Micro-Foundations of Street-Level Policy Entrepreneurship in Migration Governance

Street-level policy entrepreneurship relates to how frontline officials shape policy beyond implementation, yet existing research largely examines narrow case studies in service-oriented settings and offers limited insight into why some street-level bureaucrats engage in such behaviour while others, operating under similar institutional conditions and externalities, do not. This article investigates the triggers and drivers of street-level policy entrepreneurship in Dutch migration governance, constituting a critical less-likely context characterised by legal density, strictly framed formal discretion, and political salience. The study is guided by the question: How do street-level bureaucrats in migration governance come to engage or refrain from engaging in policy entrepreneurship? Theoretically, it bridges two strands of literature that remain insufficiently connected: street-level bureaucracy, which emphasises constraint-driven coping and moral dilemmas, and policy entrepreneurship, which conceptualises entrepreneurial action as opportunity-driven and strategic. While the street-level policy entrepreneurship literature points out that crises, knowledge gaps, or demands for innovation trigger entrepreneurial engagement, this paper argues that such conditions by themselves are insufficient to explain variation in behaviour in highly regulated policy domains. Empirically, the paper draws on interpretive process-tracing and semi-structured interviews with three groups of street-level migration officials, at the Immigration and Naturalisation Service (IND), the Repatriation and Departure Service (DT&V), and the Central Agency for the Reception of Asylum Seekers (COA), supplemented by interviews with NGO representatives and policymakers. Comparing these three positions allows for the comparison of contrasting law-enforcement and service-provider roles. The interpretive approach enables reconstruction of the sense-making processes through which actors interpret discretion, roles, and moral responsibility, and through which different behavioural pathways unfold. The findings show that entrepreneurial engagement does not follow linearly from levels of formal discretion, implementation crises, or opportunity structures. Opportunity-seeking behaviour, commonly emphasised in policy entrepreneurship research, is systematically dampened in Dutch migration governance. Law-enforcement role perceptions and extensive institutionalised feedback mechanisms channel innovation into formalised, incremental routines, thereby discouraging informal or opportunistic strategies typically associated with policy windows and entrepreneurship. Crises and knowledge gaps are widely recognised but tend to reinforce compliance and coping rather than trigger entrepreneurial action. Instead, street-level policy entrepreneurship is triggered when discretion is perceived as constraining and framed as morally problematic. This perception constitutes an activation point that initiates divergent interpretive mechanisms. Depending on how actors interpret their role and moral responsibility, these mechanisms may lead to entrepreneurial engagement, but also to compliance and paralysis. Moral sense-making and role interpretation function as key drivers that shape whether perceived constraint is accepted as a legitimate boundary or transformed into motivation for policy-shaping action. By reconceptualising discretion as an interpretive trigger rather than a linear enabling resource, the paper advances understanding of the micro-foundations of street-level policy entrepreneurship and explains why entrepreneurial action emerges selectively and unevenly in restrictive governance contexts. More broadly, the study contributes to debates on frontline agency, refrains from success bias by accounting for non-entrepreneurial outcomes, and highlights the importance of role perceptions and moral reasoning in politically sensitive policy domains such as migration governance.