Models of a republic

This page compares the different republican models of governments around the world to New Zealand's current constitutional status quo. None of these examples are meant as definitive models of what a New Zealand republic might look like - every republic is different and created by its citizens out of its circumstances - but the models presented here are a guide to the model a New Zealand republic could follow.

The different types of republics

There are basically three different types of republics. We've listed these below and provided some examples:

  • Presidential systems - are based on a strong executive President, who is indepedent of the legislative branch (Parliament or Congress) and judicial branch (the courts). Examples include the United States, Mexico, Brazil, Argentina, Chile and parts of Africa.
  • Semi-Presidential systems - have a weaker President who often shares executive power with the legislative branch, who often appoint their own head of government. Examples include France, Russia, Kenya, Taiwan, Pakistan and Haiti.
  • Parliamentary republics - have a head of State who is mainly ceremonial, with few executive powers (usually designed simply to keep the government in check). Examples include Austria, Italy, Ireland, Iceland, Portugal, Finland and Germany.

The models

  • New Zealand (Constitutional monarchy)
  • Ireland (Parliamentary republic with a directly elected head of state)
  • Germany (Parliamentary republic with an indirectly elected head of state)
  • South Africa (Parliamentary republic with a combined head of state and head of government)
  • Switzerland (Parliamentary republic with no single head of state)
  • France (Semi-presidential republic with an executive head of state and head of government)
  • United States of America (Presidential federal republic with a directly elected head of state combined with the head of government)

First, we'll look at New Zealand's constitution:

New Zealand
Coat of Arms of New Zealand Head of state Head of government
Sovereign Governor-General Prime Minister
Qualifications: Not a Catholic or married to one, males come before females None - convention is for a New Zealand resident A member of parliament, appointed by Governor-General on the confidence of Parliament.
Elected by: No-one: hereditary No-one, appointed by the Sovereign on the binding advice of the Prime Minister None, leader of the largest party in Parliament
Removed by: Can only be removed by own abdication The Sovereign, on the binding advice of the Prime Minister Party caucus vote, removal from Parliament (due to prosecution)
Term: Life None defined; usually five years None, but must win elections
Write legislation? No Yes - Member of Parliament
Veto legislation? No (see note) No
Appoint judges? Yes - on the advice of the Prime Minister Yes, by advising Governor-General

This is how New Zealand's constitution under a constitutional monarchy looks at the moment. As you can see, the "head of state" is divided between the Sovereign (the Queen) and the Governor-General, the Queen's representative. While the Queen is legally New Zealand's head of state, de facto the Governor-General does the job, cutting ribbons, making speeches and signing Bills into law. Some constitutional academics think this means New Zealand is a de facto republic anyway, because we have a virtual head of state in the Governor-General. Since 1967 all Governors-General have been New Zealanders, appointed on the advice of New Zealand's Prime Minister.

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Republic of Ireland
Coat of Arms of Ireland Head of state Head of government
President Prime Minister
Qualifications: All citizens of Ireland over the age of 35 A member of parliament
Elected by: The people of Ireland, by a direct vote using STV. None, leader of the largest party in Parliament
Term: A maximum two terms of seven years Not defined
Write legislation? No Yes - Member of Parliament
Veto legislation? No - but can refer Bills to referendum or Supreme Court No
Appoint judges? No No

The Republic of Ireland is a parliamentary republic, with a directly elected ceremonial President. While the President of the republic dates back to 1936, Ireland was actually a dominion like New Zealand until 1949, in between Ireland (then known as the Irish Free State) had both a King and a President. Since 1949 Ireland has only had a President, who is mainly ceremonial, but as you can see does have more powers than our Governor-General.

The Irish model is similar to the second republican option in Keith Locke's Head of state (Referenda) Bill.

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Federal Republic of Germany
Coat of Arms of Germany Head of state Head of government
Bundesprasident (Federal President) Chancellor
Qualifications: Must be a German citizen over 40 years of age A member of parliament
Elected by: Federal convention of delegates from federal and state parliaments, by a absolute majority None, leader of the governing coalition in German Parliament
Removed by: Impeachment, majority of Federal German parliament Loss of election
Term: No more than two terms of five years None defined
Write legislation? No Yes - Member of Parliament
Veto legislation? Yes or refer to Supreme Court No
Appoint judges? No Yes - approved by Parliament

Germany's post-war constitution was designed to prevent the rise of another dictatorship, which occured under the previous Weimar republic, which was a semi-presidential system. Under that constitution, the President held more powers than the current German President does. Today, German Presidents use their powers sparingly, mainly to resolve legislative issues. The German Parliament now has more power to appoint and remove the Chancellor.

The German model is similar to the first republican option in Keith Locke's Head of state (Referenda) Bill.

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Republic of South Africa
Coat of Arms of South Africa Head of state Head of government
President
Qualifications: Member of Parliament
Elected by: Parliament
Removed by: Impeachment - majority of Parliament
Term: No more than two Parliamentary terms (maximum ten years)
Write legislation? Yes - Member of Parliament
Veto legislation? No - But Constitutional Court may do so
Appoint judges? No - Parliament does so

South Africa's post-apartheid constitution of 1996 blends the Westminster Parliamentary system with the Washington Presidential model. The President of South Africa is basically like our Prime Minister - they're a member of South Africa's parliament - but is the head of state as well as head of government, like the President of the United States. The South African Constitutional Court has many over-arching powers to restrain the President.

Some argue that this is a "cleaner" way of setting out the powers of the head of state, while also having the added accountability. Since South Africa's political system has been dominated by the ANC since 1994, it remains to be seen how the South African constitution would work with regular changes of power.

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Swiss Confederation
Coat of Arms of Switzerland Head of state Head of government
None - There is neither a prime minister nor a president of Switzerland - the President of the Swiss Confederation is merely "primus inter pares" (first among equals) in the Swiss Federal Council.
Qualifications: Not applicable
Elected by: Members of the Swiss Assembly
Removed by: Loss of election
Term: None defined
Write legislation? Yes - can also be passed by referendum
Veto legislation? No
Appoint judges? No

Switzerland is one of those funny states that isn't formally a parliamentary, presidential or semi-presidential republic.

The current Swiss Confederation was created in 1802 as a confederation of various multi-ethnic cantons, which all have their own charactaristics. For this reason the federal state is very weak, and only deals with issues such as foreign affairs and defence. There is no formal head of state or head of government, instead there is a council of ministers with a president. The presidency rotates yearly between members of the council.

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Fifth French Republic
Coat of Arms of France Head of state Head of government
President Prime Minister
Qualifications: Must be a French citizen of 50 years of age. A member of parliament
Elected by: Directly by second-round system of voting None, leader of the largest party in Parliament. Appointed by President.
Removed by: Impeachment by Parliament Parliament only, not the President
Term: Five years, no limit on terms None defined
Write legislation? Yes, but must be passed by national assembly Yes
Veto legislation? No, but may refer laws back to Parliament, or send to referendum or "constitutional council" No
Appoint judges? Yes, with the assent of cabinet. No

France currently sits between a Parliamentary and a Presidential republic, with what is known as a "Semi-presidential" system.

The French President is more powerful than the German and Irish Presidents, but less powerful than the President of the United States. The President has the power to appoint the Prime Minister of France, but this person must be the leader of the party with the most seats in parliament.

Sometimes the President and Prime Minister may be from different political partys. This creates "co-habitation" between Presidents and Prime Ministers, and usually leads to the President being in the weaker situation. Critics of semi-presidential systems argue this causes instability and conflict. Often it leads the President to focus on one policy area, and the Prime Minister on another - for example, the President of France often looks after foreign policy and trade, while the Prime Minister looks after domestic issues.

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United States of America
Seal of the United States Head of state Head of government
President
Qualifications: No less than 35 years of age, natural born citizen of the United States and a resident of the United States for at least 14 years.
Elected by: A majority of votes in the electoral college, determined by state-by-state votes.
Removed by: Impeachment by two-thirds of Congress following trial and conviction, or resignation.
Term: No greater than two terms of four years
Write legislation? Yes, but must be passed by Congress
Veto legislation? Yes, but can also be overturned by the Supreme Court
Appoint judges? No, recommended to and approved by Congress

The United States' is the oldest, most stable and best example of a federal, constitutional republic with a presidential system. This means the United States is made up of states with their own Governors, and a Federal government headed by a President, who has wide executive powers.

Supporters of this model point to its clear division of powers between the President, Supreme Court and Congress, and the over-arching supremacy of the Constitution of the United States. Critics point to the excess of the executive (the elected presidency) and the often undemocratic way in which the presidency is elected, due to the federal nature of the system. For example, it is possible for a President to be elected without having a majority of the popular votes, but a majority of votes in the electoral college - as was the case in the 2000 presidential election.

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