- 1 Hobolt, S. B., “The Brexit Vote: A Divided Nation, a Divided Continent”, Journal of European Public (...)
1The issue of immigration control, particularly the free movement of EU citizens, was a central topic during the Brexit referendum1. Leave campaigners’ discourse often framed free movement as a threat to national sovereignty, especially concerning access to British public services and welfare.
- 2 Bale, T., “Centre-right Parties and Immigration in an Era of Politicisation”, European Journal of P (...)
2Previous research has examined public and political representations of immigration in the United Kingdom, notably public perceptions of free movement. According to Bale, the immigration issue was politically instrumentalised by Leave campaigners during the 2016 referendum campaign, shaping electoral and social attitudes toward the mobility of European citizens and institutions2.
- 3 Dennison, J., & Geddes, A., “Brexit and the Perils of ‘Europeanised’ Migration”, Journal of Europea (...)
3Drawing on this perspective, Dennison et Geddes analysed the impact of Brexit on the perception and management of migration in the UK regarding European citizens, showing that the exploitation of negative attitudes by Eurosceptic actors contributed to support for Brexit and to the shaping of post-Brexit immigration policies3.
- 4 Entman, R. M., “Framing: Toward Clarification of a Fractured Paradigm”, Journal of Communication, 4 (...)
- 5 Carstensen, M. B., & Schmidt, V. A., “Power through, Over and in Ideas: Conceptualizing Ideational (...)
4These studies highlight the central role of political discourse in legitimising migration policy, particularly through interpretive frames, defined as cognitive (beliefs about what is possible or effective) and normative (values and principles that determine legitimacy) structures employed to define problems, structure debates and justify policy decisions4 and call for an analysis of how post-Brexit migration reforms have been designed and justified using these frames. This study draws on the concept of ideational power, referring to actors’ ability to influence policy through ideas and discourse5.
5These concerns shaped public attitudes during the Brexit referendum and post-Brexit British immigration policy, notably through restrictive measures limiting European mobility and ending EU citizens’ preferential access to social rights. However, despite the end of free movement between the UK and the EU and the introduction of a points-based immigration system on 1 January 2021, debates on the effectiveness of post-Brexit immigration policies have continued.
- 6 McKeon, C., “Tories warn of voter anger as net migration hits new record of 606,000”, The Independe (...)
- 7 McKeon, C., “PM announces overhaul of immigration system as net migration hits 906,000”, The Indepe (...)
6With net migration remaining high, reaching a record of 606,000 in 2022, Prime Minister Rishi Sunak acknowledged that post-Brexit reforms had not yet succeeded in controlling migration flows, describing levels as “too high” and pledging further reductions6. Immigration remained politically contested with Keir Starmer in November 2024 criticising the Conservative approach, arguing that rising net migration levels amounted to “a one‑nation experiment in open borders” pursued through reforms that liberalised immigration rather than reduced it7.
- 8 UK Government, Restoring Control over the Immigration System: White Paper (CP 1326), London, 12 May (...)
7In 2025, immigration remained a highly contested issue in the UK. At a press conference in May 2025 on the Immigration White Paper, Prime Minister Keir Starmer acknowledged that control had not been achieved, stating: “It was the complete opposite… That’s not control. It’s chaos… net migration quadrupled. By 2023, it had reached nearly 1 million8.”
8This statement illustrates the Labour government’s rationale for introducing new regulatory frameworks to strengthen immigration controls while also highlighting the tension between tightening restrictions and preserving the rights of EU citizens. Although previous Conservative governments adopted stricter rhetoric and increasingly restrictive immigration policies, the current Labour government has pursued a more nuanced strategy, implementing both restrictive regulations and targeted measures for certain groups. While extending residency periods, raising skill and language requirements and reducing post-study visa durations, it has preserved the rights of EU citizens already holding Settled Status and seeks to establish the Balanced Youth Experience Scheme facilitating short-term mobility for young migrants9. This approach combines stricter regulations with targeted support, aiming to reinforce controls over EU migration while simultaneously maintaining protections for existing EU residents. While freedom of movement for European citizens in the UK officially ended with Brexit, the Labour government has indicated that it does not intend to relax entry conditions for EU mobile citizens, nor to reverse the EU Settlement Scheme (EUSS). On the contrary, it aims to tighten eligibility criteria, illustrating the continuing tension between tightening immigration policy and maintaining the rights of EU nationals.
- 10 Taggart, P., “A Touchstone of Dissent: Euroscepticism in Contemporary Western European Party System (...)
- 11 Brubaker, R., Citizenship and Nationhood in France and Germany, Cambridge, MA: Harvard University P (...)
9Brexit has led to a reconfiguration of domestic migration policies, raising questions about how political discourses, particularly Eurosceptic perspectives challenging EU authority10 and nationalist discourses emphasising national membership and differentiated rights11, help to legitimise political decisions and affect the rights and socio-economic conditions of EU mobile citizens.
10This article builds on previous studies and examines the extent to which Brexit has transformed the conditions of residence, work and free movement for EU nationals in the UK and how political discourse on free movement and social rights has influenced post-Brexit immigration policies and socio-economic outcomes for EU citizens. Previous research has documented the legal and institutional consequences of Brexit, including the end of free movement and the introduction of the EU Settlement Scheme and the points-based immigration system, but has paid less attention to the role of political discourse in shaping these reforms and their social effects.
11Drawing on discursive neo-institutionalism
12, this study analyses how political discourses centred on the reassertion of sovereignty over EU citizens' mobility and access to the British welfare state have been mobilised to legitimise post-Brexit immigration policy change. It examines how cognitive and normative ideas are mobilised by political actors to justify new regulatory frameworks and normalise differentiated access to rights among EU nationals. This framework highlights the role of ideas and discourse in policy-making and the inequalities they generate and focuses on actors involved in the formulation, institutionalisation and legitimation of these policies, including state actors, political parties and pro-Brexit advocacy groups.
- 13 Entman, Framing: Toward clarification of a fractured paradigm, 1993; Schön & Rein, Frame Reflection(...)
12Methodologically, the article investigates how political discourses shape policy outcomes through the analysis of policy frames, defined as ways issues are interpreted, constructed as problems and linked to norms or causal explanations13. By examining the role of cognitive and normative ideas in justifying new migration regulations, the study also assesses the social effects of these discourses on migration policy reforms affecting European mobile citizens. This reterritorialisation of migration governance involves a redefinition of access to rights and the establishment of a differentiated model of citizenship for EU nationals, who have been recategorised as migrants subject to new regulatory frameworks and restrictions on social rights.
13This article contributes to the literature by examining how political discourse has shaped the redefinition of EU citizens’ rights in the UK after Brexit, by linking discursive frames to specific policy outcomes. By combining discourse analysis with an analysis of post-Brexit migration reforms under both Conservative and Labour governments, it sheds light on the persistence of sovereignty-centred and welfare-conditional frames legitimising state-led selection mechanisms and restrictions on EU nationals’ rights. After examining Conservative discourse and policy, the discussion turns to the Labour government’s approach, assessing continuities and departures in framing strategies and policy implementation. This demonstrates that changes in political leadership have not fundamentally reoriented migration governance, but rather in the consolidation of a restrictive and conditional approach to EU migration maintained across the political spectrum following Brexit.
14The first section presents the theoretical framework and literature review, providing the conceptual and analytical tools for understanding post-Brexit migration policy. The second section examines the role of political discourse in shaping post-Brexit migration policies, focusing on the period immediately following the 2016 referendum until 2019. It identifies the main discursive frames that have structured debates on immigration, with particular attention to post-Brexit conservative discourse. By analysing the rhetorical strategies mobilised in the discourse, this section demonstrates how discourse influenced immigration policy decisions. The third section examines how these frames have been translated into specific migration policies, emphasising both continuity and change from 2019 onwards. This section also analyses Labour’s post-Brexit discourse and policy through the frames of sovereignty, welfare and social justice and national identity and evaluates their effects on EU mobile citizens’ rights. The article concludes by demonstrating the influence of ideas and political rhetoric on the creation and legitimation of migration policy.
15The analysis shows that post-Brexit migration governance in the UK reflects strong cross-party continuity, with both Conservative and Labour governments relying on similar frames of sovereignty, welfare conditionality and merit-based inclusion to shape and legitimise restrictive reforms affecting EU nationals’ residence and social rights.
- 14 Schmidt, “Discursive Institutionalism”, 2008; Schmidt, V. A. Taking ideas and discourse seriously: (...)
- 15 Entman, Framing: Toward clarification of a fractured paradigm, 1993.
- 16 Schön & Rein, Frame Reflection, 1994.
- 17 Carstensen & Schmidt, “Power through, over and in ideas”, 2016.
16Drawing on discursive institutionalism as developed by V. Schmidt14 and the concept of frames,15 this section explores how institutional change and political decision-making are shaped and legitimised through ideas embedded in discourse. Within this framework, discourse is a means through which actors construct meaning, frame problems and justify policy solutions16. Discursive institutionalism thus provides a powerful framework for critically analysing how ideological positions and discursive strategies shape legislative outcomes and affect EU mobile citizens, revealing the performativity of discourse in defining membership, rights and inclusion. To provide a more comprehensive understanding of post-Brexit migration dynamics, this article draws on the concept of ideational power, defined by Carstensen and Schmidt as actors’ ability to influence others’ normative and cognitive beliefs, establishing hegemony over ideas deemed legitimate or acceptable17.
- 18 Jobert, B., “The Normative Frameworks of Public Policy”, Political Studies, 37(3), 1989, pp. 376–38 (...)
- 19 Schmidt, “Discursive Institutionalism”, 2008.
- 20 Schmidt, “Discursive Institutionalism”, 2008; Hajer, M. A., The Politics of Environmental Discourse (...)
- 21 Hajer, The Politics of Environmental Discourse, 1995.
17This research focuses on the cognitive and normative representations conveyed by political actors which shape both decision-making processes and governmental action. The aim is therefore to analyse how migration policies concerning European Union citizens were constructed discursively through guiding frames18. Frames function as cognitive and normative structures that guide perception, mobilise support, justify decisions and facilitate institutional change19. Within discursive institutionalism, frames are not just perceptions, but strategic instruments to legitimise policies20. As highlighted by Hajer, framing entails both a performative and a strategic dimension in the construction of discursive coalitions and policy legitimacy21. Following this conceptual discussion of frames, the next section examines existing research on how political discourse has shaped public perceptions and policy regarding EU mobility post-Brexit.
- 22 Markova, E., & King, R., “Leave or Remain? The Post-Brexit (Im)mobility Intentions of EU Citizens i (...)
- 23 Bale, T., “Policy, Office, Votes—and Integrity: The British Conservative Party, Brexit, and Immigra (...)
18Since the 2016 referendum, Brexit has prompted extensive scholarly research examining the politicisation of migration and how political and media discourse shaped public perceptions of EU mobility in the UK22. Much of the existing literature highlights how anti-immigration rhetoric during the referendum campaign framed free movement as a problem associated with welfare competition, loss of sovereignty and limited border control contributing to the politicisation of migration as a central electoral issue23.
19During the referendum period, migration discourse drew on ideological frames such as national sovereignty and the welfare state while also creating new interpretive frames responding to the perceived “massive” inflow of EU citizens, shaping debates on free movement and Britain’s EU membership and defining acceptable policy solutions. It thus provided a discursive justification for legislative and policy changes affecting intra-EU mobility.
20Scholars have also analysed how these discursive dynamics translated into post-Brexit institutional and legal reforms affecting EU mobility.
- 24 Portes, J., Between the Lines: Immigration to the UK Between the Referendum and Brexit, Brexit Inst (...)
- 25 Hampshire, J., After Brexit: Immigration and the UK, Oxford: Oxford University Press, 2024.
- 26 Sobolewska, M., & Ford, R., “British Culture Wars? Brexit and the Future Politics of Immigration an (...)
- 27 Portes, J., “Immigration and the UK Economy After Brexit”, Oxford Review of Economic Policy, 38(1), (...)
- 28 Dennison & Geddes, A., “Brexit and the Perils of ‘Europeanised’ Migration”, 2018.
- 29 Morris, M., & Roy, R., Go West: Bristol and the Post-Brexit Immigration System, Institute for Publi (...)
- 30 Oliver, T., “Reflections: The UK After Brexit”, International Politics, 57(6), 2020, pp. 689–707. h (...)
- 31 McGovern, P., “Five Problems with UK Immigration Control Post-Brexit”, LSE Brexit, 2016. https://re (...)
- 32 Giovannone, M., “Brexit and Social Safeguards for EU Citizens in the UK: The Agreements’ Rules and (...)
21The framing of migration in public discourse was translated into legislative reforms : post-Brexit UK legislation ended free movement for UK and EU citizens, first through the EU Settlement Scheme, which granted settled or pre-settled status to existing residents and maintained certain social rights and later through a points-based immigration system for all migrants, establishing new entry criteria based on skills, wages and sectoral priorities24. Although these reforms were framed as restoring national sovereignty over border control, scholars such as Hampshire emphasise their contradictory outcomes: immigration levels remained high due to the liberalisation of work and student visa regimes and the creation of new humanitarian routes, reflecting the ambivalent and unresolved meanings of Brexit25. Recent post-2020 research has further highlighted the socio-economic effects resulting from these immigration policy changes in the United Kingdom26: the reduction in EU migration has generated labour shortages in key sectors of the British economy previously dependent on EU workers, notably agriculture, construction and social care27. Other studies also demonstrate that the post-Brexit nationalist approach to migration policy, explicitly aimed at curbing migration flows from the EU, has proved difficult to pursue in a globalised context28. These analyses highlight that the concerns expressed by UK employers regarding restrictions on EU workforce mobility29 reveal the tensions between the UK’s national immigration control objectives and its commitments under international law, including from bilateral agreements with the EU30, showing the challenge of balancing domestic goals with international obligations. Earlier studies also examined the consequences of post-Brexit British immigration policy for EU citizens’ status and rights31. Giovannone highlights that these changes significantly affected economically vulnerable EU nationals, particularly regarding settlement, citizenship entitlements and access to social welfare32.
- 33 Sahin-Mencutek, Z., Barthoma, S., Gökalp-Aras, N.E., et al., “A Crisis Mode in Migration Governance (...)
- 34 Schmidt, V. A., Democracy and legitimacy in the European Union revisited: Input, output and ‘throug (...)
- 35 Dennison & Geddes, Brexit and the Perils of ‘Europeanised’ Migration, 2018.
- 36 Schmidt, “Discursive Institutionalism”, 2008; Schmidt, Taking ideas and discourse seriously, 2010.
- 37 Bale, T., Political Parties and Immigration Policy in Europe: Party Politics, Public Opinion, and P (...)
22Even though post-Brexit migration policies and public debate have been widely studied, several issues remain underexplored. While many studies acknowledge the importance of political discourse, few critically examine the relationship between political discourse and policy outcomes, particularly how discursive frames on EU mobility shape post-Brexit immigration policy and EU citizens’ rights in the UK. Some scholars argue that in times of crisis, political narratives shape and legitimise policy decisions rather than simply describing them33. Others show that discourse plays an active role active in shaping institutional choices and policy solutions34, demonstrating how post-Brexit reforms selectively restructure mobility and rights for EU citizens35. Building on this gap and the neo-institutionalist literature on ideational power36 and framing in migration policy37, this study examines how post-Brexit political discourse not only justified but shaped immigration policies, which in turn affected the legal and social status of European citizens in the UK. This article considers political discourse as a key factor that, through cognitive and normative frames, shapes post-Brexit immigration policy and produces differentiated outcomes for EU citizens. Building on previous research, this study explores new aspects by showing that political discourse shapes policy rather than merely legitimises it and by demonstrating that Brexit led to a selective stratification of EU mobility, affecting both legal rights and social outcomes for EU nationals.
23Building on this framework, this study adopts a qualitative methodology combining discourse analysis and policy analysis. Policy analysis is understood as the systematic examination of how discursive constructions are translated into operational policy instruments, laws and their implementation by administrative authorities. This choice enables the examination of both the symbolic construction of migration issues and their translation into institutional arrangements. The corpus includes official documents, post-Brexit legislative texts, parliamentary debates, policy reports, political speeches and public statements by government actors. The corpus was constructed through a carefully selected set of texts produced between 2016 and 2025, corresponding to key moments of post-Brexit migration policy reform. Texts were selected for their relevance to EU citizens’ mobility, social benefits and immigration control. First, discourse analysis identifies recurrent rhetorical strategies and frames mobilised in discourses on EU free movement, showing how the legitimacy of the British immigration system is constructed. This analysis focuses on how political actors frame EU mobility and justify specific policy orientations regarding rights and welfare. Second, policy analysis examines the effects of these discursive strategies on British immigration policy and assesses their impacts on EU mobile citizens.
- 38 Entman, Framing: Toward clarification of a fractured paradigm, 1993.
24These discourses have produced political effects (e.g., Brexit), legal effects (policy evolution) and social effects (particularly on EU citizens). This study examines the ideational power of post-Brexit migration discourses, highlighting the dominance of key ideas shaping public and institutional debate. It investigates rhetorical strategies that emphasise specific narratives or values while downplaying others38, thereby shaping perceptions of political issues, policies or institutional arrangements. It also examines discourse portraying EU citizens as primarily motivated by access to social benefits rather than economic participation, highlighting how this frame influences decision-making and legitimises restrictions on social benefits and free movement.
25The analysis explores how political actors employ strategic frames to define EU mobility (problem framing) and justify restrictions on social benefits (policy framing). Three dominant frames were identified through systematic coding, based on frequency and relevance, operationalised through recurring keywords and thematic patterns, including sovereignty, control, welfare and social justice and identity and belonging. The three dominant frames identified are sovereignty, emphasising the reassertion of national control over borders and migration policy; welfare and social justice, focusing on fairness, contribution and protection of the welfare state and identity, highlighting issues of belonging, citizenship and distinctions between citizens and non-citizens. Part 3 examines how these frames, dominant in Brexit migration discourse, shape post-Brexit migration policy and their impact on policy implementation and EU mobile citizens.
26The analysis focuses on both cognitive ideas (such as strengthened border control and a points-based immigration system) and normative ideas (values and principles, including sovereignty, fairness and social justice). The ideas in the discourse relate, on the one hand, to the cognitive register, such as representations of the “ideal solution,” notably restricting access to social benefits to better control immigration and, on the other hand, to normative ideas, referring to values and principles defining what is “fair” or “desirable,” for example, discourse emphasising “national sovereignty” and the UK’s right to decide “who may enter” the country. By linking discourse to policy developments and their effects on EU citizen, this approach shows how political rhetoric is translated into concrete policy measures and produces differentiated outcomes for EU citizens.
27This section examines how these frames were strategically mobilised by government actors, political parties and prominent Brexit campaigners and their effects on immigration policies. The 2016 Brexit referendum discourses played a crucial role in shaping public perceptions of UK membership in the EU, sovereignty and national identity. Several conservative actors and Brexit campaigners sought to construct UK’s relationship to EU through these interpretive frames.
28The aim of this section is to identify the dominant ideological, cognitive and normative frames mobilised in key political actors’ discourses during the 2016 referendum campaign, show how it influenced public opinion, legitimised immigration policy and shaped the British immigration system, explain how they relate to the sovereignty, welfare and identity frames highlighted earlier and demonstrate their translation into concrete policy measures. These frames are operationalised through recurring themes, keywords and rhetorical strategies and their influence on policy is traced by linking specific discursive statements to subsequent legislative outcomes, such as the EU Settlement Scheme and the points-based immigration system.
29Prior to the Brexit referendum, Cameron’s government framed European immigration as a challenge shaped by EU obligations. In his 2 February 2016 speech on EU reform, he argued that “freedom of movement has brought benefits, but it has also brought pressures on our public services, schools and housing39. This statement illustrates how cognitive and normative frames of sovereignty and welfare were mobilised in political discourse to justify reform.
- 40 Johnson, B., “MP Statement on Immigration Statistics – The Only Way to Take Back Control of Immigra (...)
30As exemplified by Boris Johnson who stated in 2016 that migration represented cuts in social benefits and overcrowded hospitals40, Brexiteers also employed this discourse to legitimise policy measures, shape public opinion and construct a problem framing portraying immigration as a threat to national sovereignty, particularly concerning control over migration, national legislation, welfare access and who may enjoy rights equal to British citizens. By systematically comparing these discursive interventions with post-referendum legislation, this study shows the concrete mechanisms through which political rhetoric influenced the design and implementation of British immigration policy.
- 41 Johnson, MP statement on immigration statistics, 2016.
- 42 Goodwin, M., & Milazzo, C. Brexit: Why Britain Voted to Leave the European Union, Cambridge, Cambri (...)
31During the 2016 referendum, the frames mobilised by the Leavers emphasised national sovereignty, protection of jobs and management of immigration pressures, often relying on rhetorical strategies such as “taking back control” or “ending free movement”41, central slogans of the Leave campaign symbolising the desire to restore national sovereignty over migration42. This discourse exemplifies how the sovereignty frame morally and cognitively justify the end of free movement
- 43 Benford, R. D. & Snow, D. A., Framing Processes and Social Movements: An Overview and Assessment, A (...)
- 44 Goodwin & Milazzo, “Taking Back Control?”, 2017; Dennison & Geddes, Brexit and the Perils of ‘Europ (...)
32The sovereignty frame in Brexiteers’ discourse served as an overarching “master frame”: as defined by Benford and Snow, master frames refers to collective action frames that are quite broad in scope, functioning as a kind of master algorithm that colours and constrains the orientations and activities of other movements43. In this case, the sovereignty frame united sub-frames encompassing border control, protection of British identity and values and reaffirmation of national over European solidarity. This discourse rhetorically legitimised restrictive immigration policies by framing sovereignty as the protection of citizens. The Leave campaign’s central slogan “take back control” reflecting criticisms levelled at the EU concerning its migration policies exemplifies how the sovereignty frame was used to morally and cognitively justify the end of free movement44.
33Founded on the belief that the United Kingdom had lost its full political, legislative and territorial autonomy to the EU, the sovereignty frame was central to Brexiteers’ discourse. For instance, Boris Johnson, then a prominent Conservative MP and leading figure in the Leave campaign, stated during the 2016 referendum campaign:
- 45 Johnson, B., 2016 speech on leaving the EU and creating more money for the NHS, UKPOL, 2016, https: (...)
“We have set out our plan to change the immigration system after we vote to leave. We will end the ‘free movement’ of people from the EU and take back control. We will introduce a points-based system under which migrants will be admitted to the UK on the basis of their skills, not their passport. … Restoring control over our borders is a necessary step. There are billions of savings that Government will be able to make after we vote leave and escape the control of the rogue European Court45.”
34This statement exemplifies how the Leave campaign linked Brexit to regaining control over UK laws, borders and migration policy, emphasising national sovereignty and protection of British identity. By referring to legislative autonomy, it demonstrates the translation of discursive frames into concrete policy measures. These frames appealing to national sovereignty and identity emphasised the slogan “take back control,” portraying uncontrolled immigration as a threat to cultural cohesion, security, public services and welfare, which helped to legitimise restrictive immigration policies and facilitates acceptance of reforms.
35In the context of Brexit and the end of free movement, political actors mobilised ideological frames that were both normative and cognitive, justifying policy choices based on values, moral convictions and national identity.
36The sub-frame of identity frame strongly appealed to voters’ sense of national belonging and focused on protecting traditional British values, emphasising individual responsibility as well as labour and economic contribution as the ethical foundations of the “nation.” During the 2016 referendum campaign, Michael Gove stated: “Of course our security rests on the robustness of our borders… The question of values. Liberal, democratic, values. Our values under challenge46.” This portrayed a British identity as being threatened by European mobility. Identity frames legitimised policies conditioning legal immigration on integration and economic contribution. Identity frames emphasise the preservation of British cultural norms and social cohesion. Cognitively, they interpret immigration as potentially influencing societal values. Normatively, they reinforce notions of belonging and collective identity, often portraying migrants as outsiders, as illustrated by David Cameron: “We want people to come but we want people to pay in before they get out … you pay in just like everyone in Britain does47.” Together, sovereignty and identity frames were used to justify legislative reforms such as the end of free movement and the introduction of the points-based immigration system.
- 48 Fox, L., “Murnaghan Interview with Liam Fox MP, Former Defence Secretary”, Sky News, 12 June 2016. (...)
- 49 Goodfellow, M., Michael Gove is peddling the same old immigration myths. The Guardian, 2019, Novemb (...)
37Immigration was often portrayed as a risk to public order and essential services. The security frame, linked to perceived threats to border control and public safety, was frequently invoked by Conservative actors to justify stricter entry requirements and closer monitoring of new arrivals. Liam Fox, former Secretary of State for Defence and Leave supporter, stated: “We have got no control over it … an uncontrolled number … puts a lot of pressure on …GP services … school places, on local authorities planning housing48.” Similarly, the welfare and social justice frame presented Brexit as a means to protect public services and ensure social justice, suggesting that EU membership undermined national finances and public services provision of public services. For instance, Michael Gove, then Secretary of State for Justice and a supporter of the Leave campaign, argued that ‘uncontrolled immigration’ placed pressure on schools, hospitals and social cohesion49, highlighting the strain on public services. This frame emphasised prioritising access for UK residents.
38The welfare and social justice frame focuses on protecting public services, local workers and social benefits. It legitimises restrictions on low-skilled migration while framing high-skilled or contribution-based immigration as acceptable, linking moral and practical considerations. Cognitively, it interprets uncontrolled migration as a risk and normatively, it appeals to the state’s duty to protect citizens, reinforcing restrictive measures and public support for related legislation.
- 50 Johnson, speech on leaving the EU, 2016.
- 51 Fox, L., Brexit could help cut immigration to tens of thousands, AOL News, 29 May 2016. https://www (...)
- 52 Gove, M., 2016 speech on why the UK should leave the European Union, UKPOL, 8 June 2016. https://ww (...)
39The framing strategies employed during the referendum significantly influenced the new immigration system’s legitimacy. Boris Johnson stated that ending free movement and “taking back control” of borders would allow the UK to restore sovereignty over laws, borders and public finances50. Similarly, Liam Fox highlighted that uncontrolled migration put pressure on local services such as schools and GP provision51, while Michael Gove emphasised the protection of British values and social cohesion52. By presenting migration reforms through the lenses of sovereignty and security, the Leave campaign legitimised the end of free movement, connecting policy objectives to perceived threats and national interests, thus facilitating public opinion’s acceptance of reforms. These frames shaped the content of legislation (ending free movement and introducing a points-based system) and its legitimacy. This rhetorical strategy centred on sovereignty and identity normalised restrictive immigration policies by framing them as a moral defence of the British nation-state, ultimately creating a shared narrative of “taking back control” that justified policy change.
- 53 Bourdieu, P., Language and Symbolic Power (J. B. Thompson, Trans.), Cambridge, MA: Harvard Universi (...)
40Brexit referendum discourse surrounding free movement thus showed how strategic framing can turn political communication into “symbolic power”53. These frames legitimised policies, justified restrictions and shaped the institutionalisation and implementation of new migration policies.
41The post-Brexit Conservative government argued that ending free movement allows the UK to regain control over its immigration policies, thereby reinforcing national sovereignty. Measures have been introduced to tighten border controls and limit new arrivals’ access to public services. The sovereignty frame is thus employed to justify strict immigration control and the shift from a European free movement system to a more restrictive British framework, “taking back control of legal immigration by ending free movement and introducing a points-based immigration system54.”
- 55 Johnson, B., “Foreign Secretary’s Speech: Uniting for a Great Brexit”, UK Government, 14 February 2 (...)
- 56 Patel, P., “Statement on Points-Based Immigration System”, UK Parliament, 24 February 2020. https:/ (...)
- 57 Patel, P., “Home Secretary Priti Patel Speech on Immigration”, UK Government, 24 May 2021.
42In his 2018 speech “Uniting for a Great Brexit”, Boris Johnson presented a vision of a post-Brexit UK regaining control over its laws and borders while pursuing a “selective” immigration policy. He framed the need to “take back control of our borders”, asserting that the UK was not hostile to immigration but aimed to target it selectively55. Home Secretary Priti Patel also exemplifies this trend: “In line with ending free movement, there will be no immigration route for lower-skilled workers56.” She placed strong emphasis on a merit-based selective immigration approach aligned with labour market needs57. This framing reinforces the government’s post-Brexit narrative of sovereignty and control, linking immigration policy to national interest and portraying selective migration as a strategic instrument to support economic growth.
43Similarly, Liam Fox’s 2018 speech “A World Beyond Europe: A Time Beyond Brexit” stressed the end of free movement, enhanced border controls and the UK’s ability to admit migrants based on national needs: “the end of free movement does not mean the end of immigration. The UK is always open to those who want to work hard … The key difference is that we will set the rules … ensuring that we can admit the people we need58.”
44These speeches from key Conservative actors shaping post-referendum migration discourse employ sovereignty and security frames, emphasising national control and regulation, while also invoking a welfare state protection frame advocating the selective admission of high-skilled migrants unlikely to claim social benefits. The rhetorical strategy relies on mobilising sovereignty and security frames, reinforcing national belonging and the state’s legitimacy in regulating migration flows, thus constructing a narrative in which control and restriction appear justified and necessary. Similarly, the welfare protection frame presents the exclusive selection of highly skilled migrants as a pragmatic policy choice benefiting the economy while safeguarding public resources. This discourse, following a neoliberal logic, reinforces the conditional nature of inclusion, migrants being accepted upon their economic value.
45The normative ideas of sovereignty, justice and equity helped to legitimise a more restrictive migration policy. The frames mobilised during the referendum were subsequently translated into post-2020 policies.
- 59 UK Parliament, Immigration and Social Security Coordination (EU Withdrawal) Act 2020, 2020, https:/ (...)
46The discursive frames thus shaped the Immigration and Social Security Coordination (EU Withdrawal) Act 202059, which ended free movement and laid the groundwork for a points-based immigration system, aligning mobile Europeans’ status with that of non-EU nationals.
- 60 UK Home Office, EU Settlement Scheme: EU, EEA and Swiss Citizens and Their Family Members, GOV.UK. (...)
47The end of free movement and the introduction of the EU Settlement Scheme60 secured the rights of existing EU residents while restricting new arrivals and effectively creating a distinction between settled migrants and future entrants.
- 61 UK Government, Immigration and Social Security Coordination (EU Withdrawal) Act 2020.
- 62 UK Home Office, EU Settlement Scheme: EU, EEA and Swiss Citizens and Their Family Members.
48The Conservative government thus reclaimed its authority over who may remain in the United Kingdom (sovereignty frame), shaping the conditions for access to territory and rights, as evidenced by the Immigration and Social Security Coordination (EU Withdrawal) Act 202061. European citizens are integrated on conditional terms, requiring proof of continuous residence (identity frame)62.
49This approach emphasises a notion of British belonging, in which only those who comply with state-imposed requirements are recognised as part of British society, highlighting the selective and exclusionary nature of the British immigration system, reflected in the government’s statement: “The UK is taking back control of its borders while ensuring those who belong here are protected63.”
- 64 UK Home Office. The UK’s points-based immigration system: Information for EU citizens. GOV.UK. http (...)
50Since Brexit, these frames have shaped selective immigration measures. The points-based immigration system64 exemplifies this approach, prioritising skilled workers through a meritocratic framework based on an evaluation of skills, qualifications and labour market needs, while restricting low-skilled migration.
- 65 Patel, P., Home Secretary announces new UK points-based immigration system, 2020, February 18. GOV. (...)
- 66 Patel, P., Home Secretary’s statement on the New Plan for Immigration, 2021, March 24, GOV.UK. http (...)
51This approach is based on a rhetoric stating that only migrants who contribute to the British economy are admitted, as stated by Priti Patel: “Our new points-based system ensures that we attract the talent the UK needs to grow our economy and support innovation65” and reflects a neoliberal market-oriented logic. It also reaffirms legal and political sovereignty in migration policy, based on “chosen and integrated” immigration, emphasising conformity with the British economy and society, as further highlighted by Patel: “We have ended free movement and introduced a fair points-based immigration system that works for the UK66.”
52Conservative rhetoric during the Brexit referendum played a pivotal role in justifying legislative changes, particularly the end of EU free movement. Frames emphasising national sovereignty, identity and welfare and social justice presented legislative reforms as necessary and legitimate, offering normative and cognitive rationales.
53This subsection focuses on the period following Labour’s return to government (late 2024-2025). Building on the same interpretive frames of sovereignty, identity, welfare and social justice previously applied to Conservative discourse, this section examines how the Labour government frames post-Brexit migration policy. The analysis assesses whether it constitutes a rupture or a continuation of the Conservative approach to control and exclusion. This question is critical in the context of post-Brexit Britain, as evaluates whether the government change has translated into a substantive transformation of migration governance or whether policy frames persist despite political alternation.
54Before examining Labour’s discourse, it is important to note that EU migration has remained central to UK–EU relations since Brexit, despite the end of free movement. While Conservative governments implemented increasingly restrictive immigration policies, the issue of EU migration has remained a central feature of post-Brexit UK–EU relations.
- 67 UK Government, Restoring Control over the Immigration System, 2025.
- 68 Mahmood, S., “New Contribution-Based Settlement Model to Reduce Net Migration”, UK Government, 29 S (...)
55This section first examines the mobilisation of the sovereignty frame in Labour’s post-Brexit migration discourse. On 12 May 2025, Prime Minister Keir Starmer described the previous immigration system as a “chaos” and pledged to “take back control” of the borders67. In the Labour government’s discourse, the sovereignty frame links national authority to policy effectiveness. Controlling borders and reducing immigration are presented as necessary steps to restore political and administrative control over who is allowed to enter and remain in the United Kingdom. Similarly, Home Secretary Shabana Mahmood emphasises the importance of individual contribution as a means of regulating migration under UK law68. In her discourse, sovereignty means the legal power to decide who may settle in the country, showing that the UK sets its own rules for residence and citizenship, independent of the European Union.
56This framing includes both cognitive and normative dimensions that reinforce the legitimacy of the current policy framework. From a cognitive perspective, immigration is portrayed as an economic factor that must be managed efficiently to meet labour market needs. From a normative perspective, national sovereignty and protection of British citizens are presented as legitimate reasons that justify strict immigration controls and lower migration levels.
57This sovereignty-based framing is then articulated with welfare and social justice considerations. The welfare and social justice frame links sovereignty in migration management to broader concerns about the welfare state, employment and social equity. This framing appears in Keir Starmer’s Immigration Policy Speech (28 November 2024), where he stated that “securing our borders is the issue that matters to working people alongside the economy and the NHS69.” Immigration is framed as having a direct impact on jobs and public services, reinforcing the idea that managing migration is not only about sovereignty but also about safeguarding national economic resources for British citizens. This framing reinforces the post-Brexit narrative linking border control with social and economic protection.
- 70 Starmer, K., “PM Remarks at Immigration White Paper Press Conference”, 12 May 2025, UK Government. (...)
- 71 UK Government, Restoring Control over the Immigration System, 2025.
58Starmer further developed this argument in his 12 May 2025 speech outlining Labour’s immigration reforms: “We will create a migration system that is controlled, selective and fair. A clean break with the past that links access to visas directly to investment in homegrown skills… if a business wants to bring people in from abroad, they must first invest in Britain70.” By linking migration policy to investment in domestic skills and training, Starmer redefines immigration control as a means to promote economic justice and social inclusion. The reforms aim to reduce dependence on cheap foreign labour while supporting local workers “backing our young people with the hope of good, well-paid jobs in their community71.”
59Similarly, Home Secretary Yvette Cooper, in her Oral Statement on the Immigration White Paper (12 May 2025), emphasised fairness alongside control: “We will set out how we restore that control to the legal migration system so it is sustainable, fair and works for the UK72.” This highlights that Labour presents migration policy as socially responsible and sustainable, linking immigration control with social justice principles. Labour combines the sovereignty frame with the welfare and social justice frame to present immigration management as a tool to reaffirm national authority while ensuring equitable access to employment and public services. This combination largely reflects the framing strategies previously identified in Conservative discourse, despite differences concerning its political positioning.
- 73 Cooper, Immigration White Paper, 2025.
60The National Identity frame is also visible in Cooper’s statement: “This white paper sets out how we will restore control, fairness and order to the system, how we will continue to bring net migration down.”73 Labour’s approach reflects Conservative policies, though it emphasises greater inclusivity.
- 74 UK Government, Restoring Control over the Immigration System, 2025.
61Cooper further explained the White Paper: “Government will return migration policy to common sense. At its heart is a simple message of fairness…But if people want to come to Britain to start a new life, they must contribute, learn our language and integrate74.” Labour uses this frame to link migration to national identity, portraying migrants as legitimate members of the community if they contribute economically, learn English and integrate. The national identity frame reinforces the idea that migration must align with British social and economic norms, promoting cultural integration and social cohesion.
- 75 Mahmood, S. New contribution-based settlement model, 2025.
- 76 Starmer, Immigration White Paper Press Conference, 2025.
62This focus on identity reflects a conditional interpretation of social justice. The social justice frame in Labour’s discourse is illustrated in Shabana Mahmood’s Immigration Reform Speech (29 September 2025): “migrants will be required to demonstrate their contribution to British society in order to obtain permanent settlement rights75.” This shows that social justice in Labour’s migration policy is conditional: only those who contribute to society are granted permanent rights. Mahmood further explained: “we will create a migration system that is controlled, selective and fair… settlement becomes a privilege that is earned, not a right, easier if you make a contribution, if you work, pay in and help rebuild our country76.” This demonstrates how Labour legitimises selective inclusion based on merit criteria.
63These statements illustrate that post-Brexit migration policies are shaped not only by sovereignty and national identity frames, but also strategically use social justice principles to justify selective inclusion. This highlights how Labour frames post-Brexit migration as a controlled, conditional right, showing a policy approach similar to the Conservative stance on immigration.
64The moral notion of “merit” is central to Labour’s discourse, presenting the right to remain in the UK as conditional and dependent on the migrant’s contribution to the society. This framing legitimises selective immigration policies grounded in productivity, integration and alignment with British values and norms.
65When Shabana Mahmood declares: “migrants will be required to demonstrate their contribution to British society in order to obtain permanent settlement rights,” her speech exemplifies this merit-based approach, emphasising integration and contribution as prerequisites for settlement. This logic of reciprocity frames citizenship and belonging as conditional, merit-based, and culturally bounded, producing a binary opposition between ‘deserving’ migrants, those who contribute and integrate and ‘undeserving’ others, portrayed as a burden. Through migration policy, Labour discourse constructs the boundaries of the national community, defining who belongs and who remains outside.
- 77 Mahmood, S. New contribution-based settlement model, 2025.
66This moral evaluation of migrants is also reflected in legislative changes. Migrants must have lived lawfully in the UK for at least ten years, which represents twice the current period, before being able to settle permanently. Mahmood further outlines several conditions for obtaining indefinite leave to remain, including “being in work, making a certain level of National Insurance contributions, not taking any benefits payments, learning English to a high standard, having a spotless criminal record and giving back by, for example, working in your local community”77, reflecting the merit-based logic structuring the new immigration policy.
67At the same time, the 2025 immigration reforms, including the Skilled Worker visa reduction and the shorter Graduate visa, illustrate how these discursive frames are translated into law. The updated family visa framework also highlights that frames centred on control, sovereignty and moral evaluation are central to the construction of the UK’s selective immigration system.
- 78 Thomas-Symonds, N., “A New Deal with the EU Is Exactly What Britain Needs. Here’s How Labour Will A (...)
68The absence of reform of the EU Settlement Scheme (EUSS) constitutes a central empirical demonstration of this continuity. Although the Labour leadership seeks to construct a political narrative of reconciliation and pragmatic cooperation with the EU78 through agreements on the mobility of skilled workers and students, the framing of migration as a matter of control, sovereignty and conditionality has not fundamentally changed. Under Keir Starmer, no substantial reform or relaxation of the EUSS has been introduced. This continuity shows that EU nationals remain subject to the same logics of conditionality, legal uncertainty and selective inclusion established under Conservative governments. This illustrates continued alignment with post-Brexit Conservative migration policy, with migration still framed as an issue of national control and sovereignty.
69The selected excerpts highlight key dimensions of post-Brexit migration discourse. The analysis shows that main post-Brexit frames still shape discourse and policy across political parties, the Labour party remaining broadly aligned with the Conservative approach of controlled migration. These policy frames rooted in sovereignty, welfare conditionality and identity politics remain consistent, regardless of the party in power. While Labour emphasises conditional inclusion and Conservatives strict enforcement, both focus on control, sovereignty and the moral evaluation of migrants.
70Post-Brexit UK migration policies legitimise power relations in migration policy, as it frames these measures as necessary and beneficial for the country, thereby normalising them. Here, legitimisation refers to the way political discourse presents restrictive migration policies as reasonable and justified, making them socially and politically acceptable. Consequently, these frames legitimise the authority of British institutions over border and immigration management, framing state control as necessary to regulate migration, determine eligibility for residence and social rights, thus enforcing selective inclusion of EU nationals. This discourse reinforces the central role of the state as the authority deciding who can live, work and access public services in the UK, thereby legitimising the state’s immigration policies and their implementation. These frames also confer legitimacy on political actors, particularly the government, to define the rules of the immigration system and to determine who may enter the United Kingdom. The state thus redefines access to residence, work and social rights for EU nationals, privileging highly skilled migrants over lower-skilled ones, producing discriminatory effects that may marginalise certain EU nationals and shape social stratification, highlighting the social and political consequences of these decisions.
71This subsection builds on the framing analysis developed in the previous sections by examining how dominant post-Brexit migration frames are translated into concrete policy measures and social outcomes. It analyses how migration discourse has shaped post-Brexit immigration policy and its implementation, focusing on legislative changes (notably the introduction of the points-based system), tensions between national sovereignty and economic priorities and the social consequences for EU citizens living in the UK.
72By examining access to territory and rights, this section highlights the concrete effects of post-Brexit immigration reforms on both new arrivals and long-term EU residents, showing how differentiated legal statuses have contributed to growing inequalities within this population. These outcomes reflect the implementation of the sovereignty and welfare conditionality frames identified earlier, particularly through the stratification of rights based on legal status.
73With the end of free movement, the conditions for European citizens’ residence and employment’s access have fundamentally changed. Since January 1, 2021, EU citizens no longer enjoy an automatic right to live, work or study in the UK. Rights granted to EU citizens under the EU Settlement Scheme do not automatically apply to those arriving after Brexit. Existing residents benefit from acquired rights through the Scheme, whereas newcomers are subject to more restrictive measures, as defined in the new points-based immigration system. This generates socio-economic inequalities in access to British welfare state and employment opportunities and reflects the conditional inclusion as identified in political discourse. While those who settled before 2021 were able to secure their status through the EU Settlement Scheme, newcomers now face strict criteria similar to those applied to non-European migrants and must hold a residence permit or visa in order to live and work in the UK. Among the most significant changes, long-term stays now require specific visas for work, study or family reunification. With the end of the Erasmus programme, EU students are subject to international tuition fees and additional difficulties have emerged regarding UK–EU family reunification procedures, EU citizens must now meet income and visa requirements to bring their family members, just like non-EU nationals. Their access to social rights has been reduced, notably due to the end of the automatic portability of social rights between the EU and the United Kingdom (except for specific bilateral agreements). Access to social benefits and the National Health system (NHS) is now conditional on their immigration status, with some benefits requiring settled status. These policy outcomes reflect the welfare and social justice frames discussed earlier, as access to rights is increasingly conditioned by legal status and individual contribution.
- 79 Comte, E., Post-Brexit UK Has Not ‘Taken Back’ Control of Immigration, Opinion No. 657, CIDOB, Marc (...)
- 80 Sumption, M., Brindle, B., & Walsh, P. W., Net Migration to the UK, Briefing, The Migration Observa (...)
74The reforms have not significantly reduced overall migration, contrary to the promises of the Leave campaign79. Although net migration of EU citizens became negative in 202480, this drop has been compensated by a significant increase in non-EU migration. The new immigration has notably reduced the migration of low-wage EU workers in favour of highly skilled immigration. This outcome highlights the gap between immigration control-focused political discourse and economic realities. This challenges the government’s claim to have ‘taken back control’ of UK immigration. Nevertheless, despite these outcomes, successive post-Brexit governments have maintained the logic underpinning their immigration system.
75Although Labour Prime Minister Keir Starmer has sought to restore relations with the EU, he has not attempted to reinstate free movement. On the contrary, he has aimed to strengthen the immigration rules established by the previous Conservative governments. These measures reinforce the sovereignty frame by reaffirming state control over access to territory and rights. The white paper introduced stricter UK immigration rules, including higher English proficiency requirements, doubling the residency period for settled status, ending visas for social care workers, limiting skilled worker visas to graduate-level jobs, creating short-term temporary visas for lower-skilled workers and shortening post-study graduate visa duration from two years to eighteen months. These measures reflect the continued emphasis on control, selectivity and merit identified in the framing analysis.
76The analysis of the impacts of the reforms implemented by post-Brexit governments reveal tensions between sovereignty and economic objectives. While the policy seeks to attract skilled talent, at the same time, the strict points-based system restrict access to sectors which are dependent on low-skilled labour. The United Kingdom, however, had to issue temporary visas for shortage occupations to address the lack of labour in key economic sectors, particularly during the COVID-19 period. For instance, the country faced an acute shortage of lorry drivers and agricultural workers, which caused supply chain disruptions and even food shortages. This highlights the tension between anti-immigration discourse and economic pragmatism.
77In addition, the new migration policy have also negative social and economic consequences. These reforms have concrete effects on the legal and social status of European citizens. This reinforces the moral distinction between ‘deserving’ and ‘undeserving’ migrants identified earlier in the discourse of the Labour and Conservative parties. With the end of free movement, EU nationals no longer enjoy privileged status and are instead subject to a stricter system of national control, resulting in conditional inclusion and precarious legal status, restricted access to fundamental rights and social vulnerabilities for certain groups.
- 81 The Guardian, “At Least a Third of EU Citizens in the UK Report Discrimination by Public Bodies”, 1 (...)
- 82 Independent Monitoring Authority, European Citizens’ Concerns after Brexit: Report on the IMA’s Thi (...)
78According to a report by the Independent Monitoring Authority (IMA)81, an institution created under the Withdrawal Act 2020, designed to safeguard EU citizens’ rights, over one-third of EU citizens holding “settled” or “pre-settled” status report experiencing discrimination from administrative authorities and facing difficulties exercising basic rights, particularly regarding employment, mobility and access to public services82. Despite post-Brexit legislative measures such as the Withdrawal Agreement (2020), the EU Settlement Scheme and the establishment of the Independent Monitoring Authority, these findings highlight persistent obstacles for European expatriates in the UK, illustrating the gap between the formal rights of EU citizens and the actual restrictions under a highly conditional migration framework. As shown earlier, the EU Settlement Scheme operates as a key instrument of selective inclusion, illustrating the continuity of post-Brexit migration frames across discourse and policy.
79The United Kingdom’s post-Brexit migration policy demonstrates the extent to which ideas and political discourse contribute to the legitimation and the shaping of public policy. By framing the end of free movement as the reassertion of national control, post-Brexit governments constructed a sovereignty discourse that legitimised their regulatory power to define belonging and exclusion. This ideational power, mobilised in the discourse and grounded in cognitive and normative frames, transformed restrictive reforms and national control into the dominant migration policy paradigm. Through the selective inclusion of migrants based on legal status, contribution, integration and alignment with British social norms, this framing created a moral distinction between ‘deserving’ and ‘undeserving’ EU citizens, illustrating the central role of merit, conditionality and national identity in post-Brexit migration policy. As shown in this paper, although this discourse is difficult to sustain due to economic priorities, particularly the dependence of key sectors on a foreign labour, it highlights how the “take back control” rhetoric reshaped the rights of EU citizens in the UK, creating differentiated inclusion and social hierarchies. By linking discourse, policy and social outcomes, this analysis demonstrates how post-Brexit migration policy translates dominant frames centred on sovereignty, control, welfare conditionality and national identity into a strict immigration framework that shapes the inclusion and exclusion of migrants. These findings demonstrate that Labour’s post-Brexit approach, while rhetorically different and emphasising social justice, largely reproduces the Conservative framing, confirming the lasting influence of these key interpretive migration policy frames across political parties and illustrating the enduring power of discourse in shaping the framework and impacts of migration policy in the UK.
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