Abstract

This article focuses on public debates and public policy on the Islamic headscarf in the Netherlands and Germany. In the Netherlands the Islamic headscarf meets with an accommodating policy reaction, while in Germany some eight federal states have introduced legislation to ban the headscarf. This difference is explained, so I argue, by national differences in citizenship traditions. While the Netherlands represents a multicultural model, Germany used to be the paradigmatic example of an ethno‐cultural model of citizenship. Yet, the reaction of the German left to the headscarf, while often non‐accommodating, is very differently inspired by German history than that of the right. A commonality is that in both countries the issue is framed as a conflict between public neutrality and religious freedom, not gender equality. An effect of the focus in the debate on neutrality is that it obscures the agency of Islamic women and the gender dynamics in Islamic communities.