Scholarship and advocacy surrounding the freedom of religion or belief (FoRB) often focuses on severe cases of persecution in states such as China or Myanmar, where governments actively restrict religious practice and belief. However, important lessons can also be drawn from secular democracies, where there is no state church. Through these secular states, we see how legal protections for religious minorities are tested not through outward oppression, but through questions of neutrality and inclusion. As religious diversity increases in Europe, states now face the challenge of protecting religious freedom while maintaining their secular institutions.

The Netherlands and France are two secular European states seeing increases in religious diversity, but who hold contrasting approaches to FoRB. The Netherlands adheres to a tradition of accommodation while France is committed to strict separation. Comparing the two approaches, the Dutch model offers a more effective framework for protecting FoRB because it preserves state neutrality while still allowing the expression and participation of religious minorities in public life.

Secularism is often understood as simply the separation of church and state, but there is no single model of what this looks like in practice. A government is technically secular if it does not establish or endorse a state religion, but secular states differ in how they engage with religion in public life. Some view state neutrality as requiring religion to be completely private, while others see it as creating equal space for people of all faiths, or none, to participate in society. To put things in perspective, the United States is constitutionally secular, meaning the nation’s founding documents protect freedom of belief and prohibit legally establishing or privileging a religion. However, approximately 70-75% of Americans identify as religious, meaning religion can be seen in day-to-day life and in the values and priorities people of faith bring to their engagement in civic and political affairs. The American system also allows some government expressions of a generic civil religion such as printing “in God we trust” on U.S. currency, or opening congressional sessions with prayer. The Netherlands and France are both more strictly secular than the U.S., yet the Dutch model is distinctly less secularist than the French. These different interpretations have significant implications for FoRB, especially for religious minorities.

The Netherlands seeks to accommodate religious diversity while maintaining state neutrality. Shaped by the tradition of pillarisation, or verzuiling in Dutch, the government recognizes different religious and ideological communities and allows them to establish their own schools, media organizations, and social institutions with equal legal recognition. FoRB is firmly protected by the Dutch Constitution, with the government generally interpreting neutrality as treating different faiths equally rather than limiting their public expression. Religious schools receive public funding alongside secular schools, and people are generally free to wear religious clothing, subject to limited exceptions such as the partial face covering ban introduced in 2019 for safety purposes. Internationally, the Netherlands has positioned itself as a strong advocate for FoRB, joining the International Religious Freedom or Belief Alliance and working to promote religious freedom through its foreign policy.

The Netherlands is certainly not without its challenges, including debates surrounding Muslim immigrants and rising levels of antisemitism, but the Dutch maintain low levels of government restriction and protect a broad range of religious expression. The constitution does allow the government to restrict the exercise of religious beliefs to protect health, ensure traffic safety, and provide stability. The law bans full face coverings including niqabs and burqas, but also bans nonreligious attire such as ski masks and helmets in hospitals and government buildings for example. It is rare for FoRB to be restricted by measures intentionally aimed at religious freedom. These restrictions are instead a byproduct of measures focused not directly on religion, but on the safety and well-being of Dutch citizens.

On the contrary, France represents one of Europe’s strongest examples of separationist secularism, known as laïcité. Rooted in the 1905 French Law on the Separation of Churches and the State, laïcité aims to ensure state neutrality by ending state recognition and funding of any religion. Laïcité was simultaneously supposed to guarantee absolute freedom of conscience but in practice has led to policies restricting religious symbols in schools, bans on wearing of the hijab in public spaces, and the closure of places of worship. French officials argue these measures preserve equality, with Interior Minister Darmanin saying, “Our secularism is not the erasure of our religions, it is the possibility for each religion to flourish.” However, critics counter that these separatist laws disproportionately affect religious minorities, particularly Muslims. Recent controversies have fueled debate over whether laïcité protects religious freedom equally or instead restricts civilians’ ability to publicly declare their beliefs.

While France’s constitution guarantees freedom of religion, in practice, its efforts seem contrary to its legal outlines. France has relatively high government restrictions on religious practice compared with many other European democracies. Between November 2019 and January 2023, French authorities conducted approximately 28,000 investigations that resulted in the closure of 906 establishments, including more than 20 mosques, Qur’anic schools, businesses, and civil society organizations. In terms of education, the law requires parents seeking to homeschool their children to obtain authorization from the state. The government justifies this by saying homeschooled children, particularly Muslim girls, are more likely to be radicalized so their parents must be trained in secular values. In October 2023, Education Minister Gabriel Attal announced that students who observed a moment of silence in honor of two individuals killed by Islamic terrorists would not be allowed to return to school, further highlighting the strict separationism in France. This example is significant because it illustrates how the French state prioritizes laïcité even when it limits certain forms of political or religious expression.

While both approaches are far from perfect, one can see the Dutch model offers a more convincing balance between secular governance and FoRB because it interprets neutrality as equal accommodation rather than equal restriction. Instead of asking religious individuals to leave visible aspects of their identity outside the public sphere, the Dutch government seeks to ensure that people of different faiths can participate in society on equal terms. This approach more closely reflects Article 18 of the United Nations Universal Declaration of Human Rights which states, “Everyone has the right to freedom of thought, conscience and religion” including the right to change beliefs, worship alone or with others and to “manifest their beliefs in teaching, practice, worship, and observance.” A secular state should not force religious citizens to become less visibly religious in order to access education or employment. By accommodating diversity rather than suppressing it, the Dutch model better protects both individual liberties and social inclusion.

Studying the approaches of the Netherlands and France demonstrates that secularism is not a single concept, but a spectrum of policies attempting to manage religion in public life. France prioritizes a strict form of state neutrality which often limits public religious expression, while the Netherlands pursues neutrality through equal recognition and accommodation. The comparison between the two countries reveals it is indeed possible for secular states to protect religious minorities without excluding religion from public life. From it, we learn protecting FoRB is more effectively achieved by creating equal opportunities for citizens of all faiths, and none, to express their beliefs without fear of discrimination or persecution. As European societies continue to become increasingly diverse religiously, accommodationist secularism like that of the Netherlands offers a more sustainable framework for balancing state neutrality with the human right to FoRB than strict secular approaches like laïcité in France.