Selected Cases in Europe: Germany, The United Kingdom, Russia and Türkiye

Each administrative tradition in Europe reflects the unique political, social, and historical contexts of the countries that adopt them. The Napoleonic tradition, seen in countries like France, Spain, Greece, and Turkiye, is characterized by a centralized and hierarchical administrative structure, where the state plays a dominant role. The Common Law tradition, prevalent in the UK and Ireland, prioritizes individual rights, judicial precedent, and a decentralized approach to government. This reflects the historical significance of common law development, which relied heavily on case law and the role of the judiciary. The Scandinavian tradition, found in Nordic countries, is rooted in values like egalitarianism, social democracy, and a robust welfare state. This administrative approach reflects the region's strong cultural focus on equality and social welfare, fostering citizen participation and collective responsibility. Lastly, the Germanic tradition, seen in Germany and Austria, emphasizes federalism, rule of law, and technocratic efficiency. Historically, these countries have had well established legal frameworks, emphasizing governance by law and technical expertise, which has shaped their administrative systems toward precision and efficiency.

Germany’s decentralized federal system allows for significant autonomy at the state and local levels. Each of the 16 federal states has the authority to implement policies and services tailored to their specific needs, contributing to greater efficiency in public administration. Decentralization ensures that states can respond to regional concerns more effectively, improving the relevance and impact of governmental actions. Additionally, this system fosters strong citizen participation by encouraging involvement in local governance. Citizens can engage through public consultations, advisory boards, and input on local government policies. Local governments in Germany have elected councils and mayors, further enhancing the role of citizens in decision-making processes. This structure not only promotes local self-governance but also helps build public support and cohesiveness within communities.

The merit principle is a fundamental aspect of Germany’s public administration, where civil servants are selected based on qualifications, skills, and expertise, rather than political affiliation or favoritism. This competitive and merit-based recruitment process ensures that the most competent individuals are chosen for public service roles. Civil service positions are protected from political interference, enabling civil servants to perform their duties with professionalism and independence. This meritocratic approach contributes to the overall efficiency of public administration, as qualified personnel are better equipped to handle complex administrative tasks and uphold the principles of the rule of law.

The United Kingdom (UK) operates as a constitutional monarchy, where the monarch—currently King Charles—serves as the ceremonial head of state with limited political power. The monarch's role is mostly symbolic, and real political authority resides with elected officials, particularly within the Parliament. While the UK does not have a written constitution, constitutional principles and practices are shaped by political decisions and parliamentary traditions. The rule of law is a fundamental principle, meaning that government actions are subject to judicial review, and courts have the authority to examine the legality of government decisions. Parliamentary sovereignty ensures that the Parliament holds the ultimate law-making power, which is a key feature of the UK's parliamentary democracy.

The bureaucratic structures and political cultures of Turkiye and the United Kingdom (UK) share both similarities and differences, which are rooted in their distinct historical and administrative developments. Both countries have centralized bureaucracies, but the historical influences that shaped their systems are different. Turkiye’s bureaucracy stems from the legacy of the Ottoman Empire, which was known for its strong and centralized administrative control. Similarly, the UK’s bureaucratic structure comes from the Westminster system, also characterized by a centralized form of governance. Although the role of the military was very strong in Turkey in the past, it is now moderate in the last two decades. Turkey has a conservative culture, and its administrative culture is participative. Professionalism is moderate, while politicization of bureaucracy is high. It does not have a state ideology, instead it upholds secularism.

In Germany, the President holds a largely ceremonial role, being elected by the National Council for a five-year term, with a maximum of two terms. The President appoints ministers chosen by the Chancellor but has limited direct political influence. In contrast, the Chancellor, as the head of government, is the most powerful political figure, responsible for setting government policy and leading the Federal Parliament. The Chancellor is the leader of the political party or coalition with the majority in the Bundestag. Together with the ministers, the Chancellor oversees the country's administration and policies. While the President symbolizes the unity of the state, the Chancellor actively shapes and directs governmental operations.

The Ministers of the Cabinet are individually and collectively responsible for government decisions and actions. They are accountable to Parliament for the policies and operations of their departments. The distinctive administrative structure of the executive in the UK created a model named Westminster. The name comes from the Westminster Palace, where the British Parliament is located. The Westminster model was built based on the sovereignty of the parliament (Karasu, 2009: 188). This model is used also in the member countries of the Commonwealth such as Australia and New Zealand. The unitary organization of the state and the unlimited power of the sovereign parliament represent the main features of the British government system (Kuhlmann & Wollmann, 2014: 84).

The judicial system in Russia is independent of the executive and legislative branches. It is responsible for interpreting and upholding the law. There are three main jurisdictional courts in the Russian Federation: (i) Courts of General Jurisdiction, (ii) Constitutional Court, and (iii) Arbitration Court (Balci et al., 2022: 403). The highest court in Russia is the Constitutional Court, which ensures that laws and government actions comply with the Russian Constitution. Other key judicial bodies include the Supreme Court and the Supreme Court of Arbitration (Parlak & Caner, 2009: 253). Russia has various law enforcement and security agencies responsible for maintaining law and order, enforcing laws, and ensuring national security. These include the police, the Federal Security Service (FSB), and the Ministry of Internal Affairs (MVD). The Central Bank of Russia is responsible for monetary policy, currency issuance, and regulating the country’s financial system.

In German federal system, local governments (federal states) hold a dominant position since they are responsible for carrying out the majority of federal laws and initiatives, while the federal government is limited to having its own regional and local administrative offices in the areas that are explicitly listed in the federal constitution (such as the federal labor agency, federal defense administration, and the areas of customs, finance, water, and shipping). Based on past procedures, every federal state has its administrative structure (Ayhan & Lahdili, 2022: 229). As a result, Germany has a highly decentralized administrative structure, with the majority of administrative tasks being completed by subnational entities, especially local governments (Kuhlmann & Wollmann, 2014: 73). German municipalities are responsible for local administration, public services, and decision-making on a wide range of issues. Local elections are held regularly to choose local representatives and leaders. Citizens of the municipality elect the mayor and members of the local council. The local council is the legislative body of the municipality. It is responsible for passing local ordinances, budgets, and policies. Council members represent the interests of the community and may belong to various political parties.

In the context of the UK, where there is a complex system of central and local governments, as well as devolved governments in Scotland, Wales, and Northern Ireland, the relationships between these levels of government are distinctive. One of the defining features of the UK’s system is the devolution of powers to Scotland, Wales, and Northern Ireland. Each of these devolved administrations has its own parliament or assembly and varying degrees of legislative authority in specific policy areas. This means that the central government retains authority over certain reserved matters (such as defense and foreign affairs) while devolved governments handle a range of devolved matters (such as education and health) within their respective regions.

Recruitment into the German civil service is based on merit, qualifications, and expertise. Applicants go through competitive selection processes that assess their qualifications, skills, and knowledge. Political affiliation is not a criterion for employment. Civil servants are expected to adhere to high professional standards. They are guided by ethical principles, including impartiality and neutrality, to ensure that public services are delivered fairly and without bias. While most civil service positions are filled based on merit, some senior positions may be subject to political appointments, especially in the federal and state governments.
The German civil service invests in training and development programs to enhance the skills and competencies of its employees. Continuous professional development is encouraged throughout a civil servant’s career.

Municipalities are further divided into municipal districts, which are administrative units responsible for local governance. Municipal districts can encompass multiple cities and towns within a region. Municipalities have local councils known as “dumas” or “councils”. These councils are elected bodies that make decisions on local issues, including budget allocation, public services, and urban planning. In many municipalities, mayors or heads of local administration are responsible for day-to-day governance and implementation of local policies. They are either elected by residents or appointed. Moscow and St. Petersburg are considered cities of federal significance, which means they have a unique administrative status. They have their own local governments, including city councils and mayors.
Local elections are held regularly to elect members of municipal councils, mayors, and heads of municipal districts. These elections are intended to ensure representation and democratic decision¬making at the local level.

Civil servants undergo performance evaluations to assess their job performance and contributions. Performance management systems are used to set performance goals, provide feedback, and identify areas for improvement. Pay scales are determined through negotiations and agreements between the government and civil service unions. Government departments engage in workforce planning to ensure that they have the right skills and capacities to meet their objectives. This includes anticipating future workforce needs and addressing skill gaps. Civil service unions play a role in labor relations, negotiating with the government on issues related to pay, working conditions, and employment rights.

The public personnel system in Russia governs the recruitment, management, and employment of individuals in the public sector, including government agencies and organizations. It encompasses various aspects of human resource management within the public administration. A portion of the Russian public personnel system is career-based. It indicates that there are no set qualifications to work in the government or to advance in one’s profession, nor is there a clear, gradual path up the ladder. For higher level officials, commitment to oneself and to the political party is crucial (Balci et al., 2022: 409).
The civil service in Russia is organized hierarchically and consists of various levels and ranks. It includes federal, regional, and municipal civil servants.

Germany’s civil society landscape is diverse and dynamic, with a wide range of organizations focusing on various issues, including human rights, environmental protection, social justice, and cultural exchange. German CSOs are actively engaged in international and global issues, including development cooperation, humanitarian aid, and advocacy for human rights and democracy worldwide. Germany’s civil society has played a crucial role in the country’s historical development, the promotion of democratic values, and addressing social and environmental challenges. The state of civil society in Germany has always been vibrant and active, with numerous CSOs working on a wide range of issues, including human rights, environmental protection, social justice, and cultural exchange.

One of the important features of developed democracies is the existence of CSOs. The number of CSOs is also one of the important features of Anglo-Saxon culture. There has been a strong foundation of CSOs in the UK for centuries. There are many CSOs related to different interest groups such as professional, educational, ethical, and commercial. There were 870.000 CSOs and 170.000 charities, registered in 2007. They play important roles in putting forward the expectations and demands of people for any amendment or change in the legislation, regulations, or arrangements in the UK (Durgun, 2012: 59-62).
Since the 1980s, with the adoption of neo-liberal economic policies, CSOs have started to come forward. Governance requires three elements in the decision-making processes as the state, private sector, and CSOs. Therefore, CSOs have started to become indispensable components of the democratic structure.

Under Soviet rule, CSOs were tightly controlled or co-opted by the state. Independent civil society activity was heavily restricted, and any opposition to the Communist Party was met with repression. The state dominated all aspects of life, and dissent was often met with severe punishment. During the late 1980s, there was a period of political and social liberalization under Mikhail Gorbachev’s leadership, with policies like perestroika (restructuring) and glasnost (openness). This period allowed for a brief flowering of civil society activity, including the emergence of new political parties, independent media, and CSOs.

Germany continued to enhance its public financial management systems to ensure transparency, accountability, and efficient use of public funds. Reforms included budgetary improvements, financial reporting, and the use of performance-based budgeting. In addition, administrative simplification initiatives sought to reduce red tape and administrative burdens on businesses and citizens. Streamlining regulations and procedures aimed to make it easier to start and operate businesses, obtain permits, and navigate the administrative landscape. Furthermore, reforms in data protection and privacy aimed to align Germany with European Union regulations, such as the General Data Protection Regulation (GDPR).

The UK government has initiated various reforms to improve the delivery of public services. The government also continued its efforts to digitize public services and improve the online presence of government departments. This included initiatives to make government services more accessible through digital channels. Following the UK’s departure from the European Union, administrative reforms were underway to manage customs processes and immigration control, including the development of new IT systems and border infrastructure.
Administrative reforms aimed at addressing environmental issues included the implementation of policies to combat climate change, promote renewable energy, and reduce carbon emissions.

Administrative reforms have focused on increasing the efficiency of government operations, reducing paperwork, and enhancing service delivery. This includes efforts to streamline administrative procedures, reduce administrative barriers for businesses, and improve the investment climate. Reforms in public personnel management have aimed to enhance the quality of the civil service and increase professionalism among civil servants. These efforts involve improvements in recruitment, training, and performance evaluation. The Russian government has also continued its efforts to combat corruption within the public administration through various anti-corruption measures, including the establishment of anti-corruption commissions and enhanced transparency. New reforms have also sought to simplify and update regulations to create a more business-friendly environment.