The new Immigration and Asylum Bill will damage modern slavery protections

The Immigration and Asylum Bill will significantly weaken the UK’s response to trafficking and modern slavery. It will deny protection, support and recovery to many survivors. It penalises survivors for their trauma by setting arbitrary deadlines for disclosure of painful experiences. This approach punishes survivors, will embolden traffickers and in doing so enable exploitation to thrive. This harms communities and the economy.

All survivors need access to safety, recovery and justice, irrespective of when and where they are able to disclose their experience of exploitation, or even recognise an experience as exploitation. A fragmented and weak system of identification and support serves no one but the perpetrators of these crimes.

In announcing this Bill, the Home Secretary acknowledged that modern slavery is a grave crime. Yet, this Bill continues a destructive approach of prioritising an immigration control agenda over safeguarding survivors of a serious crime, accompanied by hostile and unevidenced narrative of system mis-use to ‘justify’ weakening modern slavery protections.

Damaging prevention, rights and protection 

Over the past five years, the system of modern slavery identification and support in the UK (the National Referral Mechanism – NRM), which politicians were once proud to declare ‘world leading’, has been weakened by successive regressive reforms.

In opposition, the Labour Party fought for the integrity of the NRM. Now in government, it proposes to further strip away the protection and support that the NRM offers.

We are particularly saddened and disappointed to see provisions in this Bill which would:

• Penalise survivors for their trauma with arbitrary disclosure deadlines: Introducing a specific timeframe for disclosing exploitation from arrival into the UK risks penalising some of the most vulnerable people in the system for what is a well-documented and entirely normal response to trauma. It will damage identification and push the most vulnerable people further underground.
• Remove access to leave for recovery needs: Stability and safety is crucial for recovery, including preventing re trafficking. For survivors without secure immigration status, a form of leave to remain which unlocks access to employment, housing, healthcare and a route to settlement is vital. It is impossible for survivors to recover and rebuild their lives while living with insecurity. Without stability, survivors are often unable to make decisions such as cooperating with police investigations, limiting the ability to achieve successful investigations and prosecution.  Grants of ‘temporary permission to stay’ are already rare: In 2024, just 4% of those eligible were granted temporary permission to stay and 96% of those grants were to assist with recovery – removing this option will be devastating, fuel instability and increase the risks of re-trafficking. Furthermore, grants of leave are usually for a very short period of time. In 2024, over half were for less than 12 months. While some survivors of trafficking may be able to secure permission to stay in the UK as refugees, the government is at the same time eroding refugee rights, including by halving the leave to remain granted to them. 
• Disqualify survivors from support and identification: Public Order Disqualifications are a blunt tool that can penalise survivors for convictions incurred during the course of exploitation. The Bill will expand their use by making it a duty to apply them instead of a discretion. This will leave many more survivors blocked from vital NRM identification and support, which will put them at risk of further exploitation and re-trafficking. 
• Creating a cliff edge when support and protection ends: A person’s recovery and reflection period will end if they receive a negative conclusive grounds decision. Recent years have seen both a high rate of negative conclusive grounds decisions and high rate of those decisions being overturned when reconsidered. Under these proposals victims who have been trafficked but have received a negative decision face being left without protection, accommodation or support at very short notice perhaps with no ability to challenge the decision in practice, placing them at risk of further harm. In turn, this risks creating other social challenges, such as homelessness 

Child trafficking victims

While the Bill includes some specific changes regarding the role of the Independent Child Trafficking Guardians, it is hard to see how it will improve identification and support of child trafficking victims, and we are concerned that there remains no meaningful commitment to a comprehensive child exploitation strategy.  Furthermore, taken as a whole, minimal and selective commitments on children do not mitigate wider reforms that will affect some of the most vulnerable children more and deny survivors’ protection, embolden traffickers, and place more children at risk of exploitation and harm. 

We are also concerned at other provisions in the Bill, including those that would limit the interpretation of Article 8 of the ECHR and those that will weaken the UK’s asylum system and protections including access to a fair appeals process. 

Misleading and hostile narratives driving regression

The continued use of hostile narratives about system ‘misuse’ institutionalises the environment of disbelief towards survivors, effectively pushing them further underground

In fact, the system has strong checks and balances against potential misuse, and places an exceptionally high evidential burden on survivors. 

The Bill perpetuates a misleading narrative that individuals can submit a ‘modern slavery claim’. An individual cannot self refer to the Home Office for identification. Instead, they must rely on a First Responder to identify indicators of trafficking and exploitation and make a referral to the Home Office’s two-stage decision-making process, the NRM, to be formally identified as a victim. It is important that the Bill not shift responsibility and accountability away from the organisations with responsibilities to identify and protect survivors. 

According to the Home Office’s own figures, in 2025, of 23,411 potential victims of modern slavery referred into the NRM, only 6  were disqualified on the grounds that their claims were made in ‘bad faith’. Despite the persistent rhetoric, the system of support for survivors of modern slavery has not been overwhelmed with ‘fraudulent claims’ necessitating reform.

The Independent Anti Slavery Commissioner has criticised the government for language suggesting the system is being misused. The Commissioner has also reported on the many barriers which survivors face to accessing an NRM referral, which lead many to decline a referral. 

Spreading misinformation and creating distrust and scepticism about people who have suffered a serious crime does nothing but fuel division that harms our communities and puts survivors, support organisations and legal representatives at risk. 

Supporting survivors and punishing perpetrators 

You cannot end human trafficking and modern slavery without a safeguarding-first response where all survivors are supported to rebuild their lives and the balance of risk is shifted decisively onto traffickers. Fears of disqualification, detention, removal or disbelief  prevent survivors from accessing help and support, are being used by traffickers as a tool of coercion, and undermine efforts to disrupt criminal networks. Immigration measures which undermine people’s rights to challenge exploitation are also at odds with the government’s flagship Employment Rights Act 

An effective response to trafficking and modern slavery means prioritising prevention, safety, recovery and access to long-term independent advocacy, support, safe accommodation, healthcare and legal advice. 

This Bill is yet another step away from the effective, evidence-based and survivor-centred approach that is needed to prevent human trafficking and modern slavery. It fails survivors and will benefit traffickers. We urge parliamentarians to oppose this Bill and for the government to change course.

For further information

In April, leading sector organisations united to present a strategic roadmap to eradicate modern slavery in the UK by 2036. Focused on four key interconnecting priorities, underpinned by ethical and meaningful inclusion of those with lived experience, we called for mandatory corporate accountability, a tougher criminal justice response, survivor-centred recovery, and a national strategy for child protection.  

This statement is signed by:

Anti Trafficking and Labour Exploitation Unit (ATLEU)

Anti-Trafficking Monitoring Group (ATMG)

Anti-Slavery International

ECPAT UK

Focus on Labour Exploitation (FLEX)

Helen Bamber Foundation

Hope for Justice 

Kalayaan 

Snowdrop Project