Skip to content
Focus on
road, path, timeline

The National Referral Mechanism over time

A timeline mapping how the NRM has changed over time

This timeline maps how the NRM has changed since its inception in 2008. Influencing factors include the implementation of new government policies, legal challenges, and the overall political landscape. Also shown are how these changes have been received by the third sector.

Note that this overview is not exhaustive, as changes to the NRM and access to support as obtained through the Modern Slavery Victim Care Contract are frequent.


UK ratifies the Council of Europe Convention on Action against Trafficking in Human Beings

Read ECAT here.

ECAT is ratified by all 46 members of the Council of Europe.

The Convention is the first international treaty obliging states to adopt minimum standards to assist trafficked persons and protect their rights. 1

ECAT commits to:
-A human rights based approach
– Establishment of a  mechanism
-A comprehensive scope of application2

ECAT 2009

Third sector response

Greeted as a positive development, with still more to be done, e.g. Amnesty

April 2009

ECAT enters into force; NRM established in the UK  to comply with obligations

Two agencies set up as competent authorities (UKHTC and UKBA)3

– 45 days recovery and reflection period (15 days more than ECAT obligation)
No long term support– survivors are exited from support 14 days after a positive conclusive grounds decision and 48 hours following a negative decision. 
– No right to appeal
– Lack of pre-NRM support

June 2010

Third sector response: general monitoring

Report from ATMG released. Some key issues:

– Concerns that not all potential victims are benefitting due to fear of consequences of referral – not fit for purpose4
-Failure to implement entirety of convention: no watchdog to ensure implementation is occurring5
– Issues with non-punishment, not recognising cannabis cultivators as being victims, immigration offences6


National Crime Agency Established under Crime and Courts Act

Creation of UKVI NRM hub

NCA absorbs trafficking responsibilities previously held by UKHTC

November 2014

Home Office review of the NRM


1. A tighter, professionally managed entry to the NRM

(This means first responders need to be professionalized and well equipped to bring people in so that they access support and referrals are accurate)

2. Multi disciplinary decision making

(Includes better coordination between bodies, timely decision making, consistent point of contact)

3. Comprehensive oversight of the system

(Better governance framework headed by home office, including performance evaluation and minimum standards)

July 2015

UK’s Modern Slavery Act implemented

The Act receives royal assent on 26 March 2015. The Act introduces some new legislation and consolidates other legislation under the umbrella of the modern slavery act. Some key items:

Part 1: Consolidates modern slavery offences under one act, and sets out penalties and sentencing

Part 4: Establishes the role of the IASC “encourage good practice in the prevention, detection, investigation and prosecution

Section 52: Introduces the statutory duty to notify 

Section 45: Introduces defence for victims with criminal charges

Part 6: Requires business of a certain size to provide transparency in supply chains

MSA 2015

Third sector response: submitting evidence to parliament

Sector-wide concern about lack of victim support in the act. Government advised that there was not time to include this in the Bill, and that including such a section could jeopardise its passage

As such, government commits to provide statutory guidance on victim support through section 49 of the act (duty of the secretary of state)

1 November 2015

Duty to Notify (DtN) obligation begins 

Applies to all local authorities, police forces, Home Office (UK Visas & Immigration, border force, immigration enforcement) 

This means that all the specified state authorities must complete either an NRM referral or Duty to Notify (anonymous) if they encounter someone they suspect is a victim of modern slavery

October 2016

Third sector response: general monitoring

HTF report highlights lack of long term support which makes it difficult for survivors to move on, and puts them at risk of re-exploitation

October 2017

Reforms announced

Home Secretary announces new commitments:
– A single, expert unit to be created in the Home Office to handle all cases referred from front line staff and to make decisions about (eventually SCA)
– An independent panel of experts to review all negative decisions, adding significantly to the scrutiny such cases currently receive (eventually MAAPs)
– A new digital system to support the NRM process

Home office announces:

– Government-funded ‘places of safety’ will be created so that adult victims leaving immediate situations of exploitation can be given assistance and advice for up to 3 days before deciding on whether to enter the NRM (still pending)
– “Move on” support extended from 14 to 45 days


Independent Review of the MSA

Raises concerns about long term support, lack of data from people having exited the NRM (p. 19)

April 2019

SCA launched

-SCA is separate from immigration system to prevent conflation of asylum/immigration processing with MS decisions (announcement)
-Addressing “gaps in support” for victims 
-UKHTC v. UKBA, decisions were uneven 

April 2019

Multi-Agency Assurance Panels (MAAPs) launched

-Agencies include local authorities, police, and NGO representatives
-MAAPs implemented alongside SCA to independently review all negative CG decisions 
-SCA remains only decision body, MAAP is only a review body
Further guidance & info  from Home Office

MAAPs 2019-2022

Third sector response: 2021 review of MAAPs

February 2021 ATMG Report review of MAAPs finds:
– MAAPs do not adequately assure NRM decision making due to 
lack of decision making power 
– Poor quality or minimal evidence reaching panels
– Recommends that there is multi-agency involvement in NRM decision making
– Recommends transparency in MAAP recommendations and SCA decisions

November 2019

Reconsideration request policy changed

Following legal challenge, High Court ruling it is unlawful to only allow reconsideration requests to come from certain organisations.

January 2020


The UK officially withdraws from the EU

4 January 2021

Reach-in Support Introduced

New service to support people with positive CG decisions who have exited the NRM7

March 2021

“New Plan for Immigration” policy statement published

Chapter 6
– New government rhetoric drawing attention to increase in NRM referrals as an “alarming risk” 
– Suggests migrants are misusing the NRM to “avoid detention” and “frustrate removal”

July 2021

Third sector response: government consultations

Results and response of consultation published. Some key issues:

– Concerns over government’s position as undermining the credibility of victims seeking to access the NRM.
– Concerns over lack of trauma-informed policy
-lack of evidence base supporting reasons for changes

(This position paves the way for the Nationality and Borders Act (NABA), later on)

November 2021

Immigration Enforcement Competent Authority (IECA) launched

IECA is launched, to be responsible for a specific cohort of adult cases, including:
– Foreign adults detained in an immigration removal center
– Foreign adults in prison
– Non detained foreign adults where action to pursue cases towards deportation is taken in the community 
– Further info p. 48 here 

IECA 2021

Third sector response: brief

Detention taskforce publishes briefing. Key concern:

– Creates two tier system for decision making which will discourage people with insecure immigration statuses from coming forward due to concerns about differences in decision making

December 2022

MAAP removed

Statutory guidance updated to remove MAAPs as part of the NRM process.

30 January 2023

Nationality and Borders Act (NABA) enacted

NABA comes into effect, after passing through parliament and receiving royal assent. Introduces changes to the asylum system including separating asylum seekers into 2 groups depending on how they arrived in the UK, and criminalising elements of asylum based on type of entry to UK (Right to Remain brief explainer

Part V: Modern slavery
NABA section 61
Update minimum recovery period to 30 days (previously 45)

NABA section 63: public order & bad faith disqualifications 
If a person is determined to be a threat to “public order” or has claimed to be a VoT in bad faith they are not entitled to protection against removal 

Change to Sec. 49 statutory guidance 
Evidence threshold for reasonable grounds decision changed to “reasonable grounds to believe, based on objective factors but falling short of conclusive proof,”

NABA 2023

Third sector response: major concerns

Widespread response from MS and refugee sector 

HTF explainer on new evidence threshold identifies key issues:
– Prediction of increased rejections
– Delays in decision making
– Difficulty for first responders in advising on referrals when objective evidence is not available

June-July 2023

Home office change to guidance on reasonable grounds evidence threshold

Following a legal challenge by Duncan Lewis solicitors, Home Office agrees to update Section 49 Guidance implemented on 10 July 2023

AS & BXR case argued that the increased evidence threshold was:
– A breach of Article 4 ECHR 
– Procedurally unfair
– Irrational at common law8

July 2023

High Court rules that aspects of the public order disqualification are unlawful.

High court issues order requiring government to change elements of the public order disqualification
– PoD prevents people with criminal charges from accessing victim protections. 
– Further hearings scheduled for later in the year. 

20 July 2023

Illegal Migration Act receives royal assent

Following its introduction in March, the IMA is pushed through parliament. The bill intends to deter migration through removing significant protections for anyone arriving irregularly to the UK. Some key features to include:

– Removal of MS protections for anyone arriving to the UK irregularly since 7 March 2023
– Removal of right to claim asylum for people who have irregularly entered, having passed through a country where they did not face persecution
– Grants powers to ministers to determine when certain sections of ECHR apply to certain cases

Illegal Migration Act 2023-present

Third sector response: major concerns

Following the introduction of the legislation in March 2023, the IMA has ignited widespread concerns from the MS and refugee sectors.

– UNHCR warns that the Act will extinguish the right to asylum for vulnerable people without access to safe and legal routes
– Concerns from the MS sector that by removing MS protections, the Act will put people at increased risk of trafficking and exploitation (eg. ASI)
– Pushback on government narrative that there is misuse or widespread fraud within the NRM, citing a lack of evidence (eg. joint briefing)
– Potential violations of international MS obligations law including Article 4 ECHR and ECAT9

December 2023

Withdrawal of guarantee of 12 month support post CG

– UK government announced that 12 month support is  “not necessary” in all cases and support will be decided on a case by case basis. This means that victims have to focus on evidencing need to access support, rather than on recovery
– Reversal of previous commitment of minimum support
– Confirmation that places of safety/ pre NRM support will not be available

  1. Anti-Trafficking Monitoring Group ↩︎
  2. Council of Europe[1]%7D ↩︎
  3. Anti-Trafficking Monitoring Group p. 21 ↩︎
  4. ATMG p. 7 ↩︎
  5. ATMG p. 10 ↩︎
  6. ATMG pp. 10-11 ↩︎
  7. Salvation Army ↩︎
  8. Free Movement ↩︎
  9. Joint Briefing p. 40 ↩︎