Reasonable grounds decisions in the NRM – who has been impacted by the change to the decision-making threshold?
The National Referral Mechanism (NRM) is the Home Office process for identifying victims of modern slavery. Since it was established in 2009 the number of people known as ‘potential victims’ identified and referred for support has been continuously increasing. In 2024, 19,125 potential victims were referred to the NRM by a designated First Responder organisation. In parallel with implementing the Nationality and Borders Act 2022, on 30 January 2023 the Home Office introduced an updated test for reasonable grounds (RG) decisions in the NRM which required greater objective evidence than previously. Although modified in July 2023 following legal action, the policy represents a significantly higher threshold.
A positive RG decision is necessary for access to specialist support for modern slavery victims — particularly important for adult victims who may have no other routes to assistance or protection, including protection— from being removed from the UK for those with insecure immigration status. After the introduction of the policy there was a notable increase in the rate of negative RG decisions. We have analysed the latest NRM data available via the UK Data Service1 to assess if this has continued and which cohorts of potential victims are most impacted.