House Secretary Shabana Mahmood has introduced controversial plans for the UK to embrace a “Denmark-style” asylum system, aimed toward making Britain much less engaging to unlawful immigrants and making deportations simpler.
The hardline “zero asylum seekers” method taken by Danish prime minister Mette Frederiksen in 2019 was uncommon for a centre-left social gathering.
However her Social Democrats gained seats on the 2022 election, whereas the populist right-wing Danish Individuals’s Social gathering completed twelfth – having been second in 2015 and third in 2019.
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Danish Prime Minister Mette Frederiksen visits British Prime Minister Keir Starmer, in London in February, 2025. Pic: Reuters
With Nigel Farage’s Reform UK at present main comfortably in nationwide polls, you possibly can think about why Labour are fascinated with what Ms Frederiksen is promoting.
However how comparable are Denmark’s immigration challenges to these within the UK, and what classes can we draw from them?
Lowering demand – Danish asylum claims falling
The obvious distinction between Denmark and the UK is that Denmark is considerably smaller. Its inhabitants of 6 million is just not way more than that of Yorkshire’s. So it is smart that it additionally has considerably fewer asylum seekers than Britain.
The variety of asylum claims per particular person has been comparable traditionally, nevertheless.
Within the two years earlier than Ms Frederiksen was elected prime minister, Denmark acquired a median of 57 functions per 100,000 individuals, whereas the UK averaged 55.
Since then, the UK determine virtually trebled to 145, whereas the Danish determine fell by a 3rd.
The Danish story breaks the development from the remainder of Europe, the place the variety of asylum functions to all EU nations rose by two thirds over the identical interval.
Danish immigration consultants say this isn’t a coincidence, however the results of Ms Frederiksen’s insurance policies.
“That has been made absolutely clear by the Mette Frederiksen government and the previous government before hers,” she added.
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A person walks by means of the gate at a departure centre for rejected asylum seekers in Jutland, Denmark in March 2019. Pic: Reuters
“There’s this sense among people that the UK is a safe and welcoming place,” he mentioned, additionally itemizing a number of different components drawing individuals to the UK, together with the English language, current networks of family and friends, and democracy.
Small boats vs visa overstayers – the routes taken to Denmark and Britain
A lot of the political consideration round unlawful migration within the UK is devoted to these crossing the Channel from France on small boats. A complete of 190,000 individuals arrived by way of this route since 2018, together with virtually 40,000 in 2025 alone.
In Denmark, 4 in 5 unlawful migrants recognized within the nation are individuals who beforehand had official, time-limited visas, however stayed within the nation longer than they need to have.
That sounds prefer it could be a major divergence from the UK’s system, however possibly not as a lot as you’d suppose.
New UK knowledge on this a part of the system hasn’t been printed since 2020. However within the 4 years previous to that, 250,000 individuals had been recognized as potential visa overstayers – considerably greater than the quantity to have arrived on small boats.
Mr Cuibus mentioned there’s a huge hole within the knowledge, making developments tougher to trace.
“The only hard data that we have are on failed asylum seekers,” he mentioned.
“We know that roughly half of the people who’ve been rejected for asylum in the last 20 years are still in the country.”
How functions are dealt with
In addition to attracting fewer asylum claims, Denmark can also be now extra prone to say “no” to claims than the UK has been, a reversal of the development by means of many of the 2010s.
That seems to be as a result of the UK has grow to be much less prone to refuse functions in the previous few years, moderately than a giant spike in Danish rejections. Each the UK and Denmark granted asylum to massive numbers of individuals from Ukraine throughout this era.
The adjustments Denmark launched to its asylum coverage between 2015 and 2019 didn’t considerably enhance refusals on asylum functions, however moderately made it tougher for asylum seekers to remain within the nation long-term.
The nation additionally handed measures meant to make making use of for asylum tougher, reminiscent of proscribing household reunification and threatening to confiscate valuables, which additionally contributed to deterring individuals from arriving within the first place.
Sending individuals residence
It is one factor rejecting individuals claiming asylum, however it’s one other ensuring these individuals depart safely and legally.
One of many mechanisms that protects migrants from unsafe elimination is the European Conference on Human Rights (ECHR), which the UK – and Denmark – is signed as much as, however which Reform say they would go away in the event that they win energy.
One key a part of Ms Mahmood’s plans is to alter how the ECHR is interpreted in migration courtroom instances.
It will imply that solely individuals with rapid household within the UK – for instance, a dad or mum or little one – can argue that their “right to family life” could be breached by being deported.
Denmark has had better success than its European neighbours at eradicating individuals it has determined ought to depart. Between June 2021 and June 2025, 46% of the ten,000 individuals it ordered to depart did so.
That is a considerably increased proportion than the EU common of 21% – 400,000 individuals had been returned, of the 1.9 million that had been ordered to depart. The equal charges for France and Germany had been 8% and 28% respectively.
The UK doesn’t accumulate comparable knowledge on the variety of individuals ordered to depart, however it has returned 86,000 individuals over an identical time interval – greater than another European nation.
That quantity has been climbing previously two or three years, however it’s nonetheless 25% decrease than it was within the early 2010s.
Voluntary vs enforced returns
Denmark’s asylum seeker elimination coverage depends virtually solely on “voluntary returns”, moderately than these “enforced” by authorities.
Within the UK, the proportion of voluntary returns has been steadily rising, however it’s nonetheless used for fewer than half of migrants who depart the UK.
“There are quite a few reasons for governments to prefer voluntary returns,” Mr Cuibus defined.
“The main reason why the Home Office started shifting away from enforced returns more towards voluntary returns… is money.”
“We don’t really know exactly what the costs are right now, but we had some estimates from back in 2013. And at the time, those were estimating that an enforced return cost around £15,000 per person, compared to around £3,000 for a voluntary return.
“There’s the humanitarian aspect as effectively. Enforced returns should not very nice issues to both undergo or watch or must implement,” he said. “There’s a huge want for restraints, skilled personnel.”
Individuals who are refused for asylum can apply to the Danish government for the equivalent of several thousand pounds in support to voluntarily return to their country of origin, according to the Danish Return Agency’s website.
While still potentially cheaper for the government than an enforced return, it’s not always popular politically as it can be seen to be rewarding illegality.
There has also been criticism of some of the methods used by Denmark to encourage people to leave.
Asylum seekers who find their claims rejected can be put in “departure centres”, prison-like amenities designed to encourage their voluntary deportation.
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Kaershovedgaard, a former jail and now a departure centre in Denmark. Pic: Reuters
In 2024, the European Committee for the Prevention of Torture criticised one among these amenities for his or her “carceral environment”.
Denmark’s parliamentary ombudsman described circumstances at one other as “very burdensome and restrictive for living” and “marked by brutalisation”.
Michelle Tempo, a professor from Roskilde College, mentioned Denmark’s insurance policies are a violation of worldwide humanitarian regulation.
“Denmark prides itself on this negative branding, which is based on extremely harsh rhetoric, an extreme choice of words,” mentioned Tempo, referring to a few of Denmark’s extra controversial immigration insurance policies such because the “jewellery law”, which permits the federal government to grab asylum seekers’ belongings, together with their jewelry, to fund their keep within the nation.
“It’s violating its commitments internationally according to the Geneva Convention of 1951, which ironically Denmark was the first to sign,” she mentioned.
Ms Tempo warned that the UK ought to look to different European immigration fashions, like Spain’s, which she argues is much less xenophobic and extra forward-thinking.
“In the Spanish case, they looked in terms of a long duration and said, okay, we have a low birth rate. We’re going to have a huge shortage of labour in the next 20 to 50 years.
“How can we make a authorized pathway that’s protected for individuals to return right here, construct a life that’s authorized, that’s protected, that’s structured, that’s organised?”
