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Rosa Mas Giralt and Antonella Sarlo

Existing research from migration studies and comparative social policy has highlighted the need to develop better understandings of immigrants’ social rights and their inclusion/exclusion from welfare systems. This chapter contributes to this literature by exploring to what extent the UK and Italy, two countries very different in terms of immigration histories, management of integration and structure of their welfare states, have come to converge in the last 15 years in relation to the social inclusion of (documented) immigrants. To fully understand the social rights of immigrants we need to consider the intersection of the policies which regulate immigrants’ social rights (welfare, immigration and immigrant policies) with the systems of governance (national, regional and local actors, both statutory and non-statutory) that implement these policies and mediate access to social services. The chapter analyses the trajectories of immigrant and immigration policy in the UK and Italy while paying attention to the ‘vertical’ and ‘horizontal’ divisions of labour within the two states and the role of non-governmental organisations in complementing or substituting for retrenching public provision in this area. We argue that there are important similarities between the two countries: (1) national governments concern themselves largely with immigration policies (quotas and restrictions on newcomers’ social rights) while transferring responsibility (but not resources) for immigrant integration to local governments; (2) actors from the third sector ‘compensate’ for insufficient public provision at the local level while facing a lack of funding and institutional support. In both countries these features lead to a growing territorial differentiation in services for the social inclusion of immigrants.