ABSTRACT
A simultaneous observation of European and domestic developments shows that, since the mid-1980s, refugee policies in Germany and France were no longer determined by domestic considerations alone. The discourse on limiting the asylum right has had a relatively long recent history in Germany. France's revision of its constitutional asylum right in 1993 differed in two important respects from that of Germany: the immigration discourse had a broader scope and the institutional conditions made a constitutional reform easier. The regulation of constitutional reforms in France gives the political leadership an extraordinarily powerful role as it basically requires agreement between the Prime Minister and the President. The concerns sovereignty and border controls in the Schengen debates of the early 1990s related to the problems of drug trafficking and illegal immigration; the category of "bogus" asylum seekers was only very rarely explicitly subsumed under this category.
