• Reform the NRM to facilitate timely, consistent determinations of victim status for foreign and UK national victims.
• Enhance consistent, proactive identification by screening for sex and labor trafficking indicators for all potential victims, including individuals subject to immigration control, and ensure all trafficking victims are referred to services.
• Ensure victims are not inappropriately penalized solely for unlawful acts committed as a direct result of being trafficked.
• Expand the number of First Responder Organizations (FROs) and standardize training for all FROs to ensure consistency and quality of NRM referrals.
• Vigorously investigate and prosecute trafficking crimes, particularly in Scotland and Northern Ireland, and seek adequate penalties for convicted traffickers, which should involve significant prison terms.
• Provide additional resources to the labor inspectorate to expand its capacity to identify potential trafficking crimes and consider expanding its mandate to monitor additional high-risk sectors, such as the care and hospitality sectors.
• Expand the Independent Child Trafficking Guardians (ICTG) program nationwide and increase efforts to provide services to individuals removed from the ICTG program at age 18 to ensure adequate long-term recovery.
• Further expand protective services for victims participating in criminal justice proceedings.
• Increase efforts to proactively identify victims exploited in Northern Ireland, especially child victims of forced criminality.
• Increase oversight and address structural weaknesses of short-term visa schemes to decrease vulnerabilities to trafficking.
• Expand long-term care and assess outcomes of post-NRM support.
• Improve victims’ ability to access court-ordered restitution in criminal cases and compensation through civil proceedings.
• Develop a new Modern Slavery Strategy.
• Ensure the statutory definition of trafficking under the Modern Slavery Act (MSA) and similar provisions in Northern Ireland do not require movement of the victim as an element of the crime.
• Strengthen measures on transparency in supply chains, including holding companies to account for noncompliance.
• Strengthen anti-trafficking efforts in the British Overseas Territories and in Northern Ireland.

The government slightly increased anti-trafficking law enforcement efforts.

The laws of England, Wales, Scotland, and Northern Ireland criminalized sex trafficking and labor trafficking. The 2015 MSA, applicable in England and Wales, and a similar statute in Northern Ireland, required the element of movement of a victim in the definition of “trafficking.” Scotland’s human trafficking law, by contrast, did not require victim movement in the definition of trafficking. However, other provisions in the laws of England, Wales, and Northern Ireland criminalized “slavery and servitude, and forced or compulsory labour,” which could be utilized to prosecute trafficking crimes that did not involve victim movement. The 2015 MSA and related statutes prescribed penalties of up to life imprisonment, which were sufficiently stringent and, with regard to sex trafficking, commensurate with those prescribed for other grave crimes, such as rape.

As of December 2024, the government reported at least 2,738 active law enforcement investigations of new and ongoing trafficking crimes, compared with 3,360 in December 2023. The government initiated 2,453 investigations in 2024, compared with 2,269 investigations in 2023. The Crown Prosecution Service (CPS) prosecuted 454 defendants on trafficking charges, compared with 410 prosecutions in 2023. Courts convicted 353 traffickers, compared with 311 convictions in 2023. CPS data did not disaggregate between sex and labor trafficking, nor provide data on the sentences of convicted traffickers or the percentage of convicted traffickers serving prison time. Civil society and the Home Affairs Committee continued to report case backlogs across the judicial system may have hindered successful investigations and prosecutions. Police noted investigating trafficking cases that occurred outside the UK was time consuming and complex. The government did not report any investigations, prosecutions, or convictions of government employees complicit in trafficking crimes.

In 2024, Scottish authorities initiated 187 trafficking investigations, compared with 171 investigations in 2023. Scottish authorities referred 21 cases to the Crown Office for prosecution, compared with 72 cases in 2023. Scottish authorities did not report any convictions for the second consecutive year, compared with four convictions in 2022. Police Scotland maintained a specialized anti-trafficking unit, which also cooperated with law enforcement across Europe on trafficking investigations. In 2024, authorities in Northern Ireland initiated 24 investigations, compared with 129 investigations in 2023 and zero in 2022. Northern Irish authorities prosecuted four suspected traffickers (four in 2023) and convicted three traffickers (one in 2023). Observers reported need for greater staffing and resource allocation in Northern Ireland to pursue human trafficking investigations.

The Home Office allocated £610,000 ($772,400) to the Modern Slavery and Organized Immigration Crime Unit to support the police in combating trafficking and organized immigration crime. The government trained police, immigration officials, government officials, front-line practitioners, and first responders, including on victim identification and investigative techniques. A 2024 House of Lords report recommended the government increase training and use of financial investigation techniques in trafficking crimes. The National Crime Agency (NCA) continued anti-trafficking projects and led a working group on online investigations. Some police forces supported “victim navigators” – independent social workers embedded within police units – across England and Wales to support victims through the criminal justice process, and the Scottish government funded two victim navigators. An independent review of the program found improved criminal justice outcomes on cases involving victim navigators; a 2024 House of Lords report recommended the program be implemented nationally. Police Scotland provided anti-trafficking training to various law enforcement officials, and Scottish authorities provided an NRM toolkit to guide first responders on trauma-informed victim interviewing. Observers noted the need for systematic training on investigative techniques and victim identification in Northern Ireland.

The UK participated in 14 Joint Investigation Teams (JIT) with EU Member states and EUROPOL. The UK cooperated with partners bilaterally and multilaterally on law enforcement activities, including partnerships with Romania, Albania, and Vietnam. Scottish authorities cooperated on international trafficking cases or provided legal assistance in 21 cases and in 2024, extradited five traffickers to Scotland to face criminal proceedings for human trafficking offenses committed in Scotland. Police Scotland established a JIT with Romania to coordinate on human trafficking investigations. Northern Irish authorities cooperated with other UK jurisdictions and Irish counterparts on law enforcement efforts and participated in investigations with Lithuania and Brazil. A 2022 case involving a Saudi diplomat assigned in London who allegedly exploited his domestic worker in conditions indicative of labor trafficking remained ongoing.

The government maintained victim protection efforts.

The government maintained an NRM as the framework for identifying victims and providing protection services. Designated FROs, including police, border force, local authorities, and NGOs, referred potential victims into the NRM. In 2024, first responders referred 19,125 potential trafficking victims to the NRM nationwide, compared with 17,004 in 2023. The Home Office maintained a database with disaggregated information, including the source of referral, nationality, and type of trafficking. Of the referred potential victims, 74 percent were male and 26 percent were female. Authorities identified 5,999 child potential victims, a decrease compared with 7,432 in 2023. Authorities identified 13,100 adult potential victims, an increase compared with 8,622 from 2023. The age of referral was unknown for 26 potential victims. UK nationals (4,441) comprised the majority of NRM referrals, followed by Albanian nationals (2,492), and Vietnamese nationals (2,153). Consistently, over five years, UK nationals comprised the majority of potential victims. Labor trafficking, including forced criminality, was the most common form of exploitation. Authorities categorized 1,845 referrals as “county lines” cases, a form of forced criminality in which traffickers force victims, often children and young adults, to transport drugs. A Home Affairs Committee report expressed specific concern over increased child victims exploited in forced criminality. In Scotland, first responders referred 920 potential victims to the NRM, compared with 765 referrals in 2023. In Northern Ireland, officials referred 651 potential victims to the NRM, compared with 462 referrals in 2023. In Wales, first responders referred 563 potential victims to the NRM, compared with 559 referrals in 2023.

Trafficking victims could access government services in the NRM following a referral and positive “reasonable grounds” decision. The “reasonable grounds” threshold, as amended by the 2022 Nationality and Borders Act (NABA), and subsequent legal challenges, functioned as the gateway to support in the NRM. Government officials in England and Wales were required to notify the Home Office when they identified potential victims, even if the potential victim did not wish to enter the NRM. Such referrals, which were categorized as “duty to notify,” increased in 2024, the highest rates in a year since the NRM began. Once an FRO referred a potential victim to the NRM, the Home Office’s Single Competent Authority (SCA) or Immigration Enforcement Competent Authority (IECA) was responsible for making a “reasonable grounds” decision on whether the individual may be a trafficking victim. A positive decision indicated authorities determined an individual was a potential trafficking victim. The SCA handled NRM referrals for most cases, including for UK nationals; the IECA, created in 2021, made decisions in cases involving adults subject to immigration control. Experts criticized the creation of the IECA and the return to a “dual system” approach for identifying victims – one for UK citizens and another for individuals subject to immigration control – noting many victims who lacked secure immigration status may not be identified or would fear coming forward to seek support.

Once potential victims with positive “reasonable grounds” decisions entered the NRM, the SCA or IECA then made a “conclusive grounds” decision to determine if a potential victim would receive official victim status. The SCA or IECA aimed to make a “reasonable grounds” decision within five working days of the referral. If the SCA or IECA made a positive “reasonable grounds” decision, adult victims in England and Wales received support for at least 30 days or up to the point when a “conclusive grounds” decision was made, whichever was longer. In Scotland, unlike in England and Wales, NGOs reported potential victims could access services prior to a positive “reasonable grounds” decision, and potential victims received support for 90 days or until authorities made a “conclusive grounds” decision, whichever came first. In Northern Ireland, potential victims received support for a minimum of 45 days while authorities reviewed their cases. Across the UK, if authorities recognized an individual as a victim per the “conclusive grounds” determination, under NABA, the victim was not guaranteed additional recovery periods or services.

“Conclusive grounds” determination wait times increased from an average of 526 to 637 days from 2023 to 2024. NGOs and a 2023 Home Affairs Committee inquiry reported the long wait times were detrimental to victims, including their mental health or, in some cases, resulted in victims choosing not to receive government support. Of 19,125 NRM referrals in 2024, 89 percent (17,168) were still awaiting “conclusive grounds” decisions at the end of the year. Although potential victims continued to receive services under the Modern Slavery Victim Care Contract (MSVCC) while waiting final decisions, the high volume of cases affected victims’ quality of care.

In 2024, the government reduced the backlog of referrals and decisions, having hired an additional 200 decision-making staff, resulting in 17,304 “conclusive grounds” decisions, the highest number of such decisions in a year since the NRM began. However, government officials and civil society reported the NRM’s functionality still remained strained due to the significant number of referrals and backlogs.

The government continued to implement anti-trafficking measures of NABA with the stated intent of clarifying in law the UK’s international obligations for trafficking victims. The previous government claimed undocumented migrants were misusing the NRM system to avoid deportation. Civil society, some government officials, a House of Lords report, and the Home Affairs Committee found claims of alleged abuse of the system “not compelling” and urged the Home Office to submit data to support this assessment. NABA required individuals claiming asylum to provide information to authorities related to if they are trafficking victims within a specified time period, although the government made available a “good reasons” ground for providing information outside the specified period; it increased the “reasonable grounds” threshold to require proof of additional “objective factors,” beyond a potential victim’s testimony, before authorities could issue a “reasonable grounds” decision. The Home Office reported NABA’s changes to the threshold were intended to increase the quality of information provided in referrals and improve the speed of decisions. NABA also reduced the minimum recovery period from 45 days to 30 days and limited additional recovery periods; added two disqualification statuses for potential victims on the basis of “bad faith” or “public order” if they were involved in serious criminality or threats to national security or in cases where they claimed to be a victim of human trafficking in bad faith; and specified the criteria by which authorities could grant confirmed victims temporary permission to remain in the UK, including where necessary for assisting victims to recover from exploitation, to receive compensation, or to cooperate with a criminal investigation.

Since the implementation of NABA began in 2022, subsequent legal challenges to the requirement for objective evidence for a “reasonable grounds” decision and the “public order” disqualification resulted in the government issuing revised guidance on the implementation of those provisions while decisions were paused from July 2023 to January 2024. However, even after the legal challenge, NGOs noted such requirements remained at a high threshold, and alleged that NABA created impediments to victim identification; conflated human trafficking with migrant smuggling; disproportionally impacted foreign victims; and increased reconsiderations and disqualifications. NGOs urged the government to prioritize victim protection and NGOs and experts, including organizations specializing in international law, recommended the government review and amend or repeal the modern slavery portions of NABA. Civil society expressed concern the government did not consult civil society before passing NABA. Some officials in Northern Ireland and Scotland criticized the negative impacts of NABA, including on reduced victim identification.

NRM data showed ”reasonable grounds” decisions made by UK authorities were 53 percent positive in 2024 compared to 55 percent in 2023. Additionally, government data showed 36 percent of “reasonable grounds” decisions made by the IECA were positive, while 57 percent of “reasonable grounds” decisions made by the SCA were positive. Average wait times for initial “reasonable grounds” decisions decreased to nine days in 2024 from 23 days in 2023. Of the 17,304 “conclusive grounds” decisions made in 2024, government data showed 56 percent were positive, a decrease from 66 percent in 2023 . Twenty percent of “conclusive grounds” decisions made by the IECA were positive, compared with 72 percent of decisions made by the SCA. Most negative decisions were reportedly due to referrals lacking sufficient evidence. There was also an increase in “conclusive grounds” wait times.

Experts, including civil society and government reports, assessed the government victim identification data showed discrepancies between IECA and SCA decisions, demonstrating potentially inconsistent decision processes for foreign national victims compared to UK nationals referred to the NRM. Some government entities recommended a quality assurance process, including a 2024 report of the Independent Chief Inspector of Borders and Immigration, an independent monitoring position, which inspected the IECA and found concerns with governance, oversight, safeguarding, and quality controls, including for referrals from FROs. The inspection report found inadequate training for decision-makers led to inconsistent decisions. The report said IECA decision-makers issued negative decisions without adequately seeking out all available information.

In 2024, there were 1,092 requests for reconsideration of negative “reasonable grounds” or negative “conclusive grounds” decisions, a two-fold increase from previous years. In 2024, approximately 70 percent of reconsideration requests were successful in overturning negative “reasonable grounds” and “conclusive grounds” decisions. While the IECA claimed overturned decisions reflected new evidence, NGOs noted this called into question the accuracy of the initial decisions. Service providers reported concerns with the increased time burden to refer potential victims to the NRM, due to the increased evidentiary thresholds created by NABA.

From January 2023, disqualification requests could be made based on “public order,” after potential victims entered the NRM. In response to legal challenges, “public order” disqualifications were paused from July 2023 to January 2024 while the policy was updated. Decision makers were instructed to consider re-trafficking risks before denying individual support. Observers noted it was unclear how this was applied, in practice, including for individuals in detention. In 2024, 242 individuals were disqualified on the grounds of “public order,” compared to 331 individuals in 2023 (none prior to 2023). Experts noted this may have disqualified potential victims from support, especially those who committed unlawful acts as a direct result of being trafficked, for example, victims of forced criminality.

Observers reported a limited number of FROs may have left trafficking victims unidentified. FROs made referrals into the NRM, as victims could not self-refer. Ten NGOs held first responder status (a decrease from 15 in 2023), and the government did not accept applications for additional NGOs to receive FRO status in 2024. NGO FROs referred five percent of total referrals in 2024. FROs were responsible for training first responders in their organization. Civil society and the IASC urged consistent, mandatory training for FROs. Experts noted not all FROs had the same understanding of human trafficking nor quality of referrals. Observers reported varied quality and thoroughness of referral forms may have impacted decision outcomes, with half of negative decisions recorded as lacking sufficient information, and the Home Office citing poor quality of referrals as a core challenge. The government reported immigration officers screened for trafficking indicators and the border force maintained anti-trafficking specialists. The Home Office maintained e-learning modules for first responders, on indicators of human trafficking and with instructions on how to make a referral; however, experts noted the training was outdated. Observers noted the quality of information provided to victims on their rights varied widely among first responders, in practice, at all stages of the victim support process.

The government continued implementing a five-year MSVCC, to which it allocated more than £379 million ($475.5 million), with the anti-trafficking NGO sector to coordinate the provision of care for adult victims in England and Wales under the NRM. Fewer victims received support under the MSVCC than in the previous year. The MSVCC could provide a range of support services including safehouse accommodation, financial support to meet essential living needs and assist with social, psychological, and physical recovery, access to essential services, and free health care and legal aid. A Home Affairs Committee report, a House of Lords report, and anti-trafficking experts noted gaps in British national victims’ access to services, including access to government-funded shelter. Observers noted access to legal aid remained limited for many trafficking victims, and GRETA previously expressed concern the government did not provide legal aid to potential victims awaiting entrance into the NRM.

The Scottish government continued to fund the ICTG Service (Guardianship Scotland) to provide legal assistance and basic needs to unaccompanied children and trafficking victims. The Scottish government allocated more than £12.66 million ($15.88 million) for victim protection and assistance from 2022-2025. The Scottish government’s Victim Centered Approach Fund continued to provide support to victims of crime, including trafficking victims. Northern Ireland did not report how much funding it allocated to victims services for the past two years, compared with providing two local NGOs approximately £2 million ($2.5 million) in the 2022-2023 fiscal year. In Northern Ireland, the Sexual Offences and Trafficking Victims Act and Human Trafficking and Exploitation Act 2015 provided for support and assistance for trafficking victims. Observers noted a limited number of FROs in Northern Ireland may have hindered victim identification. Referral numbers for victims exploited in Northern Ireland remained low in 2024 compared to the rest of the UK.

The government continued to utilize a recovery needs assessment to tailor ongoing support to victims’ specific needs and determine the point at which a victim would exit the support services under the MSVCC. Observers asserted the recovery needs assessment was too restrictive because it placed the burden on victims to document their ongoing need, in order to continue receiving support. After a confirmed victim transitioned out of MSVCC support, they could access assistance through the “reach-in service,” a post-NRM service that offered transitional support, including provision of information and assistance to housing, health care, translation, employment, and support with submitting paperwork.

Child trafficking victims received care through children’s services offices in local jurisdictions; social workers worked with potential child victims to assess needs and create a care plan that included health, legal, education, and accommodation support. The Home Office devolved the NRM decision process to local authorities for child victims to ensure better decision making and more timely service delivery to child victims, reaching 20 sites by January 2025. Civil society commended this program for producing more reliable decision making and allowing children access to services faster. The government reported children’s care services were under increasing pressure due to the high number of unaccompanied children arriving in small boats crossing the English Channel. The government continued the ICTG program, which covered two thirds of local authorities across England and Wales. In 2024, the government conducted an evaluation of services provided by ICTG and assessed it positively. The government changed the ICTG to remove support to individuals once they turned 18, which NGOs said hindered continuity of long-term support and increased risk of re-trafficking. A Home Affairs Committee report recommended the government extend the ICTG scheme across the country and continue support to individuals older than 18. NGOs highlighted concerns about the difficulty of protecting children whom the government relocated away from their home to parts of the country where services were available; criminal gangs actively targeted vulnerable children who were taken out of their communities and ran away or went missing. Observers also noted unaccompanied migrant children were vulnerable to trafficking and many of these children went missing after their arrival in the UK. Previously, the Home Office accommodated unaccompanied children in hotels which, after legal challenges, ended by 2024.

Scotland and Northern Ireland required the appointment of independent legal guardians for child trafficking victims and trained the guardians on the support services available. In Northern Ireland, the Health and Social Care Trust referred child victims to the NRM. In Northern Ireland, NGOs raised concern that authorities identify very few domestic child victims compared to the rest of the UK, with only 43 child victims out of 651 referrals to the NRM in 2024. NGOs reported FROs in Northern Ireland only referred three children to the NRM for “child criminal exploitation” since 2015, inconsistent with increases in such cases across England and Wales. Northern Ireland has never reported identifying a potential child victim of forced criminality from the UK, compared with over 11,000 potential child victims identified in the rest of the UK since 2015.

Foreign national victims without legal status were unable to work until they received a positive “conclusive grounds” decision, in which case victims – and any dependent children they had – could also be considered for a temporary residence permit. While the government provided subsistence payments to victims in the NRM, observers noted payments were insufficient to meet victims’ essential needs. The government did not automatically grant foreign victims legal status in the UK; authorities reviewed requests for discretionary leave on a case-by-case basis and requests were not based on an individual’s status as a confirmed trafficking victim. Under NABA, foreign victims granted a reflection period after a positive “conclusive grounds” decision could not be removed from the UK during that period; however, foreign victims with a positive “reasonable grounds” decision could be disqualified under “public order,” so the recovery period was not available, and these individuals could be removed from the UK. Observers noted a positive “conclusive grounds” decision did not lead to ongoing support, or regularization of immigration status for foreign national victims, which increased vulnerability to re-trafficking. Under NABA, “temporary permission to stay” – formerly “leave to remain” – could be granted to victims to assist in their recovery, cooperate with an investigation or criminal proceeding, or seek compensation; a positive “conclusive grounds” decision did not guarantee the temporary permission to stay, and the government did not report how many victims received temporary permission to stay. Civil society expressed concern victims could face retribution or re-trafficking if returned to their home countries.

To avoid re-traumatization, UK authorities encouraged police and prosecutors to use intelligence-led investigations, pre-recorded cross-examination, and allow victims to apply for other measures to maintain anonymity. Courts allowed victims to testify by video, behind a screen, or with the public removed from the courtroom during hearings. Courts could grant restitution in a criminal case; however, NGOs noted courts infrequently granted restitution. Although victims could apply for compensation through civil suits, this remedy was difficult to access given the small number of legal aid providers available to file such claims, and the government did not consistently inform victims of their entitlement to compensation. During the 2023-2024 fiscal year, courts recovered a total of £854,000 ($1.1 million) in seized assets from traffickers, compared with £1.1 million ($1.4 million) during the 2022-2023 fiscal year; a small portion of this was used to provide compensation to trafficking victims. A 2024 NGO report stated there were only 133 applications for compensation (out of 51,000 NRM referrals) from January 2021to May 2024, and 82 percent of these were denied. Traffickers could appeal or contest compensation orders; observers noted traffickers often moved assets, so awards were often not paid in practice. The Home Affairs Committee recommended the government provide victims with earlier and more comprehensive access to legal aid. GRETA previously noted free legal assistance was not provided to victims seeking compensation, despite a complex compensation procedure and the requirement that victims prove they have suffered a physical or psychiatric injury as a direct result of a violent crime. In Northern Ireland and Scotland, similar compensation schemes existed for victims of violent crime, including trafficking victims. In 2024, neither Scotland nor Northern Ireland reported awarding restitution or compensation to any victims; however, media reported Scottish courts awarded a group of victims exploited in the fishing industry compensation in 2024.

Victims had a statutory defense, under UK law, in England and Wales which was intended to prevent victims from being prosecuted for unlawful acts committed as a direct result of being trafficked. However, the defense did not apply to the most serious crimes, such as sexual offenses or crimes involving serious violence. In these cases, the CPS had to consider whether it was in the public interest to prosecute the trafficking victim. NGOs noted victims could only access this defense when the prosecution commenced, and therefore, it did not protect them before this point. CPS issued guidance on how prosecutors should approach such cases. NGOs called for greater research on the application of the non-punishment principle. The Home Affairs Committee raised concern that despite child criminal exploitation being the most prevalent type of identified child trafficking in recent years, there is no specific statutory definition for it. The Home Office included a provision establishing a new offense of child criminal exploitation within a bill introduced to Parliament in early 2025, which remained pending at the close of the reporting period. NGOs agreed a definition of child criminal exploitation would be helpful but supported its inclusion within the MSA, as opposed to as a separate offense. Both NGOs and government officials asserted this lack of definition may have contributed to prosecution of child victims for crimes committed as a direct result of being trafficked.

In Northern Ireland, although non-punishment measures exist, there is no comprehensive available data on how many cases authorities have used this statutory defense. In Scotland, the anti-trafficking law required the Lord Advocate to make and publish instructions about the prosecution of a person who is, or appears to be, a victim of human trafficking, which laid out a “strong presumption against” prosecution of cases where defendants were found to be victims of trafficking. NGOs welcomed government engagement on this issue, but raised concerns current instructions were not an effective safeguard for potential victims, and observers noted prosecutors sometimes awaited final decisions in the NRM to ensure they did not inappropriately prosecute victims. An NGO report found the number of potential trafficking victims in immigration detention centers tripled in four years. NGOs reported victims in detention centers faced risk of re-traumatization or negative impacts to their physical or mental wellbeing, and called for the government to urgently review its process of detaining potential victims. His Majesty’s Prison and Probation Service (HMPPS) dedicated staff as contacts on human trafficking, issued guidance for prison staff to identify victims and on the barriers for individuals to disclose exploitation in prison. Observers reported barriers to victim identification in prisons, particularly because HMPPS is not a designated FRO to make NRM referrals.

The government increased prevention efforts.

The Home Office was responsible for coordinating the government’s anti-trafficking prevention and protection efforts. In 2024, the government appointed a new Minister for Safeguarding and moved responsibility for anti-trafficking efforts under the Minister’s portfolio. The Home Office convened Modern Slavery Engagement Forums with NGOs to promote coordination, and NGOs reported the Home Office’s engagement with the anti-trafficking sector improved in 2024. The government remained without a cross-departmental body to coordinate anti-trafficking efforts, which hindered interagency collaboration. The Home Office again did not publish a required annual report on modern slavery.

In March 2025, the Home Office published a 12-month action plan to combat human trafficking, but had not replaced the 2014 Modern Slavery Strategy despite engagements across the interagency, business, academia, civil society, and survivors to develop a new strategy. The House Affairs Committee and experts urged the government to update the Modern Slavery Strategy, noting the lack of a strategy created a fragmented approach to the government’s anti-trafficking efforts. The Independent Anti-Slavery Commissioner (IASC), an independent monitoring role, maintained authority to encourage good anti-trafficking practices among government stakeholders. The IASC and an NGO published a report on child trafficking and commissioned a report on why potential victims choose not to enter the NRM. Scotland began a refresh of its Trafficking and Exploitation Strategy, which remained pending at the close of the reporting period. In July 2024, Northern Ireland published a 2024-2027 strategy to combat trafficking.

The government did not operate or fund a trafficking-specific hotline, but NGOs operated multiple hotlines that provided advice to potential victims on where to access support. The government funded a specialist helpline that provided advice and support to children and adults on “county lines,” criminal exploitation, and gangs. The government conducted awareness campaigns across the UK with a wide range of partners. The government continued work with the Modern Slavery and Human Rights Policy and Evidence Centre (PEC), an independent research center publicly funded to conduct research on trafficking trends. The government sought the input of survivors in its anti-trafficking efforts, including for policy development and programming. However, civil society called for increased involvement of survivors and the IASC continued to advocate for a government-supported survivor advisory council on human trafficking to formalize survivor engagement, as current engagement remained informal. The Scottish government funded various awareness raising projects. Northern Ireland did not report conducting any awareness campaigns. Northern Ireland’s Department of Justice commissioned research on barriers to identifying child victims of forced criminality, and Northern Ireland launched an action plan to combat child forced criminality.

In the 2024-2025 fiscal year, the government allocated £62.6 million ($85.3 million) to the Gangmasters and Labour Abuse Authority (GLAA). The GLAA operated a national licensing scheme in high-risk sectors to prevent trafficking, including in the agriculture, horticulture, shellfish gathering, and food processing sectors. NGOs continued to note the GLAA remained under-resourced to make proactive efforts to prevent human trafficking, and a 2024 House of Lords report urged increased resourcing to the GLAA to regulate all sectors. The GLAA’s mandate did not include the care, hospitality, or fishing sectors, which limited detection of trafficking despite documented vulnerabilities in those sectors. The GLAA did not report updates to its compliance strategy for labor recruitment regulations or investigations into allegations of overseas workers being charged recruitment fees, despite the law prohibiting worker-paid recruitment fees.

The government began a process of establishing a single enforcement body known as the Fair Work Agency (FWA) to integrate the GLAA and two other enforcement bodies into one with the intent of providing a single point of contact for reporting labor exploitation. NGOs noted a single enforcement body could be beneficial, but urged the Department for Business and Trade and the Home Office to ensure the GLAA’s responsibilities and specialized trafficking knowledge remain in the FWA. The Employment Rights Bill was pending Parliamentary approval. NGOs called for greater efforts to address key industries including fishing, where migrant workers face heightened trafficking risks.

NGOs urged the government to reform various short-term visas, citing increased risks to trafficking among these visa holders, including barriers to reporting abuses. For example, NGOs criticized the overseas domestic workers (ODW) visa, noting workers faced barriers to change employment in the visa’s short timeframe, leading to heightened vulnerability to trafficking for workers seeking to leave exploitative working conditions. The IASC and NGOs reported risks in the care sector due to workers’ dependency on employers for health and care visas, and the 2024 House of Lords report found insufficient protections for workers in this sector. Additionally, the government continued the seasonal workers scheme (SWS) for non-EU migrants. Operators licensed by the GLAA oversaw recruitment and placement of such workers on farms; however, an NGO study noted the short-term nature of the SWS increased workers’ dependencies on their employers and many workers accrued large debts to gain employment, which increased their risk of labor trafficking. Experts urged the government to proactively screen for trafficking victims on UK-flagged fishing vessels.

The MSA required organizations with annual turnover exceeding £36 million ($45.2 million) to publish an annual statement on the government’s modern slavery statement registry detailing efforts to ensure their operations and supply chains were free of human trafficking. The government published updated guidance for businesses on how to draft such statements. Despite these requirements, many businesses did not submit statements, and the government did not have a mechanism to ensure compliance or penalize organizations for failing to meet their reporting obligations. In 2024, the Department for Health and Social Care proposed new procurement regulations on human trafficking in supply chains for public good and services. In February 2025, a procurement act came into force, and, separately, the government put forward an amendment to an energy bill to prohibit the use of public funds if there was evidence of forced labor in a supply chain, although this remained pending at the close of the reporting period. A 2024 House of Lords report and NGOs called for stronger due diligence laws. Advocates encouraged the government to impose sanctions on imports from Chinese-owned companies allegedly complicit in forced labor in seafood provided to UK-based grocery stores. Media alleged potential forced labor in the supply chains of solar panels, tomatoes, and other goods. In 2024, the UK Court of Appeal ruled the NCA failed to investigate Uyghur forced labor in supply chains for cotton imported from China. Some officials called for a prohibition of imports of products made with forced labor from China.

The government funded a wide range of anti-trafficking programs globally, including continued implementation of programs under the £24 million ($30.1 million) dedicated for 2022 to 2025 for the Modern Slavery Fund (MSF), to a range of anti-trafficking efforts, particularly in Albania, Nigeria, Romania, Indonesia, and Vietnam. The Modern Slavery Envoy oversaw international partnerships. The government continued a program to house Ukrainian refugees fleeing the Russia-Ukraine war with a UK-based host family to prevent trafficking among this vulnerable population. The government did not make efforts to reduce the demand for commercial sex acts. The government made efforts to reduce the demand for participation in extraterritorial child sexual exploitation and abuse by its citizens, including by implementing its national action plan on combating extraterritorial sexual exploitation and abuse. The government did not report providing anti-trafficking training to its troops prior to their deployment as peacekeepers.

Trafficking in persons occurs in the British Overseas Territories (BOTs), which includes 14 territories with a constitutional link to the UK. The UK is responsible for foreign relations, security, defense, and good governance in the territories. UK officials monitor serious and organized crime risks, including human trafficking, in the BOTs. In 2024, local police identified and repatriated potential sex trafficking victims from the Dominican Republic in the Turks and Caicos Islands; however, authorities did not report whether the potential victims were provided or referred to additional care. The government did not report other victims identified in the BOTs in 2024 nor efforts to train law enforcement in the territories. Previously, there were reports of Cuban regime-affiliated medical professionals working in the BOTs, including in the Turks and Caicos Islands, British Virgin Islands, Anguilla, and Montserrat. It was likely these workers departed; however, the Cuban regime may have forced Cuban regime-affiliated medical professionals to work while in the BOTs.

Trafficking affects all communities. This section summarizes reporting on the nature and scope of trafficking over the past five years. Human traffickers exploit domestic and foreign victims in the UK, and traffickers exploit victims from the UK abroad. Although the government reported 19,125 potential victims entered the NRM in 2024, reports indicate the number of actual victims is likely higher. The majority of potential victims were from the UK, Albania, and Vietnam. A 2024 NGO report found Albanians remained highly at risk of trafficking. Forty-four percent of potential victims experienced exploitation that occurred entirely outside the UK. Labor trafficking, including forced criminality, is the most common form of trafficking among adults and children. Undocumented migrants, including children, crossing the English Channel in small boats are vulnerable to trafficking. Nearly half of all trafficking victims identified are children. Children in the care system and unaccompanied migrant children are particularly at risk of trafficking. Gangs force children to act as drug couriers from larger cities into rural areas across the UK. Traffickers force adults and children to work in agriculture, cannabis cultivation, construction, food processing, factories, domestic service, nail salons, food services, the hospitality industry, car washes, food supply industry, and warehousing, as well as on fishing boats. Traffickers increasingly exploit victims, especially migrants in the fishing industry, in forced labor through debt bondage, physical violence, or unsafe working conditions. Observers reported workers’ inability to leave vessels without violating their visa terms, heightened their risk of trafficking. Similarly, a 2023 report indicated commercial vessels accused of forced labor were owned by companies registered in the UK. Traffickers increasingly exploit victims in the care sector, which includes live-in care, nurses, and other healthcare roles; in recent years, NGO reporting showed up to a 600% increase in human trafficking cases in the care sector. Labor traffickers exploit adults with disabilities and adults from low socioeconomic backgrounds. Traffickers increasingly recruit and exploit sex trafficking victims, predominantly from Eastern Europe, through social media and online platforms. Reports indicate traffickers may have subjected some individuals from the UK to forced labor in online scam operations. Following Brexit, European Economic Area citizens without legal status in the UK were at increased risk of trafficking. Ukrainian refugees, predominantly women and children fleeing the Russia-Ukraine war, are vulnerable to trafficking in the UK.

In Scotland, most victims are from Vietnam, with many forced to work in agriculture, the fishing industry, and nail salons, and in forced criminality, including cannabis farms. Increasingly, victims are from Albania, Eritrea, Somalia, and Iran. Scottish authorities report most victim referrals originate in Glasgow and Edinburgh. In Northern Ireland, traffickers exploit victims in forced criminality, including shoplifting and the cultivation and distribution of illicit drugs. In Northern Ireland, paramilitary groups exploit children for criminal purposes, and children may be recruited by non-state actors, including extremist organizations. NGOs report paramilitary groups exploit victims in forced labor, including through debt bondage. Young women and girls from Albania, Bulgaria, and Romania, including ethnic Roma, remain vulnerable to sex trafficking in Northern Ireland and increasingly victims are undocumented Somali, Sudanese, and Eritrean nationals, including victims who traffickers exploited on their journey through Libya, Turkey, or Greece who are identified in Northern Ireland.