Norway, since the late 1960s has formalised its "adapting education for all" policy on inclusion. South Africa has only recently moved in this direction. This paper investigates the background for these policies and their implementation in terms of 4 discourses of inclusive education. Our contention is that a critical humanistic discourse - not necessarily the most dominant in Norway at this moment in time ? is preferable to ones based individual pathology, constructivism or systems thinking. Secondly, these discourses of inclusive education take up, in differing degrees, the question of user empowerment. In Norway it has been the empowerment of the users, predominantly as individuals and to a lesser extent as members of their interest groups. In South Africa, the indications are that community empowerment is the more dominant goal. These different forms of empowerment, it is argued, will have differing regulative (Foucault) effects on the relationship with and organisation of professionals as both countries move to meet the demands of inclusion and special education needs.