Changing Landscapes of
Heteronormativity: The Regulation
and Normalization of Same-Sex
Sexualities in Europe

Sasha Roseneil1, Isabel Crowhurst2, Tone Hellesund3,

Ana Cristina Santos4 and Mariya Stoilova1

This paper explores transformations in institutional norms about same-sex sexual-

ities across four European countries: Bulgaria, Norway, Portugal and the UK.

Focusing on the period from the late 1960s to the present day, it examines both

endogenous, path-dependent nationally specific factors at work in the changing

regulation of same-sex sexualities, particularly the campaigns of lesbian and gay

movements, and exogenous influences exerted by processes of Europeanization

and transnationalization. Three processes of normative change are discussed: the

legitimation of same-sex sexual practice; the protection of lesbian, gay and bisexual

(LGB) people; and the recognition of intimate relationships. We argue that there

has been a radical shift in the landscape of heteronormativity in Europe, with the

emergence of a new European norm of “homotolerance” and the progressive nor-

malization of same-sex sexualities: a process of “homonormalization”.

Introduction

Over a decade ago Anglo-American and Nordic sociologists began to
identify significant contemporary transformations in the organization and reg-

ulation of same-sex sexualities. For instance, Seidman (2002) argued that

many people in the USA are living “beyond the closet”, their homosexuality
subjectively “normalized” and “routinized” in their everyday lives and social

interactions. In Denmark, ten years after the introduction of the first law

allowing same-sex partnership registration, Bech (1999) took a stronger

1
Birbeck, University of London, UK, s.roseneil@bbk.ac.uk

2Kingston University, UK
3University of Bergen, Norway
4
Centre for Social Studies, University of Coimbra, Portugal

Socpol: Social Politics, Summer 2013 pp. 165–199

doi: 10.1093/sp/jxt006
# The Author 2013. Published by Oxford University Press.

All rights reserved. For permissions, please e-mail: journals.permissions@oup.com

Advance Access publication May 12, 2013

Social Politics 2013 Volume 20 Number 2

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position, suggesting that the distinctive figure of the modern homosexual is

disappearing in parts of continental north-western Europe. Drawing on

British data, Weeks, Heaphy and Donovan (1999) pointed to a growing con-
vergence in the ways of life of homosexuals and heterosexuals, with Weeks

more recently arguing that there has been “a long, unfinished but profound

revolution that has transformed the possibilities of living sexual diversity and
creating intimate lives” (Weeks 2007: x). And Roseneil (2000; 2002) proposed

an understanding of the postmodernization of the western regime of sexuality,

characterized by a number of “queer tendencies” in social relations, popular
culture, political activism and critique that question the normativity and natu-

ralness of heterosexuality, and re-configure the hierarchical inside/ outside,
binary relationship between heterosexuality and homosexuality. Alongside
these arguments, there is a body of work that has focused on “sexual citizen-

ship” (Weeks 1998; Richardson 1998; Bell and Binnie 2000; Cossman 2007),

“intimate citizenship” (Plummer 2003; Roseneil et al. 2012) and the legal reg-
ulation of same-sex sexualities (e.g. Wilson 1994; Stychin 1995, 2003, 2004,

2006a, b; Herman and Stychin 1995; Stychin and Herman 2000; Phelan 2001;

Cretney 2006; Andersen 2009), which offers a detailed and politically engaged
critique of the ways in which non-normative practices of sexuality and inti-

macy are regulated by law and policy.

Sitting at the intersection of these two approaches, this paper argues that
the period since the late 1960s has seen a radical restructuring of institutional

norms about same-sex sexualities in Europe. Central to the paper is the

concept of heteronormativity, which draws attention to the multitudinous
(social, legal, political, cultural) ways in which heterosexuality is normalized,

naturalized and privileged as an institution, and to the ways in which homosex-

ual practices and relationships are excluded, stigmatized, marginalized and
minoritized.

1
In analyzing the changing landscape of law and policy as it

relates to same-sex sexualities, we focus on macro-level processes of normative

change, and the “crucial moments of normative decision” (Therborn 2004),
that constitute the legal displacement and partial dis-establishment of hetero-

normativity and the parallel emergence of a new European legal norm of

“homotolerance”, which is part of a wider process of normalization of same-
sex sexualities.

Extending beyond the national contexts that are the primary focus of

Anglophone scholars of sexuality, our analysis encompasses Bulgaria,
Norway, Portugal and the UK.

2
A European comparative perspective is

important because of the growing significance of the European Union, both

in terms of its expansion across Europe, and the extension of its formal com-
petence, and because European institutions have played a particular role in

relation to the regulation of same-sex sexualities in recent years. The article

attends both to endogenous, path-dependent, national, and culturally
specific factors at work in the regulation of same-sex sexualities, and to exog-

enous influences, exerted by processes of European transnationalization and

globalization.

166 Roseneil et al.

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National Contexts: Welfare, Sexuality
and Social Movements

The countries discussed are a “social democratic” Nordic welfare state

(Norway), a “liberal”, or, perhaps more recently, a “social investment” or
“neo-liberal”, welfare state (the UK), a “post-communist” state (Bulgaria) and

a “Southern European”, post-dictatorship state (Portugal). Neither Esping-

Andersen’s (1990) work on welfare regimes, nor his feminist critics (e.g.
Lewis 1992; Orloff 1993; 1996; O’Connor 1993; Sainsbury 1996; Pascall 1997;

Daly 2000) pay any significant attention to issues of sexuality or same-sex

relationships, being largely, and unquestioningly, concerned with the hetero-
sexual family, and the relationships between men, women, the state and the

market, in the work of heterosexual social reproduction. Despite this, and in

the absence of any parallel comparative analysis of what might be called “sex-
uality regimes” or “intimate citizenship regimes”, a brief overview of the

welfare regimes and of the patterning of gender and intimate life in each of

the four countries provides important context for understanding the path
dependence of the changing regulation of same-sex sexualities within nation

states. The importance of the idea of “welfare regime” is that it proposes that

the normative arrangement of welfare in any given country, the historical
compromises, political ideologies and institutional relationships between state,

market and “family” - or intimate life more broadly-play a dynamic role in

the construction of relationships of gender, “race” and ethnicity (Esping-
Andersen 1990; Schierup, Hansen and Castles 2006), and we suggest, also of

sexuality. Particularly salient to our concerns here is the extent to which

welfare regimes facilitate “a socially acceptable standard of living, independ-
ently of family relationships, either through paid work or social security provi-

sions” (Lister 1997: 173; also Orloff 1993; O’Connor 1993).

As a “social democratic”
3
(Esping-Andersen 1990), “woman-friendly”

(Hernes 1997) welfare state, Norway has a legacy of low “conceptual polariza-

tion of genders” (Löfström 1998) and an extensive history of feminist activism,

which gave rise to a “progressive maternalism” (Hagemann 2007) and exten-
sive state commitment to gender equality. Norway is a country with a high

degree of universalism in welfare policy, with a de-familialized (Lister 1997),

individualized family policy, in which most benefits are defined without refer-
ence to family status. Part of the Nordic “vanguard of the dismantling of

explicitly patriarchal marriage” (Therborn 2004: 80), there is a long tradition

of legal individualism and “egalitarian marriage” (Melby et al. 2000; Therborn
2004), no fault divorce having been introduced in 1909. We suggest that there

is a connection between this historical organization of welfare and Norway’s

early moves toward homotolerance.
The UK is historically a “liberal” (Esping-Andersen 1990), or “liberal collec-

tive” (Ginsburg 1992) welfare state,
4
orientated strongly toward the market and

means tested benefits, which has transformed more recently under New
Labour into a “social investment state”. Having been a male-breadwinner

Changing Landscapes of Heteronormativity 167

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welfare regime, the UK now expects both men and women to be economically

active individuals, and conceptualizes children as future productive citizens

(Williams and Roseneil 2004). British social policy combines individual and
family-based benefits, but is becoming increasingly individualized (Millar

2003). The UK has a long history of feminist activism, but one which has been

more ambivalent about, and less successful at, entering the state, and hence
which has a less well-established state gender policy machine than Norway.

Bulgaria is part of the distinct cluster of post-communist European welfare

regimes (Fenger 2005),
5
which combine characteristics of Esping-Andersen’s

“social democratic” and “conservative”, traditional-family orientated welfare

regimes. With a history of state familialism and strong pro-natalist policies

under communism that financially penalized those who did not have children
(Roseneil and Stoilova 2011) and favored married couples (Therborn 2004),

Bulgaria also had a constitutional commitment to gender equality, high levels

of female employment (Koeva and Bould 2007) and was the first communist
country to declare marriage constitutionally equal and secular (Therborn

2004). The post-Communist era has seen a diminution in welfare services and

benefits (Heinen 2009), increasing poverty and inequality (Sotiropoulou and
Sotiropoulos 2007), particularly affecting women and minorities, and signifi-

cant declines in marriage and fertility rates, alongside increases in divorce and

births outside marriage (European Commission (EC) 2009).
Portugal transitioned to democracy after the overthrew of the Estado Novo

(1926–1974) dictatorship, which had “promoted values and laws related to the

rural world, marianic Catholicism, the patriarchal family, submission of
women, and a brand of nationalism that worshiped the past and praised colo-

nialism” (Vale de Almeida 2008: 6). Portugal is one of the group of Catholic

“Southern European” welfare regimes characterized by the prevalence of the
informal economy and the lack of resources for welfare expenditure, meaning

that much welfare provision is familial (Ferrera 1996; Trifiletti 1999; Flaquer

2000; Ferreira 2005), and suggesting that they might be seen as “welfare soci-
eties” (Wall et al. 2001) rather than welfare states.

6
With significant involvement

of the Catholic church in welfare provision and policy making (Ferreira 2005;

Portugal 2008), at the same time as there is a socialist focus on workers’ rights
as part of the legacy of the Carnation Revolution of 1974, there has been a

strong symbolic and rhetorical investment in “the family”. As in other

“Southern European” welfare regimes, divorce rates, fertility rates and the
political representation of women are low, and young people leave the parental

home late. But Portugal stands out from other “Southern European” countries

in having a female employment rate closer to Nordic, former Communist
Europe and liberal welfare regimes (Walby 2001) than to other Southern

European countries, and in having a higher proportion of births outside mar-

riage (Coelho 2005).
In both Norway and the UK, active campaigning for the rights of homosex-

uals (UK)/homophiles (Norway) began in the 1950s. An early exemplification
of the processes of transnational diffusion that characterize contemporary

168 Roseneil et al.

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lesbian and gay movements (Adam et al. 1999), a branch of the Danish homo-

phile organization, The League of 1948 was set up in Norway in 1950. Explicitly

referencing the 1948 Universal Declaration of Human Rights (Heli 2006), it
was probably one of the earliest attempts to harness the discourse of human

rights to campaign for homosexual rights. The Norwegian Association

(DNF-48) worked discretely for the decriminalization of male homosexuality
for many years (Kristiansen 2008), but during the 1970s this political agenda

became increasingly visible and new organizations and groups were formed. In

the UK, the Homosexual Law Reform Society, established in 1958, addressed
decriminalization in a similarly moderate and assimilationist way to DNF-48

(Weeks 1977), and in the early 1970s, in the context of the New Left and the

development of feminism, more radical grassroots gay liberationist groups
emerged. In both countries increasingly open lesbian and gay sub-cultures

developed during the 1970s, although lively urban “gay scenes” have been

much stronger in the UK than in Norway. In the UK, the major lesbian and
gay pressure group, Stonewall, was formed in 1989 to campaign against the

anti-gay Section 28 of the Local Government Act, later broadening its remit to

encompass all aspects of lesbian and gay equality. A radical queer politics of
direct action and highly visible protest developed at the same time, instantiated

during the 1990s in the groups Outrage and Lesbian Avengers. In both coun-

tries, the AIDS crisis from the mid-1980s brought gay activists into closer
contact with the state and health and welfare institutions. In Norway, this was

productive of a trustful relationship between the gay movement and the state

(Rydström 2011), and served to forge valuable personal contacts and released
funding for gay/lesbian organizations. State-movement relations were much
more fraught in the UK, where the Thatcher government engaged in openly

homophobic politics (Weeks 2007). From the 1980s onwards, the Norwegian
lesbian and gay movement, like its women’s movement, was much closer to

the machinery of state and political power than was the UK movement, with

important consequences for the pace and timing of legal change in the two
countries that we discuss later.

In contrast to the more dynamic civil societies of Norway and the UK, the

right and left wing authoritarian regimes in Portugal and Bulgaria meant that
there was little social movement activism (Sousa Santos 1992; Daskalova 1999;

Estanque 1999; Brunnbauer 2008), a relatively small urban middle class of the

type that was the backbone of the new social movements in the 1970s and
1980s in western Europe (Scott 1990; Rodrigues 1995), and hence a lack of

possibility for the development of lesbian and gay collective identities and

mobilizations (Cascais 2006; Carneiro and Menezes 2007; Pisankaneva 2009;
Roseneil and Stoilova 2011). However, in the years following the transition to

democracy in Portugal, and especially after the country’s accession to the EU,

there was a growth in citizen and student initiatives around issues such as abor-
tion, the environment and lesbian and gay politics (Sousa Santos and Nunes

2004; Santos 2013). The first LGBT movement organizations were the lesbian

group Organa, founded in 1990, and the left-wing party group GTH, in 1991,

Changing Landscapes of Heteronormativity 169

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with activism really taking off in the late 1990s. The movement mobilized EU

policy to demand lesbian and gay rights; in 2004, for instance, the Annual

Manifesto listed a series of demands, each followed by the statement: “Because
we are Europe too!” In Bulgaria, the Bulgarian Gay Organization “Gemini”,

established in 1992, was the first sign of lesbian and gay activism, focusing on

HIV prevention, community building and campaigns for protection against
discrimination and equal rights (BGO Gemini 2007). Since 2004, a growing

number of NGOs, campaigning and social groups have emerged, making

lesbian and gay identities more visible, but whether this constitutes a “lesbian
and gay movement” is debatable. The first Gay Pride in 2008 was met with

violent attacks, more recent Pride celebrations have been larger, and have

passed off peacefully (Sofia Pride 2011).

Transnational Contexts: Human Rights and the
Emergence of the “European Social Model”

With the increasing importance of supranational institutions of governance

in post World War II Europe, and the emergence of human rights discourse as
“the meta-law of national legal systems” (Pylkkanen 2007), the sovereignty of

nation states over law and policy has been diminishing. In this context, trans-

national bodies have played a significant role in the changing landscape of het-
eronormativity in Europe. At the global level, lesbian and gay rights have met

considerable resistance within the United Nations (Swiebel 2009), but in 1994

the UN Human Rights Committee ruled that laws outlawing same-sex sexual
practices are human rights violations, and that human rights law forbids dis-

crimination on the grounds of sexual orientation.
7
In 2008, the UN General

Assembly passed its first non-binding resolution, recognizing that “violence,
harassment, discrimination, exclusion, stigmatization and prejudice are

directed against persons in all countries in the world because of sexual orienta-

tion or gender identity” and condemning “violations of human rights and fun-
damental freedoms based on sexual orientation or gender identity”.

8
In 2011,

the UN Human Rights Council adopted resolution 17/19 which expressed
“grave concern” about violence and discrimination based on sexual orientation
and gender identity, and the UN Office for the High Commissioner for

Human Rights published its first report on the human rights of LGBT people

outlining “a pattern of human rights violations that demands a response” in
every region of the world (UNHCHR 2011, 24).

9

Both the Council of Europe (CoE) and the European Union (EU) have,

since the early 1980s, taken normative positions in relation to same-sex sexual-
ities, which promote, within the limits of their (changing) legal competences, a

human rights based equality agenda that has been expanding in scope. As

members of the CoE, all four countries are bound by the Convention for the
Protection of Human Rights and Fundamental Freedoms (hereafter, ECHR).

10

While there is no explicit mention of homosexuality in the Convention, from

1980 onwards a number of landmark cases and judgments by the European

170 Roseneil et al.

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Court of Human Rights have contributed to the reshaping of the regulation of

same-sex sexuality (Kollman 2007). Although not legally binding in other

member states, ECHR rulings contribute to the transnational normative order
of sexuality, and have been significant, as we indicate later, in three of our

countries. In addition, since recognizing in 1981 that homosexuals “continue

to suffer from discrimination and even, at times, from oppression”,
11
the CoE

has passed numerous non-binding recommendations and resolutions concern-

ing a range of forms of discrimination against lesbians and gay men, in rela-

tion, for instance, to residence and immigration, freedom of expression and
parenting rights, and has recommended “a broad interpretation of the concept

of family” to include “nonmarried partners, including same-sex partners”

(Recommendation 1686, 2004). In 1993 it adopted a Written Declaration
(No. 227) on “homosexual rights in the new democracies” which stated that

the rights of homosexual people not to be discriminated against needed to be

addressed in the former Communist countries.
12

A strong statement of the
new normative regime of “tolerance and non-discrimination” in relation to

same-sex sexualities was issued in 2008:

“The Committee of Ministers recalls that it is strongly attached to the
principle of equal rights and dignity of all human beings, including

lesbian, gay, bisexual and transgender persons. The Council of Europe’s

message of tolerance and non-discrimination applies to all European
societies, and discrimination on grounds of sexual orientation or gender

identity is not compatible with this message. It notes that instances of

discrimination on grounds of sexual orientation or gender identity as
well as homophobia and intolerance towards transgender persons are

regrettably still widespread in Europe” (Committee of Ministers, 2008,

1031st Meeting, item 4.3c).

As a supra-nationalizing institution, with powers that have expanded consider-

ably in recent years and an agenda that is often ahead of its member states
(Walby 2004), the EU is also an essential element of the context of law and

policy relating to same-sex sexualities in the UK, Portugal and Bulgaria.
13

Although Norway is outside the EU, as a member of the European Economic
Area and part of the Schengen framework, much Norwegian law and policy

has been brought into line with EU policy (Archer 2005), and hence, Norway

is also affected by ongoing, and intensifying, processes of Europeanization.
Social policy was largely outside the original remit of the EU, but the “social

dimension” has been increasing in importance since the mid-1980s, with the

birth of the idea of the “European Social Model”. The 1992 Treaty of
Maastricht brought “justice and home affairs” into the concerns of the EU,

and promotion of “social cohesion” and the combating of social exclusion, as

part of the political project of creating European citizenship and constructing a
shared set of European values, has become more central (Shore 2004). The

1997 Treaty of Amsterdam marked a step change in EU engagement in social

policy, introducing a new anti-discrimination agenda and a new “soft law”

Changing Landscapes of Heteronormativity 171

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mode of governance—the “open method of coordination”—which seeks to

bring about convergence between the EU and member states’ policy through

the use of benchmarking, guidelines and the sharing of best practice, to com-
plement “hard law” regulation which is binding on member states. Article 13

of the Treaty of Amsterdam created an explicit legal competence for the EU to

combat discrimination based on “sexual orientation”. The groundwork for
this had been laid by the Squarcialupi Report of 1984, which addressed sexual

orientation discrimination in the workplace, leading to a non-binding resolu-

tion of the European Parliament condemning “all forms of discrimination
based on an individual’s sexual tendencies” (OJ 1984 C 104/46-48) (Bell
1998), and the Roth Report in 1994, which proposed action on discrimination

against lesbians and gay men, and raised the issue of same-sex marriage and
parenting rights (Swiebel 2007).

14

In 2000, the anti-discrimination policy agenda legitimized by the Treaty of

Amsterdam was turned into a legally binding directive (the Employment
Equality Directive), prohibiting discrimination in employment on the grounds

of religion, belief, age and sexual orientation. This was the first EU legislation

to address same-sex sexuality.
15
Referring in its Preamble to the founding prin-

ciples of the EU-“liberty, democracy, respect for human rights and fundamen-

tal freedoms” (Council Directive 2000/78/EC: para. 1)-the Directive suggests
that the principle of equal treatment between women and men is “well estab-
lished” within Community law, and that the Community should aim “to elimi-

nate equalities, especially since women are often the victims of multiple

discrimination”. The next move is to claim “the right of all persons to equality
before the law and protection against discrimination” as a universal right, rec-

ognized by the Universal Declaration of Human Rights, and various UN

Conventions and Covenants. It is only then that reference is made to the EC
objectives relating to the development of a European strategy to promote “a

skilled, trained and adaptable workforce” (Council Directive 2000/78/EC:
para. 7). Discrimination is opposed because it “may undermine the achieve-
ment of the objectives of the EC Treaty, in particular the attainment of a high

level of employment and social protection, raising the standard of living and

the quality of life, economic and social cohesion and solidarity, and the free
movement of persons” (Council Directive 2000/78/EC: para. 11).

Also in 2000, the EU Charter of Fundamental Rights was adopted, a non-

binding but rhetorically and politically significant statement about the
meaning and reach of human rights within the Union. Article 21 of the

Equality chapter states that “Any discrimination based on any ground such as

sex, race, colour, ethnic or social origin, genetic features, language, religion or
belief, political or any other opinion, membership of a national minority,

property, birth, disability, age or sexual orientation shall be prohibited”.
16
This

was followed by a five-year £100m euro “Community Action Programme to
Combat Discrimination” (2001–6) that included sexual orientation. The

Lisbon Treaty 2007 made the Charter legally binding on member states,
17
and

the European Agency for Fundamental Rights was established, with

172 Roseneil et al.

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homophobia and sexual orientation as a key aspect of its agenda. The “renewed

social agenda” adopted by the European Commission in 2008 includes tackling

discrimination on the grounds of sexual orientation beyond the sphere of
employment, so ending the “equality hierarchy”, which offers protection

against sex/gender and racial discrimination in a wider range of areas (Swiebel
2009).

18

Alongside, and influencing, these changes in European law and policy, has

been the political activism of the transnational LGBT movement, and the

moral pressure exerted by human rights NGOs, such as Amnesty International,
Human Rights Watch and the International Gay and Lesbian Human Rights

Commission.
19
From the early 1990s, the European branch of the International

Lesbian and Gay Association (ILGA-Europe) began to secure funding from the
European Commission, and it seized the political opportunity opened up by

the establishment of the Social Platform in 1995 to become a key player within

the EU’s civil dialogue, and also obtained consultative status in the CoE. The
LGBT movement lobbied effectively for the sexual orientation provisions of

the Charter for Fundamental Rights, and gay activists working as assistants

within parliamentary groups, and sympathetic bureaucrats within the
Commission have also been crucial (Swiebel 2009).

Processes of Normative Change

Turning now to the question of how the legal and policy landscape relating
to same-sex sexuality has shifted historically, we identify three processes of

normative change: the legitimation of same-sex sexual practice, the protection

of lesbian, gay and bisexual (LGB) people and the recognition of intimate rela-
tionships. These processes have proceeded at a different pace in each of the

four countries in recent decades, and have reached different points. A full

account of the twists and turns of legal and policy change, and of the role of
the many actors involved in enacting these changes, is beyond the scope of this

paper; rather we identify key moments of normative decision and key actors,

teasing out the particular role played by nationally specific and transnational
political processes.

TheLegitimationofSame-SexSexualPractice

In all four countries, a legal distinction has long been drawn between “legiti-
mate” sex—between husband and wife—and “illegitimate” sex—outside mar-

riage, and sexual acts between men, which were specifically outlawed for many

centuries. Sexual acts between women were criminalized only in Bulgaria,
although there were attempts to do so in the early twentieth century in Norway

and England.
20

In Bulgaria, the criminalization of sexual acts between men dates back to
the reign of Simeon (893–927), with the death penalty for those found guilty,

except for the “passive” party, if he was under the age of 20 (Bulgarian Helsinki

Committee 2001). In 1896, the punishment was reduced to “confinement to a

Changing Landscapes of Heteronormativity 173

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dark cell for 6 months.” Under communism, the Penal Code of 1951 criminal-

ized both acts of “sexual intercourse” and acts of “sexual pleasure” between

people of the same sex, the latter encompassing, for the first time, sexual acts
between women (Bulgarian Helsinki Committee 2001) and increasing punish-

ment to three years imprisonment. This might perhaps be understood in the

context of the strong social and legal pressure placed on women to procreate.
Only reproductive sexual acts between spouses were considered legitimate

sexual practices (Popova 2004), and there were fiscal penalties for not having

children, public reprobation and imprisonment for infidelity (Penal Code
1956), and restrictions on abortion (Popova 2004; Brunnbauer 2008).

However, while there was a state campaign against “intellectual homosexuals”,

who were sent to corrective labour camps by the communist regime, no
women were sentenced for same-sex sexual acts (Pisankaneva 2002).

According to the Norwegian law of 1687, “fornication against nature” could

be punished by “stake and fire”, which was revised by the Penal Code of 1842
to a punishment of hard labour. In the mid-nineteenth century, three cases of

fornication against nature were taken to the Supreme Court, two of which were

cases of woman–woman sex, despite the legal definition referring to ejacula-
tion and anal intercourse. While conviction took place in one, the latter case

was acquitted, and this set legal precedent (Aarset 2000). The progressive liber-

alism that came to characterize twentienth century Norway was evident in
Section 213 of the 1902 revised Penal Code, which explicitly criminalized

sexual relations between men but also stated that they were only to be prose-

cuted if they caused public damage (Halsos 1999; Jordåen 2003). As a result
relatively few cases of homosexuality were taken to court, with the “problem”

of homosexuality shifting location to the realm of psychiatry.
21

Suggestions

that sex between women should be included in the new law were rejected.
In England and Wales, the 1533 Buggery Act made sodomy (along with bes-

tiality) punishable by hanging. Having fallen into disuse (Weeks 2000), the

death penalty for “buggery” was abolished in 1861, but the 1885 Labouchère
amendment to the Criminal Law Amendment Act extended the range of

sexual behaviour that was criminalized, and created the offence of “gross inde-

cency” between men, a term that was understood to encompass most or all
male homosexual acts, with punishment for gross indecency of up to two years

imprisonment, with or without hard labour (Cretney 2006). In 1921, an

attempt was made to criminalize same-sex sexual acts between women, but the
proposal in Parliament was defeated on the grounds that such a law would

publicize the possibility of such behaviour (Weeks 1989). The number of

offences of gross indecency “known to the police” rose dramatically between
1931, when there were 622, to 6644 in 1955 (Cretney 2005).

Portuguese law has historically been unspecific about same-sex sexual acts,

with the first Penal Code of 1852 addressing “threats to decency”(Aguiar 1926)
and its revision of 1886 “addictions against nature”(Moita 2001). The first law

used to specifically target those engaging in same-sex sexual acts was the 1912

Law on Begging and Mendacity, which referred to vagrancy, “false” beggars,

174 Roseneil et al.

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such as prostitutes and others who practiced “addictions against nature”

(Bastos 1997).
22

Male homosexuals, vagrants and prostitutes were then incar-

cerated and tortured under the Salazar regime, and there were regular police
raids on places used for same-sex encounters (Bastos 1997). Later in the dicta-

torship, the Penal Code of 1966 introduced a new offence, with a maximum

two-year sentence, targeting “whomsoever frequently makes an indecent
assault on someone of the same sex” (Article 253).

The first moves toward decriminalization in our four countries were made

in the UK,
23

where the Wolfenden Committee was set up in 1954 by the
Conservative government to investigate the working of the criminal law in rela-

tion to “homosexual offences and prostitution”, because both seemed to be

increasingly visible and widespread (Cretney 2006). The Committee recom-
mended that homosexual behaviour between consenting adults in private no

longer be a criminal offence, marking the beginning of an emerging public dis-

course of tolerance of homosexuality and of non-intervention in “the private
lives of citizens”. It took a decade of lobbying by the Homosexual Law Reform

Society and the Albany Trust before the Sexual Offences Act of 1967 was

passed by a Labour government, decriminalizing, in England and Wales,
homosexual acts that took place between two men over twenty-one years of age

“in private”. In Scotland, male homosexuality was decriminalized in 1980, two

years later in Northern Ireland, and in 1992 in the Isle of Man. The change in
the law in Northern Ireland, where religious authorities held much greater

sway, followed the first European Court of Human Rights case (Dudgeon v.

UK 1981) to find that the criminalization of consenting sexual relations
between adults in private was contrary to article 8 of the ECHR. In the 1990s,

the struggle for the equalization of the age of consent for gay men became a

key plank in lesbian and gay activism (Waites 2005). The age of consent was
reduced from 21 to 18 in 1994, and following an application to the European

Commission for Human Rights, in the case of Sutherland versus UK,
24

which

found that an unequal age of consent contravened the ECHR, eventually led to
equalization with the heterosexual age of consent (at 16 in England, Wales and

Scotland, and 17 in Northern Ireland) in the Sexual Offences (Amendment)

Act in 2000 (Waites 2005).
In Norway, DNF-48 began campaigning to decriminalize sexual relations

between men in 1950. In 1953 the Committee on the Penal Code suggested

removing the relevant paragraph, but proposed an age of consent of 18 (as
opposed to 16 for heterosexual sex), and sought to introduce a prohibition on

“homosexual propaganda”, in order to counter public fears that decriminaliza-

tion would lead to the spread of homosexuality. In contrast to the Homosexual
Law Reform Society in the UK, which adopted a conciliatory and gradualist

approach to securing legal change, DNF-48 took the position that the proposed

changes were worse than the existing (mostly sleeping) paragraph, and pressure
for decriminalization was put on hold. It was only in the late 1960s that the

issue was taken up again by the movement, and in 1972 the removal of Section

Changing Landscapes of Heteronormativity 175

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213 was supported by an overwhelming majority in the Norwegian Parliament

(Jordåen 2003).

Decriminalization occurred in Bulgaria in the Penal Code of 1968, several
years before Norway and only a year after the UK. A number of other Soviet

bloc countries had already decriminalized sexual acts between men,
25

with

pressure for change coming from the medical profession, particularly “the
flourishing field of sexology” (Long 1999:247), and Bulgaria seems to have

followed this liberalization process.
26

However, the law continued to

explicitly discriminate between homosexual and heterosexual behaviour,
criminalizing homosexual prostitution, as well as homosexual acts performed

in public places or in a manner that was “scandalous” or that might incite

others to follow a path of perversion (Penal Code 1968). No one was prose-
cuted under either article (Bulgarian Helsinki Committee 2001: 7), but they

became a target both of lesbian and gay and human rights from the early

2000s and, most significantly, of European Commissioners as part of the
accession negotiations.

27
As part of the acquis communitaire, in order to be

able to accede to the EU, Bulgaria revoked the discriminatory paragraphs in

two stages in 2002 and 2006.
28

Meanwhile, the age of consent for same-sex sex in Bulgaria has been

changed several times in recent history. In 1968, when homosexual acts were

legalized, the age of consent was set at 18 years, four years older than for het-
erosexual acts. In 1986, the age of consent was equalized, but in 1997 it was

raised to 16, as part of Penal Code amendments aimed at reducing criminality

during the economic and political transition (Kostov 1999). The age of
consent was a target of equality campaigns by gay activists, but it was ulti-

mately removed in 2002 because it fell foul of the acquis and threatened

accession to the EU (Draft Law on Alteration and Supplementation of the
Penal Code 2002).

Similarly to Bulgaria, the decriminalization of same-sex sexual acts in

Portugal was enacted in the revised 1982 Penal Code, as part of the process of
democratization and during Portugal’s process of preparation for accession to

the EC. The European legal and policy climate in this area was clearly changing

in the early 1980s, in the wake of Dudgeon v. the UK (1981), and the CoE’s
Recommendation 924 which “urged” member state to decriminalize homosex-

ual acts between consenting adults, and to equalize the age of consent. As in

the UK and Bulgaria, decriminalization was accompanied by the introduction
of an unequal age of consent (of 16, as opposed to 14 for heterosexual sex),

and the new crime of “homosexuality with minors”. Revisions to the Penal

Code in 1995 redefined crimes relating to sexuality as “crimes against sexual
freedom and self-determination”, instead of as crimes “against the values and

interests of social life”, suggesting that a new sexual norm of the “individual

right to sexual freedom and self-determination” now “outweighed the collec-
tive moral values of society in the eyes of the lawmakers”. The crime of “homo-

sexuality with minors” was thereby abolished, and a new crime of “induced

misconduct of minors by adults of the same sex” introduced. Given that the

176 Roseneil et al.

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sexual abuse of children, “teenagers and subordinates” was already illegal, this

new crime continued with the punishment of the sexual orientation of the

abuser, rather than just the act of abuse. Both the 1982 and 1995 changes to
the Penal Code, therefore, contained provisions which countered progress

toward full equality, which might be understood in the context of the absence

of social movement or pressure group campaigning around the issue in
Bulgaria. The unequal age of consent came to forefront of the agenda of the

new LGBT movement only when a scandal about the sexual abuse of boys in a

state institution for young people erupted in 2002, with media reports often
using the words “homosexual” and “paedophile” interchangeably. The move-

ment responded with demands that the differential ages of consent be revoked,

using in its lobbying both the anti-discrimination provisions in the 2004
Constitution, for which it had campaigned (see next section), and EU reports

and European Parliament resolutions on the age of consent.
29
Finally, in 2007,

after two judgments by the Constitutional Court in which the unequal age of
consent was found to be unconstitutional, the revised Penal Code equalized

the age of consent for same-sex and heterosexual sex.

So, the process of legitimation of same-sex sexual practice took place over
the space of forty years across the four countries, beginning in 1967 in

England and Wales, and ending in Portugal in 2007. Norway completed the

process in one move, whereas the other three countries required both exter-
nal pressure from European legislation and human rights provisions and

internal social movement lobbying and campaigning, with the former most

significant in Bulgaria.

TheProtectionofLesbian,GayandBisexualPeople

Historically moves to protect LGB people from discrimination and homo-
phobic speech and violence in the public sphere began after the process of

legitimation of same-sex sexual practices in the private sphere.

Protection against discrimination. The argument that LGBT people suffer
discrimination and disadvantage has been the core, unifying claim of contem-

porary LGBT movements internationally. Establishing the existence of discrim-
ination and making it normatively unacceptable has been a major focus of

activist intervention since the early 1970s in Norway and the UK, and from the

mid-1990s in Bulgaria and Portugal. The recognition by national and transna-
tional state actors of “sexual orientation discrimination”, and the move to

enact legislation to protect LGB individuals from such discrimination consti-

tute a significant victory for LGBT movements.
Norway was the first country in the world to legislate against discrimination

on the grounds of “sexual orientation” (Löfström 1998). In 1974, DNF-48 pro-

posed to the Minister of Justice that people with “homosexual inclinations” be
added to the list of those protected from discriminatory refusal to supply

goods or services (Penal Code, section 349a) and from threatening and hateful

utterances (section 135a). This proposal resulted in a report by the Committee

Changing Landscapes of Heteronormativity 177

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on the Penal Code (NOU 1979: 46), which was split on the issue, but in 1981

the Penal Code was revised to include protection on the basis of “homosexual

inclination, lifestyle or orientation” with a maximum penalty of six months
imprisonment (Hennum 2001).

30
Although these changes may seem radical

and early in a comparative context, they have not been seen as particularly sig-

nificant in Norway, possibly because section 135 tends to be interpreted quite
restrictively by the courts, with the argument for free speech (section 100)

tending to overrule section 135 (Hennum 2001). This Norwegian reframing of

anti-discrimination legislation was passed in the same year that the CoE first
recognized the discrimination and oppression facing homosexuals, and three

years before the EU first addressed sexual orientation discrimination, and it

was another two decades before the other three countries in our study intro-
duced similar laws.

The first tranche of sexual orientation discrimination legislation in the UK,

Portugal and Bulgaria was the direct result of the EU Employment Equality
Directive of 2000.

31
This Directive banned discrimination based on religion

and belief, age, disability and sexual orientation, in employment and occupa-

tion, vocational training, and membership of employer and employee organi-
zations. In accordance with the directive, Bulgaria and Portugal revised their

Labour Codes, and the Employment Equality (Sexual Orientation) Regulations

were introduced in the UK.
32

Since then all three countries have gone beyond the requirements of the

Directive, and appear to be working within the wider normative framework of

Article 13 of the Treaty of Amsterdam and the EU Charter of Fundamental
Rights in their approach to protection against discrimination. Bulgaria and the

UK have introduced legislation that extends beyond work, employment and

training, bringing them closer to Norway’s long-existent and extensive protec-
tion. Bulgaria has gone further than the UK, banning sexual orientation dis-

crimination “in principle in every part of the social sphere” (Kukova 2008).

LGBT activist and other human rights NGOs were involved in the drafting of
the Protection against Discrimination Act (PADA) in Bulgaria. Adopted in

2004, it includes all aspects of discrimination, direct and indirect, that are rec-

ognized in international and Bulgarian law, thereby following the ECHR
(Kukova 2008), and explicitly includes sexual orientation. In addition, there

are several other pieces of legislation, explicitly prohibiting discrimination on

the grounds of sexual orientation in the assessment of the patient’s health con-
dition (Health Law), refusal of social insurance (Social Security Act), provision

of judicial services (the Judicial Ethics Code) and the selection of civil servants

(Regulation of the Procedures for Selection of State Servants). While there is
inconsistency in the incorporation of protection against sexual orientation dis-

crimination into Bulgarian law, the direction of legal and policy change is

clear: the Bulgarian state is taking on board the new European norms about
sexual orientation discrimination. The UK extended protection against sexual

orientation discrimination to the provision of goods, facilities and services, in

the exercise of public functions, in education, and in the rental or sale of

178 Roseneil et al.

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properties under the Equality Act (Sexual Orientation) Regulations 2007 (and

2006, in Northern Ireland).
33

However, an exemption was made for religious

organizations for whom complying with the law could conflict with either
their doctrine and/or the views of followers, except when a religious organiza-
tion provides a public service (such as adoption and fostering), in which case,

the regulations do apply. Moreover, both Bulgaria and the UK have established
statutory equality bodies with a remit to deal with multiple forms of discrimi-

nation, including sexual orientation, although this was not required by the

Employment Equality Directive.
34

Although its legislation against sexual orientation discrimination long pre-

dates that in Bulgaria and the UK, Norway has recently enacted a number of

similar changes to its national law, including the establishment of an equality
and anti-discrimination body in 2006, and addressing sexual orientation

in several pieces of legislation including the Tenancy Act (1999); the Housing

Association Act (2003); the Residential Building Association Act (2003); and the
Working Environment Act (2005). This points to the power of the emerging

European norms about sexual orientation discrimination, and the transnational

diffusion of equality and diversity policy beyond the boundaries of the EU.
Portugal has followed a different path in respect of sexual orientation dis-

crimination, occupying a somewhat contradictory position in which it offers

both more extensive but less specific protection against discrimination. On the
one hand, it has gone no further than the Employment Equality Directive, pro-

hibiting sexual orientation discrimination only in employment, not extending

it to goods and services, and it has not established a new public body to deal
with sexual orientation discrimination.

35
On the other hand, Portugal is the

only country in our study, the fourth country in the world, and the first in

Europe, to include protection against sexual orientation discrimination in its
Constitution.

36
In 2004, revisions to the Principle of Equality (Article 13) of

the Constitution, which states “Every citizen shall possess the same social

dignity and shall be equal before the law”, place sexual orientation among the
grounds on which “No one shall be privileged, favoured, prejudiced, deprived

of any right or exempted from any duty” (Article 13, Section 2). The LGBT

movement made extensive use of EU law and rhetoric in arguing that the
Constitution should be changed to comply with article 13 of the Amsterdam

Treaty. The movement’s success with this campaign has provided it with a

resource, in the form of Constitutional equality and protection from discrimi-
nation that has subsequently been mobilized in the struggle for the recognition

of same-sex relationships.

Protection from homophobic speech and violence. While there is a
strong emerging European norm that LGB people should be protected against

discrimination, which has impacted upon law and policy in all four countries,
specific criminal law protection from homophobic speech and violence is less

consistently normative, although pressure is growing to strengthen criminal

law in this area, particularly from transnational human rights and LGBT

Changing Landscapes of Heteronormativity 179

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organizations, such as Human Rights First and ILGA-Europe, and through the

Organization for Security and Cooperation in Europe (OSCE). The concept of

“hate crimes” was developed in the USA in the mid-1980s by activists and
scholars concerned with crimes of violence, and provocation to violence,

against ethnic and racialized minorities and lesbians and gay men (Jacobs and

Potter 1998) and by 2003 it had been adopted by the OSCE to refer to crimes
that are “committed with discriminatory selection”; however, its members

have not yet reached agreement as to whether homophobic crimes should be

recognized as “hate crimes” (ODIHR 2008: 10).
37

The OSCE, nonetheless,
includes homophobic crime and violence in its annual reports on hate crimes,

and notes that they are under-reported and under-recorded (ODIHR 2008: 8).

This exemplifies how actors within transnational institutions at times actively
pursue an agenda that is at variance with some member states. In 2006, the

European Parliament passed a resolution noting an increase in racist and homo-

phobic violence in Europe, and that “strongly condemns all racist and hate
attacks, urges all national authorities to do everything in their power to punish

those responsible and to fight the climate of impunity with respect to those

attacks”.
38
The Fundamental Rights Agency has also put the question of criminal

sanctions against homophobia on its agenda, but in the absence of any binding

legal action on the issue the situation across member states is variable.

Norway was, again, the first country in the world to address homophobic
“utterances”, although statistics on hate crimes only began to be collected in

2007. The 1981 revised Penal Code that outlawed discrimination in the provi-

sion of goods and services also made it illegal to “threaten or deride, or to
incite to hatred, persecution or contempt” against anyone on account of his or

her “homosexual inclination, lifestyle, or orientation” (Section 135a). Later

revisions have strengthened these provisions, increasing the maximum penalty
to three years imprisonment, and expanding the interpretation of the “public

dissemination” of such utterances. The 2010 Penal Code states that it is an

aggravating circumstance if the crime is motivated by the victim’s religion, skin
color, national or ethnic background, homophile orientation, functional

ability or other circumstances that collide with the need for groups with a par-

ticular need for protection (Bruknapp 2009:106).
The UK and Portugal also offer criminal law protection against homopho-

bia, introduced later than in Norway but currently stronger, with the UK the

strongest. In Northern Ireland, the Criminal Justice No. 2 (Northern Ireland)
Order 2004 criminalized acts intended, or likely, to stir up hatred or arouse

fear on the grounds of sexual orientation. In England and Wales, in 2008, after

extensive lobbying from the pressure group Stonewall, the Criminal Justice and
Immigration Act introduced a new offence of inciting hatred on the grounds of

sexual orientation. The Criminal Justice Act 2003 extended statutory aggrava-

tions to include sexual orientation in England and Wales.
39
The UK is the only

one of our countries to monitor and publish information about the incidence

of sexual orientation hate crimes (Human Rights First 2008),
40

and extensive

policy guidelines have been issued about the prosecution of homophobic

180 Roseneil et al.

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crimes. In Portugal, the Penal Code was revised in 2007 to criminalize any pro-

motion, encouragement or incitement of hatred on the grounds of sexual ori-

entation (Article 240) and sexual orientation was made an aggravating factor in
offences of murder, serious assault and assault (Article 132).

Bulgaria offers no specific criminal law protection against homophobic

speech or violence, although homophobic speech is banned as harassment on
the grounds of sexual orientation by the PADA (Kukova 2008), and one case

has been brought, unsuccessfully, to court, and another to the PADC.

Homophobic intent is not an aggravating factor and there is very little public
discussion of anti-gay violence and no policy initiatives to combat it. The

Bulgarian Helsinki Committee (2001) points to police violence against homo-

sexuals, the collection of personal information from homosexual victims of
violence that does not relate to the case, and refusal to register acts of homo-

phobic violence. BGO Gemini has stated that LGBT people “very often” say

that they “prefer” “becoming reconciled [to violence] to defending their rights
and seeking legal protection” (BGO Gemini 2004).

TheRecognitionofIntimateRelationships

The legal recognition of same-sex unions and of same-sex parenting rights

has been the most recent, and is the most incomplete, of the three processes of
normative change in the four countries. Traditionally, family law has been seen

as having a particularly close relationship with a nation’s “character” (Tsoukala

2008), and family law remains relatively untouched by EU directives.
41

There
is, for instance, no directive requiring the recognition of same-sex marriage,

and a debate on mutual recognition of same-sex registered partnerships across

EU borders failed to reach agreement as part of discussions of the Stockholm
Program, the EU’s legislative agenda for 2009–2014.

However, Kollman (2009) argues that there is an emerging soft law norm

about same-sex relationship recognition in Europe. For instance, directives on
free movement, family reunification and qualifications address the rights of

same-sex partners, and in 2009 the principle of freedom of movement for

married couples and those in same-sex partnerships was reiterated,
42

and the
European Parliament adopted a resolution on the situation of fundamental

rights in the EU which called for Member States “to take legislative action to

overcome the discrimination experienced by some couples on the grounds of
their sexual orientation.”

43
In 2010, a report was adopted by the European

Parliament supporting moves to ensure the mutual recognition of both

same-sex and different-sex partnerships and marriages across national
borders.

44
Also in 2010, the Parliamentary Assembly of the CoE adopted

Resolution 1728 which states that its 47 members should not discriminate

against same-sex couples, and that the “denial of rights to de facto ‘LGBT
families’ in many member states must also be addressed, including through

the legal recognition and protection of these families”.
45

ILGA-Europe

describes this resolution as an “historic” document: “the world’s first

Changing Landscapes of Heteronormativity 181

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intergovernmental agreement codifying the application of human rights

standards to LGBT people”.
46

Norway was the first of the four countries to introduce recognition of
same-sex unions in 1993, and moved to full equality with the gender neutral

Marriage Act of 2008. The 1993 Act on Registered Partnership provided equiv-

alent rights and responsibilities to marriage for “homophile persons of the
same sex/gender”, in relation to tax, social security and unemployment bene-
fits, pensions and survivor benefits, carers’ allowances, and inheritance rights,

except that registered partners could not adopt, access assisted conception or
register their partnership in the Church of Norway. The introduction of

gender neutral marriage, which allows “two persons of opposite or same-sex”

to marry, removed all references to sexual orientation, and equalized parenting
rights for same-sex married couples, allowing adoption, second parent adop-

tion (i.e. same-sex step parents’ acquisition of parental responsibility), and, for

lesbians, access to assisted conception, with parental rights for the non-
biological “co-mother” (medmor). The struggle for relationship rights had

been the major focus of the Norwegian lesbian and gay movement since the

late 1980s, when it abandoned its 1970s critique of couplehood and focus on
discrimination against single people (Andersen 2009). There was heated public

debate about the 1993 legislation, but much less heated debate about the 2008

Act, with issues concerning parenting and children being the most controver-
sial, and both being only opposed en bloc by the most conservative political

groupings.

Portugal was the second of the four countries to recognize same-sex part-
nerships, with the introduction of legal recognition of the same-sex “de facto

unions” in 2001. The lesbian and gay movement mobilized on an unprece-

dented scale after the approval in 1999 of a law recognizing de facto unions of
heterosexual couples only, and was offered by the government legislation to

recognize “shared economies” within households of individuals. The move-

ment rejected the idea that same-sex unions were merely “shared economies”
(Santos 2013), and, after a well-organized campaign, an inclusive de facto

union law and the shared economy law were introduced simultaneously.
47

After the introduction of same-sex marriage in Spain in 2005, the Portuguese
movement began to campaign for the right to marry (Vale de Almeida 2009).

Mobilizing the Constitutional anti-discrimination legislation, a lesbian couple

took the argument to the Constitutional court, which found that the
Constitution neither demanded nor opposed same-sex marriage. Following

this, and despite opposition from the Catholic Church and centre right and

right wing parties, the Socialist government legalized same-sex marriage in
2010. Although adoption by same-sex couples and second parent adoption are

still not lawful
48
and access to assisted conception remains restricted to hetero-

sexual de facto and married couples,
49

the achievement of same-sex marriage
within a decade is a remarkable feat for lesbian and gay activism in Portugal.

In the UK, where there had been a fierce contestation about the outlawing

of the “promotion of pretended family relationships” by local authorities in

182 Roseneil et al.

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the Thatcher government’s 1988 Local Government Act (Section 28), the

lesbian and gay movement had been less focused on same-sex partnership rec-

ognition than in Norway and Portugal, and more concerned with revoking
Section 28 and equalizing the age of consent, after New Labour came to

power in 1997. With these battles won, attention turned to the question of

relationship recognition, and in 2004, the Labour government passed the Civil
Partnership Act, which introduced a distinctive legal entity for same-sex

unions, granting equality with marriage in all but name.
50

This political com-

promise, which was supported by Stonewall, but opposed by more radical
groups such as Outrage and Queeryouth, who argued for an inclusive defini-

tion of marriage, averted a backlash against this aspect of the government’s

equality agenda, and the legislation was passed with little political or public
opposition. Interestingly, same-sex parenting rights have been more robustly

recognized, and for longer, under the more liberal, market-oriented UK

assisted conception regime than in Norway or Portugal.
51
Lesbians (single and

coupled) have long been able to access assisted conception in private clinics,

as long as clinics “take account” of the “the welfare of any child who may be

born as a result of the treatment (including the need of that child for a
father)”

51
(Human Fertilization and Embryology Act (HFEA) 1990).

52

Amendments introduced to the HFEA in 2008 de-gendered this requirement,

so that account must be taken only of the need for “supportive parenting”. In
addition, the 2008 Act allows for the recognition of both partners in a

same-sex relationship as legal parents of children conceived through assisted

conception, and the Adoption and Children Act (2002) allows same-sex
couples to apply for joint adoption, and second parent adoption. Opposition

to these changes was muted, with leading Conservative MPs arguing not

against lesbians’ access to assisted conception, but merely for “some father
figure somewhere” (Watt 2008).

Bulgaria contrasts with the other three countries in having a constitutional

definition of marriage as a union of a man and woman, with the revised
Family Code of 2010 confirming this, and recommitting state and society to

the protection of family and heterosexual marriage. Same-sex marriage, part-

nership and adoption were widely debated in 2008–9, while the Family Code
was being revised, and the first Gay Pride was organized around the theme

“Me and My Family” with demands for legal recognition. The Protection

against Discrimination Commission intervened to suggest that the right to rec-
ognition of cohabitation should be extended to same-sex couples, but ulti-

mately no recognition of cohabitation (heterosexual or same-sex) was

achieved. Former Head of Parliament Gerjokov exemplified the tenor of the
debate, with reference to the traditions of the Bulgarian nation:

With all my respect for the different, I cannot accept that gay marriages

should be made legal in Bulgaria. We are a patriarchal society and this

would detonate public opinion. So those who find it necessary to be in a

Changing Landscapes of Heteronormativity 183

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same-sex [relationship] should not want the official recognition of the

state for this’.
53

However, a recent European Court of Human Rights ruling in respect of
Poland that a Constitutional definition of marriage as a union of a man and a

woman cannot be used to justify the denial of certain family rights to same-sex

partners, points to the difficulty that Bulgaria is likely to face in holding out
against the new European norm on partnership recognition.

54

National Specificities/Transnational Commonalities

Across the four countries that we have discussed there has been a radical

transformation in the normative landscape that structures and gives meaning

to same-sex sexualities over the past four decades. These countries have very
different political histories and represent different welfare regimes, yet all have

been party to a broadly similar set of changes in law and policy. Alongside this

there have been significant shifts in public opinion around same-sex sexuality
in all four countries, which parallel a global trend towards greater approval

of same-sex sexual behaviour (Smith 2011). Smith’s (2011) analysis of

International Social Survey Program data finds that there has been an average
net change per annum in the approval of same-sex sexual behaviour of

þ 4.66% in Portugal (the greatest change of any of the 31 countries studied),

þ 2.88% in Bulgaria, þ 2.87% in Norway and þ 2.13% in Great Britain.
55

Norway has had the strongest public support for both same-sex marriage and

same-sex adoption, followed by the UK, then Portugal and, a long way behind,

Bulgaria.
56

The process of normative change in each country has its own
dynamic which has to be understood in the context of the broader landscape

of the particular national relationships between the claim-making practices of

social movements and the law-making practices of states, and the relationships
between nation states and European institutions.

Sitting outside the EU, Norway led the way in the process of legal normal-

ization, its long tradition of legal individualism and its social democratic
welfare state having instituted equality as a firm principle of governance. The

Norwegian lesbian and gay movement, like its women’s movement, worked

closely with state bodies, and the close connections that have long existed
between activists and government in this small country are central to under-

standing the Norwegian state’s “extensive will to reform” ( Mühleisen et al.

2012) in the realm of intimate citizenship. The lesbian and gay movement was
able to attach itself to hallowed Norwegian values of equality, gender equality

[likestilling], and inclusion with greater ease than in any of the other countries,

to the extent that gender equality and support for gay rights have come to be
seen as characteristically “Norwegian” – with implications for migrants to

Norway from non-western backgrounds whose adherence to these sexual

norms is increasingly regarded with suspicion (Mühleisen et al. 2012).

184 Roseneil et al.

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The English liberal tradition meant that decriminalization was earlier than

in the other countries discussed here, and there was less legal intervention

against same-sex parenting than in “family-welfare” orientated Norway. But
the less entrenched commitment to the core social democratic value of equal-

ity, and the long period of Conservative government (1979–1997) at the time

when Norway was enacting partnership recognition, meant that the UK has
lagged behind Norway in moving toward full equality. The UK movement was

necessarily politically more oppositional and radical than the Norwegian

movement, in the context of the homophobic “family values” that dominated
political debate during the 1980s and the early 90s, and the movement has

never unequivocally embraced the demand for same-sex marriage. Meanwhile,

Portugal came late to the process of change, but enacted the most rapid and
radical transformation in the regulation of same-sex sexuality of the four coun-

tries. Despite the historic strength of the Catholic Church, the Portuguese

lesbian and gay movement’s agile “syncretric” strategy (Santos 2013) of direct
action, public debate, legal challenge and political lobbying mobilized emerg-

ing European norms about lesbian and gay equality alongside the democratic

socialist politics that have been important in the post-dictatorship era, to
achieve Constitutional protection and same-sex marriage in just over a decade.

In Bulgaria, where a much weaker LGBT movement/NGO sector has been
contesting the legacy of Communist familialism and Orthodox patriarchalism,
accession to the EU has been the major driver of change, and has seen the

equalization of laws relating to same-sex sexuality and the enactment of exten-

sive protection against discrimination on the grounds of sexuality. But the
changes enacted by the CoE and the EU have been significant, at different

times and in different ways, in all three of the member states in our study, each

of which has been pushed to act by ECHR rulings and EU directives.
The changes in law and policy that we have discussed must be understood

as a victory for lesbian and gay movements and their allies. Without the crea-

tivity and energy of national and transnational social movement activists, and
the translations of the demands of lesbian and gay movements by left and

centre-left political parties, same-sex sexualities would not have entered the

equalities and human rights agendas of nation states and transnational bodies.
It is important to note that almost every change in national law in Norway,

Portugal and the UK discussed in this article has been enacted by a party or

coalition of the left or centre left, as have initiatives on lesbian and gay rights
with the European Parliament, starting with the work of German Green MEPs

in the 1980s. However, it is indicative of the normalization of opposition to

sexual orientation discrimination and of same-sex relationships that took place
during the first decade of the twentieth-first century that in 2012 the

Conservative-led coalition in the UK declared its intention to legislate for

same-sex marriage.

Changing Landscapes of Heteronormativity 185

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The New European Homotolerance and Processes
of Homonormalization

Looking broadly across the sweep of legal and policy changes regarding

same-sex sexualities over recent decades, the decriminalization and equaliza-
tion of the law around same-sex sexual behaviour might be seen as the first

step in the emergence of a new European norm of “homotolerance” (Røthing

2008) which is now more or less institutionalized within the four countries we
have discussed. The establishment of legal tolerance of homosexual sexual

activity set in train a process of radical transformation in heteronormativity.

This has involved the struggle for, and achievement of, formal legal protection
against discrimination and violence for lesbians and gay men, and, less com-

pletely, the opening up of the possibility of recognition for their couple and

parenting relationships, the full achievement of which might be understood as
legal “homonormalization”, that is, the formal legal inclusion of lesbian and

gay men as full and equal citizens. We use the notion of homonormalization,

rather than the more widely used notion of homonormativity (Duggan 2002;
Puar 2007), which was coined to describe “the sexual politics of neoliberalism”

(Duggan 2002) in the USA, in order to emphasize both the incompleteness of

this process, and the historical and ongoing incommensurability of heteronor-
mativity and homonormativity as regulatory and normative regimes.

57

This transformation in the heteronormative legal and policy order has to be

understood in relation to a complex set of macro-level processes of moderniza-
tion, democratization, and transnationalization that can be traced back

through the twentieth century, and that have a distinctively European hue. The

legacies of two World Wars, of dictatorships, fascism and racism in Europe, are
the backdrop to the project of European identity and citizenship building that

discursively foregrounds equality and human rights, and that now firmly

includes sexual orientation within its agenda. However, there are important
issues to be raised about the politics of this new norm of homotolerance and

processes of homonormalization, as they enact their own modes of regulation,

discipline, exclusion and hierarchization.
First, the European identity project, and its various national instantiations

that have begun to claim homotolerance as a key element seem also to be

increasingly mobilizing this equalities agenda as a marker of the distinction
between “progressive”, “civilized” Europe and “others”—within Europe itself,

on its borders and beyond.
58

At nation state level, distinctions are drawn, and

differences measured, in numerous trans-European reports and surveys,
between the member states and candidate countries of the EU, to evaluate

“progress” in respect of the new sexuality-equality norm. It is generally the

“post-socialist” states that find themselves at the bottom of the league tables of
homotolerance, and are thereby cast as “lagging” and deficient.

59
Within some

European nations, in the decade following of 11 September, and in the context

of the “war on terror” and the public dominance of discourses about the
“clash of civilizations” (Huntingdon 1993), new forms of “sexual nationalism”,

186 Roseneil et al.

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or what Puar (2007) has labelled “homonationalism”, have developed that con-

struct the tolerance of lesbians and gay men (alongside gender equality/
women’s rights), as national values that certain racialized/religious minorities
within Europe, particularly Muslims, are seen as failing to embrace (Butler

2008; Haritaworn 2008; Mühleisen et al. 2012). The new tendency to instru-

mentalize same-sex equality (Fassin 2011) as part of a racist, Islamophobic pol-
itics in Europe needs to be named and confronted, but, as Fassin (2011) and

Zanghellini (2012) argue, this does not mean that the struggle for lesbian and

gay rights should be relinquished or that it is inherently related to such a poli-
tics. Moves toward homotolerance and homonormalization have their own

historicity and pre-date the changed political landscape that has followed the

rise in Islamic fundamentalism and the “war on terror”. Moreover, a concern
with the equality of lesbians and gay men is not essentially or exclusively

“European”. It was South Africa that was the first nation to expressly protect

against sexual orientation discrimination in its Constitution, and throughout
history there have been many ways to deal with and/or accept same-sex sexual-
ity and love in different societies.

Second, while we have adduced strong evidence of the emergence of a new
European legal and policy norm of homotolerance, we wish to emphasize the

difference between the institution of laws and policies promoting equality for

lesbians and gay men and the eradication of heteronormativity. We are not
suggesting that the legislation that has been enacted is actually being fully

implemented and its provisions utilized, or that discrimination on the grounds

of sexual orientation no longer takes place. We are not claiming that homo-
phobic speech and violence have been eradicated, and certainly not that

same-sex relationships, in all their variety, are fully recognized and allowed to

flourish. We are certainly not asserting that same-sex sexuality is fully cultur-
ally legitimate. Indeed, our research on the lived experiences of intimate life

and intimate citizenship of LGB people in the four countries suggests that this

is far from the case (Roseneil et al. 2012). People living outside normative het-
erosexuality in each of the four countries continue to experience often severe

impingements of their intimate citizenship rights, as well as routine, every day

moments of misrecognition and social exclusion. The relationship between
changes in law and policy, public opinion and homotolerance, and cultural

and social transformation in everyday life is complex, varying not just between

the countries we have studied, but within nations, between regions, and among
different social and age groups. Lives are lived in complex psychosocial tempo-

ralities, rooted in intergenerational and communal relations; they do not map

straightforwardly onto the temporalities of legal and policy change, and subjec-
tivities do not necessarily shift in time and in tune with social change.

Third, we are not saying that the move toward the normalization of

same-sex sexualities necessarily constitutes “lesbian and gay liberation”. As
LGBT and queer theorists (e.g. Bell and Binnie 2000; Warner 2000; Seidman

2002; Richardson 2004) have pointed out, the embrace of the state enacted by

processes of legal normalization is a form of incorporation and assimilation

Changing Landscapes of Heteronormativity 187

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within citizenship which leaves many elements of unequal societies unchanged.

Many hundreds of thousands of lesbians and gay men have actively fought,

and silently hoped, for this embrace; but many have not, and many remain
excluded because they do not conform to the newly recognizable, “respectabl-

ized” forms of intimacy and sexuality. Recognition of same-sex relationships is

the recognition of long-term dyadic relationships that are expected to be
monogamous (see Roseneil et al., forthcoming); recognition of same-sex

parenting expects such parenting to be carried out by a couple, not by groups

of three, four or more co-parents. Lesbians and gay men who are living outside
the couple form, and whose parenting practices do not conform to the two

parent model, remain outside the sphere of recognition. And citizenship itself

remains an inherently exclusionary status, marking insiders from non-citizens
and denizens, the politics of which are increasingly critiqued (Robson and

Kessler 2008; Roseneil 2013).

Concluding Comments

These qualifications notwithstanding, to conclude we suggest that it is both

sociologically and politically important to register the extent, scope and speed
of the normative change that has taken place, which means that same-sex sex-

ualities are no longer outlawed, and are significantly less stigmatized than once

they were. The past four decades have seen a reconstruction of the European
intimate citizenship regime, involving the decriminalization of homosexuality

and the eventual equalization of laws relating same-sex sex, the establishment

of laws and institutions seeking to protect lesbians and gay men from discrimi-
nation and violence, and, more recently, the move toward the recognition of

same-sex intimate relationships and parenting. Same-sex sexuality has been,

more or less, fully legally normalized in Norway, Portugal and the UK, trans-
forming in the process the inside/outside (Fuss 1990) relationship that has his-
torically existed between heterosexuality and homosexuality. And across all

four countries, and a range of welfare regimes, as across the wider terrain of
Europe, the normativity, protected status and naturalness of heterosexuality

have been thrown into question by the legal recognition and protection of

same-sex sexualities. This is a truly radical transformation that deserves the
continued attention of scholars of social politics.

Notes

1. First used by Warner (1991), the concept of heteronormativity has since
been widely taken up in queer theory, but can be traced back to feminist theorizing
of the institution of “compulsory heterosexuality” (Rich, 1980).

2. The research on which this paper is based was carried out as part of the
Intimate Citizenship Work Package of the FEMCIT project (Gendered Citizenship
in Multicultural Europe: the Impact of Contemporary Women’s Movements),
which was funded by the European Union Framework 6 program from 2007 to

188 Roseneil et al.

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2011 (project: 028746). See www.femcit.org and Halsaa, Roseneil and Sümer
(2012).

3. This group is comprised of the Nordic countries.
4. According to Esping-Andersen (1990), this group also comprises the United

States, Canada and Australia.
5. Esping-Andersen (1990) did not address the post-communist states in his

original typology, and later rejected the existence of a separate Eastern European
welfare model. However, we find more convincing Fenger’s (2005) argument
that there remains a distinctive welfare regime amongst former communist
states, in which he included Croatia, the Czech Republic, Hungary, Poland and
Slovakia.

6. Esping-Andersen (2002) does not accept the existence of a distinctive
Southern European welfare regime.

7. Stychin (2004) argues that there has been a “double movement of global-
ization” in relation to same-sex sexualities: the globalization of human rights,
and the globalization of an “Anglo-American, “Stonewall” model of sexuality,
identity and liberation” (2004:954). See also Cruz-Malave and Manalansan
(2002).

8. http://www.hrw.org/en/news/2008/12/18/un-general-assembly-statement-
affirms-rights-all. Accessed 27 June 2012.

9. http://www2.ohchr.org/english/bodies/hrcouncil/docs/19session/A.HRC.
19.41_English.pdf. Accessed 27 June 2012. It should be noted, however, that there
remains considerable opposition from some members of the UN to the recognition
of lesbian and gay rights as human rights.

10. Norway and the UK were founding members (1949), with Portugal and
Bulgaria joining shortly after their transition to democracy, in 1976 and 1992.

11. Recommendation 924 (1981) http://assembly.coe.int/Main.asp?link=/
Documents/AdoptedText/ta81/EREC924.htm.. Accessed 27 June 2012.

12. http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/
Doc93/EDOC6779.htm. Accessed 27 June 2012.

13. Accession dates were: UK 1973, Portugal 1986 and Bulgaria 2007.
14. Resolution on equal rights for homosexuals and lesbians in the European

Community, OJ 1994 C 61/40, Res. No. A3-0028/94, 8 Feb. 1994.
15. Council Directive 2000/78/EC, OJ L3030/16.
16. http://www.europarl.europa.eu/charter/pdf/text_en.pdf. Accessed 27 June

2012.
17. The UK has an opt-out from this, on the grounds of its common law legal

system, but the 1998 Human Rights Act gives “further legal effect” in the UK to the
fundamental rights and freedoms contained in the ECHR.

18. The Racial Equality Directive 2000/43/EC offers protection against dis-
crimination on the grounds of race or ethnicity in employment and training,
education, social security and healthcare, membership of, and involvement in,
organizations of workers and employers, and access to goods and services,
including housing.

19. Stychin (2003) and Binnie and Klesse (2011) point to the complex power
relations involved in “transnational activism” and the politics of “solidarity”,
exploring the flow of ideas and the transfer of resources between LGBT activists in
western and eastern Europe, and pointing to the ways in which western donors
have the power to set agendas.

Changing Landscapes of Heteronormativity 189

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http://www.hrw.org/en/news/2008/12/18/un-general-assembly-statement-affirms-rights-all
http://www.hrw.org/en/news/2008/12/18/un-general-assembly-statement-affirms-rights-all
http://www.hrw.org/en/news/2008/12/18/un-general-assembly-statement-affirms-rights-all
http://www.hrw.org/en/news/2008/12/18/un-general-assembly-statement-affirms-rights-all
http://www.hrw.org/en/news/2008/12/18/un-general-assembly-statement-affirms-rights-all
http://www.hrw.org/en/news/2008/12/18/un-general-assembly-statement-affirms-rights-all
http://www.hrw.org/en/news/2008/12/18/un-general-assembly-statement-affirms-rights-all
http://www2.ohchr.org/english/bodies/hrcouncil/docs/19session/A.HRC.19.41_English.pdf
http://www2.ohchr.org/english/bodies/hrcouncil/docs/19session/A.HRC.19.41_English.pdf
http://www2.ohchr.org/english/bodies/hrcouncil/docs/19session/A.HRC.19.41_English.pdf
http://www2.ohchr.org/english/bodies/hrcouncil/docs/19session/A.HRC.19.41_English.pdf
http://www2.ohchr.org/english/bodies/hrcouncil/docs/19session/A.HRC.19.41_English.pdf
http://www2.ohchr.org/english/bodies/hrcouncil/docs/19session/A.HRC.19.41_English.pdf
http://www2.ohchr.org/english/bodies/hrcouncil/docs/19session/A.HRC.19.41_English.pdf
http://www2.ohchr.org/english/bodies/hrcouncil/docs/19session/A.HRC.19.41_English.pdf
http://www2.ohchr.org/english/bodies/hrcouncil/docs/19session/A.HRC.19.41_English.pdf
http://www2.ohchr.org/english/bodies/hrcouncil/docs/19session/A.HRC.19.41_English.pdf
http://assembly.coe.int/Main.asp?link=/Documents/AdoptedText/ta81/EREC924.htm
http://assembly.coe.int/Main.asp?link=/Documents/AdoptedText/ta81/EREC924.htm
http://assembly.coe.int/Main.asp?link=/Documents/AdoptedText/ta81/EREC924.htm
http://assembly.coe.int/Main.asp?link=/Documents/AdoptedText/ta81/EREC924.htm
http://assembly.coe.int/Main.asp?link=/Documents/AdoptedText/ta81/EREC924.htm
http://assembly.coe.int/Main.asp?link=/Documents/AdoptedText/ta81/EREC924.htm
http://assembly.coe.int/Main.asp?link=/Documents/AdoptedText/ta81/EREC924.htm
http://assembly.coe.int/Main.asp?link=/Documents/AdoptedText/ta81/EREC924.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc93/EDOC6779.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc93/EDOC6779.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc93/EDOC6779.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc93/EDOC6779.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc93/EDOC6779.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc93/EDOC6779.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc93/EDOC6779.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc93/EDOC6779.htm
http://www.europarl.europa.eu/charter/pdf/text_en.pdf
http://www.europarl.europa.eu/charter/pdf/text_en.pdf
http://www.europarl.europa.eu/charter/pdf/text_en.pdf
http://www.europarl.europa.eu/charter/pdf/text_en.pdf
http://www.europarl.europa.eu/charter/pdf/text_en.pdf
http://www.europarl.europa.eu/charter/pdf/text_en.pdf
http://www.europarl.europa.eu/charter/pdf/text_en.pdf
http://sp.oxfordjournals.org/


20. The criminalization of female same-sex sexuality is historically much less
common than male, but a number of countries, including Austria, Sweden and
Finland criminalized both male and female same-sex sexual acts in the late nine-
teenth century (Crompton, 1980/81; Löfstrom, 1998).

21. In the period 1905–1950, 119 men were sentenced (Hennum, 2001) for
homosexual acts.

22. There is little research on the history of same-sex sexuality in Portugal, but
see Bastos (1997), Cascais, (2004).

23. Same-sex sexual acts were, however, decriminalized in 1930 in Denmark
and 1944 in Sweden.

24. http://cmiskp.echr.coe.int/tkp197/view.asp?action=html&documentId=
697231&portal=hbkm&source=externalbydocnumber&table=F69A27FD8FB8614
2BF01C1166DEA398649. Accessed 27 June 2012.

25. Poland in 1945, Hungary and Czechoslovakia in 1961.
26. There were a number of sexology clinics and a research institute under

communism (Okoliyski and Velichkov, 2004).
27. COM (2002) 624 final “Road Map for Bulgaria and Romania”. http://ec.

europa.eu/bulgaria/documents/abc/roadmap-br-ro-2002_en.pdf. Accessed 27
June 2012.

28. The Copenhagen criteria set out in 1993 require candidate countries to
adopt the acquis communitaire, the total body of EU laws and regulations.

29. E.g. resolution A5-281/2003 –2002/2013(INI) Available at http://www.
europarl.europa.eu/. Accessed 27 June 2012.

30. http://www.iglhrc.org/binary-data/ATTACHMENT/file/000/000/53-1.
pdf. Accessed 27 June 2012.

31. Directive n. 2000/78/EC, 20 November, http://eur-lex.europa.eu/
LexUriServ/LexUriServ.do?uri=CELEX:32000L0078:en:HTML. Accessed 27 June
2012.

32. All three countries are broadly considered to have implemented the
Directive, although there are some deviations and differences in the details of
implementation.

33. This has since been replaced by the Equality Act 2010.
34. In Bulgaria, the PADA established the Protection against Discrimination

Commission, and in the UK the Equality Act (2006) established the Equality and
Human Rights Commission in England, Wales and Scotland, and the Equality
Commission in Northern Ireland, replacing specialist bodies dealing with race, sex
and disability, and introducing the requirement for the new body to promote
equality, monitor the effectiveness of legislation and investigate discrimination on
seven “protected grounds”: age, disability, gender, race, religion and belief, sexual
orientation and gender reassignment.

35. The Commission on Citizenship and Gender Equality’s remit has been
extended to include sexual orientation discrimination.

36. The first three to do so were South Africa (1996), Fiji (1997) and Ecuador
(1998).

37. OSCE Ministerial Council Decision No. 4/03, “Tolerance and
Non-discrimination”, Maastricht, 2 December 2003, http://www.osce.org/mc/
19382. Accessed 27 June 2012.

38. European Parliament resolution P6_TA(2006)0273 http://www.europarl.
europa.eu/sides/getDoc.do;jsessionid=D6A53BF668317C341F07A1FCAC3AE922.

190 Roseneil et al.

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http://ec.europa.eu/bulgaria/documents/abc/roadmap-br-ro-2002_en.pdf
http://ec.europa.eu/bulgaria/documents/abc/roadmap-br-ro-2002_en.pdf
http://ec.europa.eu/bulgaria/documents/abc/roadmap-br-ro-2002_en.pdf
http://ec.europa.eu/bulgaria/documents/abc/roadmap-br-ro-2002_en.pdf
http://ec.europa.eu/bulgaria/documents/abc/roadmap-br-ro-2002_en.pdf
http://ec.europa.eu/bulgaria/documents/abc/roadmap-br-ro-2002_en.pdf
http://ec.europa.eu/bulgaria/documents/abc/roadmap-br-ro-2002_en.pdf
http://www.europarl.europa.eu/
http://www.europarl.europa.eu/
http://www.europarl.europa.eu/
http://www.europarl.europa.eu/
http://www.europarl.europa.eu/
http://www.europarl.europa.eu/
http://www.europarl.europa.eu/
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http://www.iglhrc.org/binary-data/ATTACHMENT/file/000/000/53-1.pdf
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http://www.iglhrc.org/binary-data/ATTACHMENT/file/000/000/53-1.pdf
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http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32000L0078:en:HTML
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http://www.osce.org/mc/19382
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http://www.osce.org/mc/19382
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node1?language=EN&pubRef=-//EP//TEXT+TA+P6-TA-2006-0273+0+DOC+
XML+V0//EN. Accessed 27 June 2012.

39. Similar provisions were introduced in Northern Ireland in 2004 (Criminal
Justice No.2 (Northern Ireland) Order), and in 2009 in Scotland (Aggravation by
Prejudice (Scotland) Act).

40. http://www.humanrightsfirst.org/wp-content/uploads/pdf/FD-081103-
hate-crime-survey-2008.pdf. Accessed 27 June 2012.

41. However, it has been suggested that European harmonization of family law
is happening “through the back door” (McGlynn 2006) through coordination
rules on the free movement of labour and the European Convention on Human
Rights.

42. http://www.euractiv.com/en/socialeurope/parliament-approves-stockholm-
programme-prison-add-ons/article-187730. Accessed 27 June 2012.

43. http://www.europarl.europa.eu/oeil/file.jsp?id=5498372. Accessed 27
June 2012.

This resolution drew on the Fundamental Rights Agency’s first thematic report,
which was about homophobia and sexual orientation discrimination in member
states. http://fra.europa.eu/fraWebsite/research/publications/publications_per_
year/2008/pub_cr_homophobia_0608_en.htm Accessed 27 June 2012.

44. http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONS
GML+REPORT+A7-2010-0252+0+DOC+PDF+V0//EN. Accessed 27 June 2012.

45. More specifically, the Assembly reiterated its recommendations of 2000
that same-sex partners be entitled to the same pecuniary rights and obligations as
different-sex couples, “next of kin” status, equality in residence rights for a foreign
same-sex partner and joint parental responsibility for children. http://assembly.
coe.int/Main.asp?link=/Documents/WorkingDocs/Doc10/EDOC12185.htm.
Accessed 27 June 2012.

46. http://www.ilga-europe.org/home/news/for_media/media_releases/47_
european_countries_unanimously_agree_on_historic_human_rights_
recommendations_for_lesbian_gay_bisexual_and_transgender_people. Accessed
27 June 2012.

47. The new legal form of shared economy might be seen to be more radically
queer than the recognition of same-sex couple relationships in its potential to rec-
ognize non-dyadic, non-conjugal relationship of interdependence, care and
support.

48. Law n.31/2003.
49. Law n. 32/2006.
50. The two differences between marriage and civil partnership are that the

latter cannot be registered by means of a religious ceremony or in a religious build-
ing, and the latter does not require “consummation” in order to be valid (see
Stychin, 2006a).

51. This is not to say that lesbians have found it easy to access assisted concep-
tion; the cost is high in private clinics, and studies suggest lesbians have encoun-
tered discrimination when seeking NHS treatment (Langdridge and Blyth, 2001).

52. http://www.legislation.gov.uk/ukpga/1990/37/contents. Accessed 27
June 2012.

53. Broadcast on Nova Television (2009) Csjylp ia naklata [Everything
about the Mother], Temata na Nova, 27 March 2009.

Changing Landscapes of Heteronormativity 191

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http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc10/EDOC12185.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc10/EDOC12185.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc10/EDOC12185.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc10/EDOC12185.htm
http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc10/EDOC12185.htm
http://www.ilga-europe.org/home/news/for_media/media_releases/47_european_countries_unanimously_agree_on_historic_human_rights_recommendations_for_lesbian_gay_bisexual_and_transgender_people
http://www.ilga-europe.org/home/news/for_media/media_releases/47_european_countries_unanimously_agree_on_historic_human_rights_recommendations_for_lesbian_gay_bisexual_and_transgender_people
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http://www.ilga-europe.org/home/news/for_media/media_releases/47_european_countries_unanimously_agree_on_historic_human_rights_recommendations_for_lesbian_gay_bisexual_and_transgender_people
http://www.ilga-europe.org/home/news/for_media/media_releases/47_european_countries_unanimously_agree_on_historic_human_rights_recommendations_for_lesbian_gay_bisexual_and_transgender_people
http://www.ilga-europe.org/home/news/for_media/media_releases/47_european_countries_unanimously_agree_on_historic_human_rights_recommendations_for_lesbian_gay_bisexual_and_transgender_people
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54. http://www.equalrightstrust.org/ertdocumentbank/Microsoft%20Word%
20-%20Kozak_v_Poland1.pdf. Accessed 27 June 2012.

55. Smith (2011) draws on ISSP data from 1991–2008. Norway has consis-
tently had the highest level of approval of same-sex sexual behaviour, followed by
the UK, then Portugal and then Bulgaria. The percentage of those surveyed think-
ing that same-sex sexual behaviour was “not wrong at all” only passed the 50
percent mark in Norway in 2008 (56.7 percent), with Great Britain recording 36.1
percent and Portugal 28.9 percent (no data on Bulgaria for 2008).

56. European Omnibus Survey, EOS Gallup Europe 2003 data: percentage sup-
porting same-sex marriage and same-sex adoption: Norway—66; 37 percent; UK—
47; 35 percent; Portugal—43; 25 percent; Bulgaria—20; 14 percent. http://www.

rklambda.at/dokumente/news_2003/News-PA-031015-Gallup-Umfrage-Text.pdf.
Accessed 27 June 2012. More recent (2006) Eurobarometer research excludes
Norway and offers lower figures in response to the question “Homosexual marriages
should be allowed throughout Europe”, and “adoption of children should be
authorized for homosexual couples throughout Europe”: UK—46; 33percent agree;
Portugal—29; 19 percent agree; Bulgaria—15; 12 percent agree. http://ec.europa
.eu/public_opinion/archives/eb/eb66/eb66_highlights_en.pdf. Accessed 27
June 2012.

57. Berlant and Warner argue that it is not possible to speak of homonormativity
in the same sense as heteronormativity “[b]ecause homosexuality can never have the
invisible, tacit, society-founding rightness that heterosexuality has” (1998:548).

58. For a wider critique of the recent politics of tolerance, see Brown (2006).
59. See Kulpa and Mizielinska (2011) for critiques of the positioning and repre-

sentation of central and eastern Europe in European discourses around same-sex
sexuality.

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