The Seasonal Worker Interest Group has provided first hand evidence of the serious levels of abuse that workers are facing in its submission to the Office of the Director of Labour Market Enforcement (ODLME).  We now reiterate our call for urgent action in response to the ever-growing evidence of exploitation and abuse. Only a complete overhaul of the scheme will deliver safety, rights and justice for seasonal migrant workers. This Seasonal Worker Interest Group submission is in response to the call for evidence to the ODLME’s Labour Market Enforcement Strategy 2025/2026; a copy of our submission can be read below.

The Seasonal Worker Interest Group is an alliance of key organisations that provide support to, or advocate for, migrant seasonal agricultural workers. As the only group working exclusively in the interests of migrant seasonal workers, our members have raised concerns about the Seasonal Worker Visa scheme (SWV) since its inception in 2019. The Organising Committee members of the Seasonal Worker Interest Group are Anti Trafficking and Labour Exploitation Unit (ATLEU); Focus on Labour Exploitation (FLEX); Work Rights Centre; and Worker Support Centre. Associate members are: Trades Union Congress; Unite the Union; FairSquare; Anti Slavery International; and The Landworkers’ Alliance.

A visa that drives exploitation

Our evidence, alongside government and independent reviews, highlights that the scheme, as currently designed, puts workers at risk of serious exploitation and abuse, including trafficking, debt bondage and forced labour. Systemic failings in the scheme design has led ATLEU to bring a legal challenge asserting that the scheme is in breach of international law. Further, here is a lack of regulatory oversight or enforcement and coordination on various issues between government departments.

A lack of safeguards, an abundance of abuse and exploitation

The scheme fails to sufficiently safeguard workers. This includes an absence of: 

• Proactive labour market enforcement inspections of farms employing workers on the scheme
• Regulation related to seasonal worker housing
• A public list of farms employing workers on the scheme
• An independent body to handle worker transfers
• Provisions for workers on the scheme who find that their job is cancelled. 

Workers face indebtedness; ongoing issues around underpayment of wages and a lack of clarity around how wages are calculated; unsafe accommodation; difficulties accessing healthcare; and restrictions on movement. In light of this, we have also called on the Low Pay Commission to task HMRC with urgently reviewing pay in the sector. 

Exploitation is growing – the SWIG requests ODLME clarification

We disagree with statements in the ODLME’s recently published labour market enforcement strategy for 2024/25 that the risk of non-compliance in the agricultural sector is reducing. As organisations working directly with workers, we are witness to the sheer weight of evidence to the contrary. For example, the Worker Support Centre saw a considerable increase in enquiries from workers in vulnerable positions during 2024 including a marked increase in workers unable to access transfers. 

We seek an urgent explanation from the ODLME as to the basis on which it has assessed in its 2024/2025 strategy that the risk of non-compliance in the agricultural sector is reducing. Our submission also details methodological limitations with the DEFRA worker surveys, which are not independent of the government or Scheme Operators, and mask other serious issues faced by workers. 

A failure to take action despite growing evidence

The previous government showed little interest in making the wholesale reforms to  the visa required to substantially improve worker welfare. Though some changes have been made to the scheme, ostensibly to try and address worker welfare issues, they have generally been implemented without adequate consultation of workers or worker welfare organisations, and as a result, are having little or no impact. 

A need for action 

In August, SWIG published a statement calling again for the scheme to be overhauled after a second scheme operator had its licence revoked. We maintain that the government must learn the lessons from the two revocations to avoid further detrimental impact to workers on the scheme and to avoid deterring workers from raising grievances. 

As it champions an Employment Rights Bill which aims to drive up standards for workers, we once again urge the new government to urgently overhaul the Seasonal Worker Visa Scheme as priority.