When ministers want a restrictive policy to look ordinary, a foreign precedent can be useful.
France has minimum service requirements during strikes. Canada asks voters to prove their identity. The Netherlands is preparing for later retirement. Denmark treats refugee protection as temporary.
All of those statements can be true. None is a complete comparison.
Policies do not exist alone. They operate inside systems of law, taxation, public services, employment rights and administrative support. Taking one rule from another country tells us little unless we also examine what surrounds it.
Yet in several major British policy debates, the foreign example has been reduced to the feature that makes life harder.
The rest of the system has been left behind.
Minimum service laws were not the whole European system
In January 2023, the Conservative government said its proposed strike legislation would align Britain with countries such as France and Spain. Ministers also cited Italy and other countries as evidence that minimum service requirements were a normal way to protect public services during industrial action.
The Strikes (Minimum Service Levels) Act 2023 allowed employers in specified services to issue work notices identifying employees required to work during a strike.
Workers named in those notices risked losing automatic protection against unfair dismissal if they continued to strike. Trade unions could also lose legal protection if they failed to take the required steps to secure compliance.
But minimum service arrangements differ substantially between countries.
House of Commons Library research found that France and Italy protect the right to strike within their national constitutions. It also found that European minimum service systems vary in their scope and legal basis, and that most provide some role for dialogue and negotiation with trade unions when services are set.
That wider context mattered.
The proper question was not simply whether France or Spain had minimum service requirements. It was who set those requirements, how disputes were resolved and what legal protection remained for industrial action.
Those details received much less attention than the existence of the restriction itself.
The British Act was repealed by the Employment Rights Act 2025, with the repeal taking effect at Royal Assent in December 2025.
Its short life nevertheless exposed the method clearly. A European restriction was cited as evidence that Britain should act. The rights and negotiating structures surrounding that restriction were not given equal weight.
Voter identification depends on the system around it
Foreign precedent was also central to the argument for photographic voter identification.
Government ministers pointed to Canada, the Netherlands and other established democracies where voters already had to establish their identity. Britain, they argued, was unusual in not requiring it.
But the cited countries did not all operate the system Britain introduced.
Canada accepts a wide range of documents. A voter without accepted identification may make a written declaration and have another eligible voter who knows them confirm their identity and address.
The Netherlands operates within a broader compulsory-identification system and issues national identity cards as well as passports and other official documents.
Britain did create a free Voter Authority Certificate for people without accepted photographic identification. That safeguard matters and should not be ignored.
It was, however, a separate document requiring an application. It was not identification already routinely held through a national system.
Before the 2024 general election, more than 210,000 applications for certificates had been made, but only around 26,000 certificates were used.
The requirement was intended to prevent personation: voting while pretending to be somebody else. The Electoral Commission had found no evidence that electoral fraud was widespread. Only a handful of alleged personation cases were reported during the five years covered by the latest Commons Library briefing, resulting in two convictions and two cautions, all in 2021.
At the 2024 general election, at least 50,000 people were initially refused a ballot because they lacked accepted identification. Around 34,000 returned with the necessary document. Approximately 16,000 did not return to cast a ballot.
The impact was not uniform. The clearest disproportionate effect was among people in lower social grades. Disabled and unemployed people were also more likely than the general population to report difficulty producing accepted identification.
The foreign comparisons showed that identification could form part of a democratic voting system.
They did not prove that Britain had reproduced the same identification infrastructure, accepted documents or fallback routes.
The checkpoint was borrowed. The route through it was different.
Retirement age is not a pension system
In 2017, the government defended increasing the State Pension age by pointing abroad.
The then Work and Pensions Secretary, David Gauke, cited increases in the Republic of Ireland, the Netherlands and Denmark, saying that raising the pension age was what “responsible Governments” did.
Britain’s State Pension age is now rising from 66 to 67 between 2026 and 2028.
But retirement age is only one part of a pension system.
The income received after retirement, the coverage of occupational pensions, taxation, support for low earners and the options available to people unable to remain in work all affect what a higher pension age means.
The Organisation for Economic Co-operation and Development’s 2025 modelling shows the scale of the difference.
For an average earner completing a full career, the projected net pension replacement rate was 96 per cent in the Netherlands and 54.2 per cent in the United Kingdom. The measure compares expected pension income with previous earnings after taxes and social contributions. It includes mandatory public and private provision and models each country’s system at its normal retirement age.
These are not current State Pension payment rates, and they are not a simple comparison between two individual benefits. They represent the wider pension arrangements into which workers are expected to contribute.
That is exactly why citing pension ages alone is inadequate.
The Netherlands was relevant when ministers discussed how long people should work. Its stronger modelled retirement income was not part of the policy being imported.
Nor does longer average life automatically mean that people can remain healthy and employed for longer.
In 2022 to 2024, healthy life expectancy at birth in the United Kingdom was 60.7 years for men and 60.9 years for women, the lowest figures recorded since the current series began in 2011 to 2013.
Healthy life expectancy at birth does not predict the exact age at which an individual will become ill, nor does it measure a 66-year-old’s remaining healthy life. It does show why rising longevity cannot be treated as proof that everyone has gained additional healthy working years.
The consequences of a later pension age depend on the work a person has done, their health, their income and whether they have private or occupational savings.
A complete foreign comparison would examine those conditions as seriously as the statutory age.
Denmark was copied selectively
The present Labour government has used the same technique in asylum policy.
Its November 2025 policy statement explicitly named Denmark as the model for making refugee protection temporary:
“Just like in Denmark, refugee status becomes temporary.”
For asylum claims made from 2 March 2026, adults granted refugee status or humanitarian protection normally receive an initial period of 30 months rather than the previous five years. Their need for protection can then be reviewed.
Denmark therefore supplied a direct precedent for reducing the security attached to refugee status.
But Denmark also allows adult asylum seekers to apply for permission to work once six months have passed, provided that their identity has been established, Denmark has accepted responsibility for considering the claim and other conditions are met. Permitted employment must comply with normal pay and working conditions.
Britain normally allows an asylum seeker to apply for permission to work only when an initial decision has been outstanding for more than 12 months through no fault of the applicant.
For applications made from 26 March 2026, permitted jobs are restricted to occupations at Regulated Qualifications Framework level 6 or above. Dependants cannot obtain permission through the same provision.
The comparison must be stated carefully.
Denmark does not give every asylum seeker an immediate or unrestricted right to work. Its route is conditional and requires official approval.
Britain nevertheless followed Denmark when introducing shorter and less secure refugee protection, while retaining a later and narrower route into employment.
The restrictive part of the Danish system was treated as a model. The part that allowed earlier economic participation was not.
This is not confined to one party
Three examples in this article came from Conservative governments: minimum service levels, voter identification and the pension-age argument.
The Danish-inspired asylum changes came from Labour.
The parties are not identical, and their wider policies should not be treated as though they are.
The common feature is the political usefulness of a foreign precedent.
A minister could say:
We have chosen to reduce this right or increase this obligation.
It is usually easier to say:
Other respected countries already do this.
The second version makes a political choice sound like routine modernisation. It shifts the argument away from whether the policy is justified and towards why Britain should remain different.
But the appearance of international agreement is created by deciding which part of the foreign system counts.
What a proper comparison would ask
Britain should learn from other countries. Rejecting foreign evidence would be insular and wasteful.
The problem is not comparison. It is incomplete comparison.
Whenever another country is offered as a model, the public should be told:
- what problem the policy was intended to solve;
- how serious that problem was;
- which rights the policy restricts;
- which safeguards surround it;
- who writes and enforces the rules;
- how decisions can be challenged;
- what public infrastructure makes the policy workable;
- what measurable results it has produced;
- who bears the cost when it fails;
- which parts of the foreign system Britain has decided not to copy.
Without those questions, “other countries do it” can become political camouflage.
The four cases examined here do not prove that every international comparison made by a British government is selective or dishonest.
They establish a narrower pattern.
European minimum service laws were cited without equal attention to constitutional rights and negotiation.
Foreign voter-identification requirements were cited without reproducing the same identification systems or fallback routes.
Higher pension ages were cited without equivalent attention to retirement income and unequal working lives.
Denmark’s temporary refugee protection was copied while its earlier route into employment was not.
Britain does not always import the worst or reject the best.
But when a foreign restriction is presented as common sense while the protection surrounding it is treated as irrelevant, unaffordable or unsuitable, that is what the result looks like.
Britain imports the worst and leaves the best behind.