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Briefing: Immigration and Asylum Bill will put survivors of modern slavery at risk

10th July 2026 – After Exploitation is joined by specialist charities in raising the alarm on the risk facing survivors of modern slavery, including human trafficking, under the Immigration and Asylum Bill. Higher evidence burdens and greater immigration insecurity are amongst the new challenges set to face survivors.

Under provisions in Part 1, 2 and 5 of the Bill, survivors would be impacted by:

  • Creation of the Independent Immigration Appeal Authority (IIAA): The Bill puts a mixture of ordinary people and legal professionals in charge of deciding asylum appeals, instead of Immigration Judges. The government claims this will ‘speed up’ the process, but ensuring people seeking asylum have a lawyer to produce all the evidence they need as early as possible is the best way to clear the backlog whilst ensuring peoples’ rights are respected, including survivors. (Part 1)
  • Limits to Human Rights claims: Changes to the definition of ‘family’ which downgrade the significance of peoples’ ties to the country where aunts, uncles, cousins, nephews, and nieces make it necessary to stay in the UK, are likely to impact some survivors submitting human rights claims. Meanwhile, decisions are due to be made based on whether people seeking asylum are predicted to use state support like the NHS, social care or welfare in the future. This risks punishing people made vulnerable by factors outside of their control, like exploitation, who may need support to recover in the future. (Part 2)
  • Return of the ‘trauma deadline’: The return of a ‘trauma deadline’ penalises victims for not disclosing traumatic details ‘quickly enough’, exacerbating the difficulties faced by survivors who may struggle to recount their experiences until they can access support. (Part 5)
  • Harm to rejected victims: The Bill’s immediate cessation of support for victims rejected by Home Office decision makers increases the risk of destitution and re-trafficking, neglecting that many victims are initially disbelieved. (Part 5)
  • Immigration insecurity: Non-UK survivors face increased immigration insecurity under the Bill, with the already limited Temporary Status for Victims of Trafficking or Slavery (VTS) becoming almost impossible to access. This will result in more survivors feeling afraid to come forward, due to the risk of immigration detention or deportation. (Part 5)
  • Survivors disqualified: The Bill’s broad measures could disqualify survivors if they have ever recieved any type of custodial sentence, disproportionately affecting those who have been exploited into committing crimes. (Part 5)
  • Children‘s support “out of reach“: While child trafficking provisions appear positive, including the rollout of support, the increased scrutiny and evidence burdens in the rest of the Bill also apply to children. This means that welcome support is undermined, as young victims of exploitation will struggle to access it. (Part 5)

MPs are set to discuss the measures as part of the Bill’s second reading is scheduled for 13th July 2026.

In response, our briefing co-authored by After Exploitation, AVID Detention, Focus on Labour Exploitation (FLEX), Freedom United, Immigration Law Practitioners Association (ILPA) and No-one Above (NOA), outlines that the ways in which the Bill undermines access to recovery, support and justice for people who have experienced modern slavery. Some provisions in the Bill are specific to victims who are also seeking asylum, and others affect all survivors regardless of their nationality (including British victims).

Much of this briefing is informed by analysis by immigration solicitor Sonia Lenegan, Work Rights Centre, Anti-Slavery International / ATLEU, and the Anti-Slavery Commissioner’s briefing on this Bill. Our thanks to the legal practitioners who volunteered their time to review this briefing.

Survivors need more certainty, not scrutiny, in order to recover. We continue encouraging MPs to reject measures which penalise victims and instead back the ‘Hear Survivors, Support Survivors‘ campaign by pledging their support for a fairer system.

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