INTRODUCTION:
The European Union (EU) upholds specific human rights principles related to equality and
discrimination, yet significant disparities exist among member states in implementing these rights,
when it comes to LGBTQ+ people. All the Member States can decide about marriage and adoption
rights, which causes the diversity in these areas of rights. In several countries of Central Eastern
Europe, LGBTQ+ people cannot get married, cannot adopt children, LGBTQ+ people feel
discriminated in numerous areas of life, meanwhile, in Western Europe, LGBTQ+ people have
gained recognition to their rights. The EU is trying to implement new laws and regulations to
combat discrimination against LGBTQ+ people, and achieve equality in all the Member States, but
adapting to the new legislations means introducing liberal values, which causes resistance in some
countries, mostly in Central and Eastern Europe.
The clear division between Central Eastern Europe and Western Europe is also
acknowledged by Joanna Mizielińska and Robert Kulpa’s chapter about ‘Contemporary
Peripheries’: Queer Studies, Circulation of Knowledge and East/West Divide in the book, called
De-Centring Western Sexualities, Central and Eastern European Perspectives. They explore the
complexities of LGBTQ movements and queer studies within the context of Central and Eastern
Europe (CEE), questioning whether these movements simply mirror Western narratives. The study
focuses on the construction of sexuality and LGBTQ activism in the region, considering the
adoption of Western labels and the emergence of transgender activism. They highlight the
challenges of Western perceptions of progress versus the CEE's ongoing transformation, framing
CEE as a "contemporary periphery" striving to align with Western ideals. (Mizielińska, Kulpa,
2011)
LGBTQ+ rights are becoming extremely diverse within the EU, due to different political
views. Magni and Reynolds’ study provides a comprehensive overview of the progress and
challenges related to LGBTQ+ rights around the world, with a particular focus on Europe. The
authors highlight legal advances in some countries, such as the legalisation of same-sex marriage
and protection against hate crime and discrimination, but also confront the harsh reality that
homosexuality remains illegal in many countries, with severe penalties in some cases. The
discussion also covers the political situation, noting that LGBTQ+ rights are accepted by centre-
right parties as a sign of modernity and inclusion in Europe. However, it also explores the complex
motivations behind this acceptance, whether it is driven by a genuine change in values or an
electoral strategy. The researchers analyse the developments in the European right's position on
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LGBTQ+ issues, including differences between centre-right, radical right and religious right parties.
While some countries have embraced LGBTQ+ rights as a national value, others, particularly in
Eastern Europe, often resist this development on the grounds of religious and nationalist values. The
paper also outlines the challenges faced by transgender and gender non-conforming individuals who
continue to face discrimination and violence, particularly from the radical right, which sees
LGBTQ+ rights as a threat to traditional values. Furthermore, the research also discusses the
concept of 'homonationalism', where LGBTQ+ rights are used to justify anti-immigrant and anti-
Islamic positions, highlighting the complexity and intersectionality of these issues. (Magni,
Reynolds, 2023)
Ideology and history have important roles in the countries’ values, which is represented in
the book of Radzhana Buyantueva and Maryna Shevtsova (called LGBTQ+ Activism in Central and
Eastern Europe - Resistance, Representation and Identity), discusses LGBTQ+ activity in post-
socialist countries, especially in Central and Eastern Europe. These are movements which are
mostly unofficial and exclusive, with low attention and restricted political visibility because of the
state-supported homophobia and the opposition to LGBTQ+ rights by conservative political and
religious elites in countries such as Poland, Hungary and Romania. The government of Hungary, led
by Viktor Orbán, has been proactive in opposing LGBTQ+ rights, for example by removing
accreditation for gender studies programmes. The chapters of the book reveal the various issues
affecting LGBTQ+ activists in the region, such as the fight for the recognition of rainbow families
and the legal definition of the family in Hungary. Hungarian activists have campaigned for
legislative reforms, notably on registered partnerships, adoption rights and access to reproductive
technologies. In spite of legal barriers, a remarkable number of LGBTQ+ people in Hungary have
built rainbow families via different methods, like adoption and artificial insemination. This raises
the issue of the intimate citizenship as a human right of rainbow families to the focus of the debate.
(Buyantueva, Shevtsova, 2020)
Based on the existing literature, history has a crucial role in the differences, but the current
politics and ideology are even more important, when it comes to the recognition of LGBTQ+ rights.
In theory, all the people are equal in the EU, but LGBTQ+ rights varies in the Member States. What
leads to the different ways of equality when it comes to LGBTQ+ rights? How can recognition be
achieved? To figure out how the diversity in equality is possible, the following research will focus
on three research questions, comparing the liberal Netherlands and the conservative Hungary, taking
also into consideration the EU’s ambitions to create equality:
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What is the EU doing to improve LGBTQ+ rights? What are the effects of the EU’s
ambitions on the Netherlands and Hungary? How did these countries’ LGBTQ+ rights
develop?
How do non-governmental organisations (NGOs), religion, and politics influence the
inequalities between the Netherlands and Hungary?
What causes the resistance towards LGBBTQ+ equality in Hungary?
Hungary was chosen to be one of the investigated countries because it is usually present as a
negative example in current literature, researches and discussions because of its discriminative laws,
By answering these questions, it will become more clear what motivated the creation of these laws
and how this different way of equality is possible compared to the Netherlands, which has been in
the forefront of recognising LGBTQ+ rights. Investigating different actors which support difference
in equality help understanding the diversity in rights.
The idea of intimate citizenship, and homonationalism appeared in several literature, so they
will be used as theories, which will help to see what changes happened in our world, what
challenges the improvement of LGBTQ+ rights. Furthermore, moral poltics theory will also be
introduces to see the core differences between conservatism and liberalism. After explaining the
theories, the methodology part will introduce the characteristcs of comparative case study and
demonstrate the cases, sources and limitations of the research. The analysis part starts with the
ambtions of the EU, why this issue became important now, what has been initiated by the European
Commission, and what has been done by the European Parliament and the Council. The analysis
continues with presentation of LGBTQ+ rights in the Netherlands and in Hungary. Following the
rights, the paper will demonstrate NGOs that support LGBTQ+ rights, and roles of religion and
government to show what effects they have on LGBTQ+ rights. At the end, the analysis arrives to
the discussion part about comparison of the two counries, in which the research sheds light on what
the conflict between Hungary and the EU is based on, which also supports the differences between
the two cases.
Sources:
Buyantueva R., Shevtsova M., 2020, ‘LGBTQ+ Activism in Central and Eastern Europe:
Resistance, Representation and Identity’, Palgrave Macmillan Cham, pp 1-49, pp 313-340
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Kulpa R., Mizielińska J., 2011, ‘Contemporary Peripheries’: Queer Studies, Circulation of
Knowledge and East/West Divide, in De-Centring Western Sexualities, Central and Eastern
European Perspectives, 2011, Ashgate, pp 11-26
Magni G., Reynolds A., 2023, ‘Why Europe's Right Embraces Gay Rights’, Journal of
Democracy, Volume 34, Number 1, January 2023, pp. 50-64, Johns Hopkins University Press