Ok — so before we go any further, it’s probably worth asking a fair question.
Is this just how things work everywhere?
Or is there something particularly British — or English — about the way we’ve handled it?
Up to now, we’ve mostly been looking at the UK. That’s deliberate. It’s the system we live in, pay for, and argue about. But it also risks leaving us with a blind spot.
So now feels like the right moment to widen the lens.
Let’s have a look at what’s happened elsewhere — maybe we find good examples, maybe someone has cracked it — or maybe different choices just led to different kinds of mess.
Because if everyone ended up in the same place, we might just be looking at an unavoidable problem.
But if some countries ended up doing noticeably better — or noticeably worse — then what we’re really looking at is design.
Same behaviours, different assumptions
One thing becomes clear very quickly when you compare countries.
The underlying behaviours aren’t radically different.
People use drugs.
People migrate.
People sell sex.
People break rules.
People respond to incentives.
What differs isn’t human nature — it’s what governments assume about it.
Some systems are built on the assumption that:
pressure will eliminate behaviour
Others start from:
behaviour will persist, so harm needs managing
That difference turns out to matter a lot.
Drugs: prohibition vs management
The most widely cited comparison is drugs, so we’ll start there.
The US and much of Europe faced similar social changes from the 1960s onwards: youth culture, new substances, urbanisation, inequality, and stress.
The policy response diverged.
The United States leaned heavily into criminalisation, mandatory sentencing, and enforcement-led deterrence.
Several European countries — most notably Portugal, but also parts of Netherlands and Switzerland — eventually shifted toward decriminalisation of users, treatment-first approaches, and regulated visibility.
What’s striking isn’t that drug use vanished in one place and not the other.
It didn’t.
What changed was:
- overdose deaths
- HIV transmission
- incarceration rates
- policing costs
- and how easily people could access help
In countries that reduced criminal penalties for users and invested in treatment, harm indicators tended to stabilise or fall — even where overall use didn’t drop dramatically.
In countries that doubled down on punishment, costs and complexity kept rising.
Same behaviour.
Different system response.
Different outcomes.
Sex work: visibility versus vulnerability
A similar pattern shows up in how countries approach sex work.
Some treat it primarily as a moral issue.
Others treat it as a labour and safety issue.
Where sex work is criminalised — fully or partially — the evidence repeatedly shows:
- work becomes more hidden
- third-party control increases
- violence risk rises
- health access drops
Where it is legalised or regulated — as in parts of Germany or New Zealand — the work doesn’t disappear, but conditions become more visible, more inspectable, and easier to intervene in when harm occurs.
Again, this isn’t about endorsement.
It’s about whether the system makes harm easier or harder to detect and reduce.
Migration: control on paper, chaos in practice
Migration is perhaps the clearest example of moral certainty colliding with system reality.
Most countries publicly insist they want “controlled” migration.
But control turns out to mean very different things in practice.
Roughly speaking, systems tend to fall into two camps:
- deterrence through hostility, or
- managed, legal, visible pathways
Where countries lean heavily on the first while economic demand still exists, the outcome is fairly predictable.
Take the United Kingdom over the last decade.
As legal work routes were tightened — particularly for lower-paid sectors — demand didn’t disappear. Agriculture, care, hospitality, construction, and logistics still needed people.
What changed was where the work moved.
Informal labour expanded.
Exploitation became easier.
Enforcement costs rose.
And public confidence fell — not because migration increased uncontrollably, but because it became less visible and less governable.
The policy said “control”.
The system produced opacity.
You see a similar pattern in parts of Italy and Greece, where strict entry controls coexist with large informal labour markets. Migrants still arrive, because the work still exists — but without status, protections, or leverage.
The result isn’t order.
It’s vulnerability.
By contrast, countries that expanded legal work pathways — even temporarily — often saw something different.
Spain’s regularisation programmes in the 2000s, for example, brought large numbers of undocumented workers into the legal system. That didn’t stop migration — but it did increase tax receipts, reduce exploitation, and make labour markets easier to regulate.
More recently, Canada has used time-limited and sector-specific work visas to align migration with demand. The system isn’t perfect — no system is — but compliance rates are higher, abuse is easier to detect, and enforcement costs are more predictable.
The key point isn’t that these countries “solved” migration.
They didn’t.
It’s that where legal routes existed, the behaviour became visible, taxable, and governable.
Where they didn’t, it didn’t vanish.
It went underground.
The behaviour didn’t disappear.
It became governable — or it didn’t.
And that difference turns out to matter a lot.
What these comparisons don’t show
It’s important to be clear about what international comparisons don’t prove.
They don’t show:
- that one culture is “better”
- that policy transfers cleanly
- that moral questions disappear
Every system has trade-offs.
Every transition has costs.
Every country makes mistakes.
But comparisons do show something else very consistently.
The pattern that keeps repeating
Across countries and issues, the same dynamic appears:
- Punishment-heavy systems tend to hide behaviour
- Hidden behaviour tends to concentrate risk
- Concentrated risk tends to increase long-term cost
- And increased cost tends to arrive outside the original policy budget
Meanwhile, systems that accept persistence and design around it tend to:
- surface problems earlier
- intervene more proportionately
- reduce extreme harm
- and spend money more predictably
Not perfectly.
But measurably.
Why this matters before we talk about money
This comparison matters because it sets up what comes next.
If every country faced the same outcomes regardless of approach, cost would just be bad luck.
But when different assumptions produce different patterns of harm, cost stops being accidental.
It becomes a design choice.
Which leads us to the uncomfortable question we’ve been circling all along:
If some approaches reliably cost more and achieve less, why do we keep choosing them?
That’s where the money enters the conversation.
Because the next step isn’t moral.
It’s arithmetic.
And that’s exactly where we’re heading next.
Further reading & supporting information (International comparisons)
This post draws on comparative policy research, government data, and long-running evaluations rather than a single dataset or study. International comparisons are imperfect by nature — cultures, institutions, and histories differ — but consistent patterns emerge across multiple sources.
The aim here is not to prove that any country “got it right”, but to show how different assumptions about persistent behaviour tend to produce different system-level outcomes.
Drugs policy
- Portugal’s decriminalisation framework and subsequent evaluations (Portuguese Ministry of Health, EMCDDA)
- European Monitoring Centre for Drugs and Drug Addiction (EMCDDA) comparative reports
- US vs EU incarceration, overdose, and harm indicators
- World Health Organization (WHO) reviews of harm-reduction approaches
Key finding across sources: decriminalisation and treatment-first models reduce extreme harm and system cost, even where overall use does not disappear.
Sex work
- New Zealand Prostitution Reform Act evaluations
- German and Dutch regulatory frameworks and labour inspections
- UN and WHO guidance on health, safety, and exploitation risks
- Academic reviews comparing criminalised vs regulated systems
Key finding across sources: criminalisation increases invisibility and risk; regulation increases visibility, safety, and inspectability — without eliminating the activity itself.
Migration
- OECD and ILO reports on informal labour markets and exploitation
- UK Home Office, National Audit Office, and Migration Advisory Committee reports
- Spanish regularisation programmes (early 2000s) and fiscal outcomes
- Canadian temporary and sector-specific work visa programmes
Key finding across sources: where legal routes exist alongside demand, compliance and tax receipts improve; where routes are restricted, informal labour and enforcement costs rise.
Enforcement, punishment, and system cost
- OECD comparisons of incarceration rates and public expenditure
- Home Office and Ministry of Justice cost-of-crime modelling
- Academic work on deterrence, incentives, and policy feedback loops
Key finding across sources: punishment reshapes behaviour and markets more reliably than it eliminates them, often increasing long-term complexity and cost.
On interpretation
These sources do not offer neat answers or perfect models.
What they do show — repeatedly — is that when policy design assumes persistent human behaviour, systems tend to become more manageable, more transparent, and less expensive over time.
When policy design assumes behaviour can be eliminated through pressure alone, costs tend to rise while control weakens.
The consistency lies not in the decimals, but in the direction.
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