IOM: UK Illegal Migration Bill Increases Risks for Modern Slavery Survivors


The International Organization for Migration (IOM) is deeply concerned by the recently proposed changes to the modern slavery protection system in the United Kingdom (UK) as part of the new Illegal Migration Bill. The proposed changes if passed would limit survivors’ ability to report trafficking and access assistance, which risks exacerbating the vulnerability of victims, giving traffickers more control over them and deepening risks of further exploitation.

IOM’s analysis of the UK Home Office’s National Referral Mechanism (NRM) – the UK’s official system to identify and support victims of modern slavery and trafficking – data highlights important concerns for survivors of modern slavery including unreasonably long waiting times for decisions, which alarmingly increase two-fold in the case of women. Based on its experience of working with survivors and carrying out research, IOM estimates that the current number of referrals is only the tip of the iceberg, with many victims going unnoticed as they choose not to seek help for fear of being deported.

“There have been several statements around irregular migrants allegedly abusing the modern slavery protection system. Publicly available data shows no evidence of abuse,” said Christa Rottensteiner, IOM UK Chief of Mission.

“In addition, only 7 per cent of individuals arriving in small boats are referred as potential victims of modern slavery,” she added.

The proposed Illegal Migration Bill in its current form would make it impossible for victims who arrive in an irregular manner to access the NRM and get the support and protection they need. Instead, these persons would be detained and removed.

Victims have a right to a period of recovery as well as protection needs that must be addressed. While States have a sovereign right to manage mobility on their territories, this must be done in compliance with international and regional law obligations and conventions, including the Council of Europe Convention on Action Against Trafficking in Human Beings (ECAT). In line with the United Nations High Commissioner on Human Rights’ guidelines on Human Rights and Human Trafficking, victims of trafficking should not be subject to detention or prosecution for the irregular entry or residence in transit or destination countries1.

IOM advocates for a shorter waiting time in the NRM, particularly for women. This could be achieved by strengthening the system capacity to process the backlog as well as the increasing number of referrals, in line with efforts by the UK government and other referral partners aimed at improving the capacity to efficiently recognize cases of modern slavery. Alongside faster decision-making, post-NRM support also needs to be improved, so that those receiving a positive decision can receive appropriate care, including support to access the labour market.

IOM stands ready to support efforts to strengthen longer-term assistance provided to survivors, including through our skills training and integration support.

“We appreciate the UK’s leadership in tackling modern slavery nationally and globally, and we encourage it to continue to lead on best practices to support survivors,” concluded Rottensteiner.


1The Inter-Agency Coordination Group against Trafficking in Persons, Issue Brief on the Non-Punishment of Victims of Trafficking, 2020

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