Increase resources to expedite the prosecution of alleged traffickers after case referrals by law enforcement and seek adequate penalties for convicted traffickers, which should involve significant prison terms. * Amend trafficking provisions in the penal code to prescribe penalties for adult sex trafficking that are commensurate with penalties prescribed for other grave crimes, such as rape. * In collaboration with civil society, expand the availability of shelters to victims of all forms of trafficking, including male and foreign victims, and allocate adequate resources and staffing to shelters. * Expand implementation of the NRM to Anjouan and Moheli and train officials on its use. * Systematically and proactively identify trafficking victims by screening for trafficking indicators among vulnerable populations across Comoros, including children in domestic work, children attending Quranic schools, and individuals repatriated or deported from the French Department of Mayotte, and refer all victims to appropriate services. * Continue to increase anti-trafficking training for front-line officials, including law enforcement, social workers, health service providers, prosecutors, judges, and civil society, on Grande Comore, Anjouan, and Moheli. * Implement the 2024-2026 NAP. * Implement and consistently enforce strong regulations and oversight of labor recruitment companies, including eliminating recruitment fees charged to migrant workers and holding fraudulent labor recruiters criminally accountable. * Expand anti-trafficking public awareness campaigns to all of Comoros, specifically targeting vulnerable populations on Anjouan and Moheli. * Develop a national-level data collection system on trafficking crimes, including anti-trafficking law enforcement efforts and identified trafficking victims.

The government increased anti-trafficking law enforcement efforts. February 2021 amendments to the criminal code criminalized sex trafficking and labor trafficking. Article 266-11 of the new criminal code prescribed penalties of seven to 10 years’ imprisonment and a fine of 30 million Comorian francs ($67,645) for crimes involving an adult victim and 10 to 20 years’ imprisonment and a fine of 30 million Comorian francs ($67,645) for those involving a child victim. These penalties were sufficiently stringent. However, the penalties prescribed for adult sex trafficking were not commensurate with those prescribed for other grave crimes, such as rape. The government coordinated with an international organization to draft the country’s first standalone anti-trafficking law; the drafted law was pending approval by the national assembly for the third consecutive reporting period.

The government investigated four trafficking cases in 2023, two for labor trafficking, one for sex trafficking, and one for an unspecified form of trafficking. This compared with four investigations in 2022. The government reported one investigation remained ongoing from the previous reporting period. The government initiated three prosecutions (one for sex trafficking and two for labor trafficking) and continued four prosecutions (three for sex trafficking and one for labor trafficking) from previous reporting periods, and the court acquitted one defendant. This compared with no prosecutions reported during the previous reporting period. The government has never reported convicting a trafficker. Police continued to lack basic resources, including vehicles, fuel, and equipment, which limited their ability to investigate trafficking cases outside Moroni. In addition, the small number of prosecutors in the country, one per island, resulted in severe case backlogs, including trafficking cases referred for prosecution. While discouraged by the government, families or village elders continued to settle many allegations of violence, possibly including sex trafficking and child domestic servitude, informally through traditional means without recourse to the formal court system.

The government’s National Brigade for the Repression of Illegal Migrant Smuggling and Trafficking in Persons (NBTIP), a specialized investigation unit on Grande Comore and Anjouan, was mandated to investigate cases of human trafficking and migrant smuggling. The NBTIP comprises 16 officers from police, gendarmerie, and civil security. The government, both independently and in partnership with international organizations, trained members of the NBTIP, police, gendarmerie, immigration authorities, and other officials on victim-centered investigation techniques, victim identification, and assistance procedures. The government previously pursued collaboration with the Government of France to investigate potential trafficking cases on Mayotte; however, reciprocation of these efforts by French officials remained limited.

The government increased victim protection efforts. The government identified 30 trafficking victims in 2023 and referred all victims to care, compared with 14 victims identified and referred to care in 2022. Of the 30 victims identified, traffickers exploited 17 in labor trafficking, 12 in sex trafficking, and one in an unspecified form of trafficking. The government, in partnership with an international organization, continued to disseminate and provide training on its SOPs for victim identification to law enforcement and other government officials, civil society, religious leaders, and the Human Rights commission. Using the SOPs, the government continued to screen vulnerable populations, including foreign migrants and victims of abuse, for trafficking indicators. The government, in partnership with an international organization, began implementing its NRM, adopted in the previous reporting period, to complement the victim identification SOPs and refer victims to protection services. The NRM was only operational on Grande Comore.

The government partnered with international organizations and local NGOs to provide services to all 30 identified victims, including temporary housing, medical care, counseling, job training, and repatriation assistance. The quality of care and availability of services remained limited, especially on Anjouan and Moheli. The government continued to provide financial support, including salaries for employees and office space, and listening centers (Service d’Ecoute). The listening centers, with assistance from civil society, continued to offer medical care, psycho-social counseling, and legal assistance mostly to women and children who were victims of abuse and violence, including potential trafficking victims. The government continued operating listening centers in four locations – two on Grande Comore, one on Anjouan, and one on Moheli. There were no NGO or government shelters available in the country to assist trafficking victims, which often resulted in government officials or community members providing temporary shelter to victims in their personal homes. The government did not have a systematic victim-witness assistance program, but victims could provide recorded testimony while their identities remained confidential. The government did not provide legal alternatives to deporting foreign trafficking victims to countries where they might face hardship or retribution; however, in practice, the government provided foreign victims the same benefits as Comorian nationals. Comorian law allowed victims of crime, including trafficking, to obtain restitution, and victims could file civil suits against their traffickers. However, courts did not award restitution and no victims filed civil suits.

The government increased efforts to prevent trafficking. The National Committee for Preventing and Fighting Trafficking in Persons (NCTIP) led the government’s anti-trafficking efforts and included representatives from relevant government agencies, listening centers, and civil society. NCTIP coordinated on trafficking cases and met quarterly. The NCTIP drafted and adopted a new 2024-2026 anti-trafficking NAP and allocated 514 million Comorian francs ($1.16 million) to its implementation. The government continued to conduct awareness campaigns in the form of print media, social media, and television advertisements, targeting local authorities, religious leaders, and the general public on Grande Comore. The government did not report conducting any awareness campaigns on Anjouan or Moheli. The government continued to fund two toll-free emergency lines on Grande Comore, Anjouan, and Moheli, which were used to report crimes to the listening centers; however, the government did not track call data related to potential trafficking cases.

The Ministry of Labor employed two labor inspectors to enforce child labor laws. However, the inspectors did not receive training on relevant trafficking laws and did not receive sufficient operational resources to conduct labor inspections of informal worksites, where children were especially vulnerable to forced labor. There were no formal labor recruitment agencies in the country, and the government remained without effective policies or laws to monitor labor migration. The government did not prohibit worker-paid recruitment fees. Unregistered recruitment agencies continued to operate and facilitate recruitment through informal channels, and some agents used predatory tactics, including charging recruitment fees and fraudulent job advertising. A 2012 ban on labor migration to several Gulf states the government considered high-risk remained in place; the policy restricted Comorians’ access to safe and legal migration, increasing their vulnerability to trafficking. Comorian authorities collaborated with the Governments of Madagascar and Tanzania to regulate labor recruitment. The government continued developing bilateral labor agreements with the Governments of Kuwait, Madagascar, Oman, Tanzania, and the United Arab Emirates to enhance protections for migrant workers. The government continued to oversee working conditions of Comorians living and working abroad, including assisting in the repatriation of trafficking victims. The government did not provide anti-trafficking training to its diplomatic personnel, nor did it make efforts to reduce demand for commercial sex acts.

As reported over the past five years, human traffickers exploit domestic and foreign victims in Comoros, and traffickers exploit victims from Comoros abroad. Traffickers exploit women and children, particularly from rural areas, in domestic servitude and sex trafficking on Grande Comore and Anjouan. Traffickers on Anjouan may subject children, some of whom were left behind by parents in pursuit of economic opportunities in other countries, to labor trafficking in domestic service, roadside and market vending, baking, fishing, and agriculture. Families living in rural areas, often on Anjouan and Moheli, frequently send their children to live with wealthier relatives or acquaintances in urban areas or on Grande Comore for access to schooling and other socio-economic benefits; these children are vulnerable to domestic servitude and sex trafficking. Most Comorian children from 3 to 7 years old (and some as old as 14) study at informal neighborhood Quranic schools headed by private instructors where they may be vulnerable to labor trafficking as field hands or domestic servants to supplement payment for instruction. The estimated 3,000 to 4,000 unaccompanied Comorian children on Mayotte are especially vulnerable to domestic servitude and sex trafficking. Traffickers exploit Comorian adults in forced labor in agriculture, construction, and domestic work on Mayotte and continental Africa. Media reported an average of 25,000 Comorians are deported from Mayotte per year and are vulnerable to trafficking. Traffickers exploit Comorian women in domestic servitude in Gulf states, particularly Oman. Traffickers exploit Malagasy women and girls in domestic servitude and sex trafficking in Comoros. Economic migrants and asylum-seekers from other African countries, including Burundi, Cameroon, Rwanda, the Democratic Republic of the Congo, Madagascar, Tanzania, and Uganda, attempting to reach Europe via Mayotte are increasingly transiting Comoros; traffickers often exploit these migrants in labor or sex trafficking in transit or on Mayotte.