A constitutive model is proposed for tailing soils subjected to freeze–thaw cycles based on the meso-mechanics and homogenization theory. The evolution of meso-structure upon loading was analyzed within the framework of breakage mechanism. When the new model is formed, tailing soils are idealized as composite materials composed of bonded elements described by an elastic brittle model and frictional elements described by a double hardening model. Based on meso-mechanics and homogenization theory, the nonuniform distributions of stress and strain within the representative volume element are given by introducing a structure parameter of breakage ratio with the derivation of the strain coefficient tensor, which connects the strains of the bonded elements and the representative volume element. The methods for determining model parameters are suggested based on the available tested results. The model proposed here can predict the deformation properties of tailing soils experiencing freeze–thaw cycles with acceptable accuracy. The strain-hardening and post-peak strain-softening behaviors of tailing soils under various confining pressures as well as different numbers of freeze–thaw cycles are well captured, and the dilatancy and contraction features are also adequately represented.