“Survivors still need to prove that support is ‘necessary’ to their recovery before they can access their right to basic support like counselling or safe housing. We know that a lower percentage of survivors are now accessing counselling compared to four years ago.”

Do survivors of traffickers like Epstein fit the framework?

As well as the increased evidence threshold, the government now requires decision-makers to use a framework – introduced in May 2024 – to consider “whether an individual is more or less likely to be a victim of human trafficking for the purpose of sexual exploitation”.

The framework says a person is more likely to be a victim if there were multiple sexual offences involving one or more offenders over an extended period; if there is “evidence of previous criminality by the perpetrator or other victims with the same perpetrator”; if there is evidence of grooming; and if the perpetrator has profited in some way from the abuse.

This rigid framework, campaigners argue, fails to grasp the complexities of the crime and puts more burden on the victims to provide evidence they may simply not have access to. It risks missing victims of abusers such as billionaire US financier Jeffrey Epstein, who trafficked and abused hundreds of girls and women with almost total impunity for decades.

Epstein’s victims, for example, may not have been able to identify the complex ways in which he profited from the abuse. Similarly, those he abused in the 1990s and early 2000s may have struggled to prove trafficking, as Epstein had no criminal convictions at the time (he later served a brief prison sentence in 2008 for soliciting a minor). Had the first victim who came forward to report Epstein in 1996 been subject to the Home Office’s current framework, she would likely have struggled to prove she had been a victim.

Grooming played a significant role in Epstein’s offending, but it is not present in every sex trafficking case, such as when victims have come to the UK legally for work, only to be sexually exploited. Traffickers use a range of tactics, including kidnapping and use of force, without necessarily relying on grooming.

“Modern slavery is a complex and often hidden phenomenon, which can take many different forms, with sometimes multiple forms of exploitation happening at once,” said Eleonora Fais, Anti-Trafficking Monitoring Group coordinator. “This is why clear definitions which are consistent with international frameworks are essential to support and strengthen identification efforts.

“When we frame forms of exploitation within very narrow criteria, like in the case of the sexual exploitation framework, this can create assumptions and stereotypes about what modern slavery should look like.

“This can limit professionals’ understanding of slavery and trafficking, and result in many people not being identified at all or being turned away from identification and support. Ultimately, this can lead to people remaining trapped in exploitation or being at risk of re-trafficking.”

A Home Office spokesperson said: “Modern slavery is a global scourge that abuses and exploits people for profit. We are committed to reviewing the modern slavery system to reduce opportunities for misuse of the system, whilst also ensuring that we have the right protections for those who need it.

“The proportion of positive decisions, both on Reasonable Grounds and Conclusive Grounds, has risen in the past year.”