The French notion of laïcité, or secularism, has sparked a number of controversies on the global stage, particularly in the United States, in recent months. A number of voices have raised concerns about French model of laïcité, some even calling it “illiberal.” Others have drawn an unfavorable comparison with the U.S. model of separating church and state.
Historically, France and the United States share more than they sometimes remember. Laïcité itself is a notion that originated during the Enlightenment and that also inspired the United States. The United States embraced the idea of sharply limiting the state’s influence over religious affairs through the U.S. Constitution’s First Amendment in 1791. France adopted the same principle in 1795 before abandoning it and then fully embracing it in 1905.
The circumstances in which the same concept was implemented diverged significantly. U.S. secularism was embedded in the experience of immigrants who fled Europe, where they were persecuted because of their religious practices. Influenced by that history, the U.S. Constitution’s Establishment Clause focused on preventing the federal government from intervening in individual religious practices.
In France, the idea of separation is grounded in the goal of freeing the state from the domination of the Catholic Church, whose influence led to the persecution of religious minorities. The result is similar, separating the state and religion to preserve civil peace in diverse societies. However, U.S. secularism focuses on individual freedom of religion whereas French laïcité focuses on collective freedom from religious institutions.
Another major factor explaining French-U.S. differences lies in their different secularization processes. In comparative terms, Americans have long been more religious than the French, although declining religious observance in the United States may have narrowed this gap somewhat in recent years. French secularization, by contrast, has been ongoing since the 19th century, and a growing number of French citizens do not practice any religion; 30 percent of French people consider themselves atheists while only 4 percent of Americans do.
In a world shaped by news cycles and social media, complex issues like laïcité can be lost in translation since differing historical, political, and social contexts cause “secularism” to mean something different in every society. French laïcité is, in this respect, very close to Mexican or Albanian secularism but very different from the model in Turkey, Belgium, or Brazil.
Critics of laïcité argue the initial liberal spirit of 1905 has now become a tool to oppress Muslims. This assumption is detached from the actual practice of laïcité. It is not anti-religious or anti-Muslim. Laïcité means French security forces protect mosques like any place of worship. Thanks to laïcité, the state guarantees religious freedom and actively protects such freedoms when needed. The government, for instance, organizes and pays for chaplains at hospitals, in the military, in prisons, and in public boarding schools to make sure worshipers can practice their religion.
There are a limited number of exceptions to religious freedom, where religious expression is restricted for reasons of public order. Regarding the wearing of religious symbols, such as the veil or a cross, they are prohibited for civil servants on duty because they represent a neutral state. In French public schools, pupils are asked to wear only discreet religious symbols to keep primary and secondary schools as neutral spaces and to avoid influencing others. Laïcité is meant to ensure schools can offer teachings without being influenced by religious beliefs. This does not prevent religion from being discussed as a historical topic, distinguishing knowledge from beliefs.
Anyone is entitled to debate whether the laïcité framework regarding these exceptions should be updated. But portraying these exceptions as systemic forms of oppression is misleading. Although French exceptions to religious freedom are often questioned in international discussions, it is worth noting that the 2004 law banning religious symbols—including wearing religious headscarves—from public schools is largely accepted by French Muslims, as the general absence of court cases or incidents involving opposition to this law since 2008 shows.
This does not mean laïcité does not face challenges. The law is not always applied well, but victims of discrimination can sue the perpetrators, and the courts are there to give clarity. When mayors wanted to ban the wearing of so-called burkinis at a beach on the French Riviera, one of the highest French courts condemned the local government and the fines were canceled.
Religious practices evolve and can create new issues like the niqab, a veil that covers the face, which was not used by French Muslims until the beginning of the 2000s but is now considered a religious obligation for 1,000 to 2,000 of them. In some cases, isolated behaviors, local conflicts, or religious groups test legal boundaries and social cohesion. Critics of laïcité often ignore developments like recurring pressures from extremists, in the name of their religion, to impose their own rules on local public institutions and communities. French authorities have been forced to address problematic situations related to a more radical minority within a largely secular population of practicing French Muslims.
A limited number of Islamists, for instance, oppose certain teachings in public schools and challenge the application of laws such as those on same-sex marriage or equality between women and men. Some of them go as far as threatening or killing civil servants and teachers, as the beheading of Samuel Paty sadly demonstrated. Terrorist attacks test a society’s resilience and aim to weaken institutions—especially at a time when others forms of extremism are on the rise; in December 2020, an extremist Catholic killed three police officers.
So far, French society has mostly been resilient. These challenges, however, trigger a very intense—and sometimes bitter, increasingly polarized, and confused—debate about current and future answers, including on religious practices and laïcité. Far-right extremists use that context as a cover for their xenophobic discourse and anti-Muslim bigotry.
They often present local incidents, for instance men refusing to be seen by female doctors in public hospitals, as widespread practices while these isolated behaviors could be dealt with proportionally within the existing legal framework. Indeed, far-right groups use the idea of laïcité in a way that is contradictory to its purpose; they seek to divide society while laïcité is meant to strengthen cohesion. This has triggered a debate, including within the French government, on the best way to prevent the far-right from hijacking and distorting laïcité.
Secularism is a living concept that different groups can try to reshape. Some politicians and activists on the right and left have also used this debate to reopen discussions that were settled in 1905. For instance, they push the notion that laïcité should not only apply to civil servants and public schools but to all public spaces, meaning religious symbols should be excluded from streets, squares, and state universities.
Pressures to develop a stricter secular framework should not be confused with attempts to apply it and preserve its spirit. But together, these debates can create a tense environment, especially when, on both sides of the Atlantic Ocean, citizens get trapped in media echo chambers that amplify polarizing voices or distort the intent of a given policy—for instance, when the government was mistakenly accused of “tracing” Muslim pupils.
It is also important not to conflate a discussion on how to define secularism with other broader issues. Like other countries, France has to address bigotry, racism, social segregation, and discrimination—especially based on religion. The French government must continue to address the roots of these problems.
There is no silver bullet, only steady and substantial government interventions, such as the new plan to invest nearly $4 billion in housing and education and new measures to facilitate access to top jobs in the civil service. These are key measures to alleviate barriers to equality that often drive discrimination and social exclusion and, like other countries, France will have to do more to strengthen social cohesion and preserve democratic values.
But using French laïcité as a scapegoat for these much broader problems is undermining a precious tool designed to bind citizens together and bolster institutions. I have conducted numerous trainings throughout the country and found that, no matter their background, the vast majority of French people believe finding the balance between protecting religious freedoms and preserving public order is an important one.
Religious groups have space to organize their worship as they wish. The Observatory for Laïcité frequently meets and trains French citizens from all backgrounds, including of course Muslims, who proclaim their attachment to laïcité as a principle allowing them to express their beliefs while guaranteeing an impartial state. To be sure, a recent poll my organization conducted showed 73 percent of French citizens expressed support for laïcité.
Whether a government emphasizes freedom of religion or freedom from religion, it might be more useful to reflect on the similarities between the U.S. and French systems and not project their respective culture wars onto the debate.
To bear witness to this, it is worth recalling a U.S. figure who was a major source of inspiration for the future French model of laïcité: In 1636, the Puritan minister Roger Williams—who founded the city of Providence after being expelled from Massachusetts—was the first to use the “wall of separation” formula between religion and the state, which he applied to his city, guaranteeing freedom of worship to all—no matter their religion.
He wrote, “There is no point in breaking with papism, translating the Bible into the vernacular, allowing even the simplest men and women to study the Scriptures if they are then forced to believe what the Church believes.” He concluded by recalling a necessity that Americans and the French agree on: “Absolute freedom of conscience is necessary for all.”
