Home Secretary Shabana Mahmood delivered a speech this morning in which she pledged to build a “firm but fair asylum system” in the UK.
Speaking in London, she said “restoring control at our borders is not a betrayal of Labour values” and insisted that the UK would “always offer protection to genuine refugees”.
The Home Secretary has embarked on a hard-line overhaul of the UK’s immigration system, with several of her changes heavily inspired by policies in Denmark.
Clearly, the UK isn’t the only country that is taking a tough stance on immigration.
Here are five countries that have pursued radical policies to tackle immigration – and how they compare to the UK.
Greece: Prison terms and tougher penalties
Greece has taken some of Europe’s toughest steps to curb irregular migration in recent years.
In September 2025, its parliament passed legislation imposing prison terms of two to five years on asylum seekers whose claims were rejected if they failed to leave the country within 14 days.
Financial penalties for undocumented migrants were also increased, reaching €10,000 for illegal entry and up to €30,000 for re-entry after a failed asylum claim.
The maximum detention period was extended from 18 to 24 months, and electronic ankle monitoring was introduced.
Ahead of the law passing, Greek migration minister Thanos Plevris said the message was “clear” for migrants: “If your asylum request is rejected, you have two choices. Either you go to jail or return to your homeland.
“The Greek state does not accept you … You are not welcome.”
In February, Greece approved further measures strengthening penalties for facilitating irregular entry. The law removed a previous pathway that allowed undocumented migrants to apply for residence after seven years.
It also increased the penalties for helping someone enter or remain in Greece irregularly, with prison terms of up to 10 years and fines of at least €50,000.
How this compares to the UK: Overstaying or entering illegally is a criminal offence in the UK, but there is no fixed short‑term deadline as there is in Greece, and cases usually focus on serious or repeated breaches.
Shabana Mahmood has embarked on a hard-line overhaul of the UK’s immigration system (Photo: PA)Hungary: Barring domestic asylum claims
Hungary has effectively eliminated access to asylum on its territory, replacing the traditional system with an embassy-based “declaration of intent” procedure.
Since May 2020, anyone seeking protection must first apply at a designated Hungarian embassy in a non-EU country, usually Belgrade in Serbia, or previously Kyiv in Ukraine, before they can enter Hungary to lodge a formal claim.
From June 2020 to the end of 2023, official figures show only 99 declarations were submitted, with 21 applicants granted a single-entry permit. In 2023, only 30 asylum applications were recorded.
European courts have repeatedly ruled that these measures violate EU asylum law.
In June 2024, the Court of Justice of the European Union (CJEU) imposed a €200m fine on Hungary for non-compliance with asylum rules, with a €1m daily penalty until the system aligns with the bloc’s rules.
The court said Budapest’s actions amounted to an “unprecedented and exceptionally serious infringement” and a “deliberate evasion” of EU law.
It claimed that Hungary had restricted access to asylum procedures, unlawfully detained applicants in transit zones, failed to allow appeals and removed migrants without proper legal safeguards — violating the EU’s rules under the common asylum policy.
But prime minister Viktor Orbán defended the measures in 2024, arguing that they protect national sovereignty. He said Hungary will not accept “a single migrant” under the EU’s new Migration Pact, scheduled to take effect in 2026, which obliges member states to share responsibility for asylum seekers.
How this compares to the UK: Unlike Hungary, the UK does allow people to apply for asylum once they have arrived in the country, whether that is by regular or irregular means.
Poland: Tough border controls
Poland has a hard-line approach to asylum along its eastern frontier.
Since March 2025, the Polish government has temporarily suspended the right to apply for asylum at the Belarus border.
According to Amnesty International, which has been critical of the move, this allows “border guards to disregard asylum applications without consideration for people’s individual circumstances” and send them back across the border into Belarus.
In a statement, the charity said that the law was “inconsistent and incompatible with international law and the Polish constitution, and poses a threat to the lives and human rights of people wishing to apply for asylum at the border”.
Poland has also strengthened its border security under its €2.5bn East Shield programme, which aims to tackle people smuggling and illegal migration, as well as protect Poland from aggression from Russia and its ally Belarus.
A 5.5-metre steel wall runs along the 186-kilometre border with the two countries, reinforced with cameras, motion sensors, anti-tank ditches and bunkers.
Around this wall is a 78-kilometre-long buffer zone that restricts civilian, journalist and NGO access, while airspace restrictions limit private flights and drones.
Internal enforcement has also intensified: deportations more than doubled in 2025 to over 2,100, and a nationwide operation in early 2026 detained 140 individuals with irregular status.
How this compares to the UK: The UK does not suspend asylum at the border or maintain exclusion zones.
Italy: Overseas processing and naval blockades
A cornerstone of Italian prime minister Giorgia Meloni’s strategy is the Italy‑Albania “return hub” model.
Ratified in 2024, the agreement allows up to 3,000 asylum seekers at a time to be transferred to Italian‑run centres near Shëngjin and Gjadër in Albania while their claims are processed under Italian jurisdiction.
Italian courts initially blocked transfers on the basis that Italy’s list of designated “safe countries of origin” — including countries such as Egypt and Bangladesh — did not align with EU law and lacked sufficient protections.
But in 2025, the European Court of Justice confirmed that national safe‑country designations must meet strict legal standards and be subject to judicial review, clearing the way for the hubs to go ahead.
Meloni said last November: “Two years have been lost, but we are determined to move forward, and it will work.”
In February this year, draft legislation was also tabled, which would authorise the Italian navy to impose 30‑day blockades on boats during periods of “exceptional migratory pressure” or “serious threat to public order,” renewable for up to six months.
Under the proposals, ships — particularly those operated by non‑governmental organisations — could face fines of up to €50,000 and seizure if they repeatedly enter Italian territorial waters in violation of the blockade. The law still needs to be passed by the Italian parliament.
Multiple groups which assist boats in the Mediterranean, including Sea Watch and Doctors Without Borders, have criticised the law, claiming the measures target NGOs which rescue people in distress at sea.
At the same time, domestic migration rules have tightened. Citizenship by descent is now limited to those with at least one Italian parent or grandparent.
How this compares to the UK: The UK does not operate offshore processing centres or naval blockades. There were attempts by the previous Conservative government to transfer asylum seekers to Rwanda, but this was dropped by Labour following the election.
Denmark: Voluntary returns and tight integration
Denmark has shaped one of the toughest asylum systems in Europe, and the UK is hoping to take some inspiration from it.
Rather than granting immediate permanent residence, most refugees in Denmark are given short‑term permits of one to two years, which must be renewed regularly.
Only after an extended period – typically eight years of continuous residence – can someone become eligible for permanent status, and even then strict criteria still apply.
The Danish government also operates “departure centres” where asylum seekers are housed and encouraged to leave voluntarily. These centres offer basic accommodation, incentives for voluntary return and limited welfare support, but have been criticised by rights groups for their austere conditions.
Denmark’s policies extend beyond status duration. Authorities may confiscate non‑sentimental assets from refused asylum seekers above a set value to contribute to accommodation costs, and the system links welfare provision closely to co-operation with return plans.
Refugees and those seeking protection are required to take intensive Danish language courses and integration classes, demonstrate employment efforts and comply with local social cohesion measures – all conditions tied to future residence rights.
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The result has been a dramatic reduction in asylum claims: provisional figures suggest applications dropped from over 21,000 in 2015 to around 1,800 in 2025, a reduction of roughly 91 per cent.
How this compares to the UK: The UK’s emerging asylum reforms echo Denmark in making refugee status temporary with periodic reviews and imposing integration conditions including English‑language requirements.
The UK is planning to allow the seizure of non-sentimental assets from refused asylum seekers to cover costs.
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