The Immigration and Asylum Bill is about to have its first debate. Whilst some measures have the potential to strengthen the UK’s response to modern slavery, Justice & Care remains deeply concerned that many aspects will make it harder for victims to access protection and support, increasing their vulnerability and potentially undermining efforts to bring traffickers and exploiters to justice.  

The much-anticipated Immigration and Asylum Bill has been published and will have its Second Reading debate in parliament on 13 July. As we suspected when the Bill was announced in the King’s Speech the Bill makes some steps forward although many lack the strategic ambition necessary to make real change. Most worrying are aspects of the Bill that reduce and limit access to support that could leave victims trapped in exploitation. 

Positive steps — but greater ambition is needed 

There are some welcome measures in the Bill. Slavery and Trafficking Prevention Orders and Risk Orders can restrict the activities of convicted offenders, or people who pose a clear risk of committing modern slavery offences. The proposals to make these orders more widely available and use electronic monitoring will give police stronger tools to stop exploitation before it happens. However, Justice & Care believes the Government should go further by making these orders mandatory following conviction for modern slavery offences, and available for a wider range of exploitation-related crimes.

The Bill also includes important protections for child victims. Enabling local authorities (or other designated authorities) to formally identify child victims alongside measures to support the continued roll-out of Independent Child Trafficking Guardians could help ensure vulnerable children are identified more quickly and supported by specialists who understand their needs. 

Stronger supply chain transparency requirements are also a positive and long-overdue development. Extending reporting obligations to public bodies, setting clearer expectations for modern slavery statements, and introducing sanctions for non-compliance should help improve corporate accountability. But transparency alone is not enough. The UK still needs stronger laws requiring businesses to undertake due diligence to prevent exploitation in their operations and supply chains, as well as measures to stop goods produced with forced labour from entering the UK market.

Areas of concern 

Our greatest concern is that the Bill continues to place modern slavery within an immigration framework. Modern slavery is a serious crime and a grave violation of human rights. Treating victim protection primarily through the lens of immigration control risks deterring people from coming forward and may leave more victims trapped in exploitation. 

The Bill targets potential misuse of the modern slavery system, but there is no evidence of widespread abuse.  There are already checks and balances in place to identify inappropriate cases, and policy must not be shaped in a way that makes it harder for  victims to access help. 

We are particularly worried about measures that will require decision-makers to treat delayed disclosures, inconsistencies or inaccuracies in a possible victim’s account as damaging to their credibility. Trauma, fear, coercion and mistrust of authorities are common barriers to disclosure. Many victims are not able to explain what has happened to them immediately, or in a perfectly consistent way. 

Removing the guaranteed minimum recovery period is also deeply troubling. Victims often need time, stability, and specialist support before they can begin to recover, disclose their experiences fully or engage safely with a police investigation. Reducing this support risks increasing vulnerability and the likelihood of re-exploitation. 

We are also concerned by the circumstances in which victims can be disqualified from support. New exemptions for children are welcome but limited. However, the broad definition of public order could exclude victims who are compelled to commit offences as part of their exploitation. Removing support makes it less likely that victims will seek help, and less likely that traffickers will be brought to justice. 

The proposal to stop granting confirmed victims temporary permission to stay in the UK on the basis that their recovery requires ongoing support is another serious concern. Survivors with significant physical or mental health needs may be left without the care and stability they need, increasing the risk of further harm. Rather than restricting protection, the Government should build a long-term, holistic support framework that enables survivors to recover safely, rebuild their lives and support efforts to disrupt the criminal networks profiting from exploitation. 

We urge the Government to amend the Bill so that it protects victims, supports recovery, and enhances efforts to disrupt and prosecute the criminal networks that profit from exploitation.