The UK’s Interest in the Danish Immigration and Asylum Model

Introduction
The Home Secretary, Mahmood, recently announced that she had dispatched a team of Home Office officials to Denmark to study the Danish immigration and asylum system. She praised Denmark’s apparent success in reducing the number of successful asylum claims and expressed her intention to model future UK measures on the Danish approach.

While the full details of the UK’s proposed reforms are yet to emerge, the focus is expected to be on individuals who have already been granted refugee status, with potential changes, reflecting Denmark’s restrictive and deterrence-based model.

Overview of Danish Asylum and Immigration Policy

According to the House of Commons Library Research Briefing (10 November 2025, No. 10391), the Danish asylum model is characterised by a series of restrictive and highly managed policies. Denmark has received fewer asylum claims per head of population than the UK in recent years, having reduced its asylum acceptance rate sharply since 2015, when a spike in applications from Syrian nationals temporarily increased the figures.

Since then, Denmark’s asylum rates have fallen significantly, while the UK’s have increased.

Key Policy Measures in Denmark

The Migration Policy Institute think tank and other observers have identified several notable features of Denmark’s asylum framework:

1. Short-term residence permits for refugees
2. Creation of “departure centres” to encourage voluntary return of refused asylum seekers
3. Tighter family reunification rules for recognised refugees
4. Confiscation of asylum seekers’ valuables to fund support
5. Exploration of offshore asylum processing arrangements, including with Rwanda

These measures signal a deliberate policy shift from promoting integration through labour market participation toward deterrence and containment.

Legal and Institutional Context

Denmark benefits from specific opt-outs under Protocol 22 of the Treaty on the Functioning of the European Union, meaning it is not bound by most EU asylum laws. However, it remains a participant in the Dublin Regulation (for transferring asylum seekers) and the Schengen Agreement (for passport-free travel). Consequently, some provisions of the EU Pact on Migration and Asylum will still apply.

Short-Term Residence Permits

Under Danish policy:

• Refugees are typically granted temporary residence permits of one to two years, reduced from the previous five-year standard.
• These permits are renewable but regularly reviewed, with revocation possible if the country of origin improves, even marginally.
• The path to permanent residence has become significantly tougher — the required qualifying period rose from five years to eight years.
• Earlier settlement is possible (after four years) only for those demonstrating sustained employment, income, and Danish language proficiency.

While designed to allow easier removal, once protection is no longer deemed necessary, this policy has created a legal limbo for some, notably Syrian nationals whose temporary protection has been revoked but who cannot safely return home. These individuals lose lawful status, housing, and access to employment or education, and must instead reside in state-run deportation centres offering only basic services.

Departure Centres

Individuals with no right to remain and who fail to cooperate with removal are required to live in departure centres.

• Residents receive no cash allowances and must eat in communal canteens.
• These centres function as both holding facilities and deterrence mechanisms, signalling to prospective asylum seekers that conditions in Denmark will be deliberately restrictive.

Family Reunification Restrictions

Refugees with temporary protection status have no automatic right to family reunification.

Offshore Processing Provisions

In June 2021, Denmark passed legislation allowing for asylum claims to be processed outside Europe.

• A 2022 joint statement with Rwanda confirmed exploratory discussions on such an arrangement, but no operational agreement has yet been implemented.
• The proposal mirrors aspects of the UK’s own Rwanda Partnership approach to externalising asylum responsibilities.

Confiscation of Valuables (“Jewellery Law”)

Under Section 40(9) of the Danish Aliens Act, asylum seekers’ assets exceeding approximately £1,200 may be confiscated to offset the costs of asylum support. This controversial measure has been criticised internationally but remains part of Denmark’s deterrence-based strategy.

Narrative and Political Strategy

The Clingendael Institute, a Dutch think tank, argues that Denmark’s “tough” asylum narrative has been politically effective in reducing applications. While only a small number of revocations and returns have actually occurred, the rhetoric of deterrence — emphasising confiscations, offshore processing, and temporary protection — has influenced migrant decision-making and shaped public perceptions.

As the report notes: “If you come to Denmark, we will take your valuables and place you in a remote centre while you await return. If you are granted protection, it is temporary. You will be sent home as soon as conditions allow.”

This deliberate projection of an unwelcoming state represents a conscious political choice rather than a purely administrative one.

Classification of Immigrant Housing Areas (“Ghettos”)

The Public Housing Act (2024 Consolidation) provides a four-level classification for housing areas, based on factors such as employment, education, income, and the share of non-Western residents.

Under the Public Housing Act (2024 Consolidation):

• Refugees living in designated public housing estates that risk becoming “parlour societies” are ineligible for family reunification, including through marriage.
• An area may be classified as a parlour society if more than 50% of residents are from non-Western backgrounds.
• There are four levels of classification for housing areas, based on criteria including social vulnerability and resident demographics.
• In “prevention areas,” housing cannot be allocated to individuals on benefits for more than two years or to non-EU nationals, though current residents are not affected.
• Children in vulnerable residential areas must attend day care from age one, and no more than 30% of children in a day-care centre may come from these designated areas.

Only parlour societies can be reclassified as “transformation areas,” where local councils and housing associations must develop formal plans to alter the area’s demographic composition and improve integration outcomes.

Implications for UK Policy

The UK’s interest in the Danish system suggests a potential shift towards more restrictive and conditional refugee protection, focused on temporary status, limited family rights, and integration controls, tied to residence and community composition.

If adopted, these measures could represent a significant redefinition of refugee protection under UK law, raising both legal and human rights considerations — particularly regarding compliance with the 1951 Refugee Convention and the European Convention on Human Rights.