Spain: contract with the state

In Spain, 2.5 percent of the population is Muslim, with the majority coming from North Africa. The Spanish government granted Islam official legal status back in 1992 in a cooperation agreement between the state and the Spanish Islamic Commission (CIE).

An estimated 30 percent of Spanish Muslim communities currently belong to the CIE, which is made up of two federations, and as such as has two general secretaries instead of a president. Decisions can only be made when both federations agree.

Because secularism is one of the Spanish state's fundamental principles, there is no real legal basis for an agreement of this kind with specific faiths. The state has, however, also signed a similar agreement with organizations representing both Christian confessions and with the Jewish community. Islam has, therefore, been placed on an equal legal footing with the other major religions.

Austria: criticism from within the ranks

Islam's position in Austria is very clear cut -- Islam has been recognized as a religion since 1912 and the Islamic Faith Community in Austria (IGGiÖ) has enjoyed the status of a public corporation since its foundation in 1979.

Because of this, the Austrian model is often held up as an example, but -- and this is a large "but" -- although the IGGiÖ seeks to represent all Muslims, many Shiite and Alevi Muslims living in Austria do not feel represented by the IGGiÖ.

In 2006, the Alevi submitted an application to the Austrian Ministry for Religious Affairs to have Alevism recognized as an official religion.

Criticism has also been voiced by the Sunnis, who claim that the IGGiÖ does not represent their interests and allege that its structures are undemocratic.

The IGGiÖ has been widely criticized for the lack of transparency in its membership practices. Only those who pay the annual membership fee are entitled to vote, but the organization does not release information about votes or lists of members.

There have also been allegations of fees being returned without reason, and the rejection of membership applications, such as happened to Günther Ahmed Rusznak, secretary general of the Islamic Information and Documentation Center and a harsh critic of the IGGiÖ.

Moreover, although almost 70 percent of Austrian Muslims are of Turkish extraction, the IGGiÖ leadership is almost exclusively made up of Arab Muslims. This means that the IGGiÖ's status as a state-recognized body is at risk.

French Islam by state decree?

Although the French Council for the Muslim Faith (CFCM) was founded in 2003 at the instigation of the then Interior Minister Nicolas Sarkozy, it is only informally recognized as a representative by the state. The council's legal status corresponds to that of a registered charitable association.

Some 88 percent of the 4,032 delegates from French mosques voted in council's first elections. The number of delegates is based on the size of each mosque; there are also 25 representatives at regional level.

Despite this high level of representation, the CFCM has been continually criticized for failing in its responsibility to represent Muslims, particularly given that the French government influences the selection of candidates for all important posts within the organization.

After all, Sarkozy succeeded in installing his preferred candidate, the imam of Paris' central mosque, Dalil Boubakeur, as the head of the CFCM.

The French state is patently looking for a proponent of "liberal" Islam as their Muslim representative -- someone who, for instance, would assist with the enforcement of the law banning religious symbols in schools.

This is exactly what upsets French Muslims, who do not consider such policies to be in line with their interests. Other critics, however, consider the council to be too radical, as one of its member federations is said to have close links to the Egyptian Muslim Brotherhood.

UK: disagreement on the political angle

The Muslim Council of Britain (MCB) was founded in the United Kingdom in 1997 with the support of the Labour government. It fulfils its responsibility of representing all Muslims in so far as it brings together some 3000 organizations from across the spectrum of British Islam, and represents an estimated 70 percent of British Muslims.

The MCB used to have a good relationship with the Labour government; however, since the London bombings, many Muslims feel badly treated and misunderstood.

The MCB has to meet the difficult twin objectives of lobbying to enable stricter forms of Islam to be practiced on the one hand, and of meeting the British public's expectation of a firm rejection of terrorism and Islamist acts of violence on the other.

The substantial group of Sufist Barelwi Muslims in Britain does not believe that the MCB can really represent all Muslims because it is dominated by the Deobandi, who practice a stricter form of Islam and are more politically organized.

The Barelwi are represented by the British Muslim Forum, which does not belong to the Muslim Council of Britain.

Although there has been no agreement with the government on Muslim affairs in the UK, the construction of Muslim primary and secondary schools is funded by the state.

This article was first published on the Qantara.de Web site, a joint project from Deutsche Welle, Germany's Federal Center for Political Education, the Goethe Institut and the Institute for Foreign Cultural Relations. Qantara.de aims to promote dialogue with the Islamic world. It is funded by the German Foreign Ministry.