Home Secretary Shabana Mahmood has announced controversial plans for the UK to embrace a “Denmark-style” asylum system, aimed at making Britain less attractive to illegal immigrants and making deportations easier.

The hardline “zero asylum seekers” approach taken by Danish prime minister Mette Frederiksen in 2019 was unusual for a centre-left party.

But her Social Democrats gained seats at the 2022 election, while the populist right-wing Danish People’s Party finished twelfth – having been second in 2015 and third in 2019.

With Nigel Farage’s Reform UK currently leading comfortably in national polls, you can imagine why Labour are interested in what Ms Frederiksen is selling.

But how comparable are Denmark’s immigration challenges to those in the UK, and what lessons can we draw from them?

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Reducing demand – Danish asylum claims falling

The most obvious difference between Denmark and the UK is that Denmark is significantly smaller. Its population of 6 million is not much more than that of Yorkshire’s. So it makes sense that it also has significantly fewer asylum seekers than Britain.

The number of asylum claims per person has been similar historically, however.

In the two years before Ms Frederiksen was elected prime minister, Denmark received an average of 57 applications per 100,000 people, while the UK averaged 55.

Since then, the UK figure almost trebled to 145, while the Danish figure fell by a third.

The Danish story breaks the trend from the rest of Europe, where the number of asylum applications to all EU countries rose by two thirds over the same period.

Danish immigration experts say this is not a coincidence, but the result of Ms Frederiksen’s policies.

“The numbers have fallen because Denmark is not a welcoming place,” Michelle Pace, Professor in Global Studies at Roskilde University in Copenhagen, told Sky News.

“That has been made absolutely clear by the Mette Frederiksen government and the previous government before hers,” she added.

In contrast, Mihnea Cuibus, a researcher at Oxford University’s Migration Observatory, told Sky News that the UK is typically viewed as an attractive country for migrants.

“There’s this sense among people that the UK is a safe and welcoming place,” he said, also listing several other factors drawing people to the UK, including the English language, existing networks of friends and family, and democracy.

Small boats vs visa overstayers – the routes taken to Denmark and Britain

Much of the political attention around illegal migration in the UK is dedicated to those crossing the Channel from France on small boats. A total of 190,000 people arrived via this route since 2018, including almost 40,000 in 2025 alone.

In Denmark, four in five illegal migrants identified in the country are people who previously had legitimate, time-limited visas, but stayed in the country longer than they should have.

That sounds like it might be a significant divergence from the UK’s system, but maybe not as much as you would think.

New UK data on this part of the system hasn’t been published since 2020. But in the four years prior to that, 250,000 people were identified as potential visa overstayers – significantly more than the number to have arrived on small boats.

Mr Cuibus said there is a big gap in the data, making trends harder to track.

“The only hard data that we have are on failed asylum seekers,” he said.

“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 applications are handled

As well as attracting fewer asylum claims, Denmark is also now more likely to say “no” to claims than the UK has been, a reversal of the trend through most of the 2010s.

That appears to be because the UK has become less likely to refuse applications in the last few years, rather than a big spike in Danish rejections. Both the UK and Denmark granted asylum to large numbers of people from Ukraine during this period.

Mr Cuibus told Sky News that between 2020 and 2023, the UK had some of the highest rates of granting asylum in Europe.

The changes Denmark introduced to its asylum policy between 2015 and 2019 did not significantly increase refusals on asylum applications, but rather made it harder for asylum seekers to stay in the country long-term.

The country also passed measures intended to make applying for asylum more difficult, such as restricting family reunification and threatening to confiscate valuables, which also contributed to deterring people from arriving in the first place.

Sending people home

It’s one thing rejecting people claiming asylum, but it’s another making sure those people leave safely and legally.

One of the mechanisms that protects migrants from unsafe removal is the European Convention on Human Rights (ECHR), which the UK – and Denmark – is signed up to, but which Reform say they would leave if they win power.

One key part of Ms Mahmood’s plans is to change how the ECHR is interpreted in migration court cases.

It would mean that only people with immediate family in the UK – for example, a parent or child – can argue that their “right to family life” would be breached by being deported.

Denmark has had greater success than its European neighbours at removing people it has decided should leave. Between June 2021 and June 2025, 46% of the 10,000 people it ordered to leave did so.

That’s a significantly higher proportion than the EU average of 21% – 400,000 people were returned, of the 1.9 million that were ordered to leave. The equivalent rates for France and Germany were 8% and 28% respectively.

The UK does not collect comparable data on the number of people ordered to leave, but it has returned 86,000 people over a similar time period – more than any other European country.

That number has been climbing in the past two or three years, but it is still 25% lower than it was in the early 2010s.

Voluntary vs enforced returns

Denmark’s asylum seeker removal policy relies almost entirely on “voluntary returns”, rather than those “enforced” by authorities.

In the UK, the proportion of voluntary returns has been steadily rising, but it is still used for fewer than half of migrants who leave the UK.

“There are quite a few reasons for governments to prefer voluntary returns,” Mr Cuibus explained.

“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 side as well. Enforced returns are not very pleasant things to either go through or watch or have to enforce,” he said. “There is a big need for restraints, trained 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 facilities designed to encourage their voluntary deportation.

In 2024, the European Committee for the Prevention of Torture criticised one of these facilities for their “carceral environment”.

Denmark’s parliamentary ombudsman described conditions at another as “very burdensome and restrictive for living” and “marked by brutalisation”.

Michelle Pace, a professor from Roskilde University, said Denmark’s policies are a violation of international humanitarian law.

“Denmark prides itself on this negative branding, which is based on extremely harsh rhetoric, an extreme choice of words,” said Pace, referring to some of Denmark’s more controversial immigration policies such as the “jewellery law”, which allows the government to seize asylum seekers’ assets, including their jewellery, to fund their stay in the country.

“It’s violating its commitments internationally according to the Geneva Convention of 1951, which ironically Denmark was the first to sign,” she said.

Ms Pace warned that the UK should look to other European immigration models, like Spain’s, which she argues is less xenophobic and more 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 legal pathway that is safe for people to come here, build a life that is legal, that is safe, that is structured, that is organised?”

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More children will face deportation under Labour’s plan to crack down on asylum seekers, the Home Office has announced.

Families – including children – of failed asylum seekers will be offered financial support so they can return to their home country, the government has said.

Politics latest: Refugees may be deported to countries such as Syria

If they refuse that support, they will be forced to leave through deportation, according to the new policy, branded “restoring order and control”.

Home Secretary Shabana Mahmood said the “world has changed and our asylum system has not changed with it”, as she said 400,000 people have sought asylum in the last four years, with half of refugees remaining on benefits eight years after arriving.

She said the system feels “out of control and unfair” to the British public who foot the bill – and said the UK’s asylum offer is much more generous compared with “many of our European neighbours”.

The Conservatives generally welcomed the plans but several Labour MPs attacked the government, including Nadia Whittome who called them “dystopian” and “shameful”.

Former Labour leader Jeremy Corbyn, who is now an independent MP, said the plans are “not just paving the path to a Reform government, Reform may as well already be in power” and accused the government of having “no moral compass”.

The new plan says the asylum system currently does not prioritise the return of families, which means many families of failed asylum seekers continue to live in the UK “receiving free accommodation and financial support, for years on end”.

“Our hesitancy around returning families creates particularly perverse incentives,” the Home Office plan says.

It says asylum seekers are currently able to “exploit the fact that they have had children and put down roots in order to thwart removal”.

This includes about 700 Albanian families whose asylum claims have been rejected, but their removal is not being enforced because they have children.

The Home Office will launch a consultation on how it can deport families, including children.

Currently, families with children under the age of 18 at the point they are refused asylum continue to receive government support until the youngest child turns 18 – even if all appeals routes have been exhausted and they are refusing to be returned.

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Temporary refugee status

Also announced in the plan was that refugee status will be made temporary and a review will take place every two and a half years, with renewal only happening if returning to their home country is not possible.

Status could be revoked if a refugee’s home country is deemed safe.

The current five years to gain permanent settled status for refugees will be quadrupled to 20 years, but they could gain indefinite leave to remain sooner by working or studying.

This would replace the “golden ticket” five year deal, the government said.

There will be a consultation to see if benefits can be removed from refugees who are able to work but choose not to be employed.

European Court of Human Rights

Ms Mahmood said the government would change how UK courts interpret the ECHR so they can deport more foreign criminals and migrants who arrive illegally.

The government said Article 8 of the ECHR – the right to a family life – is being misused by migrants to delay their removal from the UK, with new legislation to make clear a family connection means only immediate family member – a parent or child. This could stop people from “using dubious connections to stay in the UK”, they said.

Article 8 rights will only be used in the most “exceptional circumstances” and where Article 8 claims can be lodged will be narrowed, so that all claims are heard first by the Home Office and not in a court.

The UK will also work with other European countries to review the application of Article 3 (prohibition of torture), as the government said the “definition of ‘inhuman and degrading treatment’ has expanded beyond what is reasonable”.

Ms Mahmood said the government wants to remain in the ECHR, but wants to reform it – while Reform and the Conservatives are calling to leave it entirely.

Visa bans

Ms Mahmood said the government has threatened visa bans on Angola, the Democratic Republic of Congo and Namibia unless they accept the return of illegal migrants and criminals from those countries.

Penalties could result in “VIPs and tourists alike” being blocked from entering the UK unless countries with visa bans take action.

Safe and legal routes

New safe and legal routes for refugees will be established “once the government has restored control of Britain’s borders”, the Home Office said.

Three routes will be established for refugees: a study route for displaced students, a skilled worker route and a named sponsorship route run by voluntary organisations.

A cap on how many of these visas will be granted will be determined by the home secretary.

Ms Mahmood added the UK “will always remain flexible to new crises across the world as they happen”.

MPs and bereaved families have launched a new campaign urging the government to re-think its position on introducing Graduated Driving Licences.

The event, in Parliament, came at the start of Road Safety Week and ahead of the government’s highly anticipated new road safety strategy, the first in a decade, which could be published next month.

Kim Leadbeater MP told the gathering that the idea for tougher rules for new drivers “transcends party politics” and could leave to “saving people’s lives”.

Organisations, including fire services, police and crime commissioners, motoring organisations as well as road safety charities, are behind a new website, “Protect Young Drivers: Time for Change”, which documents the case for introducing stronger measures.

Graduated Driving Licences (GDLs) is a system designed to give new drivers a staggered approach to gaining full privileges on the road, such as driving at night or with a full car of passengers.

The system has been successful in countries including Canada and Australia at reducing the number of young people killed or seriously injured.

“I feel as a bereaved parent we are very easily dismissed”

Last year 22% of fatalities on Britain’s roads involved a young person behind the wheel.

Data released by the Department for Transport also shows that male drivers aged 17-24 are four times more likely to be killed or seriously injured than all drivers aged over 25.

At the start of the launch a one minute silence was held to remember victims of road traffic accidents – including five young adults who died in a crash in Ireland on Saturday night.

Chris Taylor, who lost his 18-year-old daughter Rebecca in a road traffic collision in 2008, said the grief doesn’t go away.

“I feel as a bereaved parent we are very easily dismissed,” he said. “We’ve got an opportunity. Together we are a movement that can create real change.”

The Department for Transport has previously told Sky News it is not considering GDLs.

“Every death on our roads is a tragedy and our thoughts are with everyone who has lost a loved one in this way,” said a spokesperson.

“Whilst we are not considering Graduated Driving Licences, we absolutely recognise that young people are disproportionately victims of tragic incidents on our roads and continue to tackle this through our THINK! campaign.

“We are considering other measures to address this problem and protect young drivers, as part of our upcoming strategy for road safety – the first in over a decade.”