HUMAN TRAFFICKING WATCH · DISPATCH
GRETA’s Warning on the UK Response
Findings urge protection beyond immigration status and resources to confront structural vulnerabilities.
GRETA’s latest assessment of the UK urges protections regardless of immigration status, flags deterrent effects of recent laws, and calls for resources, survivor leadership, and systemic reforms that confront inequality and restore trust in the NRM.
On 5 May 2026, the Council of Europe’s trafficking monitor, GRETA, issued its latest appraisal of the United Kingdom, tallying legislative shifts against lived realities, and finding that protections weakened where immigration control loomed largest over exploitation disclosures. The experts urged UK authorities to ensure every potential victim of modern slavery is identified and referred for support irrespective of immigration status, a baseline entitlement that reporting pathways must honor if they are to function credibly. Recent laws that heighten risks of detention and removal, they concluded, actively discourage exploited people from approaching authorities or seeking help, compounding fear at precisely the juncture when intervention is critical. GRETA further judged that the government has not adequately addressed root causes of exploitation linked to socio‑economic inequality, which shape vulnerability long before a first referral is ever made. Survivor representation and consultation in the design of policy and interventions, they emphasized, are not optional supplements but prerequisites for responses that work as intended. The same day, the United Kingdom’s Independent Anti‑Slavery Commissioner published an analysis naming inequality, poverty, and structural barriers as enablers of abuse, aligning domestic oversight with the European appraisal. Against the country’s 2008 ratification of the anti‑trafficking convention, in force since April 2009, those parallel findings read as an unfinished obligation rather than a new discovery (Labib & Labib, n.d.)
Inside the system built to find and support victims, GRETA focused on the National Referral Mechanism, where the Nationality and Borders Act 2022 and the Illegal Migration Act 2023 have, in its view, raised barriers to identification and assistance. A high evidence threshold for victim identification, layered atop the chilling effect of immigration enforcement, adds delay and doubt at the very moment when certainty is most needed, diminishing the NRM’s capacity to be a doorway rather than a gate. First Responder organizations—already contending with underfunding—face additional pressures linked to these legislative changes, which squeeze time, training, and trust in equal measure across frontline encounters. GRETA recommended increasing resources for First Responders and increasing funding for local authorities, acknowledging that statutory duties fail where budgets empty and specialist capacity thins. That call arrived in a policy environment that has not seen a new cross‑government Modern Slavery Strategy for England and Wales since 2014, even though Parliament enacted the Modern Slavery Act in 2015, leaving national priorities to be inferred rather than integrated. The cumulative consequence is fragmentation, in which identification rates, referral quality, and follow‑on care depend less on need than on local resilience and institutional memory. The report reads that pattern not as an inevitability, but as a product of choices that can be reversed with clarity and investment (Labib & Labib, n.d.)
GRETA also examined the way information flows across enforcement and oversight agencies, finding that data sharing between immigration control and labour inspection has a deterrent effect on migrant workers who might otherwise report exploitation. When approaching an inspector risks alerting removals teams, the safer calculation is silence, and silence is the condition in which forced labour spreads, wages vanish, and health and safety rulebooks become decorative rather than protective. The experts urged the United Kingdom to address vulnerabilities across visa sponsorship schemes and to improve options for migrant workers to change employers, measures that would reduce dependency on abusive sponsors and blunt leverage built on status insecurity. They further recommended significantly increasing resources for labour market enforcement bodies, whose caseloads and authorities mean little without investigators, interpreters, and time to use them. GRETA called for action to improve the visa system for migrant domestic workers, where isolation in private homes and limited bargaining power magnify the harms of every bureaucratic barrier. Parallel to enforcement, the “no recourse to public funds” condition was identified as pushing certain migrants toward homelessness and destitution, and GRETA recommended reconsidering its application to survivors of modern slavery. In each instance, the throughline is pragmatic: remove deterrents, restore options, and the law has a chance to be visible where it currently recedes (Labib & Labib, n.d.)
Beyond entry points, the mechanics of recognition and redress drew sustained scrutiny, with GRETA identifying the high evidentiary threshold for victim status as a structural challenge and noting unresolved barriers to legal representation before National Referral Mechanism referrals. The report urged the United Kingdom to strengthen efforts that facilitate access to compensation for survivors of trafficking, a right that too often remains theoretical when paperwork outpaces legal advice and time limits. GRETA also highlighted ongoing failures to implement the non‑punishment principle where survivors were compelled to commit offenses during their exploitation, a doctrine intended to prevent criminalization from eclipsing harm. On disqualification from the recovery and reflection period, it noted the UK High Court had found the application of the Public Order Disqualification to be unlawful to date, underscoring the need for closer legal conformity. The experts further recommended that any disqualification on public order or alleged bad‑faith grounds be exceptional, proportionate, and assessed case by case, aligning practice with the convention’s protective design. Each of these findings speaks to trust, because due process that recognizes coercion, secures advice, and enables restitution is what renders identification meaningful beyond the moment of decision. Without that arc, administrative statuses turn brittle, and survivors face system‑induced attrition rather than stability (Labib & Labib, n.d.)
Survivor participation emerged as both a diagnosis and a prescription, with GRETA stressing that people with lived experience must be represented and consulted in the design of anti‑trafficking policies and interventions if programs are to meet needs rather than assumptions. The report also recorded inadequate provision of long‑term support and limited grants of leave to remain for confirmed victims of modern slavery, a pattern that sends people back into precarity after brief stabilization. Identifying and referring all potential victims regardless of immigration status, as GRETA urged, requires removing practical barriers—funding, training, and mandate clarity for First Responders—and addressing data‑sharing practices that push migrants away from assistance. Local authorities, asked to coordinate housing, welfare, and safeguarding, need predictable budgets that match the scale of responsibilities, not pilot‑to‑pilot improvisation. A cross‑government Modern Slavery Strategy that knits these elements together has been missing in England and Wales since 2014, leaving discretion to substitute for direction across agencies that must collaborate to succeed. The implications are not abstract; they are counted in missed identifications, inconsistent care plans, and survivors exiting services without routes to stability or status. GRETA’s argument is that architecture matters, and that the costs of neglect are cumulative as well as avoidable (Labib & Labib, n.d.)
The roots of exploitation, GRETA found, are entangled with socio‑economic inequality that policy has not adequately confronted, which means prevention begins long before enforcement and continues long after a case file closes. That analysis was echoed by the UK’s Independent Anti‑Slavery Commissioner, who, in a report published the same day, identified inequality, poverty, and structural barriers as conditions that enable abuse, reframing vulnerability as a policy‑made environment rather than a personal attribute. When wages fail to cover rent, when debts compound, and when services are rationed, coercion finds leverage that no inspection checklist can neutralize on its own. GRETA’s recommendations therefore reached beyond criminal justice into the configuration of safety nets and the portability of rights, asking the United Kingdom to see trafficking risks as outcomes of systems that can be re‑engineered. None of this displaces the need for investigations; it places them within a broader field of obligations that includes social protection, fair work pathways, and secure status for those emerging from exploitation. The point is sequence and sufficiency, because without upstream relief and downstream support, enforcement remains busy while vulnerability replenishes itself. In that cycle, the gap between intent and impact widens, and public confidence follows it down (Labib & Labib, n.d.)
Internationally, the United Kingdom’s commitments were clear on paper, having ratified the Council of Europe Convention on Action against Trafficking in Human Beings on 17 December 2008, with entry into force on 1 April 2009, and having enacted the Modern Slavery Act in 2015. GRETA’s monitoring, including prior evaluation rounds, identified issues that remain insufficiently addressed, among them barriers to legal representation before NRM referrals and deficiencies in applying protective principles, indicating that legislative intent has yet to be matched by sustained implementation. The intervening years have also seen policy shifts—the Nationality and Borders Act 2022 and the Illegal Migration Act 2023—that, according to GRETA’s analysis, increased obstacles to identification and support, pitting migration control against victim protection in the very system meant to deliver it. Strategy has not kept pace, with no new cross‑government Modern Slavery Strategy in England and Wales since 2014, leaving stakeholders to navigate without an updated national map. The tension is not theoretical; it surfaces in field decisions, budget lines, and the calculus of risk for people who must choose whether to speak. Meeting treaty standards, in that context, is a matter of design choices that align incentives with obligations, not of slogans or single‑department initiatives. On those choices, the report is unambiguous about direction even as it allows flexibility on means (Labib & Labib, n.d.)
The path charted by GRETA is direct, if demanding: identify and refer every potential victim regardless of immigration status; remove deterrents embedded in data sharing; and provide First Responders and local authorities with resources that match their mandates. It calls for addressing vulnerabilities across visa sponsorship schemes, improving options for workers to change employers, reforming the visa system for migrant domestic workers, and reconsidering the “no recourse to public funds” condition when it pushes survivors toward destitution. It urges attention to the high evidence threshold that constrains identification, access to legal representation before NRM referrals, and concrete mechanisms to secure compensation, implementing in practice the non‑punishment principle and reserving disqualification from recovery periods for exceptional, proportionate, case‑specific situations. It asks, too, for survivor representation in policy design and for an updated, cross‑government strategy to bind disparate efforts into a coherent whole, reducing variance born of postcode, budget cycle, or political weather. None of these steps are novel; many have been on the record for years, but their repetition in 2026 is its own finding. The measure of this agenda will be whether exploited people in the United Kingdom can safely come forward and find durable support, not whether offices can point to plans. By that standard, the work is plainly unfinished (Labib & Labib, n.d.)
Locations: United Kingdom, England and Wales
Tags: policy, research, international, labor