Existing literature on City Networks (CNs), including studies on the migration and diversity policy field, look at CNs as instances of Multilevel Governance (MLG) policy-making. Yet, systematic research on the link between CNs and MLG is still scarce. The goal of this working paper by Tiziana Caponio is to understand how CNs on migration in different contexts conceive and frame their role in the governance of migration. What type of vertical and horizontal relations are CNs engaged in? And to what extent do these relationships configure the emergence of MLG-like policymaking processes? To answer these research questions, I undertake a policy frames analysis of the official discourses and main policy actions promoted by four CNs in different multilevel political settings, i.e.: the Eurocities Working Group on Migration and Integration, the European Coalition of Cities Against Racism (ECCAR) and the Intercultural Cities Programme (ICC) in Europe; Welcoming America in the United States. A key finding is that MLG, far from being an automatic outcome of city networking, is only one possible frame of policymaking interactions and not even the more relevant one.