24 R. Bauböck such conditions, why could EU citizens still claim national voting rights without applying first for citizenship? One could object to my proposal that it is not realistic that European states will reform their citizenship laws along these lines. But is it really more realistic that they will waive the condition of naturalisation for one large group of migrants altogether? And what if they were forced to do so by some daring judgment of the Court of Justice of the European Union? Would member states then not react by raising even higher the hurdles for naturalisation, which would in turn mean that fewer migrants get access to EU citizenship in the first place? If for these normative and pragmatic reasons voting rights in countries of immigration remain attached to citizenship status, what can we then do about the democratic deficit? The obvious answer is: make sure that EU citizens who move to another member state do not lose their voting rights in national elections in their countries of origin. In fact, most EU states do allow their expatriates to vote in national elections. The regulations are, however, very different. Ireland still does not grant an external franchise. The Greek constitution guarantees voting rights to Greeks living abroad, but the Greek parliament has never adopted the implementing legislation. Britain withdraws voting rights after fifteen years of residence outside the country. Italy allows those born abroad who have inherited their citizenship from Italian ancestors to vote in Italian elections but not those who have kept their residence in Italy and are merely temporarily absent on election day. Conversely, Denmark has a residence requirement for voting, but has successively extended the franchise to state employees, employees of private Danish companies, Danes working for international organisations, Danish students and others living abroad for health reasons as well as to their Danish spouses, as long as they are presumed to be only temporarily absent. By contrast, Belgium has mandatory voting and applies this duty even to Belgium citizens living abroad, although they are not forced to register as voters. In its judgement in the 2010 Rottmann case1 the Court of Justice of the EU has asserted that member states have to take EU law into account when a decision to withdraw nationality implies a loss of EU citizenship. Should 1 See the EUDO CITIZENSHIP Forum Debate: Shaw, J. (ed.) (2011), ‘Has the European Court of Justice Challenged Member State Sovereignty in Nationality Law?’, Robert Schuman Centre for Advanced Studies, EUDO Citizenship Observatory Working Paper 2011/62, Florence: European University Institute, available at http://cadmus.eui.eu/handle/1814/19654.