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The UK–Denmark Model on Illegal Migration: A Critical Overview
In recent months, the United Kingdom (UK) government has signalled its intention to adapt aspects of the Denmark model for asylum and illegal migration, amid heightened concern over irregular sea crossings and public pressure to “take back control”. The government plans to emulate Denmark’s stricter asylum-and-integration regime, which it views as having reduced both arrivals and the permanence of stay for unsuccessful claimants.
This article examines the Danish model, how the UK proposes to apply its elements, the potential benefits and pitfalls, and the broader implications for asylum policy, international law and society.
What is the Danish model?
Denmark’s approach to asylum and migration has become renowned—some say notorious—for its hard‐edged deterrent focus and expectation of integration. Key elements include:
• A sharp reduction in asylum applications: According to academic research, after Denmark introduced a package of changes around 2015-16, asylum claims fell from ≈21,000 in 2015 to about 1,500 in 2020.
• Temporary residence for some refugees: Danish law limits certain protections to time-limited status unless the refugee meets integration obligations. For example, access to family reunification rights may be delayed and permanent settlement conditional.
• Tougher rules on family reunion, social benefits, housing and what Denmark terms “parallel societies”. For instance, some Danish policies target social housing areas where immigrant communities reach certain thresholds.
• A policy stance described by some Danish officials as aiming for “zero net asylum” (with the exception of certain categories).
• Consideration of outsourcing asylum processing or transfers to third countries (though this has faced legal/ethical hurdles).
Thus the Danish model emphasises deterrence of arrival, limited settlement rights, strict integration expectations, and fast removal of failed claimants.
What the UK is proposing
The UK government, under Keir Starmer’s leadership, has publicly stated that it wants to draw on Denmark’s model. Some of the announcements and plans include:
• Reviewing the family reunion rights of asylum-seekers: The UK plans to remove the automatic right for refugees to bring family members shortly after arrival.
• Limiting the route to permanent settlement and making status temporary or conditional.
• Clamping down on small boat crossings across the English Channel via bilateral deals (for example with France) and enhanced intelligence/operational co-operation.
• Seeking to reduce the “pull factors” that encourage irregular migration, arguing that more generous settlement rights and family routes act as incentives.
• Making bilateral cooperation with Denmark part of the broader migration/irregular migration strand in the UK–Denmark Joint Statement of June 2023.
In short: the UK aims to adopt a more deterrent posture — making it harder to obtain long-term settlement, tightening family routes, raising the bar for integration and rapidly removing failed claimants.
Why the UK is looking at Denmark
There are a number of reasons why the UK sees merit in the Danish experience:
• Results: Denmark’s decline in asylum applications and its ability to remove large proportions of unsuccessful claimants (by its own account) are held up as evidence that the deterrent model works.
• Public confidence and politics: Migration is a high-salience issue in the UK. By pointing to a successful foreign model, the government seeks to show competence and responsiveness.
• Smuggling challenge and small-boat routes: With arrivals via the Channel continuing, the UK wants to reduce the business model of smugglers. A strong deterrent framework can help in that aim.
• Integration concerns: The UK government suggests that uncontrolled migration and weak integration lead to pressures on public services, social tensions and house-sharing challenges. The Danish model aligns with the idea of migration being conditional and contributory.
What would this look like in practice – UK adaptation
If the UK implements a Danish-style framework, we might expect the following components:
• Rapid processing of asylum claims, faster removal of failed claimants, fewer routes to settlement and fewer rights to family reunion.
• A system where successful applicants may be granted only temporary residence and then need to renew or meet integration tests before gaining permanent status.
• Tighter restrictions on social benefits or settlement rights unless integration conditions are met (work, language, no welfare dependency).
• Stronger bilateral return agreements with countries of origin or transit, and possibly third-country processing (though legally and ethically contentious).
• Enforcement against smuggling networks, intelligence-sharing, increased border surveillance, and coordinated action with partner countries like France and EU bodies (e.g., Frontex).
For example, UK officials visited Denmark to learn from its border control and asylum policy.
Also, the UK has increased collaboration with Frontex and France on returns and intelligence.
Potential advantages
• Reduction in irregular arrivals: By diminishing the “reward” for arriving via an unauthorised route (e.g., limited settlement prospects, reduced family-reunion rights), the UK could reduce the incentive for migrants to flee via small boats.
• Greater control of border/migration system: Tighter rules enable the state to exercise more oversight, enhance return capabilities, and reinforce the message that illegal entry and staying is not automatic.
• Improved integration outcomes: If temporary status is tied to ‘earning’ settlement by working, language acquisition and meeting integration conditions, this could yield better integration and less structural welfare dependency.
• Public trust and political legitimacy: A system perceived as fair (treating legal migration distinctly from irregular) could bolster public confidence and reduce political fallout from uncontrolled migration.
Key challenges, risks and criticisms
However, there are significant caveats and concerns with applying the Danish model in the UK context:
• Legal constraints & human rights protections: The UK must respect obligations under international law (e.g., non-refoulement, asylum law, human rights, especially via the European Convention on Human Rights). Some Danish elements — particularly offshore processing or outsourcing claims — face major legal and ethical questions.
• Scale and geography differences: Denmark is much smaller, with a different migration history and scale of asylum flows than the UK. Its land borders and sea routes are different. What worked in Copenhagen may not map easily to Dover, Calais, the Channel and the wider UK landscape.
• Moral and humanitarian concerns: Critics argue that making settlement conditional, limiting family reunification and treating asylum more temporarily could undermine refugee rights, family unity and long-term social cohesion.
• Effectiveness of deterrence uncertain: While Denmark saw falls in asylum claims, it isn’t clear if all the decline was due solely to policy changes or broader global migration patterns, nor whether the UK would achieve similar reductions. Also, smugglers may adapt and push new routes.
• Integration vs segregation issues: Strict rules on welfare are intended to promote integration, but could also push migrants into poverty or informal sectors, potentially undermining social cohesion.
• Unintended effects on labour markets and public services: Migration policy is also about managed legal migration for jobs, skills and demographic needs. A highly deterrent system risks losing those benefits.
• Political and public backlash: If perceived as too harsh or discriminatory, such policies might alienate certain communities and provoke court challenges or human-rights interventions.
What this means for the UK – key questions
1. Will deterrence work with maritime routes? The UK’s specific challenge is the Channel crossings by small boats. A Danish model may need adaptation for this unique geography and risk profile.
2. How will legal migration and refugee protection be balanced? The UK must ensure that genuine refugees are protected and that the system remains fair while still delivering deterrence for exploitative or irregular flows.
3. How will returns and removals be improved? One of Denmark’s strengths is its ability to execute removals of failed claims. If the UK cannot secure faster returns, deterrence weakens.
4. What governance and oversight will apply? Oversight bodies, tribunals, courts, and human rights bodies will scrutinise changes. The UK must ensure compliance with domestic and international law.
5. How will integration strategy evolve? If temporary status becomes the norm, the UK will need robust integration frameworks (language, employment, community participation) to ensure migrants don’t become marginalised.
6. Will public services cope with changes? Changes could affect local government, housing, welfare and social cohesion. A stronger integration pathway must accompany deterrence.
7. Is the policy politically sustainable? The UK’s recent migration policies have been contentious. The success of a Danish-style model may hinge on public support, credible delivery and transparency.
Conclusion
The UK’s move to adopt elements of the Danish model represents a significant shift in asylum and migration policy: from an emphasis on settlement and permanent rights to a more transactional, conditional approach. The allure of Denmark’s apparent success in reducing asylum applications and removals is strong.
Attached is a News article regarding the uk Denmark modal to cut illegal migration
https://news.sky.com/story/uk-looking-at-denmark-model-to-cut-illegal-migration-13466272
Article written and configured by Christopher Stanley
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