Non‐State Regulators? Civil Society as Extension of the State in a Context of a Regularization Scheme for Undocumented Migrants

“Opération Papyrus” was implemented in the Swiss Canton of Geneva between 2017 and 2018 with the aim of granting residence permits to undocumented migrants who met pre‐established criteria. This program serves as an exemplary case of involving nongovernmental actors to facilitate what were originally state‐controlled procedures. Civil society organizations (CSOs) exercised discretionary power and played a pivotal role in negotiating the program's design and acting as gatekeepers, ensuring that only eligible individuals applied, thereby reducing the administrative workload. Our paper primarily focuses on the unique role played by civil society organizations, extending the reach of the state, as they acted independently as regulators and maintained proximity to the individuals involved, enhancing the program's effectiveness. The analysis is based on 10 retrospective interviews with cantonal and federal civil servants and representatives from CSOs, supplemented with additional official documents.