This article provides a cross-national comparison of social assistance as applied to migrants. The cases, including Korea, are classified into four types of welfare regime, social democratic, conservative, liberal, and East Asian, with three countries assigned to each category. The focus is on the extent to which social protection in each country is inclusive or exclusive of migrants. Differences across the welfare regimes are stark. The social democratic regime is the most inclusive, conditioning eligibility primarily on residence. The conservative type imposes more restrictive conditions, usually requiring long-term residence of five years or more. What distinguishes the liberal welfare regime is that social assistance coverage is limited to select migrant groups, such as permanent residents and recognized refugees. Welfare regimes of the East Asian type are marked by a “nationals-only” principle that largely excludes migrants from eligibility. Korea, in particular, exemplifies a model exclusive of almost all foreign-born residents, granting social assistance only to asylum seekers and a segment of marriage migrants. Given the growing trend of settlement migration, Korea will need to consider gradually extending social assistance coverage to non-national residents.
In this article, I examine the UK’s social assistance system as it applies to migrants and explore its implications for Korea. Migrants’ eligibility for social welfare benefits in the UK is primarily determined by two principles: the No Recourse to Public Funds (NRPF) condition and the Habitual Residence Test (HRT). Notably, since Brexit, the extension of the points-based immigration system to EU and EEA citizens has further intensified welfare exclusion linked to immigration status. Even within the framework of Universal Credit―introduced under the Welfare Reform Act 2012―barriers to benefit access have become more entrenched for migrants. Drawing upon UK government statistics on Universal Credit claims by immigration status, released for the first time in 2025, this article provides an empirical analysis of benefit receipt among migrant populations. With respect to policy implications for Korea, I suggest: (1) fostering public deliberation on eligibility criteria while streamlining administrative procedures; (2) developing a database on welfare benefit receipt by migrants to enable evidence-based policymaking; and (3) incorporating humanitarian exemption clauses.
This article examines the manner in which Japan’s social assistance applies to the growing population of foreign nationals and draws policy implications for Korea. The principal issue identified is that livelihood protection, which under the spirit of Article 25 of the Constitution ought to function as a minimum guarantee, has not been recognized as a legal right but has instead been applied only mutatis mutandis to foreign-born residents. To provide background, this article contextualizes the terminology used to classify foreigners into different categories, changes in the scale and composition of the foreign-born population, and the various types of residence status. The article also examines how foreign-national residents, depending on whether or not they have registered residence, may have differing levels of access to social security in general and may be granted exceptions to rules excluding foreigners from livelihood protection. It provides an overview of the basic principles and operation of livelihood protection and presents the current criteria for its quasi-application to foreigners, linked to their residence qualifications. It also traces the formation of, and subsequent changes in, the Livelihood Protection Act, outlines the contours of relevant debates, and considers policy implications from the perspective of asking who constitutes the community of shared life on which social assistance ought to be based.
This study compares the social rights granted to immigrants in France by residency status and examines the issues raised by recent policy changes, including the 2024 immigration reform. France has long maintained a universal framework of social rights grounded not in nationality but in residency and human dignity, through the 1946 Constitution and the post-war social security system. Recent legislative and administrative measures, however, have increasingly linked access to social rights to legal residence and social contributions. The study reviews the protection of social rights across different categories of migrants―refugees, legally residing workers, international students, and irregular migrants. It concludes by discussing the implications of the French experience for South Korea, where social rights remain largely nationality-based, underscoring the relevance of a universal, dignity-based approach.
Opioid analgesics are classified as controlled substances, yet they remain essential for managing severe pain in patients with cancer, for example. Like Korea, the United States and Japan strictly regulate the prescription, dispensing, and use of these substances. Furthermore, both countries have established clinical guidelines to ensure the effective and safe use of prescription opioids for chronic pain management. With the expansion of home-based medical care, policies are also being implemented to prevent the misuse and abuse of opioids among outpatients. The experiences of the U.S. and Japan emphasize that policy interventions are essential for balancing the appropriate medical use of opioids with the prevention of their misuse and abuse.
The “10-Year Health Plan for England” responds to stagnating life expectancy, growing multimorbidity, record waiting lists, declining public satisfaction, and weak productivity in the NHS. It centres on three shifts―from hospital to community, from analogue to digital, and from sickness to prevention―backed by reforms to governance, workforce, transparency, and technology-enabled care. Yet, significant doubts remain about whether current funding levels, workforce capacity, social care provision, and digital inclusion are sufficient to make these ambitions achievable in practice. Ongoing monitoring will be essential to assess how these challenges are addressed in practice and whether the Plan can move from aspiration to delivery.
Germany has incorporated full-day care for primary school-aged children into a federally guaranteed legal framework and has further supplemented the means of realizing this entitlement during school holidays. As a result, care that was previously provided in a fragmented manner across schools and the child-and-youth welfare sector has been restructured into a legally guaranteed system of public support. This article examines the types and current conditions of full-day care in Germany and finds that regional disparities, unmet demand, and constraints in financial and human resources remain significant challenges in practice. The German case demonstrates that care policy for primary school-aged children is not merely a matter of expanding services, but a complex policy field that requires careful consideration of legal entitlement, the coherence of delivery structures, the stability of operational foundations, and the maintenance of quality standards.
This article examines the key findings of the evaluation report on Germany’s basic pension supplement (Grundrentenzuschlag), introduced in 2021, and draws implications for Korean’s pension reform. According to the evaluation report, as of 2023, 12.29% of old-age pension recipients qualify for the supplement; however, the income test disqualifies nearly half of all eligible recipients (49.5%) from actually receiving it, and the average supplement among recipients ranges from 67 to 103 euros per month, depending on region and gender. The gender gap in receipt of the basic pension supplement is pronounced: while 18.20% of female old-age pension recipients and 4.57% of male recipients qualify for the supplement, the income test works to women's particular disadvantage ― only 46.6% of eligible women actually receive the supplement, versus 70.9% of eligible men. The German basic pension supplement has demonstrated that it is institutionally feasible to support long-term, low-wage contributors through a dedicated supplement mechanism even within an earnings-related pension system; nevertheless, the operational evaluation makes clear that considerably more refined design is needed.
Germany has developed a variety of alternative residential care models to help seniors live comfortably in everyday life in family-like residential settings. Spearheaded by the German Center for Gerontology (KDA), these initiatives have introduced new approaches that address the limitations of conventional models by creating homelike environments, integrating local infrastructure, and ensuring residents’ rights to self-determination. The German government has also expanded financial support through long-term care insurance to promote innovative housing arrangements for older people. Legislation enacted in 2025 further accelerated the adoption of these alternative models. This article examines the residential long-term care models pursued in Germany, with particular attention to Bavaria’s outpatient-supported communal housing (abWG).
