In a commentary during the last shutdown in mid-January, China’s official news agency blamed “chronic flaws” in U.S. politics and mocked President Trump for having the anniversary of his first year in office damaged by his alleged inability to negotiate a deal. “The Western democratic system is hailed by the developed world as near perfect and the most superior political system to run a country. . . . However, what’s happening in the United States today will make more people worldwide reflect on the viability and legitimacy of such a chaotic political system,” China's news agency wrote, according to Reuters.
But many Europeans would reject such an assessment of the current political chaos in Washington. Government shutdowns, they say, are uniquely American and hardly an indication of the demise of Western democracy.
So why is it that the U.S. government can simply shut down while in virtually any other country — no matter how submerged in partisan squabbles — the government keeps on ticking?
First, let’s look at what’s happening in the United States.
In an annual tradition, both the House and the Senate are supposed to pass 12 appropriations bills, funding agencies and channeling spending. Because Congress often fails to pass them, interim stopgap budgets have become more frequent in recent years. But if all efforts fail, the government shuts down until a deal is brokered. Hundreds of thousands of federal workers have to stay at home while agencies largely halt their work.
Elsewhere in the world, constitutions or political systems prevent scenarios that would be comparable to the U.S. impasse, even though parliaments have a say on budgets there, too. The difference, however, is that most countries have installed specific mechanisms to escape a U.S.-style deadlock so that citizens don’t pay for partisan disagreements.
In some countries, government budgets are even more associated with the fate of those in power themselves than in the United States — which, perhaps unexpectedly, often ends up helping to reach consensus or results in a more permanent solution.
In Australia, for instance, budgets have to be passed or else the government is usually forced to resign or Parliament gets dissolved. What’s different in Australia and other countries is the threshold of lawmakers needed to confirm spending, though: an absolute majority, with over 50 percent of all members of Parliament, is sufficient. Hence, a failure to pass the budget usually only occurs when a government has lost the support of its own party or of the parties backing it. The inability to pass a budget also does not lead to an immediate funding stop but rather to a mere delay in planned investments, amounting to up to 25 percent of the annual budget.
Similar mechanisms have long been in place in other countries influenced by Britain’s Westminster-style parliamentary system, including New Zealand, Bangladesh and Canada.
In those nations, budget votes can become de-facto confidence votes on the government itself.
In contrast, the Republicans in the United States need three-fifths of Senate members to pass most legislation, which means that they frequently rely on bipartisan support. (Trump recently urged a rewriting of Senate rules to be able to pass the spending bill with a simple majority, but his plans have so far been dismissed because they would also apply when Democrats gain a majority again.)
While the U.S. president cannot simply be forced out of office in budget votes because of his independence within the bicameral political system, most other leaders abroad have far more to lose.
Even if parliamentary systems are usually better equipped to eventually force an agreement on budgets without a government shutdown, there are rare cases of long and dangerous deadlocks. The British Parliament had to impose a budget on Northern Ireland in November after the country’s divided parties were unable to agree on a deal themselves. The imminent threat — local civil service running out of money within days — was strikingly similar to what is currently unfolding in the United States.
Northern Ireland’s situation was unique, however. Its violent history has resulted in a fragile power-sharing agreement that cannot simply be dissolved. As a result, London had to step in to keep the cash flowing in the region, which is administratively part of the United Kingdom, even though it is usually governed by its own Parliament and prime minister.
Mechanisms to prevent the de facto bankruptcy of the government are not unique to the Anglo-Saxon world. When the German government faced resistance to its spending bill in 2004 for the first time in contemporary history, the blockade of the upper house of Parliament was swiftly defeated by another vote in the government-dominated lower house. Even if then-Chancellor Gerhard Schröder had failed to rally his own coalition behind him to overturn the decision of Germany’s equivalent of the U.S. Senate, the repercussions would have been comparably less severe than in the United States. German employment law makes it impossible for government employees to be simply sent home because of a political dispute.
Parliamentary systems have their own flaws, of course, as budget negotiations can become much more complicated when a minority government is in power. When Sweden's left-of-center minority government failed to pass its budget in 2014, it eventually had to agree to govern under a spending bill proposed by the opposition. The country was still never at risk of a government shutdown.
Ironically, things become a little easier when there is no elected government in place at all. Belgium was without a government for 589 days between 2010 and 2011, but the money there kept flowing, too. When European coalition talks fail or drag on for months — as it is currently the case in Germany — the most recent budget usually continues to apply and is administered by the previous government that is in place until a new leadership takes over.
Hence, civil servants continue to be paid and government-funded construction projects are not halted. “Things that won’t be funded [during this period] are, for instance, new development schemes, new construction plans or additional military investments,” Eckhardt Rehberg, a conservative German budgetary affairs spokesman, recently explained to broadcaster ARD. Germany may technically be without a budget since Jan. 1, but so far nobody appears to have noticed it.
That’s mainly because Germans have learned from history that government shutdowns tend to be one of the least successful measures to force cross-party cooperation. In the 19th century, Prussian King Wilhelm I — who later became known as the first German emperor — faced off with Prussia’s parliament (located in today’s Berlin) in a seven-year long dispute over the funding of a military expansion. Throughout that period, the monarch almost resigned, the parliament became increasingly hostile and divided, and the military expansion remained unfunded.
When Germans rewrote their constitution after World War II, much of it was based on the U.S. model. The possibility of government shutdowns, however, didn’t make it into the German Grundgesetz — very much so on purpose.
This post was first published Jan. 22. It was updated Feb. 9.
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