Two Systems, One Logic: The Deepening Convergence of UK and EU Migration Regimes

In recent months, we’ve been talking a lot about the deep shifts taking place in European migration policy. In previous articles, we unpacked what the EU Migration Pact will mean in practice once implemented, and we explored how detention, deportations, and the rising number of deaths and disappearances are not tragic exceptions but the predictable, devastating outcomes of a border regime that treats human lives as expendable.

Now, the first report on the Pact’s implementation has been released, claiming that it is already proving “successful” because the number of border crossings has decreased, However, this narrative tells us that the goal was never improving conditions for people trying to seek safety. By narrowly focusing on “reduced arrivals,” the report dismisses the human cost: increased externalisation deals, riskier routes, more pushbacks, and a growing reliance on detention and fast-tracked deportations. In other words, what is presented as progress is in fact the consolidation of a system that forces people into ever more dangerous conditions while allowing the EU to declare “victory”.

And while all of this is unfolding within the EU, the United Kingdom, driven by the same political logic, is pushing even further. The government is now in direct talks with Kosovo to establish return hubs, and it has introduced one of the most restrictive asylum changes in its recent history. The UK is strengthening its model of deterrence and externalisation that increasingly mirrors the path taken by the EU. In reality, neither is leading or following: they are reflecting and reinforcing one another, advancing a shared political project that treats the right to seek asylum as something to be minimised rather than upheld.

This article highlights the growing intersection between EU and UK policies - two systems that may be institutionally separate but are united by a common determination to deter, outsource and punish for seeking safety. And because the UK’s trajectory is becoming increasingly dangerous, we will slowly begin integrating systematic UK policy monitoring into our advocacy work. Too often, the UK is discussed as if it stands apart from Europe’s migration landscape. But it doesn’t. These policies feed off each other, legitimise each other, and intensify each other.

Externalisation and Return Hubs: Kosovo as a Testing Ground

The UK’s attempt to establish “return hubs” in Kosovo is not an outstanding experiment, but a direct reflection of the externalisation model that the EU has now embedded into its promised return policies. Just as the EU’s Return Regulation is going through the legislative process, the UK is seeking to replicate this approach by outsourcing responsibility to states at the edge of Europe with far weaker safeguards and limited accountability. Both the EU Return Regulation and the UK’s negotiations with Kosovo treat forced return and avoiding responsibility as the core objective.

Previously trying a similar Scheme with Rwanda, the UK has now entered into active discussion with Kosovo on the possibility of sending rejected asylum seekers there, once their appeals had been exhausted. The proposal mirrors the EU’s growing network of return agreements and externalisation deals: rapid removals, processing carried out beyond EU territory, and the creation of buffer zones where rights are harder to enforce, all essential parts of the new Pact on Migration and Asylum. The UK initiative to move forward with Kosovo can be seen as a projection on how return hubs might look like in practice, once the legislation has been approved.

Kosovo’s role and willingness to participate in migration externalization is not new. In recent years, the country has signed agreements with the United States and Denmark to host people due for deportation or to hold foreign nationals in facilities partly run by external authorities. These partnerships follow the same logic that underpins EU cooperation with Tunisia, Libya, Egypt, and others - delegating control of people on the move to states that have fewer resources, limited monitoring infrastructures, and reduced obligations under international law. Kosovo’s partial recognition on the international stage, and its non-ratification of several key human rights treaties, further weaken the protection environment for people who may be sent there.

This starkly parallels challenges arising within the EU’s return framework. The EU’s proposed Return Regulation will allow deportations and forced removals to contexts where safeguards are inadequate, where access to independent monitoring is restricted, and where people on the move face heightened risks of arbitrary detention, forced return, and ill-treatment. In both the EU and UK models, human rights concerns are treated as operational hurdles rather than fundamental constraints.

Civil society organisations and monitoring bodies have repeatedly warned that shifting people to countries with weaker protections creates predictable risks: limited access to legal assistance, poor detention conditions, a lack of transparency, and the real danger of people being removed onwards to places where their safety cannot be guaranteed. These concerns are not hypothetical; they mirror the documented outcomes of EU externalisation practices, from violent pushbacks to unlawful detention and forced returns carried out with little oversight.

The UK-Kosovo negotiations are therefore part of a much larger pattern. The UK is not diverging from the European model - it is amplifying it. Both systems rely on exporting responsibility to countries with less capacity, less scrutiny, and less accountability. Both present “reduced arrivals” or “increased return rates” as policy successes while obscuring the violence, deprivation, and rights violations these policies produce. And both advance a shared political project: to make access to protection increasingly narrow, conditional, and geographically distant.

What is unfolding is not a separation between UK and EU approaches but a convergence. Kosovo has become a testing ground for the UK’s externalisation ambitions in exactly the same way the EU’s Return Regulation will allow neighbouring states to absorb the human impact of its restrictive border regime. Together, they represent parallel systems of harm - systems that operate on the logic of disposability.

Introduction to the The UK’s Asylum Reform Package: A Parallel System of Deterrence

The UK’s latest reform was presented as “the biggest changes to tackle illegal migration in modern times”, and thus indicates a decisive move into the same deterrence-first model now entrenched in the EU Migration Pact. Branded as pragmatic, modern, and necessary, the reforms mirror a European trend where asylum is reframed not as a right but as a system to be restricted, rationed, and weaponized to deter people from seeking safety.

While the legislative architecture differs, the underlying logic is identical: temporary protection instead of safety, fast-track procedures instead of fair ones, criminalisation and exclusion instead of rights.

Below, we break down the UK changes and show how they reproduce the core machinery of the New EU Pact - detention, deportation, externalisation, narrowing protection pathways, and expanding state power.

Endless Uncertainty: The UK’s New Temporary Refugee Status

Under the reforms, refugee status in the UK becomes temporary by design. Individuals granted protection will only receive thirty-month residence permits, subject to repeated reassessments. This is not a policy oversight but a deliberate strategy to keep people in a state of chronic uncertainty, aligning closely with the EU’s shift toward “return-ready” systems. The reforms also extend the path to permanent residence from five years to twenty, transforming safety into a decades-long test of waiting. This policy choice undermines people’s ability to build a life and erodes a sense of belonging. As Motaz Amer highlighted in his BBC appearance, “Why would we make people wait 20 years before they can belong to a community and can call this place their home?” The UK’s temporary protection framework, therefore, does more than limit legal rights - it institutionalizes insecurity as a central feature of asylum.

During those twenty-years, the country of origin of people can be deemed safe, allowing for forced return. The UK government has already begun exploring forced returns to Syria - something unthinkable under international protection standards - mirroring an EU-level trend toward expanding “safe country” lists based on political convenience rather than actual safety. The EU Pact’s broadened use of “safe third countries” finds its UK counterpart in forced instability and uncertainty around which countries will suddenly become considered safe in the UK.

One Appeal for Overturning Asylum Decisions: Shrinking Access to Justice

The UK’s shift to a single consolidated appeal replaces a multi-stage system with a one-shot process that forces people to gather all grounds for applying for asylum at once. This structural compression replicates the EU’s own emphasis on speed over fairness in its border and accelerated procedures and the no appeal policy for decisions that have been made.

A new appeals body, staffed by government-selected adjudicators, risks replicating the systemic bias we already see in the EU where the initial screening of admissibility of applications will be screened at borders likely by police staff.

To enforce these changes, the UK plans to change how it interprets the European Convention on Human Rights applied to migration cases - narrowing Article 8 rights to family life and limiting Article 3 protections. This correlates almost exactly, the EU Pact's downgrading of procedural safeguards and its limited guidelines on how to interpret the Pact in relation to European Human Rights Law.

Withdrawal of Basic Support: Institutionalising Destitution

One of the most radical UK reforms is the removal of the legal duty to provide housing and financial support for asylum seekers. Support becomes conditional, punitive, and revocable - aligned with the EU’s expanded grounds for withdrawing reception conditions.

In the UK with the proposed changes, people who “make themselves destitute” can be denied assistance. Further, those permitted to work but unable to find employment may lose housing and families with refused asylum claims will no longer be guaranteed shelter until their youngest child turns 18. On top of all of this, assets such as jewelry can be seized to pay for accommodation.

These measures normalize destitution as a tool of migration control - exactly the same logic underpinning the EU’s increased use of detention, restricted movement, and punitive reception withdrawal.

Visa Bans and Coercion: Exporting the UK’s Border Beyond Its Borders

The reforms empower the UK to impose visa sanctions on countries that refuse to accept deportees - mirroring the EU’s externalisation deals and coercive leverage over visa policy. Specifically, Angola, Namibia, and the Democratic Republic of Congo have already been put on notice, whether to cooperate with forced returns or face restrictions. This forced return does not exclude full families and children.

This is externalisation through pressure rather than partnership - another common thread with the EU Pact’s deals with Tunisia, Libya, Egypt, and Mauritania, where returns and containment are demanded in exchange for political or financial incentives.

A Convergence, Not a Contrast: How the UK and EU Systems Reinforce One Another

When examined closely, the UK’s reforms do not diverge from the EU Migration Pact - they echo and reinforce it. Both systems replace stable protection with temporary statuses intentionally designed to keep people “return-ready,” undermining long-term security and transforming safety into a revocable condition rather than a right. They share a procedural architecture built around acceleration: single-step or truncated processes that limit appeals, erode procedural fairness, and expedite removal rather than protection. In practice, this is complemented by an expanding use of detention, border-zone containment, and legally induced destitution as tools of control, blurring the line between border management and punishment.

The UK and EU also converge in their reliance on externalisation. Each is increasingly outsourcing responsibility through return agreements, leveraged visa policies, and partnerships with countries that have fewer safeguards and weaker monitoring frameworks. Both systems invent and rely on new, politically convenient categories of “safe countries” - classifications often disconnected from the lived realities of people who are forced to flee.

Underlying these mechanisms is a shared logic: making life difficult enough that people stop trying to come. Neither the UK nor the EU is leading and neither is following; instead, they are co-producing parallel systems of deterrence shaped by similar political incentives and legitimised by each other’s actions. Where the EU normalises detention, the UK normalises destitution. Where the EU embeds externalised processing into its legal framework, the UK pursues return hubs in Kosovo. Where the EU accelerates removals through the Pact, the UK rewrites human rights protections to speed deportations. Although the institutional structures differ, the effect is the same: a systematic erosion of the right to asylum.

As both systems move toward implementation, the stakes could not be higher. The logic of disposability has moved from the margins to the centre of policy. Our task, therefore, is not only to document these developments but to challenge them, and to insist on systems rooted not in deterrence and exclusion but in rights, dignity, and shared humanity.

Words by Anna Gruber, Advocacy Manager

Collective AidNovember 19, 2025