Last week, the Labour government in Britain announced its intention to reform – again – its asylum system based on the Danish restrictive model. Both countries are led by centre-left governments and are shifting to the right on the issue of asylum in order to see off threats from far-right parties.
The Danish model includes demolishing housing where more than 50 per cent of residents are immigrants, predicating family reunification rights of refugees on financial resources and making refugee protection temporary. The first two initiatives are supposed to promote integration while the third actively prevents it, demonstrating the incoherence of the policies.
The UK seems to be considering the second two options. And in turn, Ireland’s Minister for Justice Jim O’Callaghan has signalled this country’s intention to mimic, at least to some extent, the UK model in order to prevent failed asylum seekers in the UK from taking advantage of the Common Travel Area and travelling onward to Ireland.
There is a lot to unpack in this race to the bottom.
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First of all, most of the Irish response is noise. Having opted into the EU Pact on Migration and Asylum − itself a response to the 2015 asylum “crisis” − refugee and subsidiary protection (protection for “war refugees”) status are already temporary. According to the Qualification Regulation, refugee status is granted for an initial three years and is renewable every three years, while subsidiary protection is granted for an initial one year and is renewable every two.
These periods are already ambitious in the sense that the duration of human rights-violating regimes and wars that cause mass displacement tend to be longer than a few years (consider, for example, the duration of the wars in Iraq, Afghanistan, Syria or Ukraine). And even when there is an official peace agreement or regime change, instability can rule out safe return for many years.
As for family reunification, the Irish system is already slow; so slow that when it comes to unaccompanied minors, many of them have aged out before they can apply and so they are no longer entitled to bring their parents or siblings here. But even if there were something to be gained (politically) from lowering standards, there would be something to be lost too. Having a stable status and family reunification are absolutely essential to integration.
Secondly, the Danish and UK (and now Irish) crisis narratives need to be examined. Certainly, the UK does have large numbers of boat arrivals and Ireland did also experience a large increase in asylum applicants a number of years ago. But the UK asylum figures are still a lot less than those in France, Italy, Germany and Spain. And although Ireland ranked 10 out of the EU 27 in terms of the numbers of asylum seekers hosted in 2024, our share of the EU total is just 1.8 per cent.
[ Asylum seekers should not view Ireland more favourably than UK, says O’CallaghanOpens in new window ]
The EU as a bloc hosted just over one million asylum seekers in 2024. Compare this with the almost 1.8 million refugees hosted by Uganda in the same period or the just under one million hosted by impoverished and flood-prone Bangladesh. Contrary to popular opinion, our numbers are not large.
Nonetheless, we firmly believe they are. This is due to the “politics of affect”, whereby people are encouraged to have a number of anxieties about immigration and asylum that the Government can then respond to. O’Callaghan gave a masterclass in the politics of affect this week when he offered asylum seekers’ abuse of the Common Travel Area as a reason to copy Britain’s proposed asylum retrenchment.
Indeed, the Common Travel Area – the absence of border control between Ireland and the UK – has always been used by Ireland as an excuse to mimic British immigration law. To give some examples: in 1922, Irish officials agreed to maintain British immigration law as a flanking measure because this was seen as the best way to control aliens; in 1962, Ireland adopted legislation to mimic the UK’s Commonwealth Immigrants Act – an act criticised in the Dáil as giving effect to “a most disreputable piece of colour bar legislation”, again, because of the Common Travel Area.
When Britain removed asylum seekers from the social welfare system in 1998 and placed them in privatised bed-and-board accommodation, the then-Irish Minister for Justice noted that “given that we maintain a Common Travel Area with the UK . . . a decision of this character by the UK has to be taken into account in a very serious way by any Irish Government.” This led to the introduction of the infamous direct provision system in 2000.
The crisis narrative on asylum masks a deeper crisis, or rather several interrelated crises. Owing to neoliberal economic policies pursued, especially since the collapse of the Celtic Tiger and the introduction of austerity, a huge inequality gap has opened up in Ireland. Key aspects of the welfare state, such as health, education and social housing, have been rolled back and even middle-income earners cannot afford to buy a house.
[ How the hardening of the UK’s immigration laws will affect IrelandOpens in new window ]
Rather than address the real root causes of political dissatisfaction in Ireland, it suits the Government to point to asylum seekers as the problem – something the far right is happy to capitalise on. However, this Government strategy is ultimately self-defeating: when centrist parties move to the right, this simply emboldens the right and the centre loses out.
The same forces of neoliberalism have also wreaked havoc in the Global South – on the so-called “refugee producing” countries. The economies and societies of many of these countries have been decimated by decades of structural adjustment policies; by global finance and trade rules which see money flowing from the Global South to the Global North (contrary to popular belief); by extractive and human-rights violating regimes that are propped up by beneficiary countries in the Global North; by international law rules that preserved colonial boundaries after independence, leading to numerous civil wars; and latterly, by climate change caused largely by industrialised countries in the Global North. These are the root causes of displacement. This is the real crisis.
Ciara Smyth is professor in the School of Law and Irish Centre for Human Rights at the University of Galway








