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Net Migration Policy: An Explainer Comparing Australia, Canada and the UK

September 24, 2026

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  • AustraliaAustralia
  • CanadaCanada
  • United KingdomUnited Kingdom

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Jack Kim

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Anna Boucher

Senior Counsel

Sydney, Australia

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T:+61 2 8224 8501

Shuyeb Muquit - web porthole

Shuyeb Muquit

UK Government Affairs Strategy Director

London, United Kingdom

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T:+44 (0) 20 7090 9248

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Jack Kim

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Toronto, Canada

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T:+1 416 507 3701

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Anna Boucher

Senior Counsel

Sydney, Australia

Email

[email protected]

T:+61 2 8224 8501

Shuyeb Muquit - web porthole

Shuyeb Muquit

UK Government Affairs Strategy Director

London, United Kingdom

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[email protected]

T:+44 (0) 20 7090 9248

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Anna Boucher

Senior Counsel

Sydney, Australia

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[email protected]

T:+61 2 8224 8501

Shuyeb Muquit - web porthole

Shuyeb Muquit

UK Government Affairs Strategy Director

London, United Kingdom

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By: Jack (Eui Chul) Kim, Dr. Anna Boucher, Shuyeb Muquit

Overall migration flows are a topic of significant policy and political debate in Australia, Canada and the UK. As three of the world’s leading immigration destinations, each country is grappling with how to manage population growth, labour market needs, housing pressures and public confidence in the immigration system. While their approaches differ, they share common challenges, including pressure to reduce overall immigration flows amid the increasing politicisation of migration, balanced against the economic costs of cutting migration too sharply or quickly.

This explainer examines how the government of each nation measures migration, the policy debates shaping recent reforms and the broader lessons emerging from efforts to manage net migration while maintaining international competitiveness and economic growth. 

Australia

The Australian government measures its migration levels through a concept known as Net Overseas Migration (NOM), calculated as the number of migrants who enter and remain in Australia for at least 12 months over a 16-month period, minus those who have departed. NOM provides a dynamic picture of overall migration flows and excludes short-term arrivals such as tourists. Note that the period of residence in Australia to qualify for NOM is calculated slightly differently than in the UK.  

In recent years, NOM has become one of the most contested issues within Australian politics. It increased quickly in the post-COVID-19 period from net negative annual NOM of -94,000 in March 2021 to positive 555,812 by September 2023. Although NOM has since fallen to around 301,000, migration levels remain highly contested. The incumbent Labor Party is seeking to reduce NOM further to 245,000 by 2027, as outlined in its Budget, while the Opposition Liberal Party and One Nation have argued for deeper reductions.

Whether further cuts are practically feasible is up for debate but supporters of tighter migration controls argue that high levels of NOM contribute to pressure on housing affordability and infrastructure. The extent of that impact is contested, but in a period of sustained housing shortages and sharply rising property prices across most Australian cities, this position has persisted.

Central questions prevail in Australian policy debates over where the cuts in the immigration programme should be made, and what the impacts of such cuts might be upon affected parties. In an address before the National Press Club in 2025 and then again more recently in 2026, Home Affairs Minister Tony Burke posed the question of which form of migration should be most appropriately cut and what the likely effects of this would be. Any reductions inevitably affect different stakeholders and therefore require careful consideration of their political, economic and social implications.

Relatively less attention has been paid to the potential impact of reductions in migration on Australia’s overall GDP and labour market shortages, although this remains an important consideration.  

While NOM targets of 1% of the overall population, similar to approaches in Canada (see below), have been proposed by some commentators, this has not been formally developed as Australian government policy and government response on this recommendation has been limited.  

Canada

Section 94 of the Immigration and Refugee Protection Act (IRPA) requires the federal government to provide Parliament with an annual immigration report. This report forms the basis of Canada's Immigration Levels Plan, outlining previous immigration outcomes, future admission targets, key initiatives and the number of foreign nationals who become permanent residents.  

When the IRPA came into force in 2002, Canada accepted 229,091 permanent residents.  By 2024, Canada set a single-year record with 483,591 new permanent residents. Unlike Australia and the UK, Canada measures permanent and temporary migration separately; an important distinction when comparing across the three countries. Over this 22-year period, permanent immigration targets and admissions increased as a percentage of Canada’s total population from 0.73% to 1.18%.

Former Prime Minister Trudeau planned to increase annual immigration levels to one million permanent residents by 2026. However, mounting infrastructure and housing pressures, alongside concerns regarding the integrity and scale of temporary resident programs, prompted the government to announce cuts to planned levels near the end of 2024. For the first time in Canada’s history, those targets included temporary residents.  

Prime Minister Mark Carney has continued this recalibration. Under the 2026–2028 Immigration Levels Plan, permanent resident targets will stabilize at 380,000 annually, while temporary resident arrivals are projected to fall to 385,000 in 2026 and 370,000 in both 2027 and 2028.  These targets have been developed in conjunction with a focus on transitioning people already working legally in Canada to permanent residence.

The revised approach reflects the government’s intention to establish permanent resident admissions under 1% of the total population and reduce temporary resident admissions to under 5% by the end of 2027.  As with any target-based system, however, whether these objectives are achieved will only be clear in the first quarter of 2027.

Canada continues to place economic immigration at the centre of its immigration mix. Economic programs are expected to account for approximately 63% of permanent resident admissions in 2026 and 64% in 2027 and 2028, representing the highest percentages of this kind of migration in over a decade. This emphasis is intended to address labour shortages, support regional workforces and reinforce public confidence in the economic value of immigration.    

Simultaneously, as noted, the government aims to reduce Canada’s non-permanent resident (temporary) population to less than 5% of the total population by the end of 2027. For 2026, international student arrivals are targeted at 155,000, while temporary worker arrivals are set at 230,000.

Overall, the government is attempting to slow short-term population growth while preserving immigration’s role in filling labour gaps, supporting communities and strengthening Canada’s economy. The success of this approach will depend not only on implementation but also on continued consultation with provinces, territories, employers and communities across Canada. The government recognizes the importance of immigration to Canada while balancing this with the need to restore public confidence and demonstrate a responsible and orderly immigration system. 

Early indications suggest that the revised policy direction is influencing migration outcomes. As of July 1, 2026, Canada's estimated population was 41,798,407, an increase of 146,754 people (0.35%) from the second quarter of 2025. This growth rate was considerably lower than the 0.88% increase recorded between the second quarters of 2024 and 2025. In the second quarter of 2026, the number of non-permanent residents was estimated at 2,779,774, reflecting a 0.7% decline from the previous quarter. Canada also admitted 99,148 permanent residents during the second quarter of 2026. Although this was 15,997 more admissions than in the first quarter of 2026, according to Statistics Canada it represented a 4% decrease from the number admitted during the same quarter in 2025.

These figures appear consistent with the federal government’s lower permanent and temporary resident targets for 2026.

UK

The UK defines net migration as the difference between the number of people immigrating to the UK and the number of people emigrating for 12 months or more.  It therefore combines cohorts with very different motivations, contributions and likely lengths of stay, including students, and both temporary and permanent migrants.

The UK has experience of both explicit numerical net migration targets and managing migration without one. Prior to becoming Prime Minister in 2010, David Cameron pledged to reduce annual net migration to the “tens of thousands,” an objective that proved difficult to achieve. More recent governments have continued to seek lower migration, but without identifying a fixed optimum level or numerical cap.

Headline net migration figures nevertheless remain politically significant. Rapid population change can generate legitimate concerns about housing, public services and integration and the UK’s post-pandemic surge, which saw net migration reach a record-breaking revised level of 906,000 (up from an earlier estimate of 672,000) in the year ending June 2023, inevitably created pressure for action. However, the UK’s recent experience also demonstrates why the headline figure should inform, rather than determine, immigration policy.

This experience demonstrates both the limits and power of policy control, a lesson that is particularly relevant for comparator countries such as Australia and Canada. The UK’s net migration surge reflected increased work and study migration alongside exceptional humanitarian movements, including from Ukraine and Hong Kong.

While government cannot precisely control every component of migration, particularly rates of emigration, it has powerful levers over regular migration through eligibility requirements, salary thresholds, sponsorship rules and dependant provisions.

Restrictions in these areas, introduced first by the Conservative government under PM Rishi Sunak by way of its so-called 5-point plan announced in December 2023 and continued by the Immigration White Paper published in May 2025 by Sir Keir Starmer’s Labour government, contributed to net migration falling to a provisional 171,000 in the year ending December 2025. Some of the earlier increases also proved temporary. For example, international students have left the UK in increasing numbers as post-pandemic cohorts complete their studies, contributing to the decline in British net migration through factors that were not entirely caused by government policy levers.

That success in addressing overall numbers has involved various policy trade-offs. Migration affects population size and composition of the labour force and public finances over time. The migration routes most readily restricted include care workers, where demand has traditionally been high but net fiscal contributions have been relatively low. However, restrictions can also affect migrants who contribute significantly to national productivity, labour-force growth, and public finances.

For example, the UK’s Migration Advisory Committee estimates that Skilled Worker main applicants outside the Health and Care route generate an average lifetime net fiscal contribution of £689,000 per person. The Institute of Fiscal Studies has similarly estimated that lower migration projections could reduce the Chancellor’s fiscal headroom by between £1 billion and £4 billion as slower domestic labour-force growth weighs on the economic and tax-revenue outlook.

In an increasingly competitive global market for talent, repeatedly tightening those routes creates further risks and reduces the number of migrants who deliver these economic and fiscal benefits, while weakening the overall skill set of the remaining migrant workforce.

Developing UK policy also shows that control and liberalisation need not be opposites. Overall tightening is increasingly sitting alongside targeted measures supporting strategically valuable migration, including shortage-based access and expanded Global Talent provision for research-intensive businesses.

Key Lessons for Net Migration Policy Across these Three Countries

The lessons emerging from Canada and the UK are highly relevant to Australia’s current and ongoing debate over net overseas migration. Legitimate concerns about the scale of migration can be acknowledged without allowing a single headline figure to dictate immigration policy. A more effective approach is to understand who is arriving, why they are coming, how long they will stay, and what they contribute to the economy and society, and which migration flows government can realistically control within its toolbox of policy levers, and which it cannot.

In both countries, reducing migration numbers has proved challenging and, where significant reductions have been achieved, such as in the UK, skill shortages and wider economic trade-offs have emerged, which may lead to forms of liberalisation in some targeted areas in the future.

Note: Articling Student David Mucz contributed to this blog.

Need to Know More?

As governments in Australia, Canada and the UK seek to balance migration levels with economic and political priorities, employers should monitor ongoing policy developments and their potential impact on workforce planning and talent mobility.

For policy questions about Canada, please contact Partner Jack Kim at [email protected]. For Australia, please contact Senior Counsel Anna Boucher at [email protected]. For the UK, please contact Director Shuyeb Muquit at [email protected].

This blog was published on 24 September 2026 and reflects information available at that time. Updates may occur as policies evolve. To stay informed on the latest immigration news and analysis, please subscribe to our alerts and follow Fragomen on LinkedIn, Facebook and Instagram.

Countries / Territories

  • AustraliaAustralia
  • CanadaCanada
  • United KingdomUnited Kingdom

Related contacts

Jack-Kim

Jack Kim

Partner

Toronto, Canada

Email

[email protected]

T:+1 416 507 3701

Photo of Anna Boucher

Anna Boucher

Senior Counsel

Sydney, Australia

Email

[email protected]

T:+61 2 8224 8501

Shuyeb Muquit - web porthole

Shuyeb Muquit

UK Government Affairs Strategy Director

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9248

Related offices

  • London
  • Sydney
  • Toronto

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Jack-Kim

Jack Kim

Partner

Toronto, Canada

Email

[email protected]

T:+1 416 507 3701

Photo of Anna Boucher

Anna Boucher

Senior Counsel

Sydney, Australia

Email

[email protected]

T:+61 2 8224 8501

Shuyeb Muquit - web porthole

Shuyeb Muquit

UK Government Affairs Strategy Director

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9248

Related offices

  • London
  • Sydney
  • Toronto

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Jack-Kim

Jack Kim

Partner

Toronto, Canada

Email

[email protected]

T:+1 416 507 3701

Photo of Anna Boucher

Anna Boucher

Senior Counsel

Sydney, Australia

Email

[email protected]

T:+61 2 8224 8501

Shuyeb Muquit - web porthole

Shuyeb Muquit

UK Government Affairs Strategy Director

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9248

Related offices

  • London
  • Sydney
  • Toronto

Share

  • Twitter
  • Facebook
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