Regional Studies, Regional Science
ISSN: 2168-1376 (Online) Journal homepage: www.tandfonline.com/journals/rsrs20
Intraregional mobility and free movement
in Mercosur: an interplay between state-led
implementation and subnational migrant
practices
Zoé Perko
To cite this article: Zoé Perko (2025) Intraregional mobility and free movement in Mercosur:
an interplay between state-led implementation and subnational migrant practices, Regional
Studies, Regional Science, 12:1, 488-507, DOI: 10.1080/21681376.2025.2501317
To link to this article: https://doi.org/10.1080/21681376.2025.2501317
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REGIONAL STUDIES, REGIONAL SCIENCE
2025, VOL. 12, NO. 1, 488–507
https://doi.org/10.1080/21681376.2025.2501317
Intraregional mobility and free movement in
Mercosur: an interplay between state-led
implementation and subnational migrant practices
Zoé Perko
ABSTRACT
This article examines the facilitation of internal mobility as a pillar of regional integration, focusing on the
Southern Common Market (Mercosur). Drawing on New and Comparative Regionalism theories, it
investigates how bottom-up dynamics at the subnational level interact with supranational objectives of
regional free movement in Mercosur. Through document analysis and 26 stakeholder interviews with
national and regional institutions, as well as civil society organisations, it reveals challenges in the stateled implementation of the Mercosur free movement framework, including the absence of a right of
entry in the agreements, the ineffective implementation of certain agreements, disagreements between
member states impeding efforts to strengthen the existing framework and, lastly, discriminatory
practices and arbitrary rejections at internal borders. Nevertheless, some of these limitations are
addressed and partially mitigated by bottom-up migrant practices and traditional mobility in border
regions. Cross-border interactions and mobility in subnational border regions thus represent key
dimensions of regional free movement and integration. Thereby, the article underscores the importance
of a universal definition of regional free movement that integrates historical particularities and mobility
dynamics beyond the European conceptualisation.
ARTICLE HISTORY
Received 18 March 2024; Accepted 28 April 2025
KEYWORDS
regional integration; regional free movement; regional mobility; cross-border mobility; cross-border
regions; bottom-up practices; Mercosur
JEL
F22; K37; O15; R23
1. INTRODUCTION
This article delves into a crucial aspect of regional integration: the facilitation of internal
mobility for regional citizens. This is often enabled by free movement frameworks, addressing
different dimensions such as entry or residency rights. These frameworks exist in different parts
of the world, albeit conceptualised and implemented in diverse ways (Nita et al., 2017). Among
these, the European Union is frequently highlighted as a benchmark for the success of regional
free movement frameworks (e.g., Bauböck, 2009, 2024; Brumat, 2016). Deficiencies in
CONTACT Zoé Perko
zoe.perko@hu-berlin.de
Department of Social Sciences, Humboldt-Universität zu Berlin, Berlin, Germany
Supplemental data for this article can be accessed online at https://doi.org/10.1080/21681376.2025.2501317
© 2025 The Author(s). Published by Informa UK Limited, trading as Taylor & Francis Group
This is an Open Access article distributed under the terms of the Creative Commons Attribution License (http://creativecommons.org/
licenses/by/4.0/), which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly
cited. The terms on which this article has been published allow the posting of the Accepted Manuscript in a repository by the author(s)
or with their consent.
Intraregional mobility and free movement in Mercosur
489
implementation, application gaps and the absence of robust supranational institutions in many
regional free movement regimes outside the EU thus lead some to dismiss them as aspirational
rather than operationally effective (Acosta, 2019).
At the same time, there are cautions against overly simplistic comparisons that elevate the
EU as the sole effective model. Scholars argue that the EU’s framework is shaped by unique
historical and political circumstances that cannot be universally replicated, as each free move­
ment framework reflects its distinct origins and needs (Acosta, 2019; Bauböck, 2024; Gartland
et al., 2017). Thus, understanding the underlying logic behind the emergence of a free move­
ment framework is critical to appreciating its scope and functionality, while neglecting this per­
spective risks perpetuating Eurocentric interpretations (Acosta, 2019). Nita et al. (2017)
therefore contend that the European experience should be viewed as a case study rather than
a universally applicable model.
Thereby, an exclusive focus on state-led practices in implementing such frameworks risks
providing only a partial understanding of the dynamics at play. For instance, Lavenex and
Piper (2022) highlight that regional migration governance is often analysed either through
the lens of formal intergovernmental institutions or societal dynamics. Yet, this dichotomised
approach overlooks the critical interplay between top-down and bottom-up processes. This
perspective is echoed by further findings (Arhin-Sam et al., 2022), which reveal the significant
contributions of migrants, border communities and informal traders to regional free movement
in West Africa: In the case of the regional free movement framework of the Economic
Community of West African States (ECOWAS), historical mobility patterns have often miti­
gated challenges in formal implementation.
A deeper understanding of this interaction is essential for capturing the dynamics that shape
the design and execution of regional migration policies. Ultimately, these dynamics influence
the form, scope and efficacy of migration governance across regions. Despite its significance,
this perspective remains underexplored in the literature, necessitating further investigation
into the interconnected roles of states and societal actors in shaping regional mobility in
order to counteract Eurocentric notions.
The importance of bottom-up actors has long been recognised within the framework of New
and Comparative Regionalism, which critiques earlier, Eurocentric approaches to regionalism
for neglecting the multilevel governance processes that underpin integration. These approaches
emphasise the interplay between top-down, state-driven actions and bottom-up, informal nonstate dynamics (Hettne & Söderbaum, 2000; Söderbaum, 2004). Non-state actors are pivotal in
fostering ‘real’ integration through cross-border activities, even when they remain excluded from
formal policymaking (Hettne & Söderbaum, 1999; Machado et al., 2009; Söderbaum, 2016).
For instance, Dupeyron (2009) and Grimson (2005) have shown that cross-border regions sig­
nificantly contribute to regional integration in Latin America. By transcending simplistic
dichotomies of formal versus informal or state, versus non-state-driven processes, this approach
offers a more comprehensive understanding of regional integration (Söderbaum, 2016).
These theories thus provide a useful lens for studying regional free movement, as they tackle
a similar issue: the failure to adequately consider bottom-up actors, leading to an overly statecentric and unnecessarily Eurocentric understanding of regional processes. Free movement is an
integral part of regional integration, yet its analysis has often suffered from the same limitations.
Furthermore, while this perspective offers significant analytical value, it has seldom been applied
to the study of regional free movement frameworks, leaving a notable gap in the literature that
warrants further empirical investigation. To address this shortcoming, the present article aims to
deepen the understanding of how bottom-up practices interact with and shape regional free
movement frameworks, focusing on the Southern Common Market (Mercosur) in South
America.
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Mercosur represents a significant regional integration project, characterised by its robust free
movement framework and emphasis on human rights. However, existing research on free move­
ment within Mercosur has primarily centred on the challenges associated with state-led
implementation, largely overlooking its interplay with bottom-up practices. This article, there­
fore, poses the following research question: How do bottom-up practices interact with state-led
efforts to shape the realisation of free movement within the Southern Common Market (Mercosur)?
Employing document analysis of relevant agreements and 26 interviews with representatives
of regional and national institutions, civil society and academia, the article thus investigates the
contribution of (in)formal migrant practices and cross-border activities in subnational border
regions to state-led implementation of free movement frameworks in the case of Mercosur. Fur­
thermore, the article highlights the importance of moving beyond Eurocentric paradigms in
conceptualising regional free movement, offering fresh insights into the dynamics of regional
free movement and integration in the Global South.
The article is structured as follows: Section 2 provides an overview on regionalism theories,
the importance of bottom-up dynamics and their connection to regional migration governance.
Section 3 traces the development of free movement policies in Mercosur. Section 4 describes the
data and methods. Section 5 discusses state-led implementation of the Mercosur free movement
framework and its challenges, bottom-up mobility practices and illustrates their interplay.
Section 6 discusses the empirical findings and, finally, Section 7 draws a conclusion.
2. REGIONALISM, REGIONAL MIGRATION GOVERNANCE AND
THE IMPORTANCE OF BOTTOM-UP DYNAMICS
The study of regionalism has evolved through multiple waves, with early theories primarily
focusing on the European Union (Acosta, 2016; Börzel, 2011; Söderbaum, 2016). The emer­
gence of New Regionalism expanded the scope beyond Europe, incorporating economic, pol­
itical and social dimensions of integration, including migration governance (Hurrell, 2007;
Söderbaum, 2004). Recognising the significance of multilevel governance, scholars emphasise
both state-led initiatives and informal, bottom-up dynamics, wherein non-state actors – such
as migrants – actively contribute to regionalisation (Hettne & Söderbaum, 1999; Machado
et al., 2009; Söderbaum, 2004). Cross-border mobility and interaction play a crucial role in
regional integration, highlighting the deep interconnection between migration and regionalism
(Machado et al., 2009; Moyo, 2020). Finally, the present stage of regionalism studies,
Comparative Regionalism, presents an important shift towards addressing the multifaceted
interactions among state and non-state actors, institutions, and processes across various levels,
including bilateral, regional, multilateral and global degrees (Söderbaum, 2016). This evolution
has transcended the simplistic dichotomy between formal and informal, or state and non-statedriven dynamics (Söderbaum, 2016).
These insights from regionalism theories can be transferred to the dimension of human
mobility, which is considered a key pillar of regional integration.
A central objective of states in many regional integration initiatives is to facilitate the move­
ment of people and goods within regions. Regardless of the specific constellation of these alli­
ances, nearly all of them implement instruments leading to internal openness (Gülzau et al.,
2016; Lavenex et al., 2016). As macroterritories, these integration projects combine territories
which establish independent mobility zones where citizens can enjoy the privilege of movement
(Mau et al., 2012), while often using free movement frameworks. In scholarly discourse, various
definitions of free movement exist, with many theories drawing parallels to global free move­
ment (Bauböck, 2009) or using the EU model as a reference point. Bauböck (2024), for
instance, emphasises that ‘free movement needs to combine rights of exit, transit, entry, stay,
and return’ and that the EU model provides benchmarks that other regional integration projects
REGIONAL STUDIES, REGIONAL SCIENCE
Intraregional mobility and free movement in Mercosur
491
have to achieve (p. 254). According to him, regions not fulfilling these aspects would then rather
grant mobility rights than freedom of movement. Similarly, Brumat (2016) conceptualises free
movement as a right entailing unrestricted movement, legal settlement and the enjoyment of
rights on par with citizens of the receiving state. However, in the subsequent sections, I
argue that free movement may vary considerably in configuration and scope, involving manifold
actors, with a universal definition yet to be established.
A limited body of literature has shown that bottom-up dynamics also contribute to regional
migration and its governance. Lavenex and Piper (2022) emphasise that studies of regional
migration governance, including regional free movement, often focus predominantly on formal
intergovernmental institutions through legal and political science lenses or examine social
dynamics from a sociological viewpoint. This dichotomy, they argue, tends to neglect the crucial
interaction between these dimensions, which is important for understanding the complex and
often less visible processes shaping regional policy development. Accordingly, the intertwined
nature of ‘top-down and bottom-up dynamics’ plays a decisive role in determining both the
structure and scope of migration governance across various regions (p. 2840). In that vein,
Arhin-Sam et al. (2022) make a similar contribution, yet in regard to free movement, by exam­
ining this dynamic in the Economic Community of West African States (ECOWAS). They
demonstrate that, despite formal barriers, informal border-crossing practices sustain free move­
ment in ECOWAS, revealing the paradoxical coexistence of formal and informal mobility gov­
ernance. They argue that informal understandings of borders and everyday mobility practices
enable free movement to persist, often independently of formal protocols. Nita (2013) further
argues that transnational spaces often arise from migrant practices that existed before the estab­
lishment of artificial international borders. The incorporation of these movements into legal
frameworks not only legitimises activities previously outside the scope of formal law but also
becomes an integral part of shaping the legal framework itself. Similarly, Bauböck (2024)
and Acosta (2019) highlight that large-scale irregular migration within a region often prompts
efforts to regularise such movements, as exemplified by the case of the Southern Common Mar­
ket (Mercosur). These dynamics are especially relevant in subnational border regions, such as
‘city-regions’ (Calzada, 2015), that have been characterised as key players beyond nation-states
and supranational regions. They emerge ‘in spite of the resistance of state borders’ in regard to
territoriality (Sohn, 2018, p. 299). Moreover, the relationship between regionalisation and state
territoriality can also be marked by compromise, when states have an interest in the develop­
ment of cross-border regions (Sohn, 2018). This can be characterised either by a ‘laissez-faire
attitude’ or its promotion (Sohn, 2018, p. 300). Similarly, Grimson (2005) argues in the context
of Mercosur, that social science perspectives have traditionally been centralist, viewing nationbuilding as a top-down process driven by major cities and marginalising the relevance of border
regions. However, recognising the agency of border populations reveals a dialectical relationship
between central authority and local dynamics, with border communities often playing a pivotal
role in shaping nations and states. In regard to border integration in Latin America, Dupeyron
(2009) adds that overly centralised ‘de jure’ integration often hinders the smooth development of
‘de facto’ integration, underscoring the need for a more decentralised approach to formal inte­
gration to foster effective cross-border interactions. Yet, border region studies remain ‘offbeat’ in
the field of regional studies, even though they have proven to be a significant branch (Makkonen
& Williams, 2016).
While existing literature provides valuable insights into the formal, state-led processes and
institutional frameworks that underpin regional free movement, the role of bottom-up processes
remains significantly underexplored. Despite growing recognition of the importance of nonstate actors and informal dynamics in regional integration studies, there is a notable lack of
empirical research focusing on their influence within the context of regional free movement
frameworks. This oversight leaves a critical gap in understanding how regional free movement
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Zoé Perko
operates beyond state-centric approaches. Addressing this gap is essential to develop a more
comprehensive perspective on regional mobility governance and its broader implications for
regional integration. Therefore, this article delves into the free movement of people as a key
component of regional integration, examining how state-led initiatives and bottom-up practices
intersect in facilitating cross-border mobility among regional citizens. Further addressing the
lack of research on regional integration and free movement beyond Europe, the focus is on
the Southern Common Market (Mercosur) in Latin America. Despite extensive research on
free movement within Mercosur primarily focusing on state-led practices, the synergies between
top-down and bottom-up processes regarding regional free movement and migrant practices
remain unexplored. Hence, this article will underscore the important contribution of practices
from below to top-down free movement implementation.
3. THE CASE OF MERCOSUR: REGIONAL INTEGRATION AND
FREE MOVEMENT
Founded in 1991 by the ‘Treaty of Asunción’, the Southern Common Market (Mercosur) com­
prises five full member states: Argentina, Brazil, Uruguay, Paraguay and Bolivia, while
Figure 1. Map of Mercosur.
Source: Eren Aytaç, Johanna Porten, and Alma Below (2025). Published with permission.
REGIONAL STUDIES, REGIONAL SCIENCE
Intraregional mobility and free movement in Mercosur
493
Venezuela was suspended in 2017 due to the lack of adherence to democratic principles.
Additionally, Chile, Colombia, Ecuador, Guyana, Peru and Suriname are associated states,
all participating in the free movement framework (Figure 1).
Analyses of Mercosur employing various regionalism approaches have outlined that the inte­
gration project indicates characteristics of Old Regionalism with a predominant state-led and
commercial focus (Gómez-Mera, 2008). Mercosur operates with significant national asymme­
tries, employing an intergovernmental decision-making process and exhibiting weak suprana­
tional institutions (Brumat & Acosta, 2019; Caichiolo, 2017; Margheritis, 2013; Nicolao,
2015). Consequently, agreements within Mercosur lack constraints on member states’ discre­
tionary power, resulting in diverse interpretations and applications of laws (Cardesa-Salzmann,
2012).
Gómez-Mera (2008) suggests complementing New Regionalism arguments for a compre­
hensive understanding of regional dynamics in the Southern Cone. For instance, research indi­
cates shifts influenced by societal and market actors (Doctor, 2013). Following economic crises,
labour unions have played a more supportive role in strengthening Mercosur policies (Doctor,
2013). While small and medium enterprises offer potential integration gains in Mercosur, their
role remains limited (Doctor, 2013). Additionally, cross-border relations in Latin America
often exhibit ‘real’ integration (Machado et al., 2009, p. 100). Yet, ‘while integration has led
to a more active involvement of non-state actors, (…) decisions of state actors continue to
drive the process of integration’ (Gómez-Mera, 2008, p. 293).
In regard to migration and mobility, Mercosur has developed an extensive free movement
framework, notably through residency rights and border integration measures – both key com­
ponents of the regionalisation process (CMC, 2010). Following the democratisation process of
post-dictatorships in several countries, the discourse shifted towards regional integration, envi­
sioning the dissolution of interstate borders (Grimson, 2012). Initially, the emphasis was on the
free movement of goods, services and factors of production, primarily for economic and com­
mercial integration (ISM, 2019). Human mobility was viewed through an economic and neo­
liberal lens, considering it as a productive factor (Brumat & Acosta, 2019; Hernández Granja &
Villarreal Villamar, 2017). However, with growing intraregional movements and challenges to
the neoliberal model due to economic crises in Brazil and Argentina, the social dimension of
migration gained prominence (Acosta, 2016; Brumat & Acosta, 2019; Hernández Granja &
Villarreal Villamar, 2017; Montenegro Braz, 2018). This shift enabled increased involvement
of social actors (Luciano & Ramanzini Júnior, 2023). Consequently, migrants began to be
regarded as citizens rather than mere labour force to be controlled (Hernández Granja &
Villarreal Villamar, 2017). Migration policies gradually embraced an approach that encouraged
mobility and recognised it as a human right, while exhibiting ‘exceptional policy liberalization’
(Acosta & Freier, 2023, p. 598).
Several agreements have been established to promote regional free movement, notably the
Mercosur Residence Agreement (CMC, 2002a), granting residency rights to citizens of associ­
ate and member states. This agreement offers a two-year temporary residency, extendable to
permanent residency upon proof of citizenship and a clean criminal record, guaranteeing various
rights including work, civil, family reunification, equal treatment and social security. In 2003,
the Specialised Forum on Migration (FEM) was established to foster dialogue and cooperation
on migration issues, working closely with the South American Conference on Migration
(CSM) to develop regional migration policies and share best practices. Additionally, the
Mercosur Work Subgroup Number 18 on Border Integration (SGT N° 18) was created in
2016, focusing on facilitating cross-border movements. Since 2019, significant efforts have
been made to streamline border crossings, exemplified by initiatives such as the ‘Neighbourhood
Border Transit’ card, which facilitates the movement of border communities (CMC, 2019).
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Despite these accomplishments, state-led free movement implementation encounters
numerous challenges, leading to limited effects of positive public narratives and increased
restrictiveness and non-prioritisation of free movement (Acosta & Freier, 2023; Brumat,
2020). Thereby, asymmetries among nation-states lead to differing priorities and heterogeneous
policy implementation of residency and border integration (Caichiolo, 2017; Nicolao, 2015).
Furthermore, deportations, expulsions, discrimination and unequal treatment of Mercosur
citizens intensify tensions between states (Acosta & Freier, 2023; Gallinati, 2017; Hernández
Granja & Villarreal Villamar, 2017; Rhi-Sausi & Oddone, 2009).
The absence of an effective supranational body within Mercosur allows member states
to dictate the pace and intensity of free movement implementation (Brumat, 2016; CardesaSalzmann, 2012; Rust, 2019). Decision-making by consensus often results in paralysis, delays
and varied interpretations of agreements (Dupeyron, 2009; Nejamkis, 2017; Nicolao, 2015).
Consequently, Mercosur’s limited influence over internal legislation is exacerbated by differing
rationales among member states (Matiuzzi de Souza, 2016). Weak legal foundations based on
varying interpretations and lack of crucial information necessary for uniform execution
additionally impede effective implementation (Acosta, 2019; Acosta & Freier, 2023; Brumat,
2016). Inadequate regional and national institutions, along with a lack of civil society partici­
pation, also complicate free movement implementation (Acosta, 2016; Caichiolo, 2017;
Nicolao, 2015). Despite initial integration of social actors in social summits, their influence
has waned since 2015 (Ramanzini Junior & Luciano, 2021). Furthermore, there is an absence
of an official right of entry within Mercosur’s free movement framework (Bauböck, 2024;
Cardesa-Salzmann, 2012) which has been described as a ‘major drawback’ in the Residence
Agreement by Acosta (2019, p. 13). This is attributed to the agreement’s historic development:
The long-term goal of the agreement was to solve the situation of irregular regional migrants
which resulted inter alia from the difficulty to patrol large borders and the necessity of states
to have knowledge of those who already resided within their territory (Brumat & Acosta,
2019; Montenegro Braz, 2018).
State-led free movement implementation undoubtably faces significant obstacles, impeding
free movement for Mercosur citizens. However, understanding the interplay between top-down
processes and bottom-up practices is crucial. Therefore, the article examines the relation
between those two drivers in the context of regional free movement in the following. It analyses
state-led approaches to implementing relevant agreements and bottom-up practices, including
migrant practices and civil society involvement. These dynamics are essential for evaluating the
actual materialisation and scope of free movement within Mercosur.
4. DATA AND METHODS
In order to analyse the different drivers of free movement in an intergovernmental integration
project, three illustrative member states were chosen to delineate national dynamics within the
overarching regional process – namely Uruguay, Argentina and Brazil. Uruguay hosts the main
Southern Common Market (Mercosur) institutions such as the Parliament, and Argentina and
Brazil are major players in the regional implementation process.
To facilitate their examinations, a systematic document analysis (Bowen, 2009) was con­
ducted. The method is particularly suitable for the study of organisations and institutions, as
their activities are largely mediated by official documents (Salheiser, 2019). The data encom­
passed documents from key stakeholders engaged in migration management in Mercosur,
which were publicly accessible online. The temporal scope of the study spanned from 1991,
marked by the founding treaty of Mercosur, to the interviewing period conducted in November
2022. The relevant actors and their respective documents include: 41 final declarations of the
South American Conference on Migration (CSM), the recollection of all decisions and
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Intraregional mobility and free movement in Mercosur
495
meetings of the Specialised Migration Forum (FEM), eight reunion reports of the Mercosur
Work Subgroup Number 18 on Border Integration (SGT N° 18) of the Common Market
Group (GMC), 59 treaties, agreements and decisions of Mercosur and, finally, migration legis­
lations of the national case studies. Furthermore, available documents by the Social Institute of
Mercosur (ISM) and the Institute for Public Policy and Human Rights (IPPDH), which are
also involved in migration-related processes but not solely, were combed by full-text-search
of the root words1 pertinent to the research topic. A list of analysed documents is provided
in the Appendix in the online supplemental data.
Once the relevant documents were identified, they were systematically coded using
MAXQDA. This process combined deductive and inductive approaches, as recommended by
Kuckartz and Rädiker (2022). Deductive codes were informed by existing literature, while
inductive codes emerged organically from the data. Key codes included objectives and instru­
ments related to regional integration and free movement, relationships between institutional
actors, conflicts and barriers in the implementation of frameworks, and migrant practices and
strategies in response to these barriers. The coding system was applied iteratively to ensure con­
sistency and depth in the analysis. The coded data were analysed using qualitative content analy­
sis (Mayring, 2002) to identify patterns, themes and categories within the documents.
Paraphrased and abstracted coded sections were then linked back to the conceptual framework
of this article, ensuring a coherent integration of findings with the theoretical underpinnings of
the research.
The document analysis was further enriched by 26 semi-structured interviews with 35 sta­
keholders, of which 20 were policy-makers at the regional (Mercosur) and national (Uruguay,
Argentina, Brazil) level, and 15 were representatives of civil society, migrant organisations,
NGOs or academia. The interviews were conducted in Buenos Aires (Argentina), Montevideo
(Uruguay) and Brasilia (Brazil) during a 21 days research trip in November 2022. A list of inter­
view partners is provided in the Appendix in the online supplemental data.
The selection of interviewees was guided by their relevance to the research question, ensur­
ing representation from multiple levels of governance and a balance between state and non-state
perspectives. Furthermore, the selection of interview partners aimed to capture the implemen­
tation of migration laws at the regional and national level by interviewing prominent policy
actors within the Mercosur region, with a focus on Uruguay, Argentina and Brazil. The sample
includes actors from governmental institutions, such as ministries of labour, justice and the
interior, as well as representatives from specialised forums and commissions like the Specialised
Migration Forum (FEM) and the Mercosur Parliament (PARLASUR). These actors were
selected to shed light on top-down, institutional perspectives on migration governance and
free movement frameworks. Bottom-up dynamics, non-state practices and mobility dynamics
in subnational border regions are then highlighted by additionally interviewing civil society
actors, including non-governmental organisations, grassroots movements and migrant advocacy
groups. By including various stakeholders, diverse opinions can be juxtaposed to provide a com­
prehensive understanding of regional free movement and its drivers.
The explanatory interviews (Bogner et al., 2014) touched upon the following topics:
relationship between global, regional, national and local governance, actors influencing
migration policies in Mercosur, border management measures in Mercosur, conflicts and bar­
riers to free movement in Mercosur, and bottom-up practices of migrants and civil society
organisations. The focus of the interviews was on conflicts and barriers of implementation of
regional free movement policies in Mercosur at the regional and national level, the consequences
on regional migrants, and their strategies and every-day practices in the context of these barriers.
The interviews were transcribed verbatim and, along with the selected documents, coded
combining deductive and inductive approaches as recommended by Kuckartz and Rädiker
(2022), based on the same codes as the document analysis. The interviews were also analysed
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Zoé Perko
by a qualitative content analysis (Mayring, 2002). The analysis distinguished between different
forms of knowledge based on Przyborski and Wohlrab-Sahr (2021): operational knowledge of
their institution, interpretative knowledge in a certain discourse arena and contextual knowledge
they touch upon in their role. The last two forms of knowledge can be seen critically by the
investigator, even if the person interviewed is labelled as an expert, thus allowing a more differ­
entiated analysis of the interview. Following the completion of the document and interview ana­
lyses, the findings of the thematic coding and analysis of the data from both methods were
synthesised to address the research question. This was achieved by examining, first, state-led
implementation barriers and, second, bottom-up migrant practices and their interaction with
the former. These findings are presented in the next section.
5. EMPIRICAL FINDINGS: STATE-LED IMPLEMENTATION OF FREE
MOVEMENT AND BOTTOM-UP PRACTICES
As highlighted in the literature review, state-led implementation of free movement – despite
notable successes – has encountered numerous challenges, resulting in barriers to regional citi­
zens’ free movement. This section examines the consequences of these challenges on mobility
within the Southern Common Market (Mercosur) and explores the bottom-up dynamics invol­
ving civil society organisations and migrants, illustrating their interplay in the realisation and
scope of free movement within Mercosur. The analysis draws on insights from document analy­
sis and stakeholder interviews.
5.1. Barriers to the state-led implementation of free movement
Various achievements have been reached by the Southern Common Market (Mercosur) in
regard to free movement of regional citizens. Yet, the literature and empirical data unveiled a
significant gap between the theoretical framework and its practical implementation. Therefore,
multiple interviewees noted that mobility and free movement within Mercosur are largely sym­
bolic and declarative rather than substantive (I1.1, I1.2, I4, I5, I8, I10, I17, I20). This is mainly
due to the following reasons:
Firstly, the agreements do not establish the right for resident entry, except for those with
residency permits or tourists staying up to 90 days. This deficiency often leads migrants to
cross borders irregularly, prompting scepticism about the existence of actual free movement
in Mercosur for some stakeholders (I6, I8, I9, I15). For example, a representative of
CAREF, a non-profit organisation advocating for migrants’ rights, noted that ‘[Argentina
has] incorporated the residency agreement into national legislation, which does talk about
free movement. On the other hand, in practice, (…) this is not clearly reflected’ (I6). Similarly,
a member of the Ministry of the Interior of Argentina and Specialised Migration Forum (FEM)
emphasised, that ‘one could talk about free residency, but [they] wouldn’t call it free movement’,
describing it instead as ‘free movement with control’ (I8). These perspectives underscore doubts
about whether Mercosur truly achieves free movement, often drawing comparisons to the
European model (e.g., I6, I8, I11). However, other stakeholders rejected this comparison, con­
sidering the notion of an incomplete free movement framework as Eurocentric, asserting that
free movement can manifest itself differently and is upheld by other agreements and facilitations
(I10, I11, I16, I20, I21.1). They point out that free movement does not necessarily require
unrestricted circulation. As noted by an Argentinian governmental institution, Mercosur’s
free movement framework ‘has a different connotation than in the European Union’, further
adding that an EU-style model is not necessarily their objective (I1.1). This reveals a significant
tension in stakeholders’ perceptions of Mercosur’s free movement framework. On the one hand,
the framework is criticised for its lack of a genuine right to entry. This perceived gap leads to
irregular border crossings and scepticism about whether Mercosur achieves meaningful free
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movement. On the other hand, some stakeholders reject comparisons to the EU as Eurocentric,
arguing that Mercosur’s framework reflects distinct regional priorities and does not aim to repli­
cate the EU model. This divergence reveals the need to contextualise free movement frame­
works within their unique regional dynamics rather than applying universal benchmarks.
Secondly, Mercosur’s institutional structure presents obstacles to effective agreement
implementations due to technical and political reasons, such as the scope of free movement
implementation being strongly dependent on the political interests of current governments
(I1.1, I2, I3, I5, I6, I7, I8, I10, I11.2, I12, I13, I17, I20, I21.2; Fem y Estados Associados,
2021). Especially nationalism, xenophobia and restrictive policies often lead to non-implemen­
tation and non-compliance with free movement policies (I3, I4, I5, I6, I7, I11.2, I12, I17).
Therefore, as one representative of a government institution puts it, ‘it is totally misguided to
think that we are moving towards a scheme of regional citizenship or free movement in
South America. It seems we are increasingly moving towards a more restrictive scheme’ (I3).
Furthermore, insufficient staffing and training at borders and administrative departments
further hinder implementation efforts (I2, I9, I13, I16, I20). A joint declaration of civil society
actors at the South American Conference on Migration (CSM) in 2014 emphasises these ten­
dencies by stressing
(…) the need to overcome the distance that often exists between the standards and their effective appli­
cation, as well as to combat the persistence of habits or institutional cultures that hinder the effective
application of standards and agreements. (CSM, 2014)
Thirdly, due to the necessity of consensus in Mercosur decision-making, efforts to strengthen
the framework often face opposition from specific governmental actors. This ‘logic of multila­
teralism, of consensus’ leads to ‘many issues on which there is no progress’, as a representative of
the Mercosurian Institute of Public Policy on Human Rights (IPPDH) notes (I2). The willing­
ness of nation-states stays decisive (I2, I3, I5, I6, I8, I9, I20), leading to Mercosur coming to a
standstill in case different interests don’t align (I7, I1; FEM y Estados Asociados, 2021). For
example, the Mercosur’s Single Migration Agreement (CMC, 2016), intended to replace the
Residence Agreement, encountered hurdles after negotiation in 2014. This agreement
aimed to expand rights and increase flexibility in documentation, with provisions for gradual
elimination of migration controls at internal borders. However, as stated in a document of
the FEM, Argentina and Brazil deemed the proposal unviable (FEM y Estados Asociados,
2021).
Lastly, some agreements face practical challenges due to opposition from specific actors. In
regard to mobility, concerns arise regarding the arbitrary rejection of many Mercosur citizens
along with human rights violations by border officials at internal borders, raising questions
about adherence to free movement agreements (I3, I4, I5, I6, I9). Despite regulations allowing
regional citizens to enter as tourists, residents or residency applicants with proper documen­
tation, ‘a large number of cases of discretionary behaviour by public officials from different
departments, arbitrary refoulement or rejection, abuses and violations of rights’ have been
noted by the CSM (CSM, 2014). Harassment and rejection by border agents occur along inter­
secting lines of discrimination, predominantly impacting Indigenous and racialised migrants
from countries like Bolivia, Paraguay and Colombia, as well as along socio-economic back­
ground and gender (I5, I12).
A Bolivian activist illustrates these findings:
Even being from Mercosur, it is difficult to cross the border, they stigmatise us if we have a different skin
colour. (…) Even having a document, being part of Mercosur, they treated me like a clandestine (…).
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Mercosur is nice, isn’t it? But only for those (…) who have money. (I5, Frente Social Migrante,
Argentina)
In sum, the main barriers to mobility within Mercosur for regional citizens include the absence
of an official right of entry, ineffective implementation of certain agreements, unsuccessful
attempts to strengthen existing frameworks, along with practical issues at internal borders, as
documented by empirical research. These significant gaps in ensuring equitable and functional
mobility for regional citizens result in a disconnect between the aspirational goals of Mercosur
agreements and their practical implementation as well as enforcement, undermining equitable
and functional mobility for regional citizens.
5.2. The interplay between top-down and bottom-up practices
Clearly, numerous obstacles impede migrants and mobile citizens from moving freely within the
Southern Common Market (Mercosur) region. However, top-down free movement implemen­
tation is not the sole driver influencing mobility. The process is complemented by informal and
formal bottom-up practices below the national and regional level, as detailed in the subsequent
section.
The potential role of civil society organisations as drivers of regionalism has been empha­
sised by the New Regionalism Approach and consolidated by Comparative Regionalism
(Söderbaum, 2016). However, a widespread absence of civil society inclusion in Mercosur,
both in matters of migration and mobility, was reflected in empirical data collected for this
article. Despite calls from the South American Conference on Migration (CSM) to include
civil society in various reports and declarations (CSM, 2001b), their participation remains lim­
ited. Although civil society organisations are active in forums like the CSM and have cooperated
with national institutions, especially widespread in Uruguay, their involvement with Mercosur
institutions is minimal, with many organisations compensating for national shortcomings (I3,
I4, I6, I11, I12, I15). As a representative of an Argentinian governmental institution (I3)
notes, ‘organisations that defend migrants’ rights and public defenders often have to defend
migrants’ rights regarding agreements on residency and free movement’. Yet, according to
CAREF, ‘civil society has no participation in any of the Mercosur forums or thematic groups’
(I4), thus only having limited influence in top-down policy-making. This highlights an impor­
tant gap in the inclusion of civil society within Mercosur’s top-down policymaking processes
regarding migration and mobility matters. This lack of institutional engagement forces civil
society organisations to compensate for governmental shortcomings, stepping in to defend
migrants’ rights and address shortcomings in the implementation of agreements on residency
and free movement. Civil society thus has a critical role in sustaining regional mobility, even
as their exclusion from formal frameworks limits their broader impact on regional governance.
Migrant cross-border practices and communities in border regions are, however, a signifi­
cant aspect of bottom-up free movement materialisation in Mercosur.
Whilst each Mercosur country sets up numerous authorised checkpoints (Argentina alone
approximately 230), of which many are airports (I1.2, I8), only a fraction of the borders is cov­
ered by controls. Due to its length, which spans approximately 34,000 kilometres, as well as
specific geographical characteristics, many border dyads are beyond full oversight of Mercosur
and other national institutions (I1.2, I3, I8, I10, I18, I20). According to a representative of the
Ministry of the Interior of Argentina and the Specialised Migration Forum (FEM) it is there­
fore considered ‘simply impossible’ to control cross-border mobility ‘one hundred percent’. Fur­
thermore, limited resources restrict permanent personnel deployment in remote areas, resulting
in vast sections of borders being inaccessible or unmonitored, except for designated crossings
(I8, I18). Therefore, as a representative of the Work Subgroup Number 18 on Border
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Integration (SGT N° 18) and Brazilian Ministry of Foreign Affairs explains, this results in
‘strong informality’ at borders, where migrants often operate ‘outside the rules’ (I20).
Consequently, many migrants have been crossing borders without being controlled by
nation states or have found alternative ways of circumventing the state-led shortcomings,
especially in border regions (e.g., I8, I10, I17, I18, I20, I21.2). Free movement thus materialises
through migrant practices that navigate geographical and institutional gaps where top-down
governance proves insufficient. This is largely due to the close connectivity between border
cities, where, as one interviewee from the Ministry of the Interior of Argentina and The
FEM noted, ‘one side of a street is one country and the other side is another, and that’s imposs­
ible to control’ (I8). Similarly, a representative from the SGT N° 18 and Brazil’s Ministry of
Foreign Affairs similarly stated, ‘there’s no way to control the flow between the cities’, resulting
in ‘practically free movement’ in such areas (I20). Therefore, daily cross-border activities, such as
working in a neighbouring country while residing in another, are common, as highlighted by a
former representative of the Mercosur Social and Labour Commission and Uruguay’s Ministry
of Labour (I10). For instance, despite the absence of a legal framework allowing ambulances and
fire trucks to cross borders, irregular crossings are frequent to access the nearest hospital (I20).
This illustrates how the permeability of Mercosur’s border regions fosters bottom-up prac­
tices that effectively bypass state-led limitations. Free movement materialises through migrant
practices that navigate geographical and institutional gaps where top-down governance proves
insufficient. Close connectivity between border cities enables informal cross-border activities,
such as commuting for work or accessing essential services, which persist as deeply rooted tra­
ditions rather than legal authorisation.
Adapting to the circumstances, Mercosur countries, particularly Brazil,2 have adopted a
specific approach to territoriality, shifting from an impossibly stringent border control and crim­
inalisation to regularisation: Rather than attempting to monitor national borders, these states
prioritise the regularisation of migrants to facilitate governance and ensure awareness regarding
their migrant populations (1.1, I1.2, I2, I3, I8, I10, I11.1, I12, I13, I18, I15.2). This strategy
promotes easy pathways for individuals to formalise their status, discouraging clandestine resi­
dency (I1.2, I3, I8, I13, I17, I18, SGT N° 10, 2004). The Federal Police of Brazil and a policy
advisor from Argentina underscore this trend with the following statements:
There’s a lot of kilometres to supervise. And we try to make it easy and quick for people to register and
not escape from the regular path. It’s easier to have control and to allow than be too severe (…) because
we know restrictive laws don’t hinder, they make it harder, more difficult, expensive, but people still cross
the border. (I18, Federal Police, Brazil)
We have (…) a number of crossings that do not have forces there, so that is also part of why an easy
regularisation system (…), because we know that the migrants enter. (I1.2, Policy Advisor, Argentina)
This approach shifts the focus from strict enforcement to fostering awareness of migrants’ pres­
ence and movements, emphasising governance through regularisation rather than rigid control
of entry and exit. Interestingly, the Mercosur institutions interviewed do not perceive these
informal practices as problematic, besides the fact of having to accept them for pragmatic
reasons: Policymakers emphasise that migration is not a security issue, aside from isolated
minor crimes, and view regularisation as a way to enhance security. A representative of Uru­
guay’s Ministry of the Interior and the FEM noted that it is ‘preferred to have a person ident­
ified, with their fingerprints registered, rather than an irregular migrant whose identity and
whereabouts are unknown’ (I13; approach confirmed by I1.2, I3, I8, I18, I20).
Furthermore, in the case of subnational cross-border regions, such as those with neighbour­
ing border towns, border crossings and free circulation are integral to daily life and a historical
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pattern, often occurring without control (I8, I10, I17, I18, I20). As a representative of Argen­
tina’s Ministry of the Interior and the FEM explained, border communities ‘have a way of life
where one person lives on one side of the border and their family – mother, father, uncle,
brother – lives on the other side. So, for them, the border is something daily’. Similarly, the
CSM emphasises that while this mobility is facilitated by regional integration efforts, its
roots lie in historical and fraternal ties, shared culture and traditions among citizens of the
region. Thereby, the movement of people within South America signifies the restoration of a
historical unity, while the continuous flow of individuals to and from different states character­
ises the region’s shared cultural and historical reality (CSM, 2001a, 2001b, 2004). This histori­
cal interconnectedness predates formal integration, underscoring the need for Mercosur states
to ‘strive for its deepening and dynamization’ (CMC, 2002b, p. 1). Furthermore, the region’s
migration policies reflect an open, human-rights-based approach that places migrants at the
centre of migration policy (I1.1, I1.2, I2, I4, I8, I10, I15.2, I18). As one Argentinian govern­
ment representative stated, ‘none of the states in the region has a truly securitising approach to
migration, but rather an open, inclusive approach’ (I1.1). The empirical material thus shows the
historical and cultural interconnectedness of South America’s subnational border regions, where
daily cross-border mobility predates modern integration policies. This longstanding way of life
reflects shared traditions and fraternal ties, emphasising the need for migration policies that
build on these historical patterns and prioritise an open, human-rights-based approach.
Moreover, these migrant practices are regarded as a significant bottom-up contribution that
supplements overlooked elements in state-led free movement implementation. As such, they are
not only accepted but also lauded for promoting and bolstering free movement and integration.
This perspective is exemplified by the viewpoint expressed by a member of the SGT N°18, who
highlights, that even though the region has a ‘national, bilateral and regional legal framework,
(…) many times things happen outside of that’. He further juxtaposes the ‘capitals’ representing
state-led practices with migrant practices in the following quote:
I personally believe that informality that is not illegal, (…) can function as an incentive to greater open­
ness and integration. At the border, people often get one step ahead of the law and in the capitals, we are
behind in trying to regulate things in the way they already work in practice. (…) The problem is not in
the borders; the problem is in the capitals. (…) I believe that the border communities are totally in favour
of greater integration and even free circulation. (…) We feel and hear from the border people a clear
disposition to open the borders, to have more circulation. (…) everything they can do informally,
they do outside the rules. (I20 Work Subgroup Number 18 on Border Integration (SGT N° 18) /
Ministry of Foreign Affairs, Regional / Brazil)
Later in the interview, the interviewee notes that in border cities, ‘crossing can happen in a more
free, even informal way, so things are more integrated’. Similarly, a member of the Mercosur
Parliament (Parlasur) states that ‘in border areas, there is free circulation. This is where Merco­
sur, so to speak, works’ (I21.2). The CSM (2010) further emphasises that migratory movements
are ‘an expression of the region’s integration process’, highlighting the need to enable free mobi­
lity within this regional space (p. 3). These quotes illustrate that informal cross-border circula­
tion not only complements top-down regional free movement but also strengthens regional
integration as a whole.
Thus, migrants play a crucial role in the mobility dynamics of Mercosur, prompting member
states to adjust policies rather than resorting to criminalisation. Border community voices are
incorporated into discourse, and institutions are cognisant of their social realities, explained
by historical and regional patterns. Some bottom-up practices thus compensate for the inade­
quacies of top-down free movement frameworks in Mercosur as they often surpass formal regu­
lations, showcasing a level of integration that state-led efforts struggle to achieve. By filling gaps
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left by regional and national policies and their enforcement, these bottom-up dynamics not only
support but actively drive regional integration, leading to policymakers to acknowledge and
adapt to these realities.
6. DISCUSSION
This article examined a crucial aspect of regional integration: the facilitation of intraregional
mobility, primarily achieved through free movement frameworks. Drawing on theories of
New and Comparative Regionalism, and by analysing key documents and interviews with 26
stakeholders, the article delved into the interaction between top-down and bottom-up dynamics
of free movement within the Southern Common Market (Mercosur). New and Comparative
Regionalism approaches critique Eurocentric perspectives of regional integration, highlighting
the role of bottom-up actors such as migrants and civil society (Börzel, 2011; De Lombaerde
et al., 2010; Hettne & Söderbaum, 1999, 2000; Nita et al., 2017; Schulz et al., 2001; Söder­
baum, 2004, 2016). While studies on regional migration governance (Grimson, 2005; Lavenex
& Piper, 2022) and free movement frameworks (Arhin-Sam et al., 2022 for the Economic
Community of West African States) emphasise migrant practices’ contributions to integration
and free movement materialisation, the bottom-up dynamics shaping regional free movement in
the Southern Common Market (Mercosur) remain underexplored – an empirical gap addressed
through this article. By focusing on subnational border regions in Mercosur, the article chal­
lenged traditional, state-centric definitions of regional free movement and highlighted the
need for a broader understanding that incorporates mobility dynamics beyond Europe. These
insights in regard to regional free movement contribute to expanding understanding in the
field of regionalism studies beyond Eurocentric perspectives.
The Southern Common Market has established a robust free movement framework, notably
through the Residence Agreement. However, challenges in translating its approach into effec­
tive state-led implementation hinder the intraregional mobility of Mercosur citizens.
On the one hand, the absence of a right of entry restricts intraregional mobility to specific
individuals fulfilling certain conditions, a limitation illustrated by various stakeholders and
widely recognised in literature (Acosta, 2019; Bauböck, 2024; Cardesa-Salzmann, 2012).
Some stakeholders, however, reject Eurocentric comparisons to the EU and view Mercosur’s
approach as appropriate for its regional context, emphasising regularisation rather than unrest­
ricted cross-border mobility. This aligns with historical objectives to address irregular migration
within vast and unmanageable borders (see also Acosta, 2019; Bauböck, 2024; Brumat &
Acosta, 2019; Montenegro Braz, 2018), highlighting the importance of non-Eurocentric
perspectives on regional integration and hence free movement, as advocated by New and
Comparative Regionalism approaches.
Furthermore, Mercosur’s state-led implementation is constrained by political will, insti­
tutional weaknesses and resource disparities. Here, the interviews and documents reflect existing
literature on state-led free movement implementation in Mercosur, highlighting decision-mak­
ing by consensus, the absence of supranational enforcement mechanisms, and varying national
priorities result in inconsistent implementation (see e.g., Acosta & Freier, 2023; Brumat, 2016,
2020; Cardesa-Salzmann, 2012; Matiuzzi de Souza, 2016; Nicolao, 2015; Rust, 2019).
Additionally, stakeholders report discriminatory practices and arbitrary rejections at internal
borders that affect certain regional citizens. This limitation has, however, received minimal
academic attention, with the exception of Cossi (2019) in the context of cross-border workers
between Paraguay and Argentina.
Stakeholders generally conveyed a pessimistic view of top-down policy implementation,
especially citing the renationalisation of policies and rising xenophobic tendencies in the region.
However, as highlighted by New and Comparative Regionalism, focusing solely on state-led
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policymaking offers an incomplete understanding of free movement. Some of these limitations
concerning the circulation of regional citizens are addressed by bottom-up approaches through
migrant practices and traditional mobility in border regions, despite civil society inclusion
within Mercosur remaining low. While civil society’s role in top-down policymaking thus
remains weak, empirical findings and literature indicate its broader exclusion in Mercosur,
especially concerning migration and mobility (see also Caichiolo, 2017; Nicolao, 2015; Raman­
zini Junior & Luciano, 2021). In response, migrant organisations and NGOs have stepped in to
address state shortcomings, advocating for free movement rights and playing a key role in
advancing Mercosur’s free movement framework.
However, the key finding of this article, is that bottom-up practices, particularly in sub­
national border regions, address gaps in state-led implementation and enforcement, which
significantly contribute to the realisation and scope of the free movement framework. The
inability to fully control intraregional borders, as well as some normative considerations, has
led policymakers to shift their focus from restrictive border control to regularisation strat­
egies, accepting historical cross-border mobility. Furthermore, these informal practices are
seen as a crucial bottom-up contribution, addressing gaps in state-led free movement
implementation. Policymakers recognise these practices as a means of materialising policy
goals, thus expanding the scope of free movement and fostering greater regional inte­
gration. Unlike securitised approaches, migration is viewed pragmatically, with regularis­
ation enhancing security, respecting established cross-border practices and enforcing
regional integration. This interconnectedness enforces the arguments made by Söderbaum
(2016) and Gómez-Mera (2008), who criticise the rigid divide between formal and infor­
mal processes.
Despite top-down policy limitations, migrants therefore continue to circulate freely in
border regions, driven by historical ties and daily necessities. These border regions thus
emerge in spite of the partial resistance of state borders (Sohn, 2018), through which terri­
torial demarcations have become obsolete to internal movement in accordance with suprana­
tional goals of the macroterritory. Cross-border interactions and mobility in subnational
border regions thus represent key dimensions and agents of regional free movement and
integration, representing a ‘de facto’ form of free movement, rooted in local integration pat­
terns and regional interconnectedness, as suggested by Dupeyron (2009) and Grimson
(2005), while reinforcing the research agenda for border studies (Kuhn, 2015; Makkonen
& Williams, 2016).
The findings thus show that a multilevel governance approach, as advocated by New and
Comparative Regionalism, is essential to capture the interaction and mutual reinforcement of
top-down state efforts and bottom-up contributions through migrants. It underscores the
importance of moving beyond rigid dichotomies of formal versus informal processes in
free movement and more generally regional integration, as bottom-up practices are not exter­
nal to governance structures but deeply embedded within them, shaping their evolution and
effectiveness. Regional free movement and integration in Mercosur is as much a product of
historical patterns and social realities as it is of formal institutional design, by migrants and
border communities acting as agents of integration. Theoretical frameworks of regional free
movement must therefore conceptualise regional integration as a multilevel and interactive
process where informal actors and practices play a constitutive role alongside formal insti­
tutions. By integrating these levels, this article broadens the conceptualisation of free move­
ment frameworks to include practices that are often invisible in state-focused analyses,
thereby enriching the literature. Furthermore, unlike the EU model, which is mostly treated
as the normative standard, Mercosur’s approach integrates regularisation policies and infor­
mal practices shaped by historical cross-border connections. Moving beyond Eurocentric
models, this perspective thus emphasises the need to understand regional free movement
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within its unique historical and cultural context rather than through hierarchical comparisons
with the European framework.
7. CONCLUSION
The major finding of this article reflects that bottom-up practices, especially present in cross-bor­
der regions, partly compensate the absence of a formal right of entry, inadequate implementation
of movement facilitation agreements and impeded progress in the realm of regional free move­
ment in the Southern Common Market (Mercosur). Despite unsolved issues of discrimination
at official border points, informal movements not only persist due to the relative scarcity of auth­
orised border crossings but even act as a driving force of regional free movement. Mercosur insti­
tutions recognise these informal movements as complementary to state-led free movement efforts,
particularly in border regions where actual free movement materialises. The approach to free
movement in the Mercosur region thus demonstrates a dynamic interplay between formal topdown implementation processes, migrant practices and the unique approach to border control
and regularisation by regional institutions. Cross-border interactions and mobility in these subna­
tional regions emerge as key dimensions of regional free movement and integration, showing the
importance of integrating informal practices into the governance framework.
This approach to migration and border control reinforces the initial argument for a nonEurocentric conceptualisation of regional free movement. While definitions based on the Euro­
pean Union (EU) or global free movement typically include the right of entry as fundamental
(see e.g., Bauböck, 2024), the Mercosur region challenges this notion by prioritising regularis­
ation over strict border control in adaptation to regional circumstances and normative consider­
ations. Consequently, the requirement for a specific right of entry for regional free movement in
Mercosur is partially mitigated. Rather than emphasising the right of entry, Mercosur’s
approach acknowledges geographical and historical cross-border dynamics as integral com­
ponents of free movement. It demonstrates that not all components of European free movement
have to be incorporated in the top-down implementation in order for free movement to materi­
alise. This illustrates the importance of integrating bottom-up dynamics emphasised by New
and Comparative Regionalism and their interplay with top-down processes, while transcending
the dichotomisation between formal and informal, as well as state and non-state driven (Söder­
baum, 2016). Furthermore, it emphasises the necessity to acknowledge the diverging instru­
ments of regional free movement in relation to specific regional contexts instead of a
hierarchical assessment in relation to European ideals by providing a robust geographic counter­
point. These aspects become crucial in shaping a universal and accurate conceptualisation of
regional free movement, a task that has yet to be tackled.
ACKNOWLEDGMENTS
The author is exceptionally grateful to Dorothea Biaback Anong for the insightful discussions
on previous versions of this article, as well as to Johanna Porten, Eren Aytaç, Solva Bergmann
and Philipp Weitzel for their support and editing. I acknowledge support by the Open Access
Publication Fund of Humboldt-Universität zu Berlin.
DATA AVAILABILITY STATEMENT
The documents are available through the links provided within the supplementary materials of
this article. The interview data cannot be made available due to the absence of participant con­
sent and the sensitive nature of the research.
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DISCLOSURE STATEMENT
No potential conflict of interest was reported by the author(s).
FUNDING
This work was supported by the Deutsche Forschungsgemeinschaft (DFG, German Research
Foundation), Project-ID 290045248 – SFB 1265.
ETHICS APPROVAL
As part of the CRC1265 ‘Re-figuration of Spaces’ the study has received approval according to
the ethical guidelines established in the ‘Code of Ethics of the German Sociological Association’
(DGS). According to German national regulations no further approval was required. All inter­
view participants provided informed consent by signing a form confirming their voluntary par­
ticipation, consent to audio recording, agreement to the use of their statements in publications
and acknowledgment of the anonymisation of personal data. The interview transcripts were
carefully anonymised to ensure that no participants are identifiable based on the information
presented in this manuscript. Additionally, participants were explicitly asked whether they
wished for the anonymisation to extend to their organisation and/or position. Due to the sen­
sitive nature of the research, participants did not provide written consent for their data to be
publicly shared. Consequently, the data is not available.
NOTES
1
The root words encompassed: ‘Fronter’, ‘Migra’, ‘Mobil’, ‘Movil’, ‘Circulaci’, ‘Ciudadan’,
‘Residen’, ‘Visa’ which are root words for the English terms border, migration, mobility, circu­
lation, citizenship, residency and visa.
2
Brazil’s migration law overhaul in 2017 marked a significant shift away from the criminalisa­
tion of migration towards regularisation. This transition acknowledges the sizable portion of the
population residing irregularly, posing governance challenges. Similar inclinations were
observed in Uruguay and Argentina, as evidenced by their respective case studies, and described
by Acosta and Freier (2023) in regard to Ecuador, a country that is an associate country of Mer­
cosur and that affirms in its constitution, that no individual should be identified as illegal
because of their migratory status.
ORCID
Zoé Perko
http://orcid.org/0009-0006-9312-9293
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