By Daniel Dunford, Kate Schneider and Michelle Inez Simon, Sky News Data x Forensics team
Publication Date: 2025-11-17 17:08:00
Home Secretary Shabana Mahmood has announced controversial plans for the UK to adopt a “Denmark-style” asylum system, aimed at making Britain less attractive to illegal immigrants and making deportations easier.
The hardline “zero asylum seekers” approach adopted by Danish Prime Minister Mette Frederiksen in 2019 was unusual for a centre-left party.
But its Social Democrats won seats in the 2022 election, while the right-wing populist Danish People’s Party finished in twelfth place, having been second in 2015 and third in 2019.
With Nigel Farage’s Reform UK comfortably leading the national polls, you can imagine why Labor is interested in what Ms Frederiksen is selling.
But to what extent are Denmark’s migration challenges comparable to those of the UK and what lessons can we draw from them?
Read more:
Reforms have been fairly quiet since Labor began exploring the Danish migration model, and here’s why
UK government analyzes Danish immigration model: here’s how it works
Latest in politics: Government publishes all asylum reforms, as Labor MPs attack plans
Reduced demand: Danish asylum applications decrease
The most obvious difference between Denmark and the United Kingdom is that Denmark is significantly smaller. Its population of 6 million is not much larger than that of Yorkshire. So it makes sense that it also has significantly fewer asylum seekers than Britain.
However, historically the number of asylum applications per person has been similar.
In the two years before Frederiksen was elected prime minister, Denmark received an average of 57 applications per 100,000 inhabitants, while the United Kingdom received an average of 55.
Since then, the UK figure has almost tripled to 145, while the Danish figure has fallen by a third.
The Danish story breaks the trend in the rest of Europe, where the number of asylum applications in all EU countries increased by two thirds during the same period.
Danish immigration experts say this is not a coincidence, but the result of Frederiksen’s policies.
“The numbers have gone down because Denmark is not a welcoming place,” Michelle Pace, professor of Global Studies at Roskilde University in Copenhagen, told Sky News.
“This was made absolutely clear by the government of Mette Frederiksen and the government before his,” he added.
A man walks through the door of a departure center for rejected asylum seekers in Jutland, Denmark, in March 2019. Photo: Reuters
In contrast, Mihnea Cuibus, a researcher at Oxford University’s Migration Observatory, told Sky News that the UK is often seen as an attractive country for migrants.
“There is a feeling among people that the UK is a safe and welcoming place,” he said, also listing several other factors that attract people to the UK, including the English language, existing networks of friends and family, and democracy.
Small boats versus visa overstayers: routes taken to Denmark and Great Britain
Much of the political attention surrounding illegal migration in the UK is devoted to those crossing the Channel from France in small boats. A total of 190,000 people arrived via this route since 2018, of which almost 40,000 in 2025 alone.
In Denmark, four out of five illegal immigrants identified in the country are people who previously held legitimate visas of limited duration, but stayed in the country longer than they should have.
It seems like it could be a significant divergence from the UK system, but perhaps not as much as you might think.
No new UK data has been published on this part of the system since 2020. But in the previous four years, 250,000 people were identified as potentially overstaying their visa, a number significantly higher than the number of people who arrived by small boat.
Cuibus said there is a big gap in the data, making trends harder to track.
“The only concrete data we have is about rejected asylum seekers,” he said.
“We know that about half of the people who have been refused asylum in the last 20 years are still in the country.”
How requests are handled
As well as attracting fewer asylum applications, Denmark is also now more likely to say “no” to applications than the UK, a reversal of the trend for most of the 2010s.
This appears to be because the UK has become less likely to reject applications in recent years, rather than a large increase in Danish rejections. Both the United Kingdom and Denmark granted asylum to large numbers of people from Ukraine during this period.
Cuibus told Sky News that between 2020 and 2023, the UK had some of the highest asylum granting rates in Europe.
The changes that Denmark introduced to its asylum policy between 2015 and 2019 did not significantly increase rejections of asylum applications, but instead made it more difficult for asylum seekers to remain in the country long-term.
The country also passed measures aimed at making it more difficult to apply for asylum, such as restricting family reunification and threatening to confiscate valuables, which also helped deter people from arriving.
Send people home
It’s one thing to turn away people who seek asylum, but it’s another to make sure those people leave safely and legally.
One of the mechanisms protecting migrants from unsafe removal is the European Convention on Human Rights (ECHR), which the UK (and Denmark) have signed up to, but which reformers say they would abandon if they came to power.
A key part of Ms Mahmood’s plans is to change the way 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 violated by being deported.
Denmark has been more successful than its European neighbors in expelling people it decided should leave. Between June 2021 and June 2025, 46% of the 10,000 people ordered to leave did so.
This is a significantly higher proportion than the EU average of 21%: 400,000 people were returned, of the 1.9 million who 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 has returned 86,000 people over a similar period, more than any other European country.
That figure has been increasing over the past two or three years, but is still 25% lower than in the early 2010s.
Voluntary Versus Forced Returns
Denmark’s asylum seeker removal policy is based almost exclusively on “voluntary returns”, rather than those “imposed” by authorities.
In the UK, the proportion of voluntary returns has risen steadily, but is still used for less than half of migrants leaving the UK.
“There are quite a few reasons for governments to prefer voluntary returns,” explained Mr Cuibus.
“The main reason why the Home Office started to move away from forced returns and towards voluntary returns… is money.”
“We don’t know exactly what the costs are at the moment, but we had some estimates from 2013. And at that time, they estimated that a forced return cost around £15,000 per person, compared to around £3,000 for a voluntary return.
“There is also the humanitarian aspect. Forced returns are not very pleasant things to go through, observe or have to enforce,” he said. “There is a great need for immobilization devices and trained personnel.”
People who are denied asylum can apply to the Danish government for the equivalent of several thousand pounds in help to voluntarily return to their country of origin, according to the Danish Return Agency’s website.
While still potentially cheaper for the government than a forced return, it is not always politically popular as it can be seen as rewarding illegality.
Some of the methods used by Denmark to encourage people to leave have also been criticised.
Asylum seekers who have their claims rejected can be detained in “exit centers,” prison-like facilities designed to encourage their voluntary deportation.
Kaershovedgaard, a former prison and now a release center in Denmark. Photo: Reuters
In 2024, the European Committee for the Prevention of Torture criticized one of these facilities for its “prison environment.”
Denmark’s parliamentary ombudsman described conditions elsewhere as “very onerous and restrictive of life” and “marked by brutalization.”
Michelle Pace, a professor at Roskilde University, said Denmark’s policies are a violation of international humanitarian law.
“Denmark prides itself on this negative brand, which is based on extremely harsh rhetoric, extreme choice of words,” Pace said, referring to some of Denmark’s most controversial immigration policies, such as the “jewelry law,” which allows the government to confiscate asylum seekers’ assets, including their jewelry, to fund their stay in the country.
“It is violating its international commitments under the 1951 Geneva Convention, which ironically Denmark was the first to sign,” he said.
Pace warned that the United Kingdom should look at other European immigration models, such as the Spanish one, which she said is less xenophobic and more progressive.
“In the Spanish case, they looked in terms of a long duration and said, okay, we have a low birth rate. We are going to have a huge labor shortage in the next 20 to 50 years.
“How can we create a legal path that is safe for people to come here, build a life that is legal, safe, structured and organized?”
He Data x Forensic The team is a multi-skilled unit dedicated to delivering transparent journalism from Sky News. We collect, analyze and visualize data to tell data-driven stories. We combine traditional reporting skills with advanced analysis of satellite imagery, social media and other open source information. Through multimedia storytelling we aim to better explain the world and at the same time show how our journalism is done.
