13
Language policies as key aspect 
of migration policies: an evolving 
scenario in Europe
Lorenzo ROCCA
Società Dante Alighieri
The article focuses on the role of language policies within the broader frame-
work of migration policies in Council of Europe Member States. A description 
of the system currently in place in a representative sample of countries will 
lead to considerations related to language requirements, including the linguis-
tic dimension of the knowledge of society requirements, as well as to language 
learning opportunities, where present.
Keywords: language requirements, migrants, learning opportunities, know-
ledge of society
1 Introduction
During the past two decades, language policies for migrants within the 
Council of Europe Member States have been characterized by an os-
cillation: on one hand, it is possible to notice openings represented by 
the confirmation and sometimes strengthening of learning opportuni-
ties; on the other hand, it is impossible not to detect growing closures 
constituted by the ongoing introduction or tightening of language and 
knowledge of society (later on, KoS) requirements.
This paper begins by presenting data from two sources that aim to 
explain this phenomenon. First, the results of the latest survey by the 
Council of Europe, conducted in collaboration with ALTE (Association of 
Rocca, L.: Language policies as key aspect of migration policies: an evolving 
scenario in Europe. Slovenščina 2.0, 12(2): 13–34. 
1.01 Izvirni znanstveni članek / Original Scientific Article
DOI: https://doi.org/10.4312/slo2.0.2024.2.13-34
https://creativecommons.org/licenses/by-sa/4.0/
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Slovenščina 2.0, 2024 (2) | Articles
Language Testers in Europe) are considered. Then, the updated situa-
tion is described taking into account LAPIM, the language policy index 
for migrants (Carlsen and Rocca, 2025, in press). Finally, the discus-
sion section analyses the presented evidence, addressing its implica-
tions and offering reflections on the current scenario. 
2 The picture painted by the Council of Europe and 
ALTE survey
The survey provided a representative sample of the European frame-
work, involving 40 Member States and 41 different contexts/regions. 
Flanders and Wallonia (the Dutch-speaking and French-speaking re-
gions of Belgium, respectively) were considered as two distinct regions, 
since they have legislative autonomy regarding migration policies. 
The study was conducted in 2018, with its report published two 
years later (Rocca et al., 2020). The purpose was to offer an up-to-date 
picture of language policies related to the migration context, five years 
after the previous survey and 11 years after the first one. In this sense 
the outcomes also constituted a basis for comparison, thus providing 
an overview of policy trends from 2007 to 2018. Such a comparison 
has been possible only with regard to the language and KoS require-
ments, as the 2018 survey was the first that addressed the topic of 
learning opportunities.
2.1 Language and KoS tests
The two maps on page 15 illustrate the changes in Europe’s situation re-
garding compulsory tests between 2007 (Figure 1) and 2018 (Figure 2). 
In both figures three different colours are used: grey indicates Member 
States that did not answer to the survey, dark blue are those that stated 
they had at least one language or KoS requirement, and in light blue are 
those that do not impose any such criteria on migrants at any point. 
Comparing the presence of dark blue in the two maps, it is evi-
dent that an increasing number of countries introduced language and/
or KoS requirements as an integral part of their migration policies. 
Therefore, passing language tests has become an increasingly neces-
sary step along the so-called migrants’ journey (Saville, 2009). For the 
15
Language policies as key aspect of migration policies: an evolving scenario in Europe
scope of this paper and in relation to such requirements, four stages of 
this journey are considered: the pre-entry stage, temporary residency, 
permanent residency and citizenship.
The columns in Figure 3 show that in 2018 only seven out of the 40 
surveyed countries (17%) had no language or KoS requirements (An-
dorra, Bulgaria, Ireland, Monaco, San Marino, Serbia and Sweden). The 
other 33 countries (87%) set tests to assess from one to three abilities: 
language proficiency, KoS and often also digital skills, as in many cases 
the tests were computer based. 
With regard to the aforementioned four stages, in 10 of the coun-
tries (24%) migrants had to meet certain criteria prior to their entry into 
the country of resettlement (Austria, France, Germany, Hungary, Lithua-
nia, Netherlands, North Macedonia, Romania, Turkey and the UK). A to-
tal of 13 (32%) of the countries set language and/or KoS requirements 
for temporary residency (Austria, France, Germany, Greece, Hungary, 
Italy, Malta, Netherlands, North Macedonia, Romania, Russia, Turkey 
and the UK), while 21 (51%) countries have the same requirements in 
relation to permanent residency (Austria, Belgium (Fl.), Cyprus, Czech 
Republic, Denmark, France, Germany, Greece, Iceland, Italy, Lithuania, 
Luxembourg, Malta, Moldova, Netherlands, North Macedonia, Norway, 
Portugal, Russia, Switzerland and the UK).
The number of Member States imposing language and/or KoS re-
quirements for citizenship doubled since the first Council of Europe 
survey, reaching 33 (78%) (Albania, Armenia, Austria, Belgium (Fl.), 
Figure 1: Requirements: the situation in 
2007.
Figure 2: Requirements: the situation in 
2018.
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Slovenščina 2.0, 2024 (2) | Articles
Belgium (Fr.), Croatia, Czech Republic, Denmark, Finland, France, Ger-
many, Greece, Hungary, Iceland, Italy, Latvia, Lithuania, Luxembourg, 
Malta, Moldova, Netherlands, North Macedonia, Norway, Poland, Por-
tugal, Romania, Russia, Slovak Republic, Slovenia, Spain, Switzerland, 
Turkey and the UK).
Figure 3: Number of countries with compulsory tests (2018).
Taking into account the migrants’ journey, nine countries (22%) 
had requirements at one of the four stages, 11 (27%) at two stages, 
seven (17%) at three stages, and six (15%) at all four. 
It is worth mentioning that apart from a few cases the Council of 
Europe Member States did not provide exemptions from these require-
ments for vulnerable test-takers, such as refugees and low-literate 
migrants.
Considering the sum of the numbers reported in the last four col-
umns of Figure 3, the overall number of requirements is 75 and in only 
10 cases did low-literate migrants receive some form of exemption, 
while refugees did so in just 12 cases.
Focusing on language proficiency, according to the CEFR the levels 
required have increased. For instance, while only one country had a B2 
requirement for citizenship in 2007, the number had risen to four in 
2018. Apart from the pre-entry tests that were all calibrated at CEFR 
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Language policies as key aspect of migration policies: an evolving scenario in Europe
A1, the language level required varied considerably across countries: 
both for temporary and permanent residency there was a clear average 
for A2, but within a range covering three levels, thus from A1 to B1. In 
the case of language tests related to citizenship, some countries ask 
for A2, while others expect migrants to demonstrate language compe-
tence at the B2 level, as such there are four different levels involved in 
this context, with B1 as the average. 
Standardized language tests were used in 47% of the countries: 
this means that in 53% of cases the tests used were non-standardized 
(just seven countries reported that the language tests used had been 
subject to an external audit, like the ALTE audit system)1.
In terms of KoS, 44% of the countries surveyed required migrants 
to pass a dedicated test. Most often this test focused on history and 
geography (14 countries), constitution and law (13), or the customs 
and traditions of the host country (11), with less attention to other con-
tents, like the educational system (8), the public services (7) or aspects 
of the job market (8). 
In two out of 16 cases, the KoS tests were in an official language of 
the host country, thus representing an additional language test linked 
to a CEFR level typically not specified. These KoS tests thus clearly 
function as implicit language tests, often with a required proficiency 
that exceeds the CEFR level of the language test required by the same 
country. This mainly happens because of the recurrent presence of 
highly culturally connoted abstract concepts in KoS tests.
2.2 Learning opportunities
Moving to learning opportunities, 94% of the Member States surveyed 
in 2018 provided language courses for migrants. In 32 cases the na-
tional or local government financed language courses free of charge or 
with a token fee.
In 36% of the countries the teachers involved did not receive any 
specific training, and in 42% the progress of the course was not mon-
itored at all. Moreover, there was a considerable lack of consistency 
between Member States, and what mainly differed was the number of 
1 https://www.alte.org/Setting-Standards
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Slovenščina 2.0, 2024 (2) | Articles
hours provided and the degree to which the courses were tailored to 
specific learner groups. 
Eleven Member States provided up to 250 hours of language tui-
tion, in eight cases up to 500 hours and four up to 1,000 hours. Only one 
third of the countries provided courses targeted at vulnerable groups, 
and low-literate learners in particular were rarely provided with a suf-
ficient number of hours of instruction, although research has shown 
(Kurvers et al., 2015) that such learners should receive more hours of 
tuition, at a slower pace and with tailored courses.
If it was true that in the large majority of contexts accommodations 
were provided for minors, it happened mainly within the compulsory 
education system, as in only 9% of the countries were courses offered 
outside the school system, or in any case outside the school calendar. 
This means that special second language support and reinforcement 
paths for migrant children and adolescents were almost never in place.
In 13 of the countries KoS courses were integrated into language 
courses, and thus were only offered in the second language. More gen-
erally, when KoS courses were unrelated to a language course the use 
of the second language remained predominant (19 cases), followed by 
the use of a lingua franca (17 cases). KoS courses in one of the mi-
grants’ first languages were more limited (11 cases).
3 The updated scenario described by LAPIM
Within the IMPECT project,2 aimed at investigating the integration of 
migrants with poor education and the consequences of migration tests 
for them, a new index was designed, called LAPIM, LAnguage Policy 
Index for Migrants.
The reasons behind the decision to develop this new index were 
related to the need to build an index for the first time totally focused 
on language policies for migrants, as existing indices seemed too 
comprehensive. Among them, a reference for LAPIM was the Migrant 
Integration Policy Index (MIPEX) developed by the Barcelona Centre 
of International Affairs and the Migration Policy Group. MIPEX anal-
yses migrant policies on a large scale, with 167 indicators based on 
2 https://www.hvl.no/en/research/project/impect/
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Language policies as key aspect of migration policies: an evolving scenario in Europe
the following eight dimensions: labour market mobility, education of 
children, political participation, family reunion, access to nationality, 
health, permanent residence, and anti-discrimination. The last time 
MIPEX was updated it gathered information from 38 countries, includ-
ing all EU Member States.3 Each country obtained a score ranging from 
0 (critically unfavourable) to 100 (favourable). The scoring was done in 
an Excel coding scheme where each indicator was reported in a corre-
sponding row.
Based on the related objectives, LAPIM was designed as an index 
with five different purposes:
• A modality of ranking European countries’ language policies for mi-
grants, thus in terms of a tool which allows cross-country compar-
isons in a systematic way. 
• A step forward to greater comparability with the Council of Europe 
and ALTE survey, transforming the data into values.
• An opportunity to cover more aspects and to provide much more 
details compared to the survey (for instance, related to exemptions 
or to learning opportunities).
• A means, after five years, to update and double-check the data 
from the same survey.
• A way to control the data, thus indirectly improving their reliability, 
thanks to the fact that LAPIM and the survey took into account dif-
ferent target respondents: mainly academics and language testers 
in LAPIM, and mainly policymakers in the survey. 
In order to allow comparisons with the MIPEX ranking, LAPIM uses 
the same scale (0-100), with a four-point system, meaning that the 
scoring options are 0, 33, 66 and 100. Again, as in MIPEX, LAPIM pro-
vides an Excel coding scheme, in this case with 36 rows, one for each 
indicator. A last column is included with the heading “comment”.
With regard to the related specifications, the requirements are ad-
dressed based on the four stages mentioned above: pre-entry stage, 
temporary residency, permanent residency and citizenship. For each 
stage, LAPIM offers details concerning:
3 https://www.mipex.eu/
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• The language skills required; for instance, if all four skills (listening, 
reading, speaking and writing) are required or only oral, with “oral” 
here including both listening and speaking within an exchange be-
tween the examiner and test-taker.
• The CEFR level imposed, in cases with a language requirement; 
and the languages involved in cases with a KoS requirement – if the 
official language only, or if one of the first languages of the test-tak-
er, or even if the use of a lingua franca is considered.
It is worth mentioning that while for the first three stages (pre-en-
try, temporary residency, permanent residency) LAPIM takes into ac-
count polices addressing third-country nationals, in relation to citizen-
ship it considers all migrants, thus including EU citizens. 
LAPIM pays specific attention to the theme of exemptions, with 
two dedicated rows:
• The first row allows respondent to specify whether the exemption 
takes into account one or more of the following six groups/condi-
tions: age (minors and/or the elderly); mental/physical disability/ 
trauma; status (e.g. refugees, family reunion, etc.); low-literate mi-
grants; a diploma or a degree taken in the country of resettlement.
• The second row concerns the kind of exemption, pointing out 
whether the exemption is total or partial, where “partial” refers to 
three variables: if the exemption concerns only one dimension (for 
instance, temporary residency, but not also permanent residency); 
if it regards one or more of the groups/conditions listed above; and 
if it is related to one of more skills (for instance, only speaking and 
not writing).
Addressing learning opportunities LAPIM considers only language 
courses provided free of charge or for a token fee. It is important to 
underline that the role of volunteers and NGOs in providing language 
support for migrants was not considered, as LAPIM refers only to state 
and national policies. The policy domain embodies questions regard-
ing which groups of migrants should be given free language courses, 
the number of hours that may be provided, and what training oppor-
tunities are at the disposal of specific target learners, particularly for 
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Language policies as key aspect of migration policies: an evolving scenario in Europe
low-literate migrants. This group requires more hours of tuition, as 
such individuals are challenged both by learning a new language and 
by learning to read and write. Ultimately, LAPIM covers the degree to 
which following a certain number of hours of tuition results in being 
exempted from the requirement to pass compulsory tests.
Before the data collection started, LAPIM was implemented un-
der qualitative piloting in six countries; then, based on the feedback, 
it was revised from these more diverse contexts. Afterwards, data 
were collected from language experts recruited through the ALTE and 
EALTA (European Association for Language Testing and Assessment) 
networks. 
Figure 4 reports the scores for the 20 countries surveyed to date. 
They fall into four categories, according to their position in a hypothet-
ical ordinate axis with, at the top, the most lenient respondents and, 
on the bottom, the strictest ones. Therefore, the lower the score, the 
stricter the policy applied by the country. 
Figure 4: LAPIM scores (2023).
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The correlation between MIPEX and LAPIM (Carlsen and Rocca, 
2025, in press) shows consistency among the two indices. This means, 
for instance, that the countries rated by LAPIM as having the least strict 
language policies are also identified as the most favourable by MIPEX; 
in contrast, the countries with the strictest language policies in LAPIM 
are ranked relatively low in MIPEX.
As stated above, LAPIM can serve several purposes, not least the 
double opportunity to update the data collected in 2018 by the survey 
and to provide additional information with regard to the language poli-
cies of the countries surveyed. 
The following two sections aim at giving examples of this oppor-
tunity, first listing three changes discovered in the language policies 
for migrants, then detailing the situation related to one country, with 
the additional goal to explain the rationale behind the obtaining of the 
LAPIM scores.
3.1 Changes in language polices for migrants 
The data collected by LAPIM show the changing language and KoS re-
quirements among the Council of Europe Member States. In particular, 
the presence of the column “comment” allowed the respondents to 
add useful information to obtain a better understanding of the current 
policies. Three examples of this information are given below, two con-
cerning permanent residency and one related to citizenship.
From 2022, the language level required in the Netherlands for 
permanent residency rose from A2 to B1, except for cases where the 
applicant has proven that they are not able to reach B1, in which case 
they can take the exams at level A2. This “levelling down” to level A2 
is only possible when the applicant has followed at least 600 hours of 
language classes at a designated language school. 
Similarly, with regard to permanent residency Slovenia passed 
from no requirement to A2, on the basis of the Aliens Act that came into 
force in May 2023. The level A2 applies for all four skills, with the fol-
lowing exemptions: partial, in the case of low-literate individuals (with 
less than six years of schooling) and technically for illiterate persons, 
who must demonstrate A2 abilities in speaking only; total for those with 
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Language policies as key aspect of migration policies: an evolving scenario in Europe
the refugee status or under subsidiary protection, as well as for people 
who are unable, on grounds of ill health, to sit the examination in the 
required form, and people older than 60 years. There are also some 
other exemptions (e.g. for those who have completed primary, second-
ary or tertiary education with Slovenian as the language of instruction).
In 2021 the situation changed in Greece in relation to citizenship: 
in confirming B1 as required level, the new law also requires a formal 
test with all four skills assessed, while before the test-takers only had 
to pass an oral interview.
3.2 Obtaining LAPIM scores: the case of Italy
The first section of the LAPIM Excel coding addresses pre-entry re-
quirements. As Italy does not have any test for migrants prior to entry, 
in the initial six rows (the first three related to language and the second 
three to KoS), Italy obtains the maximum scoring, 100 for each row, 
with 600 as the subtotal.
For all the other sections, Italy has laws covering all the LAPIM rows 
in various ways. Therefore, in order to justify the other scores after the 
aforementioned subtotal, an explanation of the Italian language policy 
for migrants is needed. Three requirements are currently in place:
1. For temporary residency, the DPR 179/114 (so-called Accordo di 
Integrazione) requires CEFR A2 only for speaking (an oral inter-
view, which also addresses KoS contents related to daily life). Mi-
grants have to meet this requirement within two years from their 
first arrival in order to obtain the renewal of their residency permit. 
The following exemptions are in place: total exemption for EU cit-
izens, minors under 16 years, unaccompanied minors, refugees, 
family reunions, disabled people, people with limitations in learn-
ing caused by special needs, pathologies or age.
2. The DI 7/12/215 (which replaced DM 4/6/10, so-called Decreto 
Maroni) regulates the permanent residency that can be applied 
for after five years of residency. It requires CEFR A2 for all four 
skills. The following exemptions are in place: total exemption for 
4 https://www.gazzettaufficiale.it/eli/id/2011/11/11/011G0221/sg
5 https://www.gazzettaufficiale.it/eli/id/2022/02/12/22A01025/sg
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Slovenščina 2.0, 2024 (2) | Articles
EU citizens, minors under 14 years, disabled people, people with 
limitations in learning caused by special needs, pathologies or 
age; partial exemption in case of low-literate test-takers who only 
have to pass an oral interview, and not the reading and writing 
components. 
3. Citizenship can be applied for after 10 years of residency. The DDL 
4/10/186 (so-called Decreto Salvini) introduced CEFR B1, again for 
all four skills. The following exemptions are in place: total exemp-
tion for disabled people, people with limitations in learning caused 
by special needs, pathologies or age.
The laws in force establish four ways to comply with these legal 
obligations:
1. Attendance of language courses provided by state schools called 
CPIA (see the next paragraph) allows individuals to fulfil the re-
quirements for residency (both temporary and permanent), but is 
not sufficient for citizenship.
2. With regard to residency, migrants can apply for a CPIA test with-
out being enrolled in CPIA courses; in other words they are consid-
ered “external test-takers”. For “internal students” the first meth-
od would apply.
3. The acquisition of a diploma or degree, starting from the lower sec-
ondary school level, awarded by an Italian state school.
4. The passing of an official language certification exam (A2 for resi-
dency, B1 for citizenship) awarded by one of the CLIQ institutions.7 
The foundation of learning opportunities for migrants is represent-
ed by the state schools called CPIA – Centri Provinciali per l’Istruzione 
degli Adulti. More than 4,000 teachers are employed within 129 CPIAs. 
This system provides different kinds of courses offered without any 
charge to adults aged over 15. This includes third-country nationals, as 
well as EU citizens, refugees and asylum seekers with pending status; 
6 https://www.gazzettaufficiale.it/eli/id/2018/10/04/18G00140/sg
7 CLIQ is the association recognized by the Ministries of Interior, Education and Foreign Affairs 
composed by the four official certification bodies: Università per Stranieri di Perugia, Univer-
sità per Stranieri di Siena, Università Roma Tre and Società Dante Alighieri - https://www.
associazionecliq.it/
25
Language policies as key aspect of migration policies: an evolving scenario in Europe
in other words, all migrants legally present in the Italian territory can 
access the CPIA schools.
Courses in Italian as a second language are mainly focused on A1 
and A2 levels, with an institutional formative path of 200 hours of tu-
ition for CEFR band A, including KoS elements and according to the 
Ministry of Education Guidelines.8 CPIAs can offer courses for other 
learners’ profiles, like Alfa and Pre-A1 courses for non- and low-liter-
ate migrants or B1, B2 and, rarely, C1 and C2 courses, as well. This can 
happen within the so-called “potenziamento dell’offerta formativa”, a 
higher level of institutional training that depends on several factors, 
such as supply and demand or financing.
Learning opportunities are sustained by a sort of permanent syn-
ergy, in place since 2007, between the Ministry of Education and the 
Ministry of Interior. In this, the DLCI (the Department of Civil Liberties 
and Integration of the Ministry of Interior) finances additional language 
courses targeted to third-country nationals, described in the related 
guidelines.9 In addition to a tuition fee that decreases down accord-
ing to the LASLLIAM10 and CEFR levels (from Low Alfa to B2), these 
courses, co-funded by AMIF (Asylum, Migration and Integration Fund, 
managed by DLCI), also provide two kinds of modularity:
• by skill, thus with training focused on specific language skills, such 
as writing; or
• by theme, thus with courses related, for example, to the language 
needed for specific professions.
Now the situation has been described, it is possible to give exam-
ples aimed at illuminating some of the LAPIM scores present in the 
Excel reporting for Italy. As Figure 5 shows, with regard to temporary 
residency, for instance, in the row concerning whether a compulsory 
test is required, the score is zero, because migrants are obliged to pass 
a test; in the row addressing language skills, the score is 66, as only a 
8 https://www.idaveneto.it/wp-content/uploads/2013/04/linee_guida.pdf
9 https://www.interno.gov.it/sites/default/files/2023-04/1._linee_guida_piani_regiona-
li_2023-2026.pdf
10 LASLLIAM stands for Literacy and Second Language Learning for the Linguistic Integration 
of Adult Migrants. It is the Council of Europe Reference Guide aimed at support the double 
process of learning literacy and/in the second language - https://rm.coe.int/prems-008922-
eng-2518-literacy-and-second-language-learning-couv-texte/1680a70e18
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Slovenščina 2.0, 2024 (2) | Articles
speaking test is required (the four options in this case are: 100 for no 
test; 66 if the test is only oral; 33 if it is oral plus reading; zero if it is all 
four skills, including writing). Looking at the CEFR level, the score is 33, 
as the level is A2 (66 is the score for A1 or below; zero for B1 or above).
Figure 5: LAPIM scores – Italy (2023).
3.3 Far from neutrality
The given example, with an explanation of the scoring system, clearly 
shows that a value-neutrality approach is not present within LAPIM. In 
fact, as far as the structure, content and mainly scoring are concerned, 
LAPIM follows the Council of Europe’s values of human rights and equity, 
which focus on the ways to attain a socially fair and inclusive migration 
policy (Beacco et al., 2017). For instance, when learners’ completion 
of a language and/or KoS course may exempt them from requirement 
to pass tests, there is an LAPIM indicator giving an additional score for 
Language 
Policy 
Dimension
Indica-
tor-short 
name
Sub-indica-
tors- short 
name
Description 100 66 33 0 LAPIM 
score
TEMPO-
RARY RESI-
DENCY
Language 
require-
ments
Language 
require-
ments for 
temporary 
residency
Temporary 
residency 
language 
course or 
test(s)
Language 
require-
ments for 
temporary 
residency
No require-
ment
Require-
ment to 
take a 
language 
course 
provided 
(accessible 
and free)
Require-
ment to 
take a 
language 
course 
paid by the 
migrants 
themselves 
Require-
ment 
to pass 
language 
test(s)
0
Temporary 
residency 
language 
skills 
required 
What 
language 
skill is 
necessary 
to pass the 
test(s)
No require-
ment 
Only oral 
skills 
required 
(listening 
& speaking 
in an inter-
view) 
Speaking/
listening/
reading
All four 
skills 
(speaking/
listening/
reading/
writing)
66
Temporary 
residency 
CEFR – lev-
el required  
What CE-
FR-level (or 
equivalent 
to CEFR 
–level) is 
required to 
pass the
No require-
ment
A1 or 
below
A2 B1 oral or 
above
33
27
Language policies as key aspect of migration policies: an evolving scenario in Europe
it. Moreover, the attention that LAPIM pays to the special needs of vul-
nerable learner groups is fully consistent with the guiding principles of 
preserving equal opportunities for all, starting from the most vulnerable 
persons, as the Council of Europe action plan in the context of migration 
and asylum highlights (Council of Europe, 2021). 
Although the total number of hours cannot give a complete pic-
ture of the degree of adequacy of a language course, it represents an 
important variable, especially in the case of low-literate learners. As a 
consequence, the LAPIM scoring system means that in courses target-
ed to this group the maximum score (100) is assigned only in the case 
of more than 1,000 hours of tuition; the second highest score (66) is for 
attending 700 to 1,000 hours, with a score of 33 for 400 to 700 hours, 
and zero (with the implicit message, “not enough, not adequate in prin-
ciple”) for up to 400 hours of tuition. 
The rationale behind LAPIM, and its non-neutrality, appears influ-
enced by a critical approach related to language tests being perceived 
as potential gatekeepers in the migration context. The final part of the 
paper addresses the discussion around such an approach, which is 
even more present in the language testing community in terms of a 
reaction against the growing prominence of language and KoS require-
ments, as highlighted by the data shown in this study.
4 Discussion
As data show, the new trend in migration policies has been to build 
a codependent relationship between democratic and human rights, 
on the one side, and the individual’s ability to get a certain score on a 
language test on the other, which is extremely personal and can vary 
among people. Consequently, language tests, which were originally 
thought to assess language competence, are now seen and used as 
if they measured something else, like the willingness to integrate with 
success in the country of resettlement. However, the proposition that 
the achievement of a CEFR level can be interpreted as demonstration 
of the migrant’s loyalty and commitment to be part of the host society 
is largely unsupported by research. »The CEFR cannot establish wheth-
er a certain language level is indicative of a level of integration, because 
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Slovenščina 2.0, 2024 (2) | Articles
it is only a measure of linguistic ability« (Parliamentary Assembly,11 
Recommendation 2034, 2014). In this regard, it is worth remembering 
that although language proficiency is unanimously considered a facili-
tator of the integration process, this process cannot be exclusively de-
termined by the linguistic component (Beacco et al., 2014). 
The CEFR was built upon the overarching values of the Council of 
Europe in order to promote and sustain plurilingualism, respect for di-
versity, intercultural dialogue, dignity among social agents and mobility 
across borders. Therefore, as Burzos et al. (2017, p. 423) point out:
It seems paradoxical that an instrument developed to acknowledge and 
facilitate the idea of a multilingual Europe is employed as a means to le-
gitimize monolingual policies based on the requirement of given national 
languages. For that reason, there is a growing concern that the CEFR is 
becoming an instrument to control and restrict immigration.
In the professional environment of language testing, the use of lan-
guage tests as instruments that aim to investigate migrants’ behaviours 
and attitudes unrelated to declared language construct is often defined 
as an example of test misuse. This expression is not fully defined in the 
literature, but seems to refer to at least two different things. On the 
one hand, test misuse is using a test with a different intent than the 
one originally born in mind. On the other hand, test misuse can refer 
to the negative effects on test-takers, no matter whether such effects 
are intentional or not (Shohamy, 2001, 2007; Van Avermaet and Gy-
sen, 2009; McNamara and Rover, 2006; Khan and McNamara, 2017; 
Carlsen and Rocca, 2021).
The so-called critical language testers highlight the changes in the field 
of language requirements from a “language and power” perspective. 
They identify an intention behind language examinations of regulating 
access to society or the attempt to preserve social cohesion by freezing 
out certain groups (Pochon-Berger and Lenz, 2014, p. 3).
The Council of Europe and ALTE survey revealed, and LAPIM con-
firmed, that there is a lack of agreement among Member States as to 
11 The Parliamentary Assembly of the Council of Europe (PACE) is a deliberative body com-
posed of representatives of the 46 national parliaments.
29
Language policies as key aspect of migration policies: an evolving scenario in Europe
what proficiency level is appropriate for a given stage of the migrants’ 
journey. For instance, in the case of citizenship the requirement ranges 
from no requirement, to A1 and up to B2. This reaffirms that language 
requirements often fulfil a symbolic function, instead of effective lan-
guage needs, as highlighted by Böcker and Strik (2011, p. 182): 
as there is no proven relationship between integration and a specific 
level of language proficiency, it is difficult to understand why some 
Member States should have higher requirements than others for the 
same purpose. These differences throw doubt on the argument that im-
migrants need the proficiency level they are required to demonstrate in 
order to successfully integrate.
The survey and LAPIM converge again in pointing out the presence 
of tests assessing a uniform level. The ALTE 2023 Report on uneven 
language profiles12 confirms that in a few countries differentiated lan-
guage requirements are in place (for instance, level A1 in writing, to-
gether with level A2 in reading and level B1 in listening and speaking), 
when the CEFR strongly encourages profiles: »levels are a necessary 
simplification. […] The reason why the CEFR includes so many descrip-
tor scales is to encourage users to develop differentiated profiles« 
(Council of Europe, 2020, p. 39). Language requirements are supposed 
to express real language needs, and when it comes to uneven profiles 
then more differentiated requirements would be expected, as opposed 
to a global level being used. Not all job profiles and not all roles in soci-
ety require the same competence in reception, production, interaction 
and mediation. As a logical consequence, the expectations should also 
be diversified. It does not seem necessary to establish a uniform level, 
because learners do not meet the criteria of a homogeneous profile 
(Krumm, 2007); on the other hand, an individual’s daily interactions 
in the personal, public, occupational and educational domains impose 
clearly differentiated linguistic needs.
Moreover, language tests often raise human rights issues: this is 
the case with pre-entry tests, clearly against the right to family reuni-
fication as highlighted by the European Committee of Social Rights. In 
12 https://www.alte.org/resources/Documents/Carlsen_Rocca_Machetti_2023_ALTE%20
LAMI%20Uneven%20profiles%20report.pdf
30
Slovenščina 2.0, 2024 (2) | Articles
line with this there is the Council of Europe’s aforementioned Recom-
mendation 2034 (2014), which states that 
it is important to be aware of the limitations of tests and ensure that 
they contribute to integration and do not become a barrier to it. The 
required standards sometimes exceed what is reasonably attainable, 
leading to the exclusion of many people. This raises human rights is-
sues. […] It is particularly problematic when dealing with people who 
are illiterate or with low levels of education.
Indeed, learners with poor educational backgrounds are particularly 
negatively affected by compulsory tests (Oers, 2020): they benefit less 
from language courses and perform less well on tests (Kim et al., 2014). 
Their failure is not only caused by a lack in the skills tested, but also by 
a lack of experience with the testing situation and a lack of familiarity 
with test formats, as for instance with the assessment techniques or the 
setting commonly used in language tests (Allemano, 2013). In order to 
protect this vulnerable group LASLLIAM »presents levels traceable only 
in relation to the learning process and scales describing progressions in 
a formative path, without any unrealistic aspiration to measure a sup-
posed level of integration« (Minuz et al., 2022, p. 98). With the same aim, 
LAMI highlights that »literacy is a necessary prerequisite for any kind 
of written test. […] Policy makers need to provide training courses that 
strongly support the acquisition of literacy skills« (ALTE, 2016, p. 28).13
Regarding the effects of learning opportunities on the language re-
quirements, the findings of both the survey and LAPIM show that only 
in a few cases can migrants receive an exemption from the compulso-
ry test by attending language courses. In addition, such courses are 
too often not tailored to the learners’ specific needs. On the contrary, 
they seem “flattened” to be in line with the law, in the sense that are 
mainly focused on the CEFR levels provided by the requirements cur-
rently in place, with certain negative effects. From the school system 
perspective this leads to both “teaching to the test” and the provision 
of few courses for levels that are not part of the compulsory tests, while 
from the learners’ perspective there is a motivation to simply attend a 
13 https://cdn.wildapricot.com/218795/resources/Documents/LAMI%20Booklet%20EN.pd-
f?version
31
Language policies as key aspect of migration policies: an evolving scenario in Europe
course to pass a test, rather than gain the abilities and skills needed 
for their daily lives in the second language. These and similar issues 
clearly and often emerged as the indirect impacts of the focal language 
requirements on learning environments (Rocca and Mouti, in press).
5 Conclusion
Language tests can be seen as gatekeepers which strongly discriminate 
against vulnerable groups, generally do not reflect the learners’ uneven 
language profiles, and often ignore human rights: in this context, the 
shared engagement of the language testers’ community is required, 
as seen in a growing advocacy, daily commitment, and professional re-
sponsibility to try to prevent language tests from being misused. »Vali-
dators have an obligation to review whether a practice has appropriate 
consequences for individuals and institutions, and especially to argue 
against adverse consequences« (Cronbach, 1988, p. 6). 
In recent years, ALTE has established a set of 17 common mini-
mum standards (MSs) for its members’ tests in order to establish qual-
ity profiles in examinations. Such MSs cover all stages of the language 
testing process: test construction; administration and logistics; mark-
ing and grading; test analysis; and communication with stakeholders. 
These MSs are used within audit processes aimed at checking the 
whether language tests delivered by ALTE members meet professional 
standards and accurately reflect test-takers’ abilities.
In 2024, ALTE introduced a new Minimum Standard (MS 18) in its 
audit system: You take action when test scores are interpreted and used 
for a purpose that violates the best interest of test-takers.
It reflects two key principles: Principle 1 in the ILTA Code of Ethics, 
established by the International Language Testers Associations:14 Lan-
guage testers shall not discriminate against nor exploit their test-takers 
on grounds of age, gender, race, ethnicity, sexual orientation, language 
background, creed, political affiliations or religion, nor knowingly im-
pose their own values (e.g., social, spiritual, political and ideological), 
to the extent that they are aware of them.
14 https://cdn.ymaws.com/www.iltaonline.com/resource/resmgr/docs/ILTA_2018_CodeOfEth-
ics_Engli.pdf 
32
Slovenščina 2.0, 2024 (2) | Articles
And Principle 9 in the ALTE Principles of Good Practice:15 Language 
testers shall regularly consider the potential effects, both short and 
long term on all stakeholders of their projects, reserving the right to 
withhold their professional services on the grounds of conscience.
According to these principles, MS 18 addresses the third ALTE 
mission: maximizing tests’ positive impact by making the connections 
among policy, research and practice. Indeed, this new MS represents 
a concrete attempt to raise awareness in language testers about the 
double commitment that they should have, to make clear to stakehold-
ers what would be an appropriate use of the test; and, contextually, to 
improve a system aimed at collecting information on how the test is 
used. Finally, if misuse is detected, professionals should have the duty 
to take adequate and proportionate action. 
This is only one field of action, as the advocacy of language testers 
needs to go beyond the test itself, for instance creating the conditions 
for a growing connection between learning, teaching and assessment, 
and sustaining in particular the engagement of teachers, as the very 
final aim should be policies enforcing what has been declared in a key 
Council of Europe Resolution: »rather than promoting testing, offering 
language courses [...] may offer greater advantages without running the 
risk of excluding migrants« (Parliamentary Assembly, Resolution 1973, 
2014); a Resolution with an emblematic title proposing the following 
rhetorical question: Integration test: helping or hindering integration?
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Jezikovne politike kot ključni vidik migracijskih politik: 
razvijajoči se scenarij v Evropi
Članek se osredotoča na vlogo jezikovnih politik v širšem okviru migracijskih 
politik v državah članicah Sveta Evrope. Opis trenutnega sistema v reprezenta-
tivnem vzorcu držav vodi do razmislekov o jezikovnih zahtevah, vključno z 
jezikovno dimenzijo zahtev za poznavanje družbe, ter o možnostih za učenje 
jezika, kjer so te prisotne.
Ključne besede: jezikovne zahteve, migranti, možnosti učenja, poznavanje 
družbe