Why Denmark’s asylum model might not work for the UK ...Middle East

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Why Denmark’s asylum model might not work for the UK

Shabana Mahmood will announce today that she is radically overhauling the UK’s asylum rules – a move that echoes similar measures taken in Denmark.

The Home Secretary is set to confirm that she is making all refugee status temporary and limited to 30 months, after which there will be a mandatory review.

    Refugees whose home countries are deemed safe will be expected to return at the end of the review period, while those who continue to require protection may have their status renewed.

    The tougher approach is modelled on Denmark, which Mahmood visited last week to see some of the country’s migrant return centres. 

    The country’s tough approach has yielded results, reducing asylum claims by around 91 per cent over the past decade.

    Denmark’s left-leaning Social Democratic Party, which has held power since 2019, has managed to see off the rise of the far-right Danish People’s Party over, with the latter’s support falling from 21.1 per cent in 2015 to 2.6 per cent in 2022.

    Many have attributed this electoral success to the SDP’s hardline immigration stance – something that the UK’s Labour Party facing a threat from Reform, is hoping to replicate

    But there are significant differences between Denmark and the UK when it comes to their respective asylum systems which could pose a challenge to Mahmood’s hopes.

    How do the UK’s immigration plans compare to Denmark’s?

    Temporary protection: From today, the UK plans to make all refugee status temporary, with mandatory reviews every 2.5 years. Refugees arriving via irregular routes, such as small boat crossings, will face a 30-year wait before they are able to apply for indefinite leave to remain. Those who come through legal routes will have to wait 20 years. In comparison, Denmark grants initial permits of one to two years, which can be renewed, with permanent settlement available after eight years.

    Family reunification: The UK plans to restrict family reunification to people on designated work or study routes, which means they must meet the £29,000 income threshold to be able to bring family members to the UK. Denmark applies a two-year wait for temporary status, after which reunification may be allowed.

    Asset seizures: The UK is planning to allow the seizure of non-sentimental assets from refused asylum seekers to cover costs. Similarly, Denmark has a “jewellery law,” which permits confiscation of valuables above a set threshold to help cover accommodation costs.

    Welfare support: The UK plans to remove the statutory duty to provide asylum support, making housing and weekly allowances discretionary. In reality this means the Home Office can deny support to those it feels have assets or can work. Denmark provides accommodation in centres, as well as healthcare, but also uses departure centres to encourage voluntary returns.

    Earned settlement and integration: The UK will allow refugees to reduce the settlement period through employment, study, or other contributions to the country. Denmark also imposes integration requirements, including mandatory language courses, employment obligations and housing restrictions under its “Parallel Society” law, which mandates that no more than 30 per cent of residents in certain areas are of “non-Western” origin.

    Home Secretary Shabana Mahmood arrives for the weekly Government cabinet meeting at Downing Street (Photo: Jack Taylor/Getty Images)

    How do the UK and Denmark compare on asylum claims?

    In 2024, Denmark reported it had received 2,333 asylum claims – the lowest level in 40 years, excluding the pandemic.

    This is just a fraction of the asylum claims received by the UK, which Home Office figures show hit 108,138 the same year – the highest figure recorded since 2002.

    The asylum backlog was around 2,500 in Denmark as of November 2025, according to the charity Refugees Welcome DK, while in the UK it was 64,426 as of December 2025.

    Denmark does have a significantly smaller population with around 5.9 million inhabitants as of 2025, which makes it only slightly larger than the Yorkshire region, which had a population of 5.6 million as of 2024. The UK’s population is around 12 times larger than Denmark – around 69 million according to the most recent estimates.

    But, even with this population difference taken into account, the UK still has a significantly higher asylum claim rate than Denmark.

    Analysis by the House of Commons Library suggests that there were roughly 14.5 asylum seekers per 10,000 people in the UK in 2024 compared to approximately 3 in Denmark.

    Denmark’s asylum claims hit a peak of 21,316 in 2015, but they’ve now reduced this to around 1,835 according to provisional figures for 2025 – a 91 per cent reduction.

    In comparison, the UK recorded 39,968 asylum claims in 2015. If it had reduced asylum claims at the same rate as Denmark, the 2025 figure would be around 3,600. However, provisional figures for last year suggest there were 100,625 claims, an increase of around 152 per cent.

    People picked up at sea while attempting to cross the English Channel (Photo: JUSTIN TALLIS / AFP via Getty Images)

    Why Denmark’s asylum model might not work for the UK

    Small boat arrivals: One of the biggest differences between the UK and Denmark is how irregular arrivals into the country occur.

    Denmark, which has only one land border with Germany, is part of the Schengen zone, which means arrivals are not consistently tracked, and there are no official statistics on individuals arriving by boat. By comparison, the UK recorded 41,472 small boats crossing the English Channel in 2025.

    Voluntary returns: One further challenge is how asylum seekers are returned. Denmark relies almost entirely on voluntary returns, offering financial incentives and support to encourage migrants to leave, often from “departure centres” that have faced criticism for harsh conditions. Around 97 per cent of migrants leave Denmark this way.

    In the UK, fewer than half of those leaving do so voluntarily, and scaling Denmark’s approach would be costly and complex, as it would likely require the construction of similar “departure centres” and additional resources from the Home Office.

    Legal challenges: Another key roadblock could be the European Convention on Human Rights (ECHR), which both the UK and Denmark are signatories to.

    In 2021, the European Court of Human Rights (ECtHR) struck down Denmark’s plans to make asylum seekers wait three years before they could bring over family, arguing it breached Article 8 of the ECHR on the right to family life.

    Denmark ultimately reduced the wait to two years. By comparison, the UK is proposing that family rights could be restricted until the individual is granted permanent settlement, which could take 20 years.

    Since the UK has a much larger asylum caseload than Denmark, it is likely that this approach could be challenged in court.

    Michelle Pace, a professor from Roskilde University, also told Sky News last year that Denmark’s policies are “violating its commitments internationally according to the Geneva Convention of 1951, which ironically Denmark was the first to sign”.

    Internal rebellions: Criticism at home could be an additional challenge for the UK. Unlike in Denmark, where the centre-left Social Democrats had broad support for hardline policies, the UK’s reforms have triggered significant rebellion from within the Labour Party and from humanitarian organisations.

    When the plans were first announced, the Refugee Council said plans for a 20-year wait for settlement “echoes past injustices, including errors seen during the Windrush scandal”, while Labour MP Nadia Whittome told the BBC the plans were a “dead end – morally, politically and electorally”.

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