Council of Europe report highlights rise in UK trafficking victims and migrant vulnerabilities

FOURTH EVALUATION ROUND
Measures to prevent and detect vulnerabilities
to human trafficking

EVALUATION REPORT
UNITED KINGDOM

GRETA
Group of Experts
on Action against
Trafficking in Human Beings

GRETA(2026)03

Adopted on 21 November 2025
Published on 5 May 2026

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Executive summary

This report, covering the period from July 2021 to November 2025, evaluates the measures taken by the United Kingdom (UK) to prevent vulnerabilities to trafficking in human beings (THB), detect and support vulnerable victims, and punish the offenders. In doing so, it pays particular attention to the use of information and communication technology (ICT) to commit human trafficking offences as well as to the use of technological innovations to prevent THB, protect victims, and prosecute traffickers. The report also evaluates progress made in selected areas examined by GRETA during previous evaluation rounds.

A series of steps have been taken to develop the legislative, policy and institutional framework for action against THB in the four constituent countries. Legislative developments include the adoption of the Nationality and Borders Act (NABA), which introduced changes to the system for the identification and protection of victims of THB, and the Online Safety Act, as well as the development of legislation aimed at preventing abuses in the employment sphere and child criminal exploitation. Following the UK general elections in July 2024, the UK Government has renewed engagement and consultation with civil society, including through the organisation of roundtables chaired by the Home Office Minister for Safeguarding and Violence against Women and Girls who was given the lead on modern slavery. GRETA welcomes the adoption of new policy documents, in particular the Home Office Action Plan on Modern Slavery 2025/26, Northern Ireland's Modern Slavery and Human Trafficking Strategy 2024/27, and Scotland's refreshed Trafficking and Exploitation Strategy in 2025.

The UK is a country of origin, destination and transit for victims of human trafficking. The number of referrals to the National Referral Mechanism (NRM) has significantly increased over the years (from 12 687 in 2021, to 17 390 in January-September 2025). Labour exploitation was the predominant form of exploitation and concerned mostly adult victims with foreign citizenship. For child victims, the main form of exploitation was criminal exploitation, affecting predominantly UK children. The UK has remained the first nationality of persons referred to the NRM, followed by Eritrea, Vietnam and Albania.

Considerable research has been carried out in the UK into vulnerabilities to THB and the effectiveness of preventive measures. Asylum seekers, refugees and irregular migrants are particularly vulnerable to THB, as well as migrant workers in sectors at heightened risk of exploitation, such as domestic and care work, hospitality and agriculture. Children and young persons are also particularly vulnerable to THB, including unaccompanied or separated children, children under the child protection system and children from ethnic minorities. GRETA welcomes the efforts made by the authorities to engage with persons with lived experiences of human trafficking.

Across the UK, child protection referral mechanisms have been set up in order to prevent child trafficking, identify children at-risk and refer them to assistance. Awareness raising on trafficking risks and online safety are taking place at schools. Measures have been taken to address the criminal exploitation of children, in particular the phenomenon of 'county lines'. However, less attention has been paid to other forms of exploitation of children. Effective prevention is also hampered by insufficient resources of local authorities. Further, due to a shortage of places in foster families and children's homes, many unaccompanied children have been placed in hotels or unregulated accommodation such as caravans or tents, GRETA urges the UK authorities to ensure that these children are placed in safe and appropriate accommodation and are appointed legal guardians. It also calls on the authorities to improve the support provided to children under the care of local authorities in their transition to adulthood with a view to preventing them from being trafficked.

The UK authorities have taken steps to prevent THB for the purpose of labour exploitation, such as the visa sponsorship and employer licensing systems, as well as obliging employers to pay domestic workers at least the national minimum wage. However, the safeguards put in place are insufficient, as demonstrated by the number of victims identified each year among migrant workers. GRETA calls on the UK authorities to improve effective possibilities for migrant workers to change employers and to increase the resources allocated to labour market enforcement bodies. GRETA also considers that the UK authorities should improve the provision of information to migrant workers and strengthen the prevention of trafficking in supply chains and the enforcement of the modern slavery statements.

The UK authorities have taken measures to improve the assessment of vulnerabilities of asylum seekers and irregular migrants, including through new screening guidance for asylum and immigration staff. However, the fact that migrants face increased risks of detention and deportation prevents them from reporting exploitation to the authorities and seeking support, a situation which is abused by traffickers to target migrants and maintain control over them. GRETA urges the UK authorities to ensure that a vulnerability assessment is systematically carried out at an early stage, to strengthen access to legal aid for asylum seekers, to provide safe and adequate accommodation to asylum seekers and refugees and to improve their access to the labour market.

GRETA considers that the UK authorities should take additional measures to address the gender dimension of human trafficking, including by developing interventions targeting the intersections between human trafficking and violence against women and domestic violence, measures aimed at reducing demand for the exploitation of persons in prostitution and at supporting persons wishing to exit prostitution, and further efforts to prevent child and forced marriages.

The 2014 Modern Slavery Strategy recognises homelessness as a vulnerability factor. Despite measures taken to prevent homelessness, GRETA notes that the 'no recourse to public funds condition (NRPF), which can be imposed on foreigners under working visa schemes or who are irregularly in the UK, increase risks of homelessness. GRETA calls on the UK authorities to assess the NRPF condition on vulnerabilities to human trafficking and reconsider its application to persons at risk of human trafficking.

People from Black and other ethnic minorities, as well as Roma and Travellers, are vulnerable to human trafficking due to intersecting factors such as poverty, discrimination and marginalisation. GRETA considers that the UK authorities should make additional efforts to prevent human trafficking of persons from disadvantaged minorities, including by addressing root causes (poverty, access to employment, education and housing and discrimination) and involving organisations or individuals representing ethnic minorities in the design of anti-trafficking policies and activities.

While welcoming the research conducted on the intersection between human trafficking and disability, GRETA considers that the UK authorities should take additional measures to address the vulnerability of persons with disabilities to human trafficking, including by developing guidance and training on human trafficking for professionals working with persons with disabilities and special needs and by strengthening the early identification of persons with disabilities who are at risk of trafficking.

With a view to reducing the delays in the identification of victims of human trafficking, the UK authorities are undertaking reforms to the National Referral Mechanism (NRM), alongside recruiting additional decision-making staff and devolving NRM decisions concerning children to local multi-agency panels. However, GRETA notes that the NRM decision-making process has become increasingly complex, with a high threshold of proof, turning into a quasi-judicial mechanism that is very difficult for victims to navigate. GRETA calls on the UK authorities to ensure that the identification procedure has a reasonable duration and that all individuals for whom there are reasonable grounds to believe that they are victims of trafficking are identified and referred for support, irrespective of their immigration status.

There have been changes in the duration of the assistance provided to victims of THB in England and Wales following the entry into force of the NABA. Victims are currently entitled to a recovery period of at least 30 days (previously it was 45) after a positive reasonable grounds decision, followed by a move-on period of at least 45 days (previously 90 days) after a positive conclusive grounds decision. In Scotland, access to support is available for 90 days or longer in some circumstances. In Northern Ireland, the provision of support after the conclusive grounds decision was extended to 12 months or more, depending on the individual circumstances of the victim. GRETA considers that the authorities should improve victims' access to long-term support in England and Wales and ensure victims' timely access to psychological assistance across the UK. As regards children, the authorities should ensure that specialised assistance is provided to all child victims and victims transitioning to adulthood, and make the Independent Child Trafficking Guardianship scheme operational across the whole territory of England and Wales.

GRETA welcomes the measures taken by the UK authorities to strengthen the criminal justice response to human trafficking. The National Crime Agency (NCA) has continued to co-ordinate targeted law enforcement operations on human trafficking, but part of its human resources have been reassigned to fighting migrant smuggling. There is a need for increased prioritisation and resources, better co-ordinated approach among law enforcement and other agencies, and strengthened guidance and training. GRETA considers that the UK authorities should reinforce financial investigations and the use of special investigative techniques in trafficking cases, ensure that human trafficking is investigated and prosecuted as such, and provide further training and guidance to relevant professionals.

Efforts are being made by police forces across the UK to use specialised web crawlers and other technology tools to detect human trafficking and collect and analyse digital evidence. The Online Safety Act 2023 introduced a list of priority offences, including human trafficking, for which online service providers are obliged to put in place the necessary systems and processes to identify, assess and address these offences. GRETA welcomes the efforts made to address human trafficking facilitated by ICT and considers that the UK authorities should strengthen co-operation with ICT companies and Internet service providers, develop data-sharing procedures with companies holding relevant data, and reduce risks of human trafficking facilitated by adult services websites.

In relation to follow-up issues from the previous evaluation round, GRETA welcomes the steps taken in England and Wales to increase the amount of funding allocated to legal aid providers. In Scotland and Northern Ireland, efforts are being made to offset shortages of legal aid providers through the provision of public funding or dedicated programmes for legal advice to victims of trafficking. Notwithstanding these developments, GRETA is concerned by the continuing difficulties faced by victims in accessing legal assistance and free legal aid. It once again urges the UK authorities to ensure that legal assistance is provided during the identification process and prior to entering the NRM, and that free legal aid is accessible across the UK and covers the procedure for obtaining state compensation.

The number of victims of trafficking who are granted compensation from the perpetrators by criminal courts remains low. There continue to be obstacles to the compensation of victims of labour exploitation in employment tribunals. GRETA urges the UK authorities to ensure that victims can obtain compensation of the full damage suffered and that compensation is available for all victims of trafficking, including undocumented workers. Further, GRETA calls upon the authorities to enable victims of human trafficking to effectively access state compensation within reasonable time (through the Criminal Injuries Compensation Authority and Northen Ireland's Criminal Injuries Compensation Scheme) and to review the eligibility criteria for state compensation in order to make it accessible to victims of all forms of human trafficking.

With a view to executing the judgment of the European Court of Human Rights in V.C.L. and A.N. v. United Kingdom, revised guidance on the non-prosecution of victims of human trafficking was produced in England, Wales and Scotland. However, GRETA is concerned that victims of trafficking continue to be prosecuted and convicted for offences that they were compelled to commit as part of their exploitation. GRETA once again urges the UK authorities to ensure that the non-punishment provision can be applied to all unlawful activities that victims were compelled to commit, that coercion and other means are not required for the statutory defence of children, and that the allocation of the burden of proof does not substantially hinder the application of the non-punishment provision.

Following the adoption of the NABA, access to the recovery and reflection period has been enshrined in UK law. Section 63 of NABA provides for the disqualification of victims from accessing the recovery and reflection period if they are a threat to the public order or if they claimed to be victims of trafficking in bad faith. In July 2024, the UK authorities updated the Modern Slavery Statutory Guidance, obliging the decision-makers to conduct an assessment of the re-trafficking risks of the victim once it is determined that a public order disqualification can apply. GRETA urges the UK authorities to ensure that 'public order' and 'bad faith' disqualifications are applied in very exceptional circumstances, with due regard to the circumstances of the individual cases and with respect for the principle of proportionality.

Section 65 of NABA provides for the granting of residence permits to victims of trafficking for the purpose of assisting victims in their recovery from any physical or psychological harm, enabling victims to seek compensation, or enabling victims to co-operate with the authorities in an investigation or criminal proceedings. In practice, requests for residence permits are often denied on the grounds that assistance and compensation can be obtained in the country of return of the victim. GRETA urges the UK authorities to ensure that all victims of trafficking who have received a positive conclusive grounds decision and whose immigration status requires it are issued a renewable residence permit.

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III. Addressing vulnerabilities to trafficking in human beings

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iii. Asylum seekers, refugees and irregular migrants

72. During the reporting period, the number of persons seeking international protection in the UK has increased: 108 000 individuals applied for asylum in 2024, double the number in 2021. The majority of applicants were adult men (59%), and the main countries of origin were Pakistan, Afghanistan, Iran, Bangladesh and Syria. 3% of the claims (4 104) were made by unaccompanied asylum-seeking children. 37 000 migrants arriving on small boats across the English Channel were detected in 2024 (compared to 28 526 in 2021 and 299 in 2018), mostly from Afghanistan, Syria and Vietnam, and the vast majority of them applied for asylum. In 2024, 84 000 individuals received an initial decision on their asylum applications which was positive in 47% of cases, compared to 67% in 2023. The decrease in the rate of positive decisions is attributable to the entry into force of the NABA which raised the standard of proof of asylum claims introduced after 28 June 2022. The main countries of origin of individuals granted asylum in 2024 were Iran, Eritrea, Sudan, Syria and Afghanistan. [91]

73. Staff of the Home Office who are competent to register and process asylum claims (UK Visas and Immigration, Immigration Enforcement and Border Force) are instructed to undertake a screening of asylum applicants with a view to establishing any health needs, disabilities and other vulnerabilities or safeguarding concerns, including if the asylum seeker is a possible victim of trafficking. The screening includes an interview based on a dedicated questionnaire. According to the authorities, staff follow mandatory safeguarding training to identify and address vulnerabilities of asylum applicants. There are also dedicated safeguarding and modern slavery champions to provide assistance to staff. Further, as part of the screening process, all asylum seekers must be provided with the leaflet 'Information about your asylum claim', which informs them of their rights and responsibilities as well as where to get support and legal aid. However, this leaflet is only available in English.

74. According to a joint report by UNHCR and ECPAT UK published in 2022, the assessment of vulnerabilities is not systematically carried out at the early stages of the asylum procedure and lacks a trauma-informed approach in order to allow individuals to disclose experiences and needs. [92] In May 2023, UNHCR published an audit report of the UK's screening procedures which highlighted that Home Office staff work under difficult conditions, with inadequate training, facilities, guidance and oversight. It recommended several measures, notably to ensure that the procedures are carried out by more specialised staff, develop standardised procedures, redesign the screening questionnaire, provide training to interview officers, and introduce safeguarding and modern slavery officers at points of initial contacts. [93] In July 2024, screening guidance was made available by the Home Office to relevant staff. Further, dedicated waiting and screening facilities were introduced for families and children (Kent Intake Unit and Manston) or vulnerable persons (Croydon). Further, in Kent, a dedicated training team was established and a training programme has been delivered to all new workers, who are also allocated a work-based mentor.

75. Accommodation of asylum seekers is delegated by the Home Office to private contractors running reception centres. Due to the increase in asylum seekers, the use of hostels and hotels has intensified over the past years. According to the authorities, Home Office staff put details of any safeguarding concerns or alerts on the accessible shared database for the hotel providers to provide appropriate accommodation. However, reports suggest that there is a lack of vulnerability assessment in the allocation of accommodation to asylum seekers and, as a result, vulnerable individuals, including possible victims of trafficking, are placed in inappropriate large-scale accommodation which increases risks of trafficking and exploitation. [94] Difficulties in relation to housing also arise after being granted asylum as refugees have only 28 days to transition from asylum accommodation and receive limited support to do so, which increases the risk of homelessness and vulnerabilities to human trafficking.

76. NGO interlocutors underlined that asylum seekers lack information and guidance through the asylum process, as well as access to timely and specialised legal aid. According to 2024 data published by the Law Society in relation to England and Wales, most legal aid providers are concentrated in big cities such as London and Birmingham, far from where asylum seekers are accommodated. [95] The lack of access to legal aid increases the risk of the asylum claim being denied, especially following the entry into force of the NABA and the IMA. In their comments on the draft report, the UK authorities indicated that following a comprehensive review of civil legal aid, the Ministry of Justice recently announced increases in legal aid fees for immigration and asylum, as well as housing and debt matters, which will inject an additional £20 million into the civil legal aid sector each year. In relation to Scotland, the authorities indicated that in 2023/24 civil legal assistance in immigration and asylum was funded by £12 million.

77. Asylum seekers have the right to work if they have been awaiting a decision on their asylum claim for over 12 months. Job possibilities are limited to the ones included in the Immigration Salary List (formerly entitled Shortage Occupation List) which usually require specific skills and qualifications. According to the authorities, asylum seekers are encouraged to take part in volunteer activities while waiting for their asylum claim to be processed and can participate in languages classes. However, the restrictions imposed on asylum seekers in terms of access to employment, combined with the low level of financial support they receive (around £50 per week, or £9 for those receiving meals in their accommodation), increase the risk that they will accept jobs in the informal economy or in exploitative conditions in order to meet their basic needs.

78. The number of migrants held in immigration detention has increased: 20 604 in 2024, which is 12% more than in 2023. The majority were from Albania, Romania and Brazil. [96] The statutory guidance "Adults at risk in immigration detention" was updated in May 2024. The guidance defines 'adults at risk' as individuals suffering from a condition or having experienced a traumatic event, including human trafficking, that would likely render them particularly vulnerable to harm if they are placed or maintained in detention. According to the guidance, in all cases in which immigration detention is being considered, an assessment must be made of whether the individual is an 'adult at risk'. Further, based on rule 35 of the Detention Centre Rules and rule 32 of the Short-Term Holding Facility Rules, medical practitioners must report to the Home Office cases in which there is evidence that a detainee may have been a victim of torture, or for any other reason their health would be injuriously affected by detention, for release to be considered. In January 2023, the ICIBI published a report on the third annual inspection of 'Adults at risk in immigration detention'. According to it, inspectors found missed opportunities by Home Office, health care and contractor staff to identify vulnerable detainees for whom rule 35 might be appropriate. It also noted that disclosures of detainees in relation to experiences of modern slavery were not always followed up. In their comments on the draft report, the UK authorities indicated that, following engagement with NGOs, they are currently reviewing the 'adults at risk' policy.

79. In October 2024, His Majesty's Inspectorate of Prisons published a report on the short-term facilities at Western Jet Foil, Manston and Kent Intake Units where migrants are detained following their arrival by small boats. The report noted that progress had been made in addressing the challenges caused by the increased arrivals of migrants, but also highlighted shortcomings, such as inadequate co-ordination among agencies, lack of safe environment for children, insufficient privacy and recourse to interpretation to facilitate the disclosure of vulnerabilities, as well as delays in taking safeguarding measures for vulnerable individuals. [97]

80. During the evaluation visit, GRETA visited the Heathrow Immigration Removal Centre (IRC) which combines Colnbrook and Harmondsworth removal centres under one management structure, making it the largest IRC in Europe, with a capacity of 965. It is a prison-like structure managed by a private company (Mitie Care and Custody Ltd). At the time of the visit, the IRC was holding around 700 adult men. About 50% of then had been issued a deportation order at the end of a prison sentence served in a prison in the UK. The rest were foreign nationals whose asylum claims had been rejected and who refused to leave the UK voluntarily. The main countries of origin of detainees were Albania, India, Pakistan and Romania. Within 48 hours of arrival at the IRC, detainees are interviewed by the induction teams which follow a questionnaire including questions about trafficking and vulnerabilities. An interpreter is present if needed. Detainees are also examined by medical staff who can apply rule 35 of the Detention Centre Rules if needed. Measures taken by IRC staff to identify possible victims of trafficking are detailed in paragraph 0130. GRETA notes positively the commitment of staff to detecting and supporting vulnerable individuals.

81. While recognising the challenges faced by the UK authorities in the context of the increased arrival of asylum seekers and irregular migrants, GRETA is concerned that the immigration legislation adopted in recent years (NABA and IMA) has increased vulnerabilities to human trafficking of persons with insecure or irregular immigration status. The fact that migrants face increased risks of detention and deportation prevents them from reporting exploitation to the authorities and seeking support, a situation which is abused by traffickers to target migrants and maintain control over them. Further, the NABA and IMA have considerably reduced opportunities to obtain refugee status in the UK and thus to receive protection and support which could reduce their vulnerability to exploitation and trafficking. The application of the 'public order disqualification' (see paragraph 255) and the 'no recourse to public fund' (see paragraph 97) have further increased these vulnerabilities by denying migrants access to support mechanisms and putting them at risk of homelessness.

82. GRETA urges the UK authorities to take further measures to address the vulnerabilities of asylum seekers, refugees and irregular migrants to THB, in particular by:

- ensuring that a vulnerability assessment of asylum seekers, refugees and irregular migrants is systematically conducted at an early stage, and that safeguarding referrals and measures are made;

- strengthening access to legal aid for asylum seekers at all stages of the international protection proceedings;

- providing safe and adequate accommodation to asylum seekers and refugees and improving their access to the labour market, vocational training and English language courses;

- raising awareness of asylum seekers, refugees and irregular migrants on their rights, the risks of human trafficking and the rights of victims of THB;

- assessing the impact of the Nationality and Borders Act and the Illegal Migration Act on the prevention of human trafficking and the vulnerabilities of migrants.

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V. Follow-up topics specific to the United Kingdom

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5. Residence permits

266. In its 3rd report on the UK, GRETA urged the authorities to ensure that all victims who have received a positive conclusive grounds decision and whose immigration status requires it are issued a renewable residence permit on grounds of their personal situation or for co-operating with the authorities in criminal investigations or proceedings, and that all child victims are issued a residence permit in accordance with the best interests of the child. [274]

267. The legislative framework on residence permits has been revised following the adoption of the NABA, which enshrined the granting of residence permits for victims of trafficking in domestic law. Section 65 of NABA provides that upon a positive conclusive grounds decision, victims who are not British citizens and do not have 'leave to remain' (i.e. residence permit) in the UK may be granted it if it is necessary for the purpose of: 1) assisting victims in their recovery from any physical or psychological harm; 2) enabling victims to seek compensation; 3) enabling victims to co-operate with the authorities in an investigation or criminal proceedings, all in relation to the relevant exploitation (i.e. the exploitation they received a positive conclusive grounds decision for).

268. The requirements in relation to residence permits are detailed in the Immigration Rules Appendix Temporary Permission to Stay for Victims of Human Trafficking or Slavery, [275] which came into force on 30 January 2023. The duration of the residence permits to assist victims in their recovery and for co-operation in criminal investigations or proceedings is of a maximum of 30 months across all applications, and for the purpose of seeking compensation, a maximum of 12 months across all applications. Residence permits allow victims to access public funds, work and study, and are also granted to dependent children of victims. Guidance for case workers on granting temporary permission to stay was issued in January 2023 and updated in August 2025. [276]

269. On 17 March 2022, the Court of Appeal of England and Wales handed down its judgment in EOG & KTT v Secretary of State for the Home Department. Both cases concerned whether the Secretary of State's policy on grants of leave to victims of trafficking was intended to and did in fact comply with the requirements of the Council of Europe Anti-Trafficking Convention. The Court found that the policy did not properly reflect the requirement of Article 14, paragraph 1.a, of the Convention. [277] In a more recent judgment of 28 February 2025 concerning foreign victims of trafficking who had received a positive reasonable grounds decision, but were denied a residence permit due to a deportation order, the Court of Appeal of England and Wales found that the policy excluding victims of trafficking who are subject to deportation orders or proceedings from leave to remain is lawful. [278] The Court also found that Article 14 of the Convention does not have direct effect in UK law, and that Section 65 of NABA does not intend to give effects to Article 14, paragraph 1.a., as it does not use the expression 'their stay is necessary owing to their personal situation'.

270. GRETA notes that the new grounds for leave to remain introduced by the NABA, namely, to "assist victims in their recovery from any physical or psychological harm", is narrower than "where necessary owing to personal circumstances" which applied previously. [279] In GRETA's views, granting a residence permit on account of the personal situation of the victim, which is provided for in Article 14, paragraph 1.a, of the Convention, covers a whole range of situations, such as the victim's safety, state of health and family situation.

271. Following the judicial reviews, the UK Government has revised its policy and guidance on temporary permission to stay for victims of human trafficking. [280] In July 2024, the UK Government temporarily paused all decision-making in relation to residence permits. In August 2024, decisions were reinstated, except in relation to residence permits necessary to assist victims in their recovery from physical or psychological harm. In October 2024, all decision-making resumed. In February 2025, the UK Government temporarily paused decisions that considered possible grants of residence permits for individuals subject to deportation orders. In June 2025, this temporary pause was amended to include individuals subject to deportation proceedings. In August 2025, decision-making resumed.

272. GRETA was not provided with official data on the number of residence permits granted and/or refused to victims of human trafficking. According to NGOs, which obtained data through Freedom of Information (FOI) requests, in 2020-2022, 364 adults and 21 children were granted leave to remain in the UK as victims of trafficking. In 2023, 123 victims were granted temporary permission to stay, including 110 on the basis of their recovery needs and 10 on the basis of their co-operation in criminal investigations or proceedings. It seems that no residence permits have ever been granted to victims to enable them to seek compensation. GRETA notes that the number of residence permits granted to victims is low compared to the number of victims who receive a conclusive grounds decision each year (6 578 in 2023, including both UK and foreign nationals). Further, the duration of the residence permit is often too short to allow victims to recover from trauma. In 2023, 24 victims received residence permits of less than 6 months, 36 received permits of 6 to 12 months, 39 received permits of 13 to 24 months, and 14 received permits of more than 24 months.

273. According to NGOs, requests for residence permits are often denied on the grounds that assistance and compensation can be obtained in the country of return of the victim. In order to determine if the support to recover from physical or psychological harm can be provided in the country of return, case workers are required to make an assessment of both the availability and the likely accessibility of treatment to the victim. Further, when a residence permit is granted to victims of trafficking, this is usually after a very lengthy procedure. GRETA was given the example of a victim who waited for 21 months before being granted a positive conclusive grounds decision, and another 12 months before being granted a residence permit. The process for requesting the renewal of a residence permit is also costly (between £1 000 and £3 000), which prevents many victims from requesting a renewal. In their comments on the draft report, the UK authorities specified that there is no fee payable for an initial consideration of a residence permit and in respect of an application for an extension of the residence permit where the individual has either not accrued in total 30 months of the granted residence permit or was not initially granted 30 months of the residence permit, and the application is to allow the individual to have a total of 30 months of the residence permit. When access to a residence permit is refused, this does not mean that victims will be returned to their country of origin, particularly if that country does not co-operate in their return or if it is considered that they would be at risk upon return (see paragraphs 278-280). As a result, many victims remain without regular migration status in the UK, despite having received a positive conclusive grounds decision.

274. As a result of these challenges, most victims of trafficking decide to go through the asylum process in order to regularise their stay in the UK. [281] However, pursuant to Section 16 of NABA, applications of asylum seekers "with connection to a safe third country", notably if they have transited through a safe country where they could have applied for asylum prior to arriving in the UK (which is the case of many victims of trafficking) may be declared inadmissible. Further, pursuant to Section 59 of IMA, asylum seekers from countries considered 'safe', such as EU countries and Albania, which is the case for a large number of victims of trafficking referred to the NRM, will have their asylum applications automatically declared inadmissible, except in exceptional circumstances. While Section 59 of IMA has not entered into force yet, the Border Security, Asylum and Immigration Bill does not propose to repeal it.

275. GRETA notes with concern the very low number of child victims of trafficking who are granted a residence permit (see paragraph 272). According to the UK authorities, for child victims, Section 55 of the Borders, Citizenship and Immigration Action 2009 requires that any functions related to immigration, asylum and nationality are discharged having regard to "the need to safeguard and promote the welfare of children." However, they did not specify in practice how the welfare of children is taken into account, and there is limited explanation in this regard in the guidance for case workers on temporary permission to stay.

276. In view of the limited progress made during the reporting period on access to residence permits for victims of trafficking, GRETA once again urges the UK authorities to ensure that:

- all victims of human trafficking who have received a positive conclusive grounds decision and whose immigration status requires it are issued a renewable residence permit, in accordance with Article 14(1) of the Convention, including on the basis of their personal situation;

- child victims are issued residence permits, in accordance with the best interests of the child, pursuant to Article 14(2) of the Convention;

- residence permits are issued to victims in a timely manner;

- victims of trafficking are not denied access to residence permits on the grounds of having committed offences as a result of their exploitation (see also the recommendation in paragraph 252).

6. Repatriation and return

277. In its 3rd report on the UK, GRETA urged the authorities to review the victim return and repatriation policies, including by ensuring that the principle of the best interests of the child is respected and that the return of victims is conducted with due regard for their rights, safety and dignity, is preferably voluntary and complies with the principle of non-refoulement, as well as by carrying out comprehensive risks assessment prior to the return, in compliance with Article 16 of the Convention. [282]

278. As noted in the previous GRETA report, the UK authorities do not run a dedicated return programme for victims of human trafficking. The Home Office Voluntary Returns Service (VRS) which is operated by Immigration Enforcement concerns all persons who are living in the UK without leave or have been refused leave to enter or stay in the UK. The assistance provided in the VRS includes a plane ticket, accessing travel documents and cash assistance from £1 500 to £3 000 depending on their personal circumstances and the country of return. The UK authorities indicated that, in 2023, the Home Office developed information sheets in English, Albanian and Vietnamese about the return programme and the support available in the country of destination. According to the authorities, individuals are encouraged to return voluntarily if they have no right to reside in the UK. They underlined that for any return, either voluntary or forced, all asylum and human rights claims are first carefully considered and individual assessments are made based on evidence taken from a wide variety of sources.

279. For victims referred to the NRM, risk assessment prior to the voluntary return is conducted by support providers under the MSVCC in England and Wales, or by the relevant support providers in Scotland and Northern Ireland. For instance, GRETA was informed that in Scotland, when victims express the wish to return to their country of origin and after given them time to reflect on their decision, the NGO TARA undertakes a risk assessment.

280. Different NGOs have also developed their own repatriation programmes. The Salvation Army operates the project 'Beyond' with a view to supporting victims wishing to return to their home country to reintegrate safely and with support. The process begins with a pre-departure plan to identify the needs of the victim, map out where the connections are and research the services that can be provided in their home country. This is followed by a risk and needs assessment to outline the plan on arrival. Contacts are maintained with the victims after their return to know whether they feel safe and if referrals to external organisations have gone as planned, and to identify any indicators of re-trafficking. The follow-up process can be in place for up to 6 months after they leave the UK. In addition, the project also offers victims a grant of up to £1 000.

281. There is no official data on the number of returns of victims of trafficking. According to data from the Salvation Army, between June 2020 and June 2024, a total of 178 adult victims assisted by the MSVCC accessed either the Government or NGO funded Voluntary Returns Service in order to return to their country of origin. [283] Further, in Scotland, at least 22 victims were supported in their repatriation in 2021-2024. There is no data on the voluntary return of child victims, nor forced returns of victims of trafficking.

282. The concerns expressed by GRETA in the previous report in relation to the victim's safety upon return remain valid. [284] A report of the IASC called on the UK Government to develop protocols and protection mechanisms for victims upon return to their home nation, transparently and clearly defining the UK responsibilities in this process. [285]

283. In 2024, UK International Development provided a short-term grant to IOM UK in order to examine the current capacities of UK support organisations to conduct risk assessments and develop risk management plans with victims of trafficking who choose to return to their country of origin. The project also included mapping of support services for victims of trafficking in Albania, Brazil, China, India and Pakistan, [286] as well as training of UK support organisations. In their comments on the draft report, the UK authorities stated that the 'Improving Reintegration Outcomes for Survivors of Modern Slavery' project, delivered by the IOM and funded by the Home Office through the Modern Slavery Fund, responded to the need for enhanced support in voluntary return and reintegration for survivors in the UK. Phase one ran from August 2024 to March 2025 and focused on strengthening the capacity of UK support providers assisting survivors with voluntary return or repatriation. According to the UK authorities, the project successfully delivered all planned outputs, including a national assessment of current return arrangements, five country-specific service directories, and a package of risk assessment and support tools. Webinars reached over 125 stakeholders across the UK, and a high number of attendees reported increases in knowledge and intention to apply learning. [287] The Home Office has extended the project until March 2026. This next phase has continued to improve reintegration outcomes by updating service mapping, delivering capacity-building activities, conducting lived experience research, and piloting virtual orientation support for survivors considering return.

284. While noting positively the efforts made by the UK authorities to ensure the safe return of victims, notably to develop risk assessment prior to return and provide information on the return programme, GRETA considers that the UK authorities should continue their efforts to ensure that the return of victims of trafficking to other countries is conducted with due regards for the rights, safety and dignity of victims, including by:

- developing further repatriation programmes for victims of human trafficking in co-operation with destination countries;

- collecting data on the number of voluntary and/or forced returns of victims of trafficking.

[287] Resources developed during this phase are available here: Improving Return and Reintegration for Survivors of Modern| IOM United Kingdom