Norm proponents as drivers of deinstitutionalisation: the case of Germany’s arms export to Israel

Introduction

On 7 October 2023, Hamas launched an unprecedented attack on Israel, killing approximately 1,200 people and taking over 250 hostages. Israel’s military response in Gaza has, at the time of writing, killed over 45,000 Palestinians, displaced the overwhelming majority of Gaza’s population, and generated formal proceedings at the International Court of Justice alleging genocide. In the weeks immediately following the attack, Germany authorised a tenfold increase in arms export licences to Israel, including anti-tank weapons subsequently reported as used against residential buildings and tank ammunition documented as deployed indiscriminately in densely populated areas. At the same time, Germany was simultaneously scaling up arms transfers to Ukraine in response to Russia’s full-scale invasion, positioning itself as a leading supporter of the rules-based international order. Both sets of transfers occurred under the formal oversight of a state widely regarded as one of the world’s most restrictive arms exporters, operating under a legal framework explicitly designed to prevent the supply of weapons to active conflict zones and to parties at risk of committing serious violations of international humanitarian law.

This juxtaposition – the maximum rhetorical commitment to arms export restraint alongside maximum practical flexibility in its application – is the puzzle that motivates this paper. It is not simply a story of political hypocrisy or institutional failure, though both are present. It is, this paper argues, a symptom of a deeper structural condition: the deinstitutionalisation of international arms control norms, driven not by the opponents of those norms but by one of their principal architects and most prominent advocates. To understand how this is possible, and what it means for the future of the international arms trade regime, this paper applies role theory to the German case.

The ongoing wars in Ukraine and Gaza have placed the institutional framework of international arms trade regulation under unprecedented strain. Both conflicts have intensified arms transfers on a scale that strains established regulatory categories, exposing limitations and loopholes within the Arms Trade Treaty (ATT), the EU Common Position on Arms Exports, and national export control legislation. Germany occupies a particularly revealing position within this landscape. It is the third-largest arms exporter globally, a co-architect of the EU Common Position, and a state with a constitutionally anchored pacifist tradition and a publicly declared commitment to restrictive export policy. In 2023, it published its first-ever National Security Strategy (NSS), explicitly reaffirming its commitment to clear criteria and rules-based arms export governance through a forthcoming Arms Export Control Act. Yet in the same period, it was authorising transfers to two active conflict zones under conditions that multiple legal scholars, UN experts, and civil society organisations have argued constitute violations of the ATT and potentially implicate Germany in serious human rights abuses and crimes against humanity. The tension between Germany’s declared regulatory ambitions and its actual export behaviour demands systematic explanation.

The study of arms trade regulation at this particular juncture is timely for both scholarly and policy reasons. The wars in Ukraine and Gaza, alongside the protracted conflict in Yemen and the broader reconfiguration of global security alignments following Russia’s 2022 invasion, have collectively exposed the limits of the post-Cold War arms control architecture in ways that earlier scholarship could not anticipate. The ATT, which entered into force in 2014 with considerable normative ambition, has proven unable to prevent major exporters from supplying parties to active conflicts characterised by documented International Humanitarian Law (IHL) violations. The EU Common Position, despite its formal legal bindingness, has generated divergent national interpretations that have effectively disabled its harmonising function in precisely the cases where it matters most. I argue in this paper that these cases reflect a deeper process of norm erosion that, if unaddressed, will progressively hollow out the institutional foundations of international arms control and generate dangerous precedents for global security governance more broadly.

Yet the scholarly literature has not kept pace with these developments. International Relations as a discipline has, over the past three decades, devoted considerable attention to the processes through which norms emerge, cascade, and become institutionalised (Finnemore and Sikkink, 1998; Katzenstein, 1996; Sikkink et al., 2009). The reverse process, deinstitutionalisation, understood as the weakening, contestation, reinterpretation, or selective abandonment of established norms, has received comparatively little systematic attention, and remains both under-conceptualised and insufficiently grounded in empirical analysis (Deitelhoff and Zimmermann, 2019; Panke and Petersohn, 2012). Where deinstitutionalisation has been studied, the focus has tended to fall on institutional withdrawal by norm opponents – states that openly reject or exit from regulatory frameworks – rather than on the more theoretically challenging process through which norm-championing states erode the norms they publicly uphold through the accumulation of justified exceptions. This is a critical lacuna. If deinstitutionalisation can be driven by proponent states rather than opponent states, through mechanisms that preserve formal institutional structures while evacuating their substantive constraining power, then existing frameworks for understanding norm robustness and institutional stability require fundamental revision.

This paper addresses that lacuna by investigating the following question: under what conditions does role conflict within norm-promoting states drive the deinstitutionalisation of international institutional norms? It advances the argument that Germany’s selective compliance with arms export regulation, and particularly its systematic exceptionalism toward Israel, cannot be fully explained by strategic calculation, commercial interest, or enforcement failure alone. While these factors form part of the broader context of German arms export policy, the paper argues that the distinctive treatment of Israel also reflects an unresolved interrole conflict between two constitutive national role conceptions: Germany as a civilian power committed to multilateralism and human rights, and Germany as the historical guarantor of Israeli security, obligated by Holocaust responsibility to ensure Israel’s survival. When these roles collide, the latter tends to be prioritised through processes of discursive role prioritisation, institutional accommodation of role conflict, and differential audience management.

The paper makes three contributions to existing scholarship. First, it identifies the proponent state as a distinct and undertheorised agent of deinstitutionalisation, whose norm violations are particularly consequential because they cannot be dismissed as the behaviour of outsiders or norm opponents. Second, it develops a role-theoretical mechanism-level account of how identity conflicts within norm-championing states generate institutional erosion from within, advancing beyond Finnemore and Sikkink’s (1998) norm life cycle model by theorising the conditions under which internalised norms are selectively de-applied. Third, it grounds these theoretical claims in an empirical analysis of Germany’s arms export policy, drawing on official documents, parliamentary records, quantitative export data, legal proceedings, and civil society documentation to trace the causal mechanisms at work across an extended time period.

The paper proceeds as follows. The next section reviews the literature on norm institutionalisation and deinstitutionalisation, situating the paper’s contribution within existing debates. The theoretical framework that follows develops the role-theoretical account of deinstitutionalisation, deriving five propositions that structure the subsequent empirical analysis. The methodology section justifies the case study design and process-tracing approach. The empirical section then analyses Germany’s general approach to arms export regulation, its specific allegiance to Israel and the exceptionalist practices this generates, the broader implications of these dynamics for the deinstitutionalisation of international arms control, and discusses potential alternative explanations. The conclusion draws together the theoretical and empirical findings, reflects on their generalisability, and identifies directions for future research.

Literature review

The study of international norms – the shared expectations and standards of appropriate behaviour among actors in the international system (Finnemore and Sikkink, 1998; Katzenstein, 1996) – has become central to constructivist and sociological approaches in International Relations (IR). Scholars have long examined how norms emerge, become embedded in institutions, and influence state behaviour (Checkel, 1999; Sikkink et al., 2009). In parallel, a growing body of literature is turning to the weakening, erosion, or reversal of norms, known as deinstitutionalisation (Deitelhoff and Zimmermann, 2019; Panke and Petersohn, 2012). This dual focus – on both norm construction and norm decay – provides essential analytical tools for understanding contemporary challenges to the liberal international order.

The institutionalisation of norms refers to the process by which new normative frameworks are developed, promoted, and embedded into international structures, shaping how actors understand and respond to global challenges. Finnemore and Sikkink’s (1998) influential norm life cycle model identifies three key stages: norm emergence, norm cascade, and norm internalisation. In the early phase, norm entrepreneurs such as transnational advocacy networks, international organisations, or morally authoritative states advocate for new standards, drawing on moral authority, material incentives, or persuasion (Keck and Sikkink, 1998). As more states adopt the norm (the cascade phase), it becomes increasingly embedded through mechanisms such as international law, treaties, bureaucratic practices, and socialisation processes (Johnston, 2001). Once internalised, norms can appear ‘taken for granted’ (Jepperson et al., 1996, p.45), structuring state identity, preferences, and behaviour in ways that actors may no longer consciously question.

International organisations (IOs) play a crucial role in this process. As Barnett and Finnemore (2004) argue, IOs not only implement norms but also act as normative agents, interpreting, diffusing, and sometimes constituting new standards of appropriate conduct. The creation of robust legal frameworks – such as the Responsibility to Protect (R2P), the Arms Trade Treaty (ATT), or international humanitarian law (IHL) – represents the formal codification of normative expectations. These frameworks are often accompanied by monitoring mechanisms, compliance procedures, and sanctioning systems designed to ensure adherence (Tallberg, 2002). The institutionalisation of norms around human rights, democracy, and arms control are frequently cited as evidence of successful norm consolidation in the post-Cold War era (Risse et al., 2013).

However, institutionalisation is neither linear nor irreversible. As March and Olsen (2008) note, institutional stability depends on continued reproduction through practice, resources, and legitimacy. When these conditions erode, even deeply institutionalised norms may become vulnerable to contestation or abandonment.

Deinstitutionalisation of norms, defined as the weakening, contestation, reinterpretation, or outright abandonment of established norms, has received increasing scholarly attention over the past decade (Deitelhoff and Zimmermann, 2019; Hofferberth and Weber, 2015; Sandholtz and Stiles, 2009). This reflects growing concerns about the fragility of liberal internationalism, human rights regimes, and democratic values in the face of global power shifts, authoritarian resurgence, and normative contestation (Risse et al., 2013).

Deitelhoff and Zimmermann (2019) conceptualise norm robustness as dependent on both the degree of contestation (validating, applicatory, or fundamental) and the institutional strength supporting the norm. Norms may be weakened through several mechanisms: discursive contestation, institutional withdrawal, norm appropriation and dilution, reinterpretation and double standards, and active norm reversal. First, discursive contestation means that states challenge the legitimacy or interpretation of norms through counter-framing or rival narratives (Wiener, 2014). For example, the R2P norm has been contested by states invoking sovereignty or non-interference principles (Bellamy, 2015). Institutional withdrawal happens when states disengage from treaty obligations, defund international organisations, or refuse participation in monitoring mechanisms. Examples include US withdrawal from the UN Human Rights Council (2018) or Russia’s departure from arms control agreements. Norm appropriation and dilution happens when actors selectively adopt norm language while hollowing out its substantive content. Krook and True (2010) highlight how resistance to gender equality norms often involves strategic appropriation, undermining their transformative potential without overtly rejecting them. Similarly, Bloomfield and Scott (2018) show how ‘norm antipreneurs’ actively work to prevent or reverse norm acceptance. Reinterpretation and double standards can be found when states invoke norms selectively, applying them to adversaries while exempting themselves or allies (Sandholtz, 2019). This undermines the norm’s universality and perceived legitimacy. Lastly, McKeown (2009) explores how states may engage in deliberate rollback of norm commitments (active norm reversal or backsliding) to pursue domestic or strategic goals, even while maintaining rhetorical allegiance. This is particularly evident in democratic backsliding and human rights regression (Levitsky and Ziblatt, 2018).

Wiener (2014, 2004) further argues that norms are inherently contested because they are embedded in social practices and interpreted differently across cultural and political contexts. This interpretive flexibility means that institutionalised norms rarely collapse suddenly; rather, they face gradual erosion as actors engage in ‘normative friction’ (Acharya, 2004) or invoke rival norms to justify non-compliance. For instance, the tension between humanitarian intervention norms and sovereignty norms creates ongoing contestation in international politics (Welsh, 2013).

Moreover, external shocks – such as war, financial crises, or pandemics – can disrupt established normative orders, accelerating processes of deinstitutionalisation (Wiener and Puetter, 2009). In such moments, institutional inertia may not be sufficient to preserve norms unless there is continued political will, material resources, and social legitimacy to uphold them (Sandholtz and Stiles, 2009).

While the deinstitutionalisation literature has identified various mechanisms of norm erosion, less attention has been paid to how role conceptions and normative exceptionalism can drive states to diverge from established international norms. Role theory in IR (Holsti, 1970; Cantir and Kaarbo, 2012; Thies and Breuning, 2012) posits that states develop national role conceptions (NRCs) – shared understandings of their identity, position, and appropriate behaviour in international society – which shape foreign policy choices.

Recent work has explored how special relationships can create normative exceptions. Bromley et al. (2012) examine how alliance commitments may override human rights considerations in arms exports. Aggestam (2008) analyses how identity-based foreign policy can justify contradictory practices. However, the specific mechanism linking role conceptions to deinstitutionalisation remains undertheorised.

Arms export control represents a particularly significant area of norm institutionalisation and contestation. Since the end of the Cold War, a robust normative framework has emerged emphasising responsible arms transfers, humanitarian considerations, and conflict prevention (Bromley et al., 2012). Key instruments include the Arms Trade Treaty United Nations (2013), Council of the European Union (1998), or National export control laws.

These norms have been institutionalised through legal frameworks, bureaucratic procedures (licensing systems, risk assessments, parliamentary oversight), and monitoring mechanisms (annual reports, civil society scrutiny) (Erickson, 2015; Stohl and Grillot, 2012). Compliance is often seen as a marker of responsible statehood and commitment to the rules-based international order (Bromley et al., 2012).

However, arms export norms have also proven highly contested and vulnerable to deinstitutionalisation. States frequently invoke security imperatives, alliance commitments, or strategic interests to justify exceptions (Bromley, 2012). The gap between rhetorical commitment and actual practice is well-documented. Yet most scholarship focuses on ad hoc violations or commercial/strategic drivers of non-compliance (Erickson, 2015; Bromley et al., 2012).

What remains underexplored is how deeply institutionalised roles, particularly those rooted in historical identity and moral obligation, can systematically override institutionalised export control norms, even among states with strong democratic credentials and public commitment to humanitarian principles. This is precisely the puzzle that Germany’s arms exports to Israel present.

This paper contributes to both gaps by examining Germany’s arms export policy toward Israel as a case of role-driven selective deinstitutionalisation. Germany maintains one of the world’s most restrictive arms export control regimes, yet consistently grants exceptions for Israel. This case illuminates how deeply institutionalised roles can override equally institutionalised norms, creating normatively justified exceptions that erode norm universality without formal abandonment.

Theoretical framework: can role theory explain the deinstitutionalisation of international norms?

Role theory offers a powerful analytical lens for understanding how states perceive and enact their identities and behaviours in the international system, and it holds significant potential for explaining processes of norm deinstitutionalisation (Harnisch, 2012; Cantir and Kaarbo, 2012). Originating from social psychology and symbolic interactionism, role theory treats the concept of ‘role’ as central to social life, applicable across individual, state, and systemic levels of analysis (Thies, 2017; Wehner and Thies, 2021). While traditionally employed to explain foreign policy continuity and identity-driven behaviour, role theory’s emphasis on role conflict, role contestation, and role reconstruction makes it particularly suited to analysing how deeply institutionalised norms can be selectively eroded or abandoned (Breuning, 2017).

At its heart, role theory in Foreign Policy Analysis (FPA) begins with the idea that states, much like individuals, hold beliefs or images about their identity – known as national role conceptions (NRCs) – which shape their actions in the international system (Holsti, 1970; Thies, 2017). NRCs represent a state’s self-understanding of its position, purpose, and appropriate conduct within international society (Wish, 1980). These conceptions are not merely strategic calculations but are constitutive of state identity, defining what a state is rather than merely what it wants (Harnisch et al., 2011).

Critically, roles operate at the intersection of agency and structure. They are both self-ascribed (ego roles) and alter-cast (how others expect the state to behave) (Harnisch, 2012). Role performance emerges from the interaction between a state’s internal role conception and the role expectations of relevant audiences, such as other states, international organisations, domestic constituencies, and transnational civil society (Thies, 2017). When ego and alter roles align, role performance is stable and reinforces existing social structures. When they diverge, role contestation emerges, creating opportunities for institutional change (Wehner and Thies, 2021).

Role expectations are norms, beliefs, and preferences concerning how an actor in a particular social position should perform, taking into account the behaviours of those in complementary positions (Thies, 2017). These expectations can be held by: the role occupant itself (role conceptions); occupants of complementary positions (counter-roles), such as allies, adversaries, or international organisations; and an audience that observes and evaluates role performance (Harnisch, 2012). The audience is crucial, as it establishes the consensual reality for a role, provides behavioural cues, offers social reinforcement through rewards and sanctions, and helps maintain role behaviour over time (Thies, 2017). Audience reactions can either validate a state’s role performance (strengthening role enactment) or challenge it (creating pressure for role revision).

When states face contradictory normative expectations embedded in different roles, the concept of role conflict becomes an important tool for understanding the dynamics through which norms are contested, reinterpreted, or abandoned (Harnisch, 2012). A role conflict occurs when an actor occupies two or more positions requiring contradictory or incompatible role enactments (Thies, 2017; Aggestam, 2008). Interrole conflict arises when a state concurrently holds multiple positions that necessitate divergent behaviours (Thies, 2017). For example, a state may simultaneously hold roles as a ‘human rights advocate’ (requiring adherence to international humanitarian law) and a ‘strategic ally protector’ (requiring support for a partner regardless of their human rights record).

National role conceptions are not held or interpreted uniformly across the state. Political leaders, parties, ministries, parliamentary actors, courts, and civil society may attach different meanings and priorities to competing roles (Cantir and Kaarbo, 2012). Interrole conflict therefore also creates domestic political contestation over which understanding of appropriate behaviour should guide policy. The consequences of such contestation depend not simply on whether disagreement exists, but on whether the actors articulating competing role conceptions can translate their preferences into authoritative decisions. Political leadership and control over relevant decision-making institutions may privilege one interpretation, while parliamentary scrutiny, judicial review, coalition politics, or sustained societal pressure may strengthen competing interpretations. Domestic contestation should therefore be understood as part of the process through which national roles are interpreted and hierarchised, rather than as an external reaction to an already established state role.

Role theory provides a causal mechanism linking role conflict to norm deinstitutionalisation through three interrelated processes: role prioritisation, role reconstruction (role making), and audience acceptance.

A first mechanism could be provided in role prioritisation under conflict. When confronted with incompatible role demands, states cannot simultaneously satisfy all expectations. They must prioritise which role takes precedence (Aggestam, 2008). This prioritisation is shaped by identity salience, when roles central to national identity (constitutive roles) are more resistant to abandonment than peripheral or instrumental roles (Breuning, 2017); audience power (Cantir and Kaarbo, 2012); material stakes (Barnett, 1993); or historical path dependence (Harnisch et al., 2011). Critically, when a state prioritises a particularistic role (e.g., “special relationship protector”) over a universal norm (e.g., “humanitarian arms export control”), it initiates selective deinstitutionalisation. The norm is not rejected in principle but is subordinated in practice for specific contexts.

Second, role making and normative justification can provide another causal mechanism linking role conflict to norm deinstitutionalisation. Rather than simply violating norms, states facing role conflict often engage in “role making” – the creative reinterpretation or reconstruction of roles to reconcile conflicting demands (Harnisch, 2012). In the context of norm deinstitutionalisation, role making manifests as normative justification for exceptional behaviour. States invoke their special identity or historical obligations to argue that the norm remains valid in general but does not apply in their specific case due to unique circumstances, the conflicting role supersedes the norm because it represents a deeper moral obligation (e.g., historical guilt, alliance loyalty) or that compliance with the norm would violate the state’s core identity, making it an illegitimate constraint (Krebs and Jackson, 2007). This differs from hypocrisy (claiming to support a norm while secretly violating it) or strategic instrumentalisation (manipulating norms for material gain). Instead, role-driven exceptionalism involves sincere belief that the divergent behaviour is normatively justified by the state’s special position (Sending, 2002). Role making thus becomes a mechanism of selective deinstitutionalisation: the norm’s universality is eroded through accumulation of “justified exceptions,” even as its formal institutional status remains intact.

A third mechanism is provided by audience acceptance and norm erosion. The success of role-driven norm deviation depends critically on audience reactions (Thies, 2017). If relevant audiences such as international organisations, allied states, civil society, domestic publics accept the normative justification offered by the role-making state, the exception becomes legitimised, weakening the norm’s constraining power (Harnisch, 2012). However, when audiences remain silent or divided, role-driven exceptionalism can become entrenched, creating precedent for future deviations and gradually normalising selective compliance. This produces a gap between rhetorical commitment and actual practice that is sustained by normative justifications rather than strategic silence. The cumulative effect is norm fragmentation: the universal applicability of the norm is replaced by a patchwork of exceptions, undermining its robustness (Deitelhoff and Zimmermann, 2019) and reducing its precision and obligation (Abbott and Snidal, 2000).

Synthesising the above, we can derive several theoretical propositions linking role theory to norm deinstitutionalisation:

Proposition 1: Interrole conflict increases the likelihood of norm deinstitutionalisation when one role is constitutively central to state identity while the norm is procedurally institutionalised but not identity-defining. Norms that are not deeply integrated into national identity are vulnerable when they conflict with constitutive roles.

Proposition 2: Role-driven norm deviation is more likely to be sustained when role-based justifications are accepted by politically consequential audiences, particularly when they draw on established values or historical obligations.

Proposition 3: Role-driven norm deviation is more likely to persist when institutional arrangements provide sufficient discretion, opacity, or limited oversight to accommodate exceptions without requiring the formal rejection of the norm.

Proposition 4: The effect of domestic role contestation depends on the ability of competing actors to influence authoritative decision-making. Role-driven norm deviation is more likely to be constrained when actors defending norm compliance can translate their position into policy or legal constraints, and more likely to persist when actors prioritising the competing role control key decision-making arenas or when challengers lack effective institutional access.

Proposition 5: Norm deinstitutionalisation driven by role conflict differs from interest-driven deviation in its durability: identity-based roles are more resistant to change than strategic interests, making role-driven deinstitutionalisation harder to reverse even when material conditions change.

The framework is not expected to apply equally across all cases of norm erosion. Role-driven deinstitutionalisation should be most likely where four conditions are present. First, the state must be meaningfully committed to the norm in question; the framework is less useful for explaining behaviour by actors that openly reject the norm. Second, the norm must come into conflict with a national role conception that is sufficiently central to political identity to command priority over ordinary policy commitments. Third, political actors must be able to justify exceptional behaviour through role-based claims that carry legitimacy among consequential audiences. Fourth, institutional arrangements must provide enough discretion for the resulting exception to be accommodated without requiring formal abandonment of the norm. Where these conditions are absent, interest-based explanations, weak enforcement, or open norm contestation are likely to provide a better account.

The framework should also be situated within broader transformations of the international order. Role conflicts do not arise in isolation from changes in states’ external environments. Geopolitical fragmentation, changing security alignments, and increasing tensions between universal normative commitments and particularistic security obligations can make previously manageable role tensions more politically salient. In this sense, role conflict is not necessarily the ultimate cause of deinstitutionalisation. It is better understood as a meso-level mechanism through which wider structural pressures are interpreted by domestic actors and translated into policy and institutional practice. Structural change may therefore increase the likelihood of role conflict, but the consequences for norm erosion depend on how competing roles are prioritised, justified, contested, and institutionally accommodated.

Methodology

The study adopts a single-case design (Gerring, 2004) focused on Germany’s arms export policy toward Israel. Case study methodology is particularly well-suited to this research because it enables in-depth analysis of causal mechanisms, permits examination of complex interactions between identity, institutions, and behaviour, and allows for theory development and refinement through empirical engagement (George and Bennett, 2005).

Following Gerring (2004), the German case functions as both a critical case and a deviant case: As a critical case, Germany represents a relatively favourable setting for norm compliance given its strong institutional commitment (Maihold et al., 2021), democratic accountability (Oppermann and Brummer, 2024), normative reputation (Brummer and Oppermann, 2016; Maull, 2000), and historically rooted commitment to military restraint (Herf, 1997). If norm deinstitutionalisation occurs even under these favourable conditions, it suggests the mechanism is robust and generalisable to other contexts where institutional constraints are weaker (Flyvbjerg, 2006).

At the same time, Germany is a deviant case because its frequent departures from its own export control principles (particularly regarding Israel) sit uneasily with these expectations. This makes the case useful for examining how conflicts between different national role conceptions are managed in practice.

The core empirical analysis covers the period from the adoption of the EU Common Position in December 2008 to 30 April 2026. Earlier material is used only where necessary to reconstruct the historical development of Germany’s civilian-power role and its commitment to Israeli security. The period after 7 October 2023 receives particular attention because the war in Gaza brought the tension between Germany’s arms export commitments and its relationship with Israel into especially sharp relief. Developments in 2025 and early 2026 are included to examine how this tension evolved under changing political conditions.

Source collection was organised around the principal policy episodes and institutional arenas relevant to German arms export policy. For political discourse, the analysis included public statements and speeches by senior government actors directly addressing Israel, German arms exports, Israeli security, Staatsräson, or Germany’s historical responsibility. Parliamentary material included Bundestag debates, parliamentary questions and government responses dealing with arms exports to Israel and the principal comparison cases discussed in the analysis. Licensing evidence was drawn from official federal arms export reports (Rüstungsexportberichte) and recipient-specific licensing information published by the government or provided in responses to parliamentary questions. Civil society and legal sources were included where they directly challenged, documented, or sought judicial review of the export decisions under examination. Sources were not selected according to whether they supported the role-theoretical argument. Where the same searches identified competing commercial, strategic, legal, or institutional explanations, these were retained and considered as part of the analysis.

The different sources are used in combination rather than treated as equivalent forms of evidence. Official documents and licensing data establish policy decisions and changes in export practice, while speeches and parliamentary records provide evidence of how political actors understand and justify those decisions. Legal proceedings and civil society documentation help identify challenges to official policy and the institutional limits placed on contestation. Triangulation across these materials is used to distinguish between official justification, institutional practice, and observable policy outcomes (Flick, 2018).

Each proposition was assessed by tracing the relevant mechanism across the empirical material. Proposition 1 was assessed by examining episodes in which Germany’s arms export commitments came into conflict with its stated obligation to Israeli security and identifying which obligation prevailed. Proposition 2 was assessed through the justifications offered for exceptional decisions and the reactions of relevant political and societal audiences. Proposition 3 was assessed by examining whether discretion, opacity, and limits on parliamentary and judicial oversight enabled exceptional decisions to be accommodated within the existing regulatory framework without formal rejection of the underlying norm. Proposition 4 was assessed by tracing disagreement among government actors, parties, parliament, courts, and civil society and examining whether changes in the balance of this contestation preceded changes in policy. Proposition 5 was assessed through temporal and within-case comparison, particularly by comparing the persistence of the Israel exception with more interest-driven episodes of German arms export policy and by examining the 2025 suspension and subsequent return to case-by-case licensing.

The analysis proceeds through process tracing across key episodes in German arms export policy. These episodes are used to examine how political actors articulated competing obligations, how those claims were translated into institutional decisions, and how domestic and international audiences responded. Particular attention is given to moments of policy change or contestation, including restrictions on exports to Saudi Arabia, the sharp increase in licences to Israel after October 2023, and the restriction and subsequent resumption of case-by-case licensing for Israel in 2025. These episodes provide variation within the German case and make it possible to assess both the operation and the limits of the proposed mechanisms.

Germany’s approach to international arms export regulations

Despite its strong normative and legal foundations on international arms exports, Germany’s actual compliance has faced significant challenges and discrepancies. This tension is not incidental but reflects a deeper structural condition: a role conflict arising from the incompatibility between Germany’s identity as a civilian power committed to multilateralism and human rights, its economic and strategic interests as a leading arms exporter, and, in the case of Israel, its unique historical allegiance. As Proposition 1 suggests, norms that are embedded in bureaucratic procedures and legal frameworks but not deeply integrated into national identity are vulnerable when they conflict with constitutive roles. Germany’s arms export control regime exemplifies precisely this vulnerability: formally robust but normatively outranked when it collides with identity-defining commitments.

On the one hand, Germany has formally adopted a pacifist stance and comparatively strict legislative provisions on arms exports, stemming from its post-World War II constitution and a commitment to peace (Platte and Leuffen, 2016). The Kriegswaffenkontrollgesetz (War Weapons Control Act, KrWaffKontrG) of 1961 requires export licences to be refused if weapons are likely to be used in “peace-threatening action” or violate international obligations, including international humanitarian law (IHL) and human rights (Hüllinghorst and Roll, 2021). Germany’s political guidelines explicitly claim a “restrictive and responsible” arms export policy, emphasising human rights and monitoring the location of weapons (Saupe, 2022). Germany has also been a proponent of European-level controls, including the Council of the European Union (1998) and the European Union Council (2008), both of which incorporate human security principles and IHL criteria. This official stance aligns with domestic public opinion, which largely opposes arms exports: a 2016 survey recorded 83 percent objection to German arms exports in general, and only 5 percent of respondents supported increasing the military budget (TNS Emnid, 2016; YouGov, 2021, cited in Saupe, 2022).

However, this normative commitment clashes structurally with Germany’s economic interests and its role as a strategic arms exporter. The German defence industry, while modest in overall economic terms, is highly export-dependent, with exports generating over 42 percent of its revenue between 2011 and 2014 (Saupe, 2022). Arms transfers are framed internally as a form of industrial subsidy that helps “ensure the survival of the German defence industry and its innovative capacity” and reduces procurement costs for the Bundeswehr (Saupe, 2022). This commercial logic frequently overrides normative criteria. Quantitative analyses reveal that higher levels of human rights protection in recipient countries actually negatively influence both the likelihood and volume of German arms transfers, after controlling for other variables. This is a finding that aligns Germany more with a “trading state” model than the “civilian power” it publicly claims to be (Platte and Leuffen, 2016). The gap between rhetorical commitment and actual practice has been sustained not through strategic silence but through discursive justifications that present commercial and security rationales as compatible with, rather than in tension with, Germany’s normative identity. As a consequence, the German military budget has risen steadily since 2013, reaching its highest absolute level since the Cold War in 2021, and arms export volumes reached an all-time high in 2019 (Saupe, 2022). This trajectory raises substantive questions about whether a de facto military-industrial complex (MIC) operates beyond effective democratic control in Germany (Saupe, 2022). These considerations form an important part of the broader context of German arms export policy, although they do not by themselves explain the distinctive treatment of Israel discussed below.

The legal framework itself, despite its strict appearance, contains structural loopholes that enable selective compliance. The KrWaffKontrG operates on a “prohibiting unless allowed” logic for war weapons, while the Außenwirtschaftsgesetz (Foreign Trade and Payments Act) follows an inverse “allowing unless prohibited” principle (Nassauer and Steinmetz, 2005; Saupe, 2022). This dual structure creates significant interpretive latitude. Critically, only a limited subset of armament components falls under the stricter KrWaffKontrG: many parts and components of combat aircraft, tanks, and other military platforms are not classified as war weapons and are therefore subject to considerably less restrictive export rules (Forensis, 2024). This produces what Forensis (2024) describes as a “double standard,” in which components are treated as “armaments lite” relative to complete weapons systems, despite embodying technical know-how with a longer operational lifespan than the weapon itself. The export of 3,000 portable anti-tank weapons, reportedly used against residential buildings in Khan Younis, Gaza, and 10,000 rounds of 120 mm tank ammunition to Israel in 2023 illustrates how this classification structure facilitates transfers that would be difficult to justify under a more coherent legal framework (Forensis, 2024). Export licence decisions for sensitive cases are taken by the Federal Security Council in confidentiality, with only approvals published, effectively shielding decisions from parliamentary or public scrutiny (Saupe, 2022). This was evident in the post-October 2023 decision to authorise ammunition and weapons deliveries to Israel during heightened hostilities, which were approved by the Federal Security Council (Bundessicherheitsrat) without a Bundestag vote (Bundesregierung, 2025). The interpretation of the EU Common Position’s eight criteria also varies substantially across member states, with terms such as “clear risk” lacking sufficient precision to generate consistent assessments (Wisotzki and Mutschler, 2021). Taken together, these features support Proposition 3: institutional discretion and limited transparency allow exceptional decisions to be accommodated within a formally restrictive regulatory framework, without requiring the government to reject the underlying arms control norm.

Germany has simultaneously positioned itself as a proponent of European-level arms export governance, supporting both the (Council of the European Union (1998) and the European Union Council (2008); Holm, 2006). However, the practical impact of these instruments has been limited. The Code has been criticised as a “lowest common denominator” agreement that, in some assessments, loosened rather than tightened German standards (Holm, 2006). Despite its formal legal bindingness, the Common Position falls under the EU’s Common Security and Defence Policy, which remains primarily subject to national jurisdiction and lacks direct enforcement authority at EU level (Wisotzki and Mutschler, 2021). During the Arab Spring and the Yemen War, EU member states, including Germany, continued to authorise transfers to warring parties in the MENA region despite documented IHL violations, demonstrating the limits of European harmonisation in practice (Wisotzki and Mutschler, 2021). German-supplied patrol ships were among the equipment received by Saudi Arabia and the UAE during the Yemen conflict, whose conduct has been widely condemned as involving gross violations of IHL (Wisotzki and Mutschler, 2021).

The cumulative pattern across three decades of German arms export practice is well-documented. A longitudinal study spanning 30 years found that the German federal government has “consistently violated its own political guidelines” by exporting military equipment to states implicated in serious human rights abuses and violent conflicts, including Egypt, Brazil, and Turkey (Efrat and Yair, 2024). In several cases, German-supplied arms were used by recipient governments to suppress their own civilian populations (Efrat and Yair, 2024). While Germany officially maintains monitoring procedures for delivered weapons, this oversight is frequently insufficient in practice (Saupe, 2022).

Civil society organisations and NGOs provide an important source of domestic contestation over German arms export policy. In terms of Proposition 4, their significance lies not simply in the existence of criticism, but in their capacity to translate that criticism into constraints on government decision-making. That capacity has remained limited. German domestic law currently provides no general right of judicial review over arms export licensing decisions, creating a significant accountability gap (Wisotzki and Mutschler, 2021). The limited possibilities for external review help preserve government discretion and allow exceptional decisions to be accommodated within the existing regulatory framework. Legal challenges by NGOs, including the Palestinian human rights organisation Al-Haq, against German arms exports to Israel have been dismissed on procedural grounds, partly because licences had been paused prior to adjudication and German administrative law generally prohibits challenges to anticipated decisions (Hartmann et al., 2024). This institutional lacuna is itself a form of role-driven norm erosion: by insulating export decisions from judicial scrutiny, Germany’s regulatory architecture reinforces the exceptionalist logic that is undermining the democratic accountability and ordinarily a safeguard against norm deviation. The case therefore illustrates the interaction between Propositions 3 and 4. Contestation exists, but institutional barriers limit the ability of challengers to convert it into authoritative constraints on export policy.

Germany’s allegiance to Israel

The role conflict already embedded in Germany’s arms export framework is most acutely expressed in its relationship with Israel. Where the tensions identified in the previous section arise from competing institutional logics and commercial pressures, the Israel case introduces a qualitatively different driver: a constitutive role rooted in historical guilt that operates as a near-absolute normative trump. This is precisely the dynamic anticipated by Proposition 1, which holds that procedurally institutionalised norms are most vulnerable when they collide with roles that are identity-defining rather than merely instrumental. Germany’s Staatsräson towards Israel, that is, the principle that Israel’s security is inseparable from Germany’s own reason of state, represents perhaps the clearest contemporary example of a constitutive role systematically overriding an otherwise robust regulatory regime.

This role is not merely implicit. German chancellors and foreign ministers have articulated it explicitly and repeatedly in official settings. Angela Merkel, addressing the Knesset in 2008, declared Israel’s security to be part of Germany’s raison d’être (Merkel, 2008). This is a formulation that elevated bilateral commitment above the register of ordinary foreign policy. More recently, then Chancellor Olaf Scholz, addressing the Bundestag on 12 October 2023, declared that “Israel’s security is part of Germany’s raison d’état” and that Germany’s “responsibility deriving from the Holocaust makes it our permanent duty to stand up for the existence and security of the State of Israel” (Scholz, 2023). Then Foreign Minister Annalena Baerbock similarly framed arms support for Israel in regional terms, arguing that “the security of the State of Israel is paramount for my country” and that “lasting security for Israel” required regional peace, since “lasting security for Palestinians will only be possible if there is lasting security for Israelis” (Baerbock, 2024). Friedrich Merz, back then leader of the CDU opposition and now Chancellor, made the prioritisation logic explicit, insisting that “there should be no cracks in the solidarity with Israel when Israel does what it needs to defend itself” (cited in Beck, 2025). These statements are analytically significant not merely as political rhetoric, but as acts of role-making in the sense theorised by Harnisch (2012). They publicly reconstruct the normative exception as a moral obligation, framing deviation from arms control norms as ethically required rather than ethically problematic. The recurrence of this framing across successive governments and leading political actors suggests that it has acquired substantial acceptance among German political elites. This provides initial support for Proposition 2, although audience responses are not uniform, as the domestic contestation discussed below demonstrates.

The practical consequences of this role-driven exceptionalism are substantial and empirically well-documented. Between 2009 and 2018, Germany was Israel’s second-largest arms supplier, accounting for 24 percent of Israel’s imported arms (Forensis, 2024). Following the Hamas attacks of 7 October 2023, the German government authorised a tenfold increase in military equipment export licences to Israel relative to 2022, with the majority of approvals granted in the weeks immediately following the attacks (Becker, 2025). This surge encompassed equipment from almost all Military List categories, including the specific items noted previously. This includes anti-tank weapons that the Israeli army has reportedly deployed against residential buildings in Khan Younis, and tank ammunition documented as having been used indiscriminately in Gaza (Forensis, 2024). In addition, Germany authorised Israel to operationalise two of five Heron TP combat drones previously leased from an Israeli manufacturer, which were subsequently used for both surveillance and strike operations in Gaza (Forensis, 2024). These decisions were taken despite formal warnings from UN experts of a “plausible risk of genocide” and explicit calls from international bodies to suspend weapons transfers pending legal assessment of IHL compliance (Forensis, 2024). The willingness to proceed under these conditions illustrates how thoroughly the Staatsräson role has displaced ordinary risk assessment procedures, not through a failure of institutional design, but through the deliberate subordination of procedural norms to a constitutive identity commitment.

What makes this case analytically distinctive is the degree to which the exceptionalism has been institutionalised through opacity rather than openly contested. Export data concerning Israel has been systematically redacted from official reports since 2019, ostensibly to protect commercial confidentiality (Forensis, 2024). This dynamic shapes the domestic environment in which Germany’s role towards Israel is interpreted and contested. Criticism of Israeli military conduct has at times been associated with antisemitism in German public debate (Becker, 2025), potentially raising the political costs of challenging established interpretations of Germany’s responsibility towards Israel. Contestation has nevertheless persisted through parliamentary scrutiny, civil society advocacy, and legal challenges. As Proposition 4 suggests, however, the existence of contestation is not sufficient in itself; its effects depend on whether actors advancing competing role interpretations can translate their position into authoritative political or legal constraints. The Federal Security Council’s confidential decision-making process and the limited possibilities for judicial review restrict this capacity. Al-Haq’s litigation, for instance, was dismissed partly on the procedural ground that the relevant licences had already been paused, and German administrative law’s general prohibition on challenges to anticipated decisions foreclosed interim relief (Hartmann et al., 2024).

The audience dimension of this case extends beyond the domestic sphere and has significant implications for the international arms control regime. Germany’s role performance is observed by other states, international organisations, and transnational civil society, all of whom draw inferences about the conditionality of norm adherence from German behaviour. Within the EU, the anti-undercutting mechanism of the Common Position, under which member states notify each other of licence denials, presupposes a degree of normative consistency that Germany’s Israel exception undermines. When a state that positions itself as a norm entrepreneur and civilian power grants a tenfold increase in arms licences to a party under active genocide investigation at the International Court of Justice, it signals to other EU member states that the criteria of the Common Position are politically negotiable rather than legally binding.

Global civil society such as international NGOs, human rights monitors, or legal advocacy networks represent the most consistent source of normative contestation, though one operating under significant structural constraints in the German context. The ATT, supported by a broad coalition of states and civil society organisations, was explicitly designed to prevent arms transfers that risk contributing to serious IHL or human rights violations. Yet the treaty’s threshold language of “overriding risk” was deliberately set high during negotiations, with Germany and the United Kingdom among the states resisting more stringent formulations, effectively making approval easier to justify in marginal cases (Wisotzki and Mutschler, 2021). This negotiating history is itself an instance of role-driven norm shaping: Germany participated in constructing the regulatory framework in ways that preserved flexibility for precisely the kinds of exceptions it subsequently invoked. International civil society’s challenge to German arms transfers to Israel has thus encountered not only domestic legal barriers but a treaty architecture that Germany helped design to accommodate its own exceptionalist practices. The result, as Proposition 5 anticipates, is a form of norm erosion that is particularly durable: because the deviation is grounded in a constitutive historical identity rather than temporary strategic calculation, it persists across changes of government and shifts in material circumstances, and has become embedded in institutional arrangements – legal, procedural, and discursive – that actively resist correction.

This pattern of continued support was, however, challenged by developments in the second half of 2025. In August 2025, the German government temporarily suspended approvals for exports of military equipment that could be used in Gaza, before announcing in November that exports to Israel would again be assessed on a case-by-case basis. The shift and subsequent reversal brought disagreements over the practical meaning of Germany’s commitment to Israeli security more clearly into view.

The August–November 2025 episode provides a particularly useful within-case test of domestic role contestation. The temporary restriction demonstrated that Germany’s commitment to Israeli security did not produce a single uncontested policy response. Rather, political actors disagreed over what Staatsräson required under conditions of mounting humanitarian concern in Gaza. The subsequent return to case-by-case licensing also shows that the hierarchy between competing obligations remained open to political renegotiation. The episode therefore supports Proposition 4 not simply because contestation occurred, but because changes in the position of actors with access to executive decision-making were accompanied by changes in policy.

The same episode also qualifies Proposition 5. The August restriction demonstrates that identity-based commitments do not prevent temporary policy reversal. Yet the relatively short duration of the restriction, followed by a return to case-by-case licensing without abandonment of the Staatsräson commitment, suggests greater resilience at the level of the underlying role conception than at the level of individual policy decisions.

The deinstitutionalisation of international arms control

The empirical record examined in the preceding sections points toward a broader theoretical conclusion: that deinstitutionalisation in international arms control may not primarily be a product of enforcement failure or bad faith, but of unresolved role conflicts within the very states that design, champion, and are expected to uphold the normative framework. Germany’s case offers a theoretically generative instance of this dynamic, one that allows us to move toward a more structurally grounded explanation of how institutional norms erode from within.

Existing scholarship on deinstitutionalisation has identified a range of mechanisms through which norms weaken: discursive contestation, institutional withdrawal, norm appropriation and dilution, and active norm reversal (Deitelhoff and Zimmermann, 2019). These mechanisms share an implicit assumption that norm erosion is driven primarily by actors who are hostile or indifferent to the norm in question. What the German case reveals, however, is a distinct and undertheorised pathway: deinstitutionalisation driven not by norm opponents but by norm proponents. These are states that are simultaneously architects of the regulatory framework and systematic producers of justified exceptions to it. Thus, norms can be procedurally entrenched and discursively championed while being substantively eroded by the very actors most publicly committed to them, provided those actors can draw on sufficiently resonant role-based justifications.

Role theory provides the framework to explain this dynamic. As established in the theoretical framework, states develop national role conceptions (NRCs) that are not merely strategic self-presentations but constitutive of identity. They define what a state is rather than merely what it wants (Harnisch et al., 2011). Germany’s postwar identity is structured around two such constitutive roles that are, in the domain of arms exports, fundamentally incompatible: the civilian power committed to multilateralism, human rights, and the restraint of military force (Maull, 2000) on the one hand; and the guarantor of Israeli security on the other, obligated by Holocaust responsibility to ensure Israel’s survival regardless of the constraints this places on other normative commitments. When these roles collide, the resulting interrole conflict cannot be resolved through ordinary policy adjustment, because both roles are anchored in core identity commitments rather than instrumental preferences. The conflict is instead managed, e.g., through role prioritisation, role-making, and the cultivation of audience acceptance. This occurs in ways that progressively hollow out the universality of the arms control norm while preserving its formal institutional status.

This management process operates through three interrelated mechanisms. The first is discursive role prioritisation: through repeated, high-level invocations of Staatsräson – from Merkel’s Knesset address to Scholz’s Bundestag declarations – German political elites publicly establish a hierarchy of roles in which historical obligation to Israel supersedes procedural commitment to arms export regulation. This is not dissimulation; as Proposition 2 anticipates, the justification draws on a historically established understanding of Germany’s responsibility towards Israel and has been reproduced by successive governments and leading political actors. Its persistence at the highest levels of German politics indicates substantial elite acceptance, even though the implications of this commitment for particular policies remain contested. The tenfold increase in export licences to Israel in the weeks following 7 October 2023 represents the most recent and stark expression of this prioritisation (Becker, 2025; Forensis, 2024). This constitutes a logic that, once established, is available to other actors in analogous situations.

The second mechanism, captured in Proposition 3, is institutional accommodation of role conflict: rather than generating pressure to resolve the incompatibility between Germany’s civilian power role and its Israeli security guarantee role, the regulatory infrastructure has been progressively adapted to accommodate it. The dual legal structure, with the KrWaffKontrG’s “prohibiting unless allowed” logic alongside the Außenwirtschaftsgesetz’s “allowing unless prohibited” principle, creates interpretive latitude that is systematically exploited to reclassify transfers in ways that evade stricter scrutiny. The Federal Security Council’s confidential approval process, the redaction of Israel-specific export data since 2019, and the absence of civil society judicial review rights together illustrate the institutional conditions identified in Proposition 3. This suggests that deinstitutionalisation does not always manifest as the collapse or abandonment of institutional structures, but can proceed through their internal reconfiguration.

The third mechanism is differential audience management: as Proposition 2 specifies, the sustainability of role-driven norm deviation depends partly on whether its normative justification is accepted by politically consequential audiences. Audience responses in the German case have been uneven. The repeated endorsement of Germany’s special responsibility for Israeli security by successive chancellors, foreign ministers, and major governing parties indicates considerable continuity at the level of political elites. At the same time, civil society organisations, legal advocates, opposition actors, and, at particular moments such as in the August–November 2025 episode, actors within governing parties have contested how this responsibility should be translated into policy. Proposition 4 addresses this second dimension. It suggests that the consequences of such disagreement depend not simply on the existence or intensity of contestation, but on whether competing actors can translate their interpretation into authoritative decisions. Civil society actors have mounted sustained challenges through litigation, investigative documentation, and advocacy, but structural barriers in German administrative law and the opacity of the Federal Security Council process have limited their capacity to generate binding constraints.

Taken together, these three mechanisms constitute an account of role-driven deinstitutionalisation that advances beyond existing frameworks in several respects. First, it disaggregates the process of norm erosion into distinct but interrelated causal pathways (discursive, institutional, and audience-related) that can be analysed separately and traced empirically. Second, it identifies the proponent state as a distinctive and undertheorised agent of deinstitutionalisation, one whose norm violations are particularly consequential precisely because they cannot be dismissed as the behaviour of outsiders or norm opponents. Third, the framework highlights how institutional design can facilitate norm erosion: opacity, classification loopholes, and the exclusion of civil society from judicial review provide conditions under which role-based exceptions can be accommodated within a formally compliant institutional framework.

The systemic implications of this dynamic for the international arms control regime are considerable. The ATT was premised on the expectation that major arms exporters would apply its criteria consistently and transparently, and that peer pressure among signatories would generate convergence toward higher standards. Germany’s behaviour undermines both premises: it demonstrates that consistent application is structurally improbable for states with constitutive role conflicts, and that the peer pressure mechanism is disabled when multiple major exporters are simultaneously engaged in analogous selective compliance. The EU Common Position’s anti-undercutting mechanism, which requires member states to notify each other of licence denials, presupposes a baseline of normative consistency that Germany’s Israel exception corrodes. This has implications not only for how we understand the current erosion of the arms trade regime but for the broader study of institutional fragility in the liberal international order.

What about alternative explanations?

The analysis so far has argued that role conflict is important for understanding Germany’s arms exports to Israel. However, role conflict is not the only possible explanation. Commercial interests, strategic considerations, and weaknesses in arms export control also matter. Indeed, the earlier analysis has shown that all three play a role in German arms export policy more generally. The question is therefore not whether these factors matter, but whether they are sufficient to explain the particular pattern found in the Israeli case.

A first alternative explanation is commercial interest. Germany has a large and export-dependent defence industry, and commercial considerations have long shaped German arms export decisions (Platte and Leuffen, 2016; Saupe, 2022). Israel is also an important recipient of German military equipment. SIPRI identifies Israel as Germany’s third-largest recipient of major arms in 2021–25, accounting for around 10 per cent of German exports of major arms during this period (George et al., 2026). Commercial interests therefore cannot simply be ruled out. They help to explain why continued exports are attractive to German producers and why restrictions may face resistance.

However, commercial interests alone do not explain the way in which the relationship with Israel is justified. German political leaders rarely defend arms exports to Israel primarily in terms of jobs, exports, or the interests of the defence industry. Instead, they repeatedly refer to Germany’s historical responsibility for the Holocaust and to Israel’s security as part of Germany’s Staatsräson (Merkel, 2008; Scholz, 2023). This language has continued under the current government. In January 2026, Foreign Minister Johann Wadephul linked Germany’s commitment to Israel’s security directly to the Shoah, while also describing Israel as an exceptional partner in German security and defence cooperation (Wadephul, 2026). Commercial interests can therefore help to explain why arms exports take place, but they do not fully explain why support for one recipient is presented as a historical and moral obligation.

A second explanation is strategic interest. Germany and Israel cooperate closely in security and defence, and the relationship brings clear strategic benefits for Germany. This has become even more visible as Germany has purchased Israeli defence systems and expanded bilateral security cooperation. Wadephul, for example, explicitly argued in 2026 that cooperation with Israel serves Germany’s own security as well as Israel’s (Wadephul, 2026). Strategic considerations are therefore part of the explanation. Yet they again leave an important part of the pattern unexplained. A purely strategic account would expect support for Israel to vary mainly according to Germany’s assessment of security costs and benefits. What we see instead is a continuity in the language of historical obligation across different governments. Merkel’s formulation of Israeli security as part of Germany’s raison d’état was repeated by Scholz after 7 October 2023 and remains present under the current government. The strategic relationship and the historical role therefore reinforce one another, but the strategic explanation alone does not account for the special normative status given to Israeli security.

A third alternative is weak enforcement. As discussed above, Germany’s arms export regime leaves governments considerable room for interpretation. The division between different export-control laws, the confidentiality of decisions taken by the Federal Security Council, variation in the interpretation of export criteria, and the limited opportunities for judicial review all make selective implementation possible (Wisotzki and Mutschler, 2021; Hartmann et al., 2024). These institutional weaknesses are important because they create the space in which exceptions can be made.

But weak enforcement does not tell us which recipients benefit from this flexibility or why. The same institutional framework has also allowed German governments to restrict exports when they were politically willing to do so. The contrast with Saudi Arabia is useful here. Following the killing of Jamal Khashoggi, the German government stopped issuing new arms export licences to Saudi Arabia and also acted to prevent exports under existing individual licences (Bundesregierung, 2018). This suggests that Germany’s regulatory system, despite its weaknesses, does not make restrictions impossible. Institutional flexibility is therefore better understood as a permissive condition: it makes exceptional treatment possible, but it does not by itself explain why that flexibility is used differently across cases.

The comparison also helps to clarify what the role-theoretical explanation adds. Commercial interests help to explain why arms exports are economically attractive. Strategic interests help to explain why Germany values security cooperation with Israel. Weaknesses in export control help to explain how governments retain room for manoeuvre. But none of these factors alone explains why support for Israel has repeatedly been framed as a duty arising from Germany’s historical identity, or why this commitment has remained politically salient across governments. Role theory draws attention to this additional element: when arms export norms conflict with Germany’s historically rooted role as a guarantor of Israeli security, political actors have repeatedly given greater weight to the latter.

This does not mean that role conflict determines every German decision concerning Israel. The restrictions introduced in August 2025 are important evidence against such a deterministic interpretation. They demonstrate that the meaning and practical implications of Staatsräson remain politically contested. At the same time, the restrictions were temporary. In November 2025, the government announced that they would be lifted from 24 November and that exports to Israel would again be considered on a case-by-case basis. By January 2026, the Foreign Minister was again describing Israel as an exceptional partner in arms cooperation. Rather than disproving the role-conflict argument, this sequence points to the need to examine how competing role conceptions are contested within government and under what conditions one temporarily prevails over another. This issue is particularly important for Propositions 4 and 5.

Taken together, the alternative explanations therefore qualify rather than displace the role-theoretical account. Material interests and institutional weaknesses are part of the broader explanation of German arms export policy. The more specific claim of this paper is that role conflict helps to explain the selection, justification, and persistence of the Israeli exception: why Israel is treated differently, why this treatment is justified through reference to historical responsibility, and why the commitment has remained resilient despite substantial political and legal pressure (see Table 1).

Table 1. Summarises how each proposition is assessed in the empirical analysis, the types of evidence used to evaluate the proposed mechanism, and the observations that would weaken the respective proposition.

Conclusion

This paper set out to explain a puzzle that sits at the intersection of role theory and institutional change: why does Germany – a state with normative credentials, strong democratic accountability, and a publicly declared commitment to restrictive arms export regulation – systematically deviate from those commitments in its transfers to Israel? The answer developed across the preceding sections is that this behaviour reflects a structurally grounded process of role-driven deinstitutionalisation, in which constitutive identity commitments override procedurally institutionalised norms in ways that are sincerely justified, audience-validated, and progressively embedded in institutional practice.

The analysis has made three principal theoretical contributions. First, it has identified the proponent state as a distinct and undertheorised agent of deinstitutionalisation. Existing scholarship on norm erosion has focused predominantly on actors hostile or indifferent to the norms in question, such revisionist powers, authoritarian states, or ‘norm antipreneurs’. Germany’s case demonstrates that some of the most consequential norm erosion is produced by states that are simultaneously architects and violators of the regulatory framework, whose deviations are particularly damaging precisely because they cannot be dismissed as the behaviour of outsiders.

Second, the paper has disaggregated the process of role-driven deinstitutionalisation into three interrelated causal mechanisms: discursive role prioritisation, institutional accommodation of role conflict, and audience acceptance. It has traced each empirically through the German case. Discursive role prioritisation operates through the repeated public invocation of Staatsräson, which establishes a public hierarchy in which Holocaust-rooted obligation to Israel supersedes procedural arms control commitments, and which resonates sufficiently with domestic audiences to sustain the exception over time. Institutional accommodation operates through the adaptation of the regulatory apparatus such as dual legal structures, classification loopholes, Federal Security Council opacity, and the exclusion of civil society from judicial review. This enables selective compliance within a formally intact institutional shell. A third mechanism captures audience reactions: when relevant audiences accept the normative justification advanced by the role-making state, exceptional conduct is legitimised and the norm’s constraining power weakened, whereas audience silence or division allows such exceptionalism to become entrenched, establishing precedents for future deviations and gradually normalising selective.

Third, the paper has identified important additions to the existing institutionalisation literature. Role theory, as developed here, provides a mechanism-level account of how identity conflicts within norm-championing states generate deinstitutionalisation from within, without formal norm rejection and often without conscious norm violation. The five propositions receive varying degrees of support across the case. Constitutive roles can override procedurally institutionalised norms when the two come into conflict (Proposition 1); role-based justifications centred on historical responsibility have achieved durable acceptance among important political elites, although their policy implications remain contested (Proposition 2); institutional discretion, opacity, and limited oversight facilitate the accommodation of exceptional decisions within an otherwise restrictive regulatory framework (Proposition 3); domestic role contestation affects policy most clearly when actors advancing competing interpretations are able to influence authoritative decision-making, while actors lacking such access have struggled to impose binding constraints (Proposition 4); and the identity-rootedness of the Staatsräson role contributes to the durability of the resulting exceptionalism across changing political circumstances (Proposition 5).

The framework is therefore most likely to travel to cases in which norm-promoting states face a conflict between established international commitments and constitutive national roles, and where political and institutional conditions permit exceptional treatment to be justified without formal norm rejection. It should be less applicable where states openly contest the validity of the norm, where deviations can be adequately explained by short-term material interests, or where institutional constraints leave little room for selective application. Cases such as the United States’ selective application of democracy-promotion norms, France’s historically privileged security relationships in Francophone Africa, or the United Kingdom’s post-Brexit relationship with international legal commitments may provide useful comparative tests, but whether they exhibit the same mechanisms remains a question for future research. In this sense, role conflict is not presented as an alternative to broader structural explanations of norm erosion, but as a mechanism through which such pressures are interpreted and translated into policy within norm-promoting states.

Ultimately, the credibility of international norms in domains like arms control depends not only on the strength of their formal institutional infrastructure but on the degree to which the states that champion them have resolved, or developed institutional means of managing, the identity conflicts that generate pressure for selective application. Germany’s trajectory suggests that where such conflicts remain unresolved, even the most robust regulatory frameworks will remain vulnerable to erosion from within: not through the opposition of norm opponents, but through the justified exceptions of their most prominent advocates. Addressing this vulnerability requires not only policy reform and institutional redesign, but a more honest reckoning by norm-promoting states with the tensions between their multiple, and sometimes incompatible, foreign policy roles.

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Footnotes

Edited by: Dimos Chatzinikolaou, University of Nicosia School of Business, Cyprus

Reviewed by: Francesco Antonelli, Roma Tre University, Italy

Hongsong Liu, Shanghai Jiao Tong University, China