Home Secretary Shabana Mahmood delivered a speech this morning, vowing to implement a ‘firm but fair asylum system’ in the UK. Speaking in London, she emphasized that ‘restoring control at our borders is not a betrayal of Labour values’ and reiterated that the UK would ‘always offer protection to genuine refugees.’ The Home Secretary’s reforms have been heavily influenced by policies in Denmark, as the UK seeks to adopt a more stringent approach to immigration.

Greece’s Harsh Measures Against Irregular Migration

Greece has implemented some of the most stringent measures in Europe to curb irregular migration. In September 2025, its parliament passed legislation imposing prison terms of two to five years on asylum seekers whose claims were rejected if they failed to leave the country within 14 days. Financial penalties for undocumented migrants were also increased, reaching €10,000 for illegal entry and up to €30,000 for re-entry after a failed asylum claim.

The maximum detention period was extended from 18 to 24 months, and electronic ankle monitoring was introduced. Ahead of the law passing, Greek migration minister Thanos Plevris said the message was ‘clear’ for migrants: ‘If your asylum request is rejected, you have two choices. Either you go to jail or return to your homeland. The Greek state does not accept you … You are not welcome.’

In February 2026, Greece approved further measures strengthening penalties for facilitating irregular entry. The law removed a previous pathway that allowed undocumented migrants to apply for residence after seven years. It also increased the penalties for helping someone enter or remain in Greece irregularly, with prison terms of up to 10 years and fines of at least €50,000.

Hungary’s Embassy-Based Asylum System

Hungary has effectively eliminated access to asylum on its territory, replacing the traditional system with an embassy-based ‘declaration of intent’ procedure. Since May 2020, anyone seeking protection must first apply at a designated Hungarian embassy in a non-EU country, usually Belgrade in Serbia, before they can enter Hungary to lodge a formal claim.

From June 2020 to the end of 2023, official figures show only 99 declarations were submitted, with 21 applicants granted a single-entry permit. In 2023, only 30 asylum applications were recorded. European courts have repeatedly ruled that these measures violate EU asylum law.

In June 2024, the Court of Justice of the European Union (CJEU) imposed a €200m fine on Hungary for non-compliance with asylum rules, with a €1m daily penalty until the system aligns with the bloc’s rules. The court said Budapest’s actions amounted to an ‘unprecedented and exceptionally serious infringement’ and a ‘deliberate evasion’ of EU law.

Prime Minister Viktor Orbán defended the measures in 2024, arguing that they protect national sovereignty. He said Hungary will not accept ‘a single migrant’ under the EU’s new Migration Pact, scheduled to take effect in 2026, which obliges member states to share responsibility for asylum seekers.

Poland’s Border Policies and Human Rights Concerns

Poland has adopted a hard-line approach to asylum along its eastern frontier. Since March 2025, the Polish government has temporarily suspended the right to apply for asylum at the Belarus border. According to Amnesty International, this allows ‘border guards to disregard asylum applications without consideration for people’s individual circumstances’ and send them back across the border into Belarus.

The charity said that the law was ‘inconsistent and incompatible with international law and the Polish constitution, and poses a threat to the lives and human rights of people wishing to apply for asylum at the border.’

Poland has also strengthened its border security under its €2.5bn East Shield programme, which aims to tackle people smuggling and illegal migration, as well as protect Poland from aggression from Russia and its ally Belarus. A 5.5-metre steel wall runs along the 186-kilometre border with the two countries, reinforced with cameras, motion sensors, anti-tank ditches and bunkers.

Around this wall is a 78-kilometre-long buffer zone that restricts civilian, journalist and NGO access, while airspace restrictions limit private flights and drones. Internal enforcement has also intensified: deportations more than doubled in 2025 to over 2,100, and a nationwide operation in early 2026 detained 140 individuals with irregular status.

Italy’s Return Hub Model and Blockade Proposals

A cornerstone of Italian Prime Minister Giorgia Meloni’s strategy is the Italy-Albania ‘return hub’ model. Ratified in 2024, the agreement allows up to 3,000 asylum seekers at a time to be transferred to Italian-run centres near Shëngjin and Gjadër in Albania while their claims are processed under Italian jurisdiction.

Italian courts initially blocked transfers on the basis that Italy’s list of designated ‘safe countries of origin’ did not align with EU law and lacked sufficient protections. But in 2025, the European Court of Justice confirmed that national safe-country designations must meet strict legal standards and be subject to judicial review, clearing the way for the hubs to go ahead.

Meloni said last November: ‘Two years have been lost, but we are determined to move forward, and it will work.’ In February this year, draft legislation was also tabled, which would authorise the Italian navy to impose 30-day blockades on boats during periods of ‘exceptional migratory pressure’ or ‘serious threat to public order,’ renewable for up to six months.

Under the proposals, ships—particularly those operated by non-governmental organisations—could face fines of up to €50,000 and seizure if they repeatedly enter Italian territorial waters in violation of the blockade. The law still needs to be passed by the Italian parliament.

Denmark’s Influence on the UK’s Immigration Reforms

Denmark has shaped one of the toughest asylum systems in Europe, and the UK is hoping to take some inspiration from it. Rather than granting immediate permanent residence, most refugees in Denmark are given short-term permits of one to two years, which must be renewed regularly.

Only after an extended period—typically eight years of continuous residence—can someone become eligible for permanent status, and even then strict criteria still apply. The Danish government also operates ‘departure centres’ where asylum seekers are housed and encouraged to leave voluntarily.

The UK’s immigration policies are increasingly mirroring these approaches, as Home Secretary Shabana Mahmood continues to implement reforms aimed at tightening border controls and managing asylum claims more rigorously. The impact of these policies on both migrants and the broader European immigration landscape remains to be seen.