Are we holding traffickers accountable or punishing survivors?

A statement by survivors of modern slavery on the Immigration and Asylum Bill – September 2026 

As survivors who have experienced modern slavery, we write to express our profound concern about the impact the Immigration and Asylum Bill would have on people who have experienced trafficking, exploitation and abuse, and on those who may need protection in the future.

We welcome the effort made in the Bill to strengthen law enforcement’s ability to prevent and disrupt trafficking, improve support arrangements for trafficked children, and increase transparency in business and public authority supply chains. Stronger legal powers need to be accompanied by specialist modern slavery training, lived-experience expertise, effective intelligence-sharing and coordination. Survivors also need safe and secure ways of providing evidence about perpetrators, trafficking methods and other potential victims without exposing themselves to retaliation or further harm. 

The Immigration and Asylum Bill continues the harmful conflation of modern slavery and immigration enforcement; placing an unfair and unrealistic burden on survivors to prove that they have been exploited, making it harder for victims of modern slavery to be identified, believed and supported.  

Many survivors do not immediately recognise that they are being exploited. Leaving exploitation is difficult, and disclosing experiences of abuse can take considerable time. Many provisions in the Bill do not reflect these realities, instead they risk benefiting traffickers. If survivors feel they have to prove themselves straight away, or worry they will not be believed, many will be too frightened to come forward at all, seek help or engage with authorities. That means people could stay trapped in exploitation for longer, struggle to get the support they need and be left more vulnerable afterwards. In turn this makes it harder to find traffickers, gather evidence and hold the people responsible to account.  

Access to support and protection should be based on survivors’ rights and needs, not whether they are able or willing to participate in criminal proceedings. Survivors need to feel safe, which requires access to accommodation, independent advocacy, legal advice, mental health support and time to recover. For foreign national survivors, immigration status and recourse to public funds provide essential stability for recovery. Survivors cannot begin to recover if they do not know where they will be living, whether they will be able to support themselves, or whether they will be allowed to remain in the country. Living with that uncertainty keeps people in survival mode and can make them vulnerable to exploitation again. These issues must be addressed to enable effective recovery, reintegration and reduce risks of re-trafficking. 

The drastic changes introduced by this Bill are justified on the basis of preventing misuse of the system. However, no evidence has been published to demonstrate widespread abuse of the system and to assess that the Government’s response is proportionate. Measures intended to protect the integrity of the system should not result in victims being unable to access the support and protection they need and are entitled to.

Authorities must not create a situation where seeking protection feels less safe than remaining under a trafficker’s control. If the law appears to confirm traffickers’ threats about removal, punishment or loss of support, it could unintentionally give traffickers another means of controlling victims.

We are particularly concerned about the Bill’s focus on early disclosure and credibility. As survivors, we know that trauma can affect how and when someone is able to speak about what happened to them. You do not always understand straight away that what happened was exploitation or abuse. Sometimes it takes years to make sense of traumatic experiences, to feel safe enough to talk about them, and to trust the people asking you to share something so painful and personal. Trauma does not follow a neat timeline, and neither does disclosure. A survivor taking time to speak should never be used as a reason to doubt them or question their credibility.  

Delayed disclosure should not be treated as dishonesty. Talking about exploitation is one of the hardest things you can ever do: you do not just walk into a room and tell a stranger everything that has happened to you.  

A system that makes survivors prove their credibility before it gives them the safety needed to disclose their exploitation has the process the wrong way round. The responsibility cannot rest solely on survivors to disclose in the way or at the time the system expects. The system also has a responsibility to create the conditions in which disclosure becomes possible and to earn survivors’ trust. 

Trauma can affect memory, communication and the ability to give a consistent account. Fear of traffickers, shame, coercion, language barriers, poor access to legal advice, mental health needs, and previous negative experiences with police, immigration officials or authorities can all delay disclosure. It is extremely difficult for someone in or leaving exploitation to access advice about their rights and options. Many professionals are not trained to spot the signs of exploitation, and survivors are not given the chance to explain what has happened properly. Placing strict expectations on survivors to disclose within set timeframes puts responsibility on the survivor for any delay, rather than recognising the control and harm caused by traffickers or the gaps in the system of identification and support.  

Differences in communication, eye contact, body language, processing, memory or emotional presentation can be influenced by neurodivergence and should not be mistaken for dishonesty or lack of credibility. There is no single way in which a victim or survivor will present, and decision-makers need to understand this alongside trauma responses. 

In addition to delayed disclosure, under the Bill, survivors who give similar accounts of their exploitation will also be seen as less credible. However, these similarities may reveal common methods used by traffickers, help identify other victims, or expose a wider trafficking network. This information could therefore be valuable for prevention and investigation rather than being used to undermine credibility. 

Many survivors are forced, threatened or manipulated into offending as part of their exploitation. However, the Bill would lead to people being disqualified from protection because of criminal convictions. A system that automatically penalises people for offences connected to their exploitation risks punishing victims instead of protecting them, shifting responsibility from the perpetrator to the survivor.  

The impact of these changes will be to discourage survivors from coming forward at all. Many survivors already fear that they will not be believed or taken seriously. If people believe that any delay, inconsistency or difficulty explaining their experience could be used against them or interpreted as ‘bad faith’, more victims may remain hidden, unsupported and at risk of re-trafficking.

Survivors need stability, support and time to rebuild their lives. However, the Bill restricts the grounds for survivors to be granted temporary leave to remain, meaning survivors will no longer be granted temporary status to help with their recovery. Recovery does not happen in a few weeks, and this change will put many survivors in a very precarious situation.  

Whilst temporary immigration status might be granted to allow a survivor to make a compensation claim or to support criminal proceedings, someone experiencing trauma, fear or depression may simply not be psychologically ready to assist an investigation. The system should first create safety and stability so that survivors can recover and, where they are able and willing, engage meaningfully with law enforcement. Recovery and protection should not be something a survivor has to earn through cooperation. 

Going through the NRM and disclosing exploitation can already be extremely difficult. If survivors also fear that a negative decision could suddenly remove their support, they may spend the recovery period worrying about whether they disclosed everything correctly, whether they will be believed and what will happen to them. For those who receive a negative conclusive grounds decision, they could be left without accommodation, stability or support, and therefore extremely vulnerable to further exploitation.  

The reforms introduced by the Bill should therefore be assessed not only in terms of efficiency and decision-making, but also in terms of the impact on survivors’ long-term stability and recovery.  

Whilst legislative and policy reform may seek to improve efficiency, it may also be psychologically harmful. Progress should therefore mean improving the system for the people experiencing it, not simply making it faster or more administratively efficient. Survivors should be treated with dignity, compassion and respect. They should feel safe asking for help without worrying that they will be punished or removed. 

To achieve a trauma-informed response to modern slavery, trauma needs to be understood consistently by survivors, first responders, NGOs, healthcare professionals, decision-makers, policymakers and legislators. This requires training to understand trauma, coercive control, memory, fear, disclosure and the realities of exploitation. Policy-makers must understand that trauma does not follow a timetable and that survivors do not always fit a neat or expected narrative. Frontline professionals must be trained to recognise potential signs of exploitation and trauma informed practice to help build trust with survivors and help them feel safe.  

Wherever possible, survivors should be asked what would help them feel safe enough to speak openly, including whether they have particular needs or preferences about the person interviewing them. The person asking the questions, the environment, communication needs and previous experiences of authorities can all affect someone’s ability to disclose. It is crucial not to be make assumptions but to ask the individual what they need. Without that understanding there is a serious risk that trauma responses will be mistaken for deception.  

Survivor voices must be central to any reform of modern slavery protections. If people with lived experience had been meaningfully consulted, the Bill would better reflect how exploitation, fear and recovery actually work. Protecting victims is not separate from bringing traffickers to justice; it is essential to it.

Our shared objective must be to prevent exploitation taking place, and to hold traffickers to account. Whilst the Bill includes some measures with the potential to disrupt trafficking networks, it also introduces measures which increase fear and uncertainty for survivors. The success of these reforms should be measured not only by how quickly or efficiently the system operates, but by whether we are better able to identify people in exploitation, and whether survivors feel safer, able to build trust, supported in their recovery, and protected from re-trafficking. 

We are deeply concerned that, rather than improving identification and access to justice, the Immigration and Asylum Bill risks creating further barriers for survivors who need safety and support. The system of identification and support should not start from a position where the survivor feels they need to prove that they deserve to be believed. The focus should be on stopping traffickers, protecting survivors and preventing people from being exploited again. 

We stand ready to work with Parliament and Government to co-develop modern slavery protections that are informed by lived experience, understand the realities of trauma and stigma, and give survivors a genuine chance to recover and rebuild their lives.  

Co-signed by lived experience consultants working with Hope for Justice, bringing direct experience, insight and expertise on modern slavery and survivor recovery.