Two kinds of parliamentary democracy and federalism – Canada and Germany compared

Canada and Germany represent two of the federations where the federal system is combined with a parliamentary democracy. As has been noted in comparative research, both cases differ in the pattern of federalism. In Germany, the constitutions requires federal and Länder governments to make joint decisions in significant policy fields, whereas in Canada, federal and provincial governments are autonomous and coordinate their policies at best in voluntary negotiations. What has been neglected in comparative research is the difference in parliamentary democracy. In Germany, the election system usually generates coalition governments. The Canadian first-past-the-post system creates one-party governments, either ruling with a majority or as minority governments. As a consequence, the Canadian parliamentary system strengthens the executive, which can use its power to conclude intergovernmental agreements. However, these agreements are subject to veto power of sovereign parliaments. Since they are based on voluntary negotiations, parliamentary vetoes do not cause a stalemate in policy-making. They either trigger opt outs of individual provinces or renegotiation. Variations in intergovernmental relations and changes in government induce policy change, although joint decisions required to change the federal constitution or to manage interdependence between all provinces (climate change policy, internal trade regulation, standards of social policy) are difficult to achieve. Parliamentary democracy and federalism are loosely coupled and balanced in mutual adjustment over time. In Germany, intergovernmental negotiations and coalition governments are tightly linked, with the consequence that in both arenas compatible compromises need to be settled. Accordingly, significant policy innovation is unlikely while incremental change prevails. Exits from deadlocks can be found in external arenas like expert councils or the constitutional court, i.e. beyond federalism and democracy.