the United States tends to accept a greater amount of family based migration, due to its history as a large immigrant country. Religion may also be a category considered as a non-economic immigration factor.

It remains true however, that in most countries the distribution of economic to non-economic migrants is largely in favour of economic ones. Family or Humanitarian immigration is generally low compared to economic one. For example, 2020 Canadian immigration targets allocate over two-thirds of all immigration to economic immigration. Less than a third is allocated for family and humanitarian immigration together.

What is an economic migrant?

What makes a migrant economic? The most commonly shared view of what that means usually comes from a notion of the migrant “adding” something to the country they are migrating to. Some form of value-add to the economy, or society, may classify them as an economic migrant.

What that something is, is of course heavily contested. Does a prior education add more to the country? How many years of prior work experience would be ideal? There are numerous debates to have in order to define this economic “merit”.

Balancing Economic Qualifications and Human Capital

An economic migrant is defined through two factors, their economic qualifications and a human capital factor. The balance between these two is usually what differentiates different immigration systems.

The economic qualification is the “on paper” part of the definition and encompasses a migrants formal skills: their education, work experience, desired job offer, annual income, and other factors that can easily be translated into economic terms. These qualifications tend to be highly sought after by countries and given lots of points. Everyone wants a PhD educated business man with millions of dollars in disposable income to invest in the country, because it “adds” most to the economy.

However, there is another factor that is increasingly being considered by countries such as Canada in evaluating economic immigrants, the human capital factor. Also described as “fit”, this is a method were a country attempts to admit economic migrants based on what a region or industry needs most, rather than the highest possible qualifications. Other considerations may be “adaptability” to cultural norms, or how easy it will be for an immigrant to be successful.

Canada has well documented issues with highly qualified migrants working below their qualifications, because there is little opportunity for them working in their field, or they face issues with discrimination and integration. It has also been shown that economic migrants may be more successful with a robust social network, provided by a family. Even though they may be highly educated, Canada is increasingly recognizing that “on paper” qualifications may not be enough to guarantee a successful immigration strategy. An army of doctors may be less useful than a number of migrants for jobs which are not filled by Canadians.

Discussing the difference between economic, non-economic and human capital considerations make it clear that the definition of “merit” is much more complicated than it may be assumed, and that a successful immigration strategy relies on a complicated set of factors which may go much beyond just economic qualifications. If Canada is taken as an example for a successful immigration system the question ought not to be how many points a doctor gets, but rather how to find the best fit for the system. And that may very well include successful economic immigrants which are not traditionally considered highly qualified.

So we can see that “merit” is a difficult concept to define. Therefore, we should be exceptionally careful when discussing what determines the best immigration system, points-based or otherwise.