ABSTRACT This article develops and applies an innovative methodology based on social network analysis and cluster analysis to analyze the organization of policymaking relations in multi-level political systems, focusing on the migration policy field. In doing so, it addresses four limitations of existing research on multi-layered migration policymaking, which tends to focus on policy and legal documents rather than real-world interactions, conceptualize governmental levels in morphological terms, neglect conflictual interactions, and narrowly focus on big cities. This innovative approach is applied to the heuristic case of Italian asylum policy after the 2015 “refugee crisis”, which allows to derive three conceptual claims about the organizations of multi-level migration-related policymaking interactions. First, these interactions can be highly conflictual and multi-level migration policymaking should not necessarily be seen as a negotiated order among public and non-public actors. Second, existing typologies need to be complexified, accounting for the significance of intricately nested and overlapping “multi-level networks” emerging over and above multi-layered institutional structures. Third, showing that Italian asylum policy actors interact more frequently and collaboratively with “like-minded” actors regardless of official roles and governmental levels, the article identifies a new “political” or “ideological” axis along which collaborative and conflictual relations can be organized.