How Japan, Denmark, Switzerland and Mexico Guard Their Own Borders

Picture a country that requires immigrants to learn its language, pass a test on its institutions, show they can support themselves, wait for years and, in one case, win a vote of the national parliament before becoming a citizen. Now picture the cable-news panel announcing that this country has abandoned its values.

Funny, isn't it? The same people who would call that country's policies bigoted if an American politician proposed them tend to admire the country itself, because it is Danish, or Swiss, and has nice trains. The truth is simpler and less flattering to the panel. Controlling who enters and who joins is what a normal democracy does, and America, if anything, is among the more relaxed ones.

The claim

Here is what I will argue. Border control is ordinary statecraft, practiced by free, prosperous, thoroughly respectable democracies on every continent. It is not evidence of bigotry, and a policy cannot be shown to be bigoted merely by showing that it is restrictive, because the countries most admired by critics of American enforcement are often the strictest. The honest debate is about which rules and how many people, not about whether a nation may decide.

To make the case without cherry-picking I will examine four very different countries: Japan in East Asia, Denmark in Scandinavia, Switzerland in the Alps and Mexico, our neighbor to the south. I will stick to features of each system that are well established, and I will say where a detail changes often enough that you should check the current law.

Japan: citizenship by descent, entry by invitation

Japan is the standing counterexample to the idea that a rich democracy must absorb large numbers of newcomers. Its nationality law is built on descent: a child generally acquires Japanese nationality through a Japanese parent, and being born on Japanese soil to foreign parents does not by itself confer citizenship. There is no birthright citizenship of the American kind.

Naturalization is possible but it is a discretionary act. An applicant generally must have lived in Japan for a period of years, show good conduct, show the ability to support himself or herself, and in general give up any other nationality, since Japan does not ordinarily allow dual citizenship. The Ministry of Justice decides.

On asylum, Japan is a party to the refugee convention, but it recognizes very few people as refugees in comparison with other wealthy countries of similar size. It has also relied on specific channels for foreign labor, such as technical-intern and skilled-worker programs, rather than a general immigration channel. Japan's example is a double-edged one, and I will say so. It shows a prosperous democracy can maintain strict control, and it also faces demographic strain from a shrinking and aging population, a reminder that restriction has costs and that a country must choose its trade-offs openly.

Denmark: integration is the price of admission

Denmark is a very different animal. It is a small, generous welfare state, and it has concluded that a generous welfare state and loosely controlled borders do not mix. It has tightened its rules over two decades, under governments of the left as well as the right, and the Social Democrats in particular have made the restrictive turn.

Citizenship in Denmark generally passes by descent. Naturalization requires a long period of residence, commonly counted in about nine years, a Danish language test, a citizenship test on Danish society, culture and history, a record free of serious crime, and a period of self-support without public benefits. And here is the feature that should make Americans blink: in Denmark, naturalization is conferred by law. The Folketing, the national parliament, passes naturalization acts listing the individuals approved. The legislature itself, and not an office, admits the citizen.

On asylum, Denmark has moved from the idea of permanent settlement toward temporary protection. The government has said that protection is meant to last only as long as it is needed, and it has reviewed the status of some refugees, particularly from Syria, when conditions changed. In 2021 the Folketing passed a law that would allow the country to transfer asylum seekers to a third country for processing outside Europe, a controversial move that drew criticism from the European Union and refugee organizations. Whether one admires it or not, it is the statute of a democracy, passed by an elected legislature.

Danish integration requirements for newcomers include language and employment expectations. The message is clear: you are welcome to join the society on the terms of the society.

Switzerland: three levels of citizenship

Switzerland has the most distinctive system, because citizenship there is layered. A Swiss citizen is a citizen of a municipality, a canton and the Confederation, all three at once. Under the Swiss Citizenship Act as revised in 2018, naturalization at the federal level requires a settlement permit, known as the C permit, and a period of residence of ten years, with the years between ages eight and eighteen counting double. Applicants must show language ability, with oral and written levels set by federal rules, integration into Swiss life, respect for the legal order and no threat to security. The cantons and municipalities add their own requirements and run their own procedures, and in some places local bodies have had a real say.

Switzerland is not a member of the European Union, though it participates in the Schengen travel area and in the Dublin system for assigning responsibility for asylum claims. In 2019 it introduced an accelerated federal asylum procedure intended to decide most claims quickly in federal centers. And in a 2014 national vote, Swiss voters narrowly approved an initiative against mass immigration, which forced a long and difficult argument over how to reconcile the result with the country's agreements with the EU.

What I take from Switzerland is the principle of local consent. A democracy can decide that the community that is asked to take someone in should have a voice in the process. Our own Constitution gives the power over naturalization to Congress, not to the states, and for good reason, as the history in Before Ellis Island, the States Ran Immigration and the Court Stopped Them shows. But the Swiss example reminds us that citizenship is a membership, and a membership can be earned slowly.

Mexico: the strictest neighbor

Now to the country that sits on our southern border and whose government often lectures ours. Mexico's constitution, in Article 30, grants nationality both by birth on Mexican territory and by descent, which means a child born in Mexico is generally Mexican. Naturalization under the nationality law requires a period of residence, generally five years, which is shortened to two for people from Latin American countries and the Iberian peninsula, and for certain others such as spouses of Mexican citizens. Applicants must show knowledge of the language and Mexican history and culture, and they must renounce their other nationality in the formal declaration.

And Mexico's constitution treats foreigners very differently from how ours does. Article 33 gives the executive the power to expel foreigners and bars foreigners from taking part in the country's political affairs. Mexico's Ley de Migración of 2011 governs entry, and the National Migration Institute runs checkpoints and detention facilities, including in the southern states along the Guatemalan border. Mexico has enforced controls along its own southern border for years, a fact that bears directly on the American debate, because American policy increasingly relies on Mexico to apply them. We have a longer discussion of that arrangement in Remain in Mexico and Safe Third Country Rules, How Each Is Supposed to Work.

I say this with respect for Mexico and Mexicans, not as an accusation. A sovereign has a right to control its own borders, and Mexico exercises it. When Mexican officials, or American critics of our own enforcement, describe the idea of control as inhumane, they are describing the actual practice of the country next door.

The comparison

A word on how to read the table. I have limited it to features that are well established, and I have written some entries in general terms, because specifics change. Dual-nationality rules, naturalization wait times and asylum procedures are amended often, and anyone relying on a particular entry should check the country's current law. The pattern, though, is stable and it is the point: every one of these governments sets terms for entry and membership, and none treats citizenship as an automatic right of presence.

The best objection, and the answer

The strongest objection goes like this: "These are not comparable cases. Japan, Denmark and Switzerland are small, homogeneous countries that never saw themselves as nations of immigrants. America is different. We are a country built by arrivals, and holding ourselves to the standard of countries with no such tradition is a betrayal of what we are."

There is something to that. America's history is unique, and I take it seriously, as in the argument about a creedal nation in Lincoln's Electric Cord and the Case for a Civic Nation Anyone Can Join. But three things follow.

First, Mexico is the exception to your exception. It is a country of immigrants in its own way and a neighbor in the same hemisphere, and it controls entry with real severity. Nobody argues that Mexico has betrayed its identity.

Second, the principle of the comparison is not about copying other countries' numbers. It is about the claim that a nation may set terms. The Danes and the Swiss do not apologize for requiring a language test. America's tradition of welcoming newcomers is compatible with, and has always rested on, rules about who is admitted and how. For the early history, see One Uniform Rule, How the First Congresses Wrote America's Naturalization Laws.

Third, the comparison cuts the right way on the humanitarian question. The countries that manage entry most clearly are generally the ones that can keep a promise to the people they admit. A system in which no one controls the flow is one in which the promise cannot be kept.

What America could adopt

A conservative has to say which of these practices would actually fit. Here is my list, in order of how well I think each would translate.

1. A serious language and civics requirement tied to naturalization. We already have a civics test and an English test. Denmark and Switzerland show they can be taken seriously. The question is whether the bar is meaningful, and Twelve Questions From the Citizenship Civics Test and the Answers Behind Them gives a sense of it.
2. A period of self-support before access to benefits. The American rule on this is already old, and the history of it is in Self-Sufficiency Was the First Immigration Rule, the Public Charge Story. Denmark's benefit-free period is an example of a rule that applies it clearly.
3. Processing asylum claims quickly and at or near the first safe country. Switzerland's accelerated federal procedure and the Danish debate over third-country processing point in this direction. The American version is the subject of the safe-third-country discussion linked above.
4. A points-based selection system for work visas. Canada, among others, uses one, as discussed in Thinking of Moving to Canada? Its Points System Might Not Pick You, and an American version is sketched in What an American Points System Would Look Like Written Into Law.
5. Legislative accountability. The Danish practice of naturalization by statute is probably not suited to a country of our size. The principle underneath it, that the elected representatives own the rules, is exactly right, and it argues for Congress writing the definitions that agencies now rewrite every few years.

What I would not copy is a ban on dual nationality or the discretionary opacity that characterizes some of these systems. American citizenship rests on a creed and on clear, published rules. We should want rules at least as transparent as the ones we have.

The case in brief

1. Border control is ordinary statecraft, practiced by free and prosperous democracies, and strictness is not evidence of bigotry.
2. Japan relies on descent and a discretionary naturalization process, Denmark requires language, civics and long residence with the parliament approving citizens by statute, Switzerland layers federal, cantonal and municipal consent over ten years of residence, and Mexico sets residence and cultural requirements and reserves expulsion power to its executive.
3. The countries most often held up as models for American policy are, in many respects, stricter than America is.
4. The sound lessons to borrow are meaningful language and civics tests, a self-support period before benefits, fast asylum processing near the first safe country, and rules written by legislatures and not by agency memo.
5. A nation of immigrants is still a nation, and a nation sets terms.

What you can do: choose one of the four countries above, find its current nationality or citizenship law on the official government website, and compare one requirement with the American equivalent, then bring the comparison to your next town-hall or debate meeting.