At a time of global unrest and in the aftermath of the pandemic in what has been described as ‘an altered world’ [1], the challenges facing European nations and beyond in ensuring quality education for all seem insurmountable. A vehicle by which this can be achieved is inclusive education. However,  how inclusive education is understood globally is highly contested and it is regarded as being socio-culturally and historically situated [2,3]. It is argued that the theory and practice of inclusive education lacks a tight conceptual focus, leading to ambivalence and confusion in its enactment [2] - ‘an enigma of ‘wicked proportions” [4]. In a critical systematic review of global inclusive education [5], an extensive range of understandings of what inclusive education constitutes emerge. For some, the problem is seen as residing within the contradictory interests and intentions within public policy [4]. Others position it in relation to paradigmatic wars [6,7]. It has even been argued that it is a redundant concept, Honkasita and Koutsokenis [3] making a case for the term ‘inclusion in education’ on the basis that the former is in danger of becoming an ‘empty signifier’. 

Slee [8] highlights attempts to silence inclusive education through the colonisation of its language, arguing that the ‘structures and cultures of schooling reinforce privilege and exacerbate disadvantage’ (p.11). Rix [9] attests that the quest for certainty has led to the creation of bounded systems with the function and position of individuals proscribed by the system. Whilst many perceive exclusion and inclusion as dichotomous, Hansen [10] makes the case that inclusion can only be understood in relation to its ‘other’ – exclusion: ‘inclusion presupposes exclusion’ (p. 94). Mowat [7] builds on this argument to postulate that ‘inclusion and exclusion lie on a continuum with fluid and not static boundaries that are experienced differentially and contextually’ (p.39). It therefore follows that the imperative is to seek to understand the nature of these boundaries, the underlying philosophical and political ideologies and who and what determines them. 

Commitments to inclusive education have been articulated in policy across the UK and Ireland, in the context of increasingly inclusive rhetoric in education policy globally over recent years. Knight, et al. [11] identify significant divergence in the articulation and portrayal of inclusive education policy within and across the four nations that constitute the United Kingdom. Within the context of educational reform, they raise issues around the enactment and implementation of policy from a practitioner perspective and comparability for researchers across the nations, particularly pertaining to issues of equity and injustice.

Building on a critical policy analysis of the articulation and portrayal of inclusive education policy across the four nations that constitute the United Kingdom [11], within each of which education is a devolved function of government, the paper seeks to understand how England, Wales, Scotland, Northern Ireland, and Ireland articulate and portray their inclusive education policies and the political and ideological motivations and priorities that are apparent within these policies. The paper explores the commonalities and differences, challenges and tensions in public policy and its enactment across the five nations through a critical analysis of policy and reviews of policy, relating this to current research in the field. It constitutes:

Critical analysis of policy based around the questions of:

• How do the 5 nations articulate and portray their inclusive education policies?
• How are differing political and ideological motivations and priorities signposted and acknowledged in inclusive education policy in the 5 nations?

Examination of policy into practice (including reviews of current systems)

Identification of challenges and next steps.

Educational policy does not reside within a vacuum. It is shaped by the wider context in which it is formed and the culture, value and belief systems therein [12] in an iterative process, resulting in intended and unintended consequences [11]. It is both the product of deliberations and the process by which policy is formed, articulated and translated into practice. Rather than conceiving policy as a straightforward linear process [13], the starting point of this paper is to recognise the dynamic and complex nature of this process. The paper draws upon the principles of critical policy analysis such that the political and ideological underpinnings of policy but also its relationship to practice can emerge. In selecting the policies and reviews for analysis within each nation, the team took account of their relevance, provenance and currency. Each nation interrogated the documents in relation to the objectives previously articulated using a process of thematic analysis. Thereafter a comparative critical frame was produced to enable similarities and differences, challenges and tensions to emerge both within and between the nations in the framing of policy and its enactment. Through this analysis we find not only divergence between the five nations, but also within the policy of each nation, with varying impact on inclusive education practice. While documentation from Scotland shows a clearer voice and fewer examples of problematising the learner, across all nations we see complicated messaging and a lack of coherence in inclusive education policy. Through this reflection on policy and practice in each nation, we propose recommendations for each nation, along with considerations for UK and Ireland as a whole.

The European Agency for Special Needs and Inclusive Education (EASNIE) has noted that, while all European countries demonstrate a commitment towards the creation of more inclusive education systems, the means by which they go about this is shaped by their past and current contexts and histories [14]. Watt [14] draws attention to the lack of progress with regard to the recommendations of the United Nations that the UK should ‘adopt and implement a coherent strategy with concrete time and measured goals on increasing and improving inclusive education’ (p. 265, drawing on UNCRPD, 2017:11). Whilst cautioning against the unthinking application of policy borrowing [16], there is no doubt that there is much to be gained from examining in depth the commonalities and contradictions in the articulation and enactment of policy in inclusive education within and across nations as it is only by this means that tensions and challenges within the system can come to light and the aim to ensure quality education for all children and young people be realised, as expressed within the Sustainable Development Goals. There is no under-estimation of the scale of the task, and it is hoped that the findings from this study will enable deep and critical reflection which should inform inclusive education policy across Europe and beyond, creating the conditions for effective policy making and practice and rigorous research.

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