In the 1970s the Dutch military ceased to consider homosexuality a reason to prevent individuals from entering the military. This policy change coincided with larger legal changes in the Netherlands, which included changing age of consent laws for same-sex contact to 16, the same as for heterosexual contact, and incorporating an anti-discrimination clause addressing sexual orientation in the Dutch constitution.

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Yet officially allowing homosexuals to serve was only the first step in creating a more tolerant military culture. The Dutch military formed a working group called Homosexuality and Armed Forces to improve the climate for sexual minorities. In the 1980s, this group became the Homosexuality and Armed Forces Foundation, a trade union that continues to represent gay and lesbian personnel to the ministry of defense.

Although homosexuals in the Dutch military rarely experience any explicitly aggressive acts against them, they are troubled by subtle signs of and cultural insensitivity on the part of their heterosexual colleagues. Gay and lesbian military personnel are highly sensitive to these attitudes and typically respond by not expecting a high level of acceptance from their heterosexual colleagues, at least in terms of their sexual orientation.

Even so, a high level of loyalty characterizes homosexual personnel in the Dutch military. Indeed, research suggests that, given the difficulties they face, "only the most highly motivated, loyal homosexuals will choose a career in the armed services and persist in it."

In spite of the difficulties in fully integrating sexual minorities, the Dutch military continues to work to promote their inclusion. The Dutch military sees its duty as creating "the conditions under which all individuals can function fully." This acceptance of all types of people distinguishes the Dutch military from many other European militaries.

Great Britain's Monumental Shift in Policy

Long considered one of the more restrictive and homophobic of European militaries, the British Armed Forces reversed its position in 2000 and has taken steps in the past few years to create a more hospitable environment for gays and lesbians in its ranks.

In January 2000, the British Armed Forces lifted its ban on gay and lesbian personnel, following a ruling by the European Court of Human Rights. Like the United States, Britain had long excluded gay and lesbian service members and cultivated a military culture that defined itself in opposition to homosexuality.

For example, in 1994, the British Ministry of Defense justified its ban by arguing that "homosexual behavior can cause offense, polarize relationships, induce ill-discipline, and as a consequence damage morale and unit effectiveness."

Yet as increasing numbers of its allies, including Canada, Australia, New Zealand, and some of the European countries discussed above, lifted restrictions in the 1990s, the British policy became less tenable.

Unlike many other European countries, the British military also faced a much more organized gay and lesbian rights movement than many other European countries. This group of activists worked tirelessly to change the policy, and their legal challenges to the ban, which they began in 1994, eventually led to its removal.

The incorporation of the European Union Human Rights Act into British law allowed the legal challenges of these gay activists to overturn the ban. Unlike British legal protections, the European Union Human Rights Act implicitly protects gay men and lesbians from discrimination.

The small group of gay service members who challenged the ban first had to exhaust all British legal channels, but once they did, they were able to take their case before the European Court of Human Rights. Doing so allowed them to invoke the European Union Human Rights Act. The court ruled in their favor and required the British armed forces to reverse its discriminatory policy.

By all accounts, the lifting of the gay ban in the British military has been a success. Unlike those of other northern European countries such as the Netherlands, the new British policy does not explicitly guarantee gay men and lesbians the right to serve. Rather, it states that homosexuality in itself does not constitute grounds for dismissal.

The new British policy establishes a social code of conduct that applies to all service personnel. All service members are prohibited from engaging in social behavior that undermines the trust, cohesion, and operational effectiveness of the military. Such behavior includes unwelcome sexual attention, offensive displays of affection, or sexual harassment. The policy allows for discretion on the part of the commanding officer to decide what is appropriate.