The Danish Model of Immigration Control: A Blueprint for the UK?

The UK’s Labour Party, led by Keir Starmer, is looking to Denmark as a model for tightening immigration policies. This move, echoed in a joint article with Danish Prime Minister Mette Frederiksen, raises the question: what exactly is the “Danish model,” and can it be effectively applied to a country as different as the UK? This article examines the core tenets of Denmark’s approach, its impact, and the challenges of replication.

What is the Danish Model?

Denmark’s immigration policies, developed over the past decade, are characterized by a focus on indirect deterrence. Rather than heavily restricting entry at the border – given its geographical position – Denmark has concentrated on making conditions for asylum seekers and refugees as unappealing as possible. This has involved over 100 legislative changes to the Aliens Act, according to Thomas Gammeltoft-Hansen, Denmark’s first professor of migration and mobility law.¹

Key elements of the Danish model include:

• Temporary Residence Permits: Refugee status is typically granted for one to two years at a time, with no automatic path to permanent residency.¹
• Integration Requirements: Permanent residency requires fluency in Danish and several years of full-time employment.¹
• Restricted Welfare Benefits: Cuts to social benefits for immigrants and asylum seekers.³
• Family Reunification Delays: Lengthy wait times and increased fees for family reunification applications.¹
• Designated ‘Ghettos’: Restrictions on immigrants moving to certain housing areas.¹

Has the Danish Model Been Effective?

Whereas some measures may appear symbolic, analysis suggests the Danish approach has been partially effective in reducing asylum arrivals compared to other European countries.¹ However, this has reach at a cost. The policies have been criticized for undermining integration opportunities and hindering access to the labor market for those already in Denmark.¹ The approach essentially “punishes those who have already arrived” to deter future arrivals.¹

The UK’s Interest and Potential Challenges

Keir Starmer’s Labour Party sees the Danish model as a potential solution to control illegal immigration, particularly via the English Channel, and to increase the time required for permanent residency to 20 years.⁴ However, significant differences exist between the UK and Denmark. The UK has a population more than ten times larger than Denmark’s, and its economic and social context is vastly different.¹

Denmark, like many European nations, now recognizes the necessitate for labor migration to address demographic challenges and workforce shortages.³

The Broader Context of Mobility

Historically, access to mobility has been crucial for economic growth and cultural exchange.³ While once limited by geography, mobility is now largely governed by law, encompassing refugee law, labor migration laws, transportation law, and health regulations.³

Calls for Reinterpreting Human Rights Law

Both the UK and Denmark have recently called for a modernization of the European Convention on Human Rights to account for migration challenges.¹ However, some scholars suggest this is a call for devolution – a weakening of human rights protections – rather than genuine modernization.¹

The adoption of the Danish model by the UK remains a complex issue, fraught with challenges and potential unintended consequences. Whether the UK can successfully replicate Denmark’s approach, and whether it is even desirable given the differing contexts, remains to be seen.