From Divergent Paths to Convergent Policies: A Comparative insight into the Dutch and UK Asylum Policies

This thesis investigates the domestic and transnational factors that drive restrictive asylum policy in the Netherlands and United Kingdom in 2024. In spite of the divergent institutional frameworks, the Netherlands' membership and alignment with EU asylum norms and the Brexit-driven unilateralism of the UK, both countries have opted for restrictive asylum policies by framing asylum seekers as national security, welfare and cultural risks. By using Kingdon's Multiple Streams Framework (MSF), this qualitative case study determines how populist political strategy, crisis frames, and transnational policy diffusion all came together to create ‘policy windows’ for restrictive policy reform. This thesis analyses legislative texts, party manifestos, media reports, and interviews with specialists and shows that restrictive policies are the outcome of convergence of three streams: (1) problem framing (e.g. crisis narratives), (2) policy emulation (i.e. copying transnational policy designs), and (3) populist electoral rhetoric (e.g. Netherlands’ PVV and UK Conservatives' and Reform party). The research findings show that asylum policy restrictiveness is not an inevitable outcome of structural problems, but is instead a politically constructed choice, driven by political agency and transnational interdependence. This thesis adds to the Multiple Streams Framework and refines the framework by linking transnational policy diffusion to the policy stream as a solution for domestic crises.