Policy convergence within the United Kingdom and France has become apparent in recent years in the form of new migrant incorporation and citizenship regimes that have decidedly assimilationist roots. Traditionally, pluralist Britain has followed a hands-off approach to integration, allowing immigrants to maintain their ethnic or racial identities whereas France has pushed for full civic assimilation at the expense of those same identities. Now, 'earned citizenship' -- which demands that migrants bear the brunt of integration through a series of exams and expected civic activism before achieving the 'prize' of liberal rights and protections -- has become the policy norm in both states. Most explanations for this shift of immigrant incorporation center on economic problems, social cohesion issues, or rate of migration. I argue that is not the demographics of migration that has caused this policy convergence but rather the perception of citizenship itself in these two states. Citizenship has undergone a transformation, from a legal status with rights and privileges available to immigrants after a set residency period to a status that can only be achieved through proof of loyalty and deservedness, after which one is able to access the full catalogue of rights and protections. By changing the perception of citizenship, the state changes the citizenship regimes that aim to incorporate migrants into society. These regimes are influenced by historical events and institutional path dependency, but are still malleable and evolving entities. By focusing on the case of the United Kingdom, I demonstrate that the literature of citizenship regimes has overlooked the ability of these regimes to adjust and change, at times drastically, due to a disconnect between the citizenship theory literature and the citizenship regime literature.