Autonomous regions exist all over the world, and the clearest examples include Hong Kong and Macau in China, Greenland and the Faroe Islands within the Kingdom of Denmark, the Kurdistan Region in Iraq, the Åland Islands in Finland, Spain’s 17 autonomous communities and two autonomous cities, and the Native American tribes recognized within the United States. Each is a subnational territory that runs its own internal affairs while remaining part of a larger sovereign nation. What differs is the legal instrument that created the arrangement, the range of powers the territory actually holds, and how secure that self-governance is against a central government that changes its mind.
Hong Kong and Macau: One Country, Two Systems
Hong Kong and Macau are China’s two Special Administrative Regions. The framework preserves the legal and economic systems these territories developed before returning to Chinese sovereignty. Hong Kong’s Basic Law keeps in place the common law system inherited from British rule, including the ordinances, rules of equity, and customary law that preceded the handover.1Hong Kong e-Legislation. Basic Law – Chapter I Macau operates under a civil law tradition rooted in Portuguese codes, with its own Basic Law guaranteeing a high degree of autonomy under the Central People’s Government.2Basic Law of the Macao Special Administrative Region. The Basic Law of the Macao Special Administrative Region of the People’s Republic of China
Both regions issue their own currency, run their own tax and public finance systems, and set their own trade regulations. The authority to issue Hong Kong dollars sits with the regional government rather than Beijing.3Right of Assembly. The Basic Law of the Hong Kong Special Administrative Region Beijing retains two areas: foreign affairs and defense.2Basic Law of the Macao Special Administrative Region. The Basic Law of the Macao Special Administrative Region of the People’s Republic of China
Hong Kong is also the most recent example of an autonomous region seeing its autonomy sharply narrowed. In 2020, Beijing imposed a National Security Law by decree, bypassing Hong Kong’s legislature. The law reserved to Beijing the authority to interpret it, allowed cases to be transferred to mainland China for trial, permitted closed proceedings, and barred anyone convicted under it from public office. A national security commission was required in Hong Kong, with a Beijing-appointed adviser attached. Where the law conflicts with existing Hong Kong legislation, the Beijing law prevails.
Greenland and the Faroe Islands
Greenland and the Faroe Islands each have their own self-governance arrangement inside the Kingdom of Denmark, established decades apart. The Faroe Islands set up Home Rule in 1948, creating a self-governing community with its own parliament, the Løgting, and an executive, the Landsstýri.4The Government of the Faroe Islands. The Home Rule Act The Faroese government now runs trade, taxation, fisheries, energy, education, social security, and culture, among other fields.5UK Parliament. Dr Jacques Hartmann – Written Evidence
Greenland’s Home Rule Arrangement came later, in 1979, and was replaced by the Self-Government Act that took effect on June 21, 2009.6Statsministeriet. Greenland The 2009 Act recognized Greenlandic as the official language and transferred control over mineral resource activities to the local government, with extraction revenue accruing to the Greenland Self-Government authorities.7Statsministeriet. Act on Greenland Self-Government
Both territories legislate in the areas they administer and bear the financial responsibility for them.8Statsministeriet. The Unity of the Realm Foreign policy, defense, and security policy cannot be transferred from the Danish central authorities. Denmark also provides financial subsidies to both.
The Kurdistan Region in Iraq
The Kurdistan Region is a federal region recognized directly in Iraq’s 2005 Constitution, which acknowledges the region and its existing authorities.9Constitute. Iraq 2005 Constitution Article 121 gives the regional government executive, legislative, and judicial powers, except in areas reserved to the federal government.
Internal security is one of the most significant of those powers. The constitution assigns the Kurdistan Regional Government responsibility for its own security forces, including police, security services, and the Peshmerga.9Constitute. Iraq 2005 Constitution These forces operate independently of the Iraqi national military. The regional parliament also drafts laws on healthcare, education, and local administration. Oil remains a long-running flashpoint: the region produces significant crude, and control over exports and revenue-sharing between Erbil and Baghdad has been in constant dispute.
The Åland Islands
The Åland Islands are a Swedish-speaking archipelago whose autonomy rests on international law as well as Finnish domestic law. In 1921, the Council of the League of Nations ruled that Finland would retain sovereignty over the islands on the condition that Finland guarantee the population’s Swedish language, culture, and local customs.10United Nations Peacemaker. Act on the Autonomy of Aland The Act on the Autonomy of Åland carries that guarantee into Finnish law.
The Ålandic parliament legislates over public order and security, healthcare and medical treatment, social welfare, education, farming, forestry, hunting, fishing, environmental protection, building and planning, local taxation, and municipal administration, among other areas.10United Nations Peacemaker. Act on the Autonomy of Aland Finnish national authorities keep foreign relations, general judicial matters, and customs.
Two features set Åland apart. First, it has been demilitarized since an 1856 convention, which originally prohibited Russia from fortifying the islands. A 1921 convention extended the prohibition to any military or naval establishment, military aircraft, or war-related installation, and treats the zone as neutral in wartime.11University of Calgary. 1856 Convention on the Demilitarisation of the Aland Islands 1921 Second, although Finland is an EU member, Åland sits outside the EU’s VAT and excise territory. A tax border runs between Åland and mainland Finland, and goods moving across it are treated as imports for VAT purposes.12Vero.fi. Aland Islands Tax Border and Importing Goods
Spain’s Autonomous Communities
Spain’s 1978 Constitution turned one of Europe’s most centralized states into one of its most decentralized. Section 143 lets bordering provinces with shared historical, cultural, and economic characteristics form self-governing communities, each with a statute of autonomy approved by the national parliament.13La Moncloa. Part VIII Territorial Organization of the State The country now has 17 autonomous communities and two autonomous cities.
The constitution lists 22 categories of powers a community may assume, including urban planning, public works, agriculture, culture, social assistance, and health. After five years, communities can expand their authority through statute amendments. The Basque Country has taken this the furthest, with historic territories that collect nearly all taxes themselves, including income and corporate taxes, rather than relying on transfers from Madrid. In exchange, the Basque government pays an agreed quota to the central government for shared national costs such as defense.14Euskadi.eus. The Statute of Autonomy of the Basque Country Most other communities operate under a common regime in which the central government collects taxes and redistributes funds.
Spain also shows how autonomy can be paused. Section 155 lets the central government take the measures necessary to compel a community to meet its constitutional obligations, with Senate approval by an overall majority.13La Moncloa. Part VIII Territorial Organization of the State In October 2017, after Catalonia held an unauthorized independence referendum and its parliament voted to declare independence, Spain invoked Article 155 for the first time. The central government dismissed the Catalan president and his cabinet, suspended the region’s autonomy, and called new elections. The intervention lasted roughly seven months.
Native American Tribal Sovereignty
Native American tribes fit into a legal category that predates the U.S. Constitution and has no exact parallel elsewhere. The Commerce Clause gives Congress power to regulate commerce with “foreign Nations,” “the several States,” and “the Indian Tribes,” treating tribes as distinct political entities separate from states, the federal government, and foreign nations.15Congress.gov. ArtI.S8.C3.9.1 Scope of Commerce Clause Authority and Indian Tribes
The framework rests on three principles from Supreme Court decisions in the 1820s and 1830s. Tribal authority on reservation land is organic, meaning it was not granted by the states where that land sits. Congress holds plenary power over Indian affairs. And the federal government has a trust relationship with tribes and a duty to protect them. Congress has reinforced these by statute. The Indian Self-Determination and Education Assistance Act finds that prolonged federal domination of tribal programs has “served to retard rather than enhance” tribal progress, and affirms tribal control over governance and education.16Office of the Law Revision Counsel. United States Code Title 25 – 5301
In practice, tribes set their own tax policies on reservation land, regulate commerce, operate enterprises like casinos under federal Indian gaming law, and prosecute tribal members for crimes committed on their land. Criminal jurisdiction over non-members has historically been limited, and Congress has restored parts of it in stages, including limited jurisdiction over non-Indians in domestic violence cases. Unlike the other regions above, tribal sovereignty is not a grant from a central government but a pre-existing authority that the federal government has recognized, limited, and at times restored.
How the Legal Foundation Shapes Durability
The examples fall into four broad categories, and the category matters for how secure the arrangement is.
- Constitutional provisions. Iraq’s recognition of the Kurdistan Region and Spain’s system of autonomous communities are both written into national constitutions. That makes them hard to revoke through ordinary legislation, since amendments usually require supermajorities. Constitutions often also carry override tools such as Spain’s Article 155.
- International treaties. Åland’s status rests on a 1921 League of Nations decision and international conventions on demilitarization. Treaty-based autonomy adds an external enforcement layer, and Finland cannot revoke Åland’s status by ordinary law without violating its international obligations. It is the most structurally secure form, and also the rarest.
- Statutory grants. Denmark’s arrangements with Greenland and the Faroe Islands are acts of parliament: the Self-Government Act of 2009 and the Home Rule Act of 1948. In theory the Folketing could amend them; in practice the political cost makes that nearly unthinkable, but the legal barrier is lower than constitutional entrenchment.
- Inherent sovereignty. Native American tribal sovereignty does not derive from a constitutional grant or a statute. The legal theory is that sovereignty was never given in the first place, so it does not rest on a document a legislature could repeal, even though Congress retains plenary power in practice.
Hong Kong’s recent history is the reminder that runs through all of these. On paper the Basic Law was meant to hold until 2047. In 2020 Beijing acted through a route the Basic Law did not anticipate, and the practical scope of Hong Kong’s self-governance narrowed sharply. Self-rule depends on the text of the law and on the political conditions that keep the text meaningful.