EU Citizenship based on Common Values: Implications of Commission v Malta (C-181/23) for the European Dimension in Citizenship Education

The Commission v Malta judgment defines EU citizenship as a status grounded in common values, mutual trust, and solidarity. By declaring Malta’s commercialisation of citizenship illegal, the Court affirms the pivotal role of EU citizenship within the Union’s constitutional framework, recognising that citizenship is not just a formal legal category but the basis for a socially meaningful bond. This interpretation has implications for citizenship education, requiring curricular content that reflects the constitutional significance of EU citizenship in a system specific to the Union. In exercising their competence in education, Member States should not manifestly disregard the European dimension and the very nature of EU citizenship. Citizenship education aligned with the EU Treaties and the Charter of Fundamental Rights aims to prepare citizens for effective participation in democratic life. Revisiting the untapped potential of Article 165(2) TFEU, the EU must breathe new life into the Treaty-based “European dimension in education”, which is distinct from mobility and internationalisation, and support the development of a citizenship education framework tailored to the European context in order to empower citizens to actively contribute to democratic resilience.