The EU’s immigration asymmetry

Ten years after the Brexit referendum, the European Union continues to hope that Britain’s departure was an anomaly. Yet the vote revealed a structural weakness that has only become clearer with time: a borderless travel area cannot function sustainably when individual member states can unilaterally make large-scale admission decisions whose costs and consequences cross every internal border.

The decisive catalyst famously came in 2015. Angela Merkel’s government, confronted with a surge of asylum claims during the Syrian civil war, suspended the Dublin Regulation — the EU rule that normally requires asylum claims to be processed in the first member state an individual enters. Germany’s “wir schaffen das” policy saw over a million people arrive that year. What was presented as national compassion quickly became a European problem. The resulting secondary movements across the Balkans, Austria, Hungary, and France brought images of chaos into British living rooms.

Freedom of movement and Schengen are related but distinct. Freedom of movement is the core EU treaty right allowing citizens of member states to live, work, study and settle anywhere in the Union. The Schengen Agreement is a separate treaty that abolishes routine internal border controls among its 29 participating countries (most, though not all, EU members) while establishing common rules for the external frontier. 

Britain never joined Schengen, but as an EU member it was still exposed to the political and practical repercussions of Schengen-area policies on third-country migration. When one major participant, Germany, effectively opened the external door in 2015, the resulting waves of non-EU arrivals moved freely inside the zone, generating startling scenes that no British opt-out could block from the national debate.

Euroscepticism in Britain had deep roots — the euro, the European Court of Justice, the democratic deficit. But 2015 gave those arguments a visceral quality. Nigel Farage’s “Breaking Point” poster, showing a long queue of migrants with the slogan “The EU has failed us all,” captured a widespread sense that control over who entered Europe was slipping away from national electorates.

A decade later, the EU’s response has been largely technical. Frontex, the EU border agency, has been expanded. Bulgaria, for example, has received support for physical barriers, surveillance technology, and drone operations along its border with Turkey. The 2024 Migration and Asylum Pact, which begins applying from mid-2026, introduces faster asylum screening at the external border, stricter return rules, and a “flexible solidarity” mechanism. Under this, frontline states under pressure no longer face mandatory relocation of migrants; other countries can instead choose to pay into a fund, offer operational help, or support returns.

These are improvements at the margins, but they do not fix the core asymmetry. The EU has tools to punish a country that refuses to accept relocated migrants or take other associated measures. It has no effective mechanism to restrain a country whose generous admission or regularisation policies impose fiscal, social, or security costs on its neighbours.

That tension resurfaced in April 2026. Pedro Sánchez’s government approved the regularisation of roughly 500,000 undocumented migrants who had been in Spain for at least five months. Presented as an economic necessity to formalise workers and support an ageing society, it was a unilateral national decision, but one with clear implications for the rest of the Schengen area. France’s Marine Le Pen and Jordan Bardella immediately warned that mass legalisation in Spain would generate onward movement and political pressure further north. A similar outcry was raised by right-wing figures in Germany, Italy, and beyond. This is the inescapable logic of open internal borders: one country’s policy choice becomes every other country’s reality.

Nowhere was the original tension more starkly illustrated than in Hungary. Viktor Orbán built his European reputation by refusing the 2015 relocation quotas, erecting border fences, and arguing that compulsory “solidarity” could not substitute for democratic consent. His government was swept from power only weeks ago in the April 2026 elections by Péter Magyar’s Tisza party. Irrespective of Orbán’s broader record, the migration stance he championed still reflects a live political reality across much of the continent. Eurobarometer polls continue to show immigration among voters’ top concerns.

The EU’s design, however, makes the problem harder to solve. It enjoys the benefits of open internal borders while leaving most decisions about who enters Europe in national hands. When one state chooses openness, the downstream effects on housing, schools, welfare, and public order are shared; the decision itself is not. The Migration Pact’s shift to flexible solidarity is tacit recognition that compulsory relocation was politically unsustainable. That, it must be said, is a real legacy left behind by Viktor Orbán at the European level.

A serious response by the EU would acknowledge this externality head-on rather than wishing it away. At present, one member state can launch a major admission or regularisation programme, reaping the domestic political or economic credit while the fiscal, social, and security costs are dispersed across the entire Schengen area.

A genuine Schengen discipline mechanism would therefore impose clear procedural and financial guardrails. This could include mandatory prior notification to other member states and the Council for any large-scale regularisation or exceptional admission; independent impact assessments of likely onward flows, welfare burdens, housing pressure, and crime implications; temporary safeguard clauses allowing affected states to reimpose limited internal controls; and, crucially, automatic financial penalties. The initiating state could be required to make compensatory contributions to the EU budget or directly to burdened neighbours, or face graduated withholding of structural funds and cohesion payments until the costs are internalised. 

The EU … has still not resolved the contradiction Brexit forced into the open

Such tools would go some way to ensure that governments bear the real-world consequences of their choices within a shared borderless space. Whether this is politically feasible is more of an open question, but without some capacity to punish irresponsibility as well as reward compliance, the EU risks remaining trapped in the same cycle of unilateral action, resentment, and crisis.

Britain did not leave the EU solely over migration. But the 2015 crisis exposed with brutal clarity a deeper flaw: the EU had created a borderless lived reality without creating a mechanism capable of managing its external boundary in a way that commanded broad consent. Ten years on, the Union is somewhat better equipped at the edges, but it has still not resolved the contradiction Brexit forced into the open. Until it does, migration pressure will continue to reopen the sovereignty questions that Britain ultimately chose to settle by leaving.