Civil society organisations (CSOs) represent a key part of the political landscape surrounding refugee policy: as highly flexible bodies, they are able to fill more effectively the gap between the formal political institutions of the state and international society and the lived experience of refugees on the ground. However, despite growing interest in these organisations, there has not been an attempt to model a comprehensive framework of how the wider political and social debate about refugee policy has translated into the pattern and nature of CSOs. This paper offers such a framework, drawing on Sicakkan’s (2021) cleavage model, as operationalised through political opportunity structures. It highlights a number of expected elements in both transnational and national CSO activity that will form the basis for on-going research.