Five European Immigration Crackdowns, and How the UK's Asylum Overhaul Compares

Speaking in London this morning, Home Secretary Shabana Mahmood promised to build a "firm but fair asylum system". She argued that restoring control at the borders is not a betrayal of Labour values, and said the UK would always offer protection to genuine refugees. Her overhaul draws heavily on Danish policy, but Britain is far from alone in hardening its stance. The i Paper looked at five European countries and set each against what the UK does now.

Greece has moved some of the furthest. In September 2025 its parliament passed a law imposing prison terms of two to five years on asylum seekers whose claims fail and who do not leave within 14 days. Fines rose to €10,000 for illegal entry and up to €30,000 for re-entry after a rejected claim. Maximum detention went from 18 to 24 months, and electronic ankle monitoring was introduced. Migration minister Thanos Plevris put the choice bluntly: jail or return home. In February, Greece went further. It scrapped the route that let undocumented migrants apply for residence after seven years, and set penalties of up to 10 years in prison and fines of at least €50,000 for helping someone enter or stay irregularly. In the UK, entering or overstaying illegally is also a crime, but there is no fixed short deadline, and prosecutions usually target serious or repeated breaches.

Hungary has effectively shut off asylum on its own territory. Since May 2020, anyone seeking protection must first lodge a "declaration of intent" at a designated embassy outside the EU, usually in Belgrade, previously in Kyiv. Only then can they enter Hungary to make a formal claim. From June 2020 to the end of 2023, just 99 declarations were submitted and 21 applicants received a single-entry permit. Only 30 asylum applications were recorded in 2023. European courts have repeatedly found this breaches EU law. In June 2024 the Court of Justice of the European Union fined Hungary €200m, plus €1m a day until it complies, calling the conduct an "unprecedented and exceptionally serious infringement". Prime minister Viktor Orbán has defended the system as protecting sovereignty and said Hungary would not take "a single migrant" under the EU Migration Pact due in 2026. The UK, by contrast, accepts asylum claims from people already in the country, however they arrived.

Poland has suspended the right to claim asylum at its Belarus border since March 2025. Amnesty International says this lets guards ignore applications and push people back into Belarus, and calls it incompatible with international law and the Polish constitution. The €2.5bn East Shield programme adds a 5.5-metre steel wall along the 186-kilometre frontier with Belarus and Russia's Kaliningrad neighbour, fitted with cameras, motion sensors, anti-tank ditches and bunkers. A 78-kilometre buffer zone restricts civilians, journalists and NGOs, and airspace limits cover private flights and drones. Deportations more than doubled in 2025 to over 2,100, and a nationwide operation in early 2026 detained 140 people with irregular status. The UK neither suspends asylum at its border nor keeps exclusion zones.

Italy's centrepiece under prime minister Giorgia Meloni is the Albania "return hub" deal, ratified in 2024. It allows up to 3,000 asylum seekers at a time to be held in Italian-run centres at Shëngjin and Gjadër while Italy processes their claims. Italian courts first blocked transfers, finding Italy's list of safe countries of origin, which includes Egypt and Bangladesh, did not match EU law. In 2025 the European Court of Justice confirmed such designations must meet strict standards and face judicial review, clearing the way for the hubs. Meloni said last November: "Two years have been lost, but we are determined to move forward, and it will work." Draft legislation tabled in February would let the navy impose 30-day blockades, renewable up to six months, with fines up to €50,000 and ship seizure for repeat violators, mainly aimed at NGO vessels. It still needs parliamentary approval. Sea Watch and Doctors Without Borders say it targets those rescuing people in distress. The UK has no offshore centres or blockades; Labour dropped the Conservatives' Rwanda plan after the election.

Denmark is the model Britain is studying most closely. Most refugees get one- to two-year permits that must be renewed, and typically wait eight years of continuous residence before permanent status is possible. "Departure centres" house asylum seekers and encourage voluntary return; rights groups criticise their austere conditions. Authorities can take non-sentimental assets above a set value from refused applicants to cover accommodation, and welfare is tied to cooperation with return plans. Refugees must take intensive language and integration classes and show they are seeking work. Provisional figures put applications at about 1,800 in 2025, down from over 21,000 in 2015, roughly 91 per cent.

The UK's emerging reforms echo Denmark on temporary status with periodic review and integration conditions including English-language requirements, and it plans to allow seizure of non-sentimental assets from refused applicants. How closely Britain follows Denmark, and whether it faces the legal obstacles that met Hungary and Italy, will shape the debate ahead.