The UK’s New Asylum Strategy: The Danish Model of Deterrence

For years, Denmark has been held up across Europe as the archetype of a tough, deterrent-based asylum regime. It is the model now explicitly influencing the UK’s direction of travel. To understand what the UK’s new asylum policy aims to achieve, and the risks embedded within it, we need to understand what Denmark has done and what political conditions made it possible.

Immigration has dominated Danish politics for decades. The rise of the Danish People’s Party, a far-right populist movement, steadily pulled the political centre towards harsher stances on migration. A decisive shift came in 2015, when the People’s Party broke through in traditionally Social Democratic strongholds. The Social Democrats concluded that unless they matched the far right’s hawkishness, they risked long-term electoral damage. Senior figures openly declared that “not a sheet of paper” should separate their immigration policies from those of the far right. What began tactically soon became a defining ideological stance.

Under Prime Minister Mette Frederiksen, this hardened consensus produced a sweeping redesign of the asylum system. Asylum claims are now at a forty-year low and net migration sits at around 30,000 per year for a country of six million. Yet these headline figures only make sense when viewed through Denmark’s governing logic: asylum is temporary; belonging is conditional; deterrence is the primary tool of management.

To achieve this, Denmark deliberately removed “pull factors”. Family reunification rules were tightened. Social benefits for asylum seekers were reduced. Ministers repeatedly communicated, domestically and internationally, that asylum seekers should choose anywhere but Denmark. Some measures were more symbolic than operational, the law allowing border guards to confiscate valuables above €1,300 was rarely used, but its purpose was clear.

Settling into Danish communities was also reframed. Refugees must demonstrate not only linguistic and civic competence but a deeper cultural “Danishness”. Citizenship applications can be scrutinised by parliamentary committees who probe applicants’ social media posts or personal views. Applicants who meet every formal criterion can be blocked if their values are deemed incompatible with those of the Danish state.

At the sharper end, Denmark introduced the so-called “ghetto laws”, enabling the demolition of housing blocks and the forced redistribution of residents in areas where at least half the population has a “non-Western background”. Residents face restrictions on family reunification and may be relocated to promote “social mixing”. Abroad, these policies attract accusations of social engineering; inside Denmark, they are largely uncontroversial, supported across the mainstream political spectrum.

This political consensus is the key distinction. Unlike the UK, Denmark’s governing and opposition parties broadly agree on the fundamentals of immigration control and have frequently struck cross-party deals. That stability allows policies, some extreme by British standards, to endure, deepen, and gradually normalise. Even so, the ground continues to shift: the Danish People’s Party now campaigns for “re-migration”, a euphemism for mass deportation of settled migrant families. It is unworkable but illustrates how consensus on deterrence accelerates rightward drift.

The UK government’s new asylum and returns policy statement, Restoring Order and Control, situates itself firmly within this same deterrent logic. It describes its proposals as the most far-reaching reforms in modern times and presents Denmark as evidence that tougher laws reduce arrivals.

The package rests on three broad commitments: reducing arrivals, accelerating removals, and tightly controlling “safe and legal” routes.

A central shift is towards temporary protection. Refugees will no longer be on a straightforward five-year route to settlement; instead, protection will last only as long as their home country remains unsafe. Once conditions improve, return becomes the default expectation. If conditions do not improve, then a refugee can apply for settlement after 20 continuous years of living in the UK or sooner (the likely period being 10 years) if they switch to a different visa status. This reflects Denmark’s approach, where refugees repeatedly renew short-term protection rather than move towards permanence.

The government also intends to restrict asylum support more aggressively. People deemed able to support themselves, or who have broken “our laws or rules”, may be refused accommodation and financial support. Those with assets may be required to contribute to their own housing costs.

In accommodation policy, the government plans to end hotel use entirely and shift to large, communal sites, including repurposed military bases. Ministers point to Denmark, Germany and Belgium as comparators where centralised sites form the standard asylum estate.

In the labour market, the reforms signal a significant expansion of right-to-work enforcement, including mandatory digital identity verification for all workers by the end of this Parliament. The objective is explicit: to make it harder for people with irregular status to survive in the informal economy.

On removals and appeals, the government proposes a structural overhaul. A new appeals body will sit alongside the tribunal system, with statutory timelines, a single primary appeal route, and accelerated procedures for “manifestly unfounded” claims. The intention is to reduce repeat appeals and speed up removals, particularly from countries designated as safe.

Human rights protections are also directly targeted. Ministers plan to legislate for a narrow statutory definition of “family life” to reduce reliance on Article 8 ECHR in deportation cases. They also want to “evolve” jurisprudence under Article 3, especially where returns are blocked due to poor prison conditions or health risks. Modern slavery protections will be narrowed, with reforms aimed at stopping what the government sees as opportunistic last-minute claims.

Finally, safe and legal routes will be recast. A capped resettlement programme, shaped by local authority capacity and community sponsorship, will determine annual intake. New routes for refugee students and skilled refugees will be introduced. The message is clear: this is the “right way” to seek protection; irregular arrivals will face far tougher treatment.

The question is not whether these reforms resemble Denmark’s, they plainly do, but whether the UK can implement them, and what they mean for future governments.

Denmark’s tough stance rests on a rare political consensus. Labour, by contrast, still has some internal opposition, at least for now. It contains MPs, members, unions, city mayors and affiliated groups with fundamentally different views on asylum, enforcement and the ECHR. Many represent, or rely on, diverse communities directly affected by these policies.

Keeping this package intact through legislation, and then through operational delivery, will require navigating constant internal conflict. The Lords will resist. Backbench Labour MPs will rebel. This will not be a stable settlement.

Temporary protection regimes require reliable assessments of when countries become safe, functioning return agreements, identity documentation, and a well-resourced Home Office. None of this currently exists. The department struggles with even basic casework functions.

The proposed appeals body, digital ID system, large-scale sites and return timetables all assume a level of competence and investment the Home Office has not demonstrated for years. It is also unclear whether legal aid will remain available across repeated reassessments over a period that could span decades.

Much of the package may therefore function primarily as a deterrent signal rather than a practical system, much like Denmark’s confiscation law.

The parallel to Blair’s employer sanctions is relevant. Introduced with soft enforcement, they later became the backbone of the Conservative’s “hostile environment”. Once deterrent architecture enters the statute book, it becomes extremely difficult to remove. More importantly, it becomes available to any future government.

A future Reform-influenced administration, or a Conservative–Reform coalition, would inherit this strict framework which can be tightened further without needing new primary legislation. Denmark shows how quickly the Overton window shifts once deterrence becomes normalised.

Policies that are uncontentious in Denmark, forced relocations, demolition of “ghetto” housing, would trigger major political, legal and community resistance in the UK. Even the UK’s milder equivalents (large sites, expanded enforcement, narrower rights) will be contested by local authorities, devolved governments and civil society.

The UK is a multi-ethnic, multi-national state with a more plural political culture. Attempts to centralise identity, belonging and integration through the state are unlikely to land cleanly.

Labour may hope these reforms neutralise asylum as a wedge issue. Denmark’s experience suggests the opposite: it took years for the centre-left and the general public to accept deterrence as the governing logic, after which the far right simply sets the next benchmark. The argument shifts from whether to control migration to how much further to go. A future government could easily claim it is only “finishing what Labour began”.

The UK’s new asylum strategy mirrors the Danish model’s focus on temporary protection, restricted rights and deterrence but without the political consensus and social homogeneity that sustain it. That means implementation is likely to be partial, heavily litigated and internally contested. Yet the lasting effect will be the legal and institutional architecture created that future governments could exploit even if Labour does not. The Danish model shows how quickly deterrence can be normalised. 

Photo credit: The official photostream of the Prime Minister of the United Kingdom.