Toward a Theoretical Framework for the Critical Study of EU Roma Policy Processes

Over the past fifteen years, under the influence of the EU Roma Strategic Frameworks for 2010–2020 and subsequently 2020–2030, a complex, multi-layered governance structure has developed around policies concerning the diverse communities summarized under the umbrella term “Roma.” This structure involves EU institutions, national governments, administrative bodies, and civil society organizations, supported by various coordination mechanisms. While the EU Roma Strategic Frameworks represent a unique and ambitious attempt at coordinated action to improve the situation of marginalized Roma communities across the EU, persistent shortcomings remain. These include limited meaningful participation of Roma communities in the policy process, insufficient political commitment, and the continued presence of widespread and largely unchallenged antiziganism. Overall, no significant improvement attributable to the strategic frameworks can be observed. Research on Roma policies — particularly from Critical Romani Studies — has closely linked these failures to the social construction of Roma as a target group and to systematic exclusions from policy processes. This conceptual paper elaborates a theoretical framework for analyzing the EU Roma policy process through a critical lens, drawing on the literature review and theoretical foundations of my PhD project. It brings together insights from Critical Policy Studies, Policy Design and Social Construction Theory, and Policy Network Analysis to conceptualize Roma policy as a process shaped by power relations in network interactions. Centering Roma participation as both an analytical and normative concern, the paper focusses on the actors involved in the policy process and their influence on Roma inclusion or marginalization rather than policy outcomes as such. The paper advances two interrelated analytical propositions. First, it examines National Roma Contact Points (NRCPs) as institutionalized coordination actors embedded within state administrations. While NRCPs are formally mandated to ensure vertical and horizontal coordination, monitoring, and Roma participation, successive evaluations point to limited authority, uneven resources, and weak connections to local governance structures and Roma communities. Conceptually, NRCPs occupy an ambiguous position within the EU Roma policy process: they may function as bridges between governance levels but are rarely powerful enough to significantly influence policy processes and may even operate as gatekeepers that filter participation and stabilize existing power asymmetries. Second, the paper examines cities and transnational city networks as non-institutionalized but increasingly influential actors in the Roma policy field. As cities are primary sites of policy implementation, city networks have the potential to link interest representation, advocacy, and knowledge production more closely to local realities. At the same time, from a critical perspective, their role raises open questions of representation, particularly regarding whether they facilitate participatory and context-sensitive policy processes or reproduce existing exclusions by privileging administrative and expert voices over Roma self-representation. By juxtaposing NRCPs and transnational city networks, the paper treats their roles as open empirical and theoretical questions. Its main contribution lies in outlining a Critical Roma Policy Process Research agenda, proposing analytical tools for critically examining participation, power, and representation across governance levels within EU Roma policy.