This article explores the responses of European local authorities to the public service needs of residents with irregular immigration status and the tensions with national governments to which this can give rise. Drawing on a study of responses by national and local tiers, including a mapping of national legal frameworks on entitlements to health care and education, it identifies factors that lead to divergence between local and national policy framing and responses. Finding that socio-economic and individual consequences of exclusion dominate in shaping local framing of policy responses in contrast to national government priorities, it explores the implications for modes of multi-level governance (MLG) on this issue. It expands on the concept in the literature of 'decoupling', contrasting relationships of overt conflict with low-visibility strategies of conflict avoidance; demonstrating the differing forms this 'shadow politics' of migrants' rights and shadow provision of services can take, including arms-length provision through NGOs. Thus the dynamic of MLG is itself one part of explaining the nature of local responses to the challenges that migrants with irregular status can pose.