In light of International Human Trafficking Awareness day, marked on the 11th of January, we are reminded that trafficking and exploitation present a complex policy challenge with grave implications for human rights and migrant protection in Scotland. In our line of work supporting people to secure status under the EU Settlement Scheme, we see how immigration uncertainty, delayed decision-making, and incorrect advice can create conditions of labour exploitation and heightened vulnerability. This blog aims to offer an evidence-based snapshot of Scotland’s current trafficking landscape to explain the value of identifying and accessing trafficking related rights and to share safeguarding mechanisms.
What is Human Trafficking?
Scotland’s human trafficking framework is anchored in the Human Trafficking and Exploitation (Scotland) Act 2015. It is aligned within the Palermo Protocol definition of trafficking, which recognises exploitation as arising through coercion, deception or abuse of power. These principles underpin the Scottish Government’s 2025 Trafficking and Exploitation Strategy, seeking to strengthen prevention, improve identification, and enhance victim-centred responses.
Scottish Landscape
Official statistics from the UK’s National Referral Mechanism (NRM) – the primary system for identifying potential victims – show a sustained rise in referrals in Scotland. NRM referrals increased from 765 in 2023 to 920 persons in 2024. Labour exploitation was the largest category of these referrals, followed by criminal and sexual exploitation. Likewise, broader UK NRM data shows a record of 19,125 NRM referrals for potential modern slavery victims in the UK – a steep rise from 2023. As a result, the government has pledged to eradicate an already existing backlog of decisions on modern slavery cases, within the next 2 years.
Labour exploitation remains the most frequently recorded form, followed by criminal and sexual exploitation. Adult men are disproportionately represented in labour and criminal exploitation referrals, while children continue to account for a significant proportion of cases, according to Home Office statistics from 2024. As acknowledged in policy, these figures are widely understood to underrepresent the true scale of exploitation due to trafficking’s hidden nature and its social stigmatisation.
Evidence submitted by JustRight Scotland to parliamentary inquiries highlights that NRM data capture only those individuals who are identified and able to engage with the system. Many survivors remain unidentified or disengaged due to delays, fear of immigration consequences, or lack of trust in statutory processes, proving wider accessibility issues. These systemic barriers, combined with policy environments that increase dependency on employers, expose gaps in protection. Those experiencing overlapping forms of exploitation are particularly silenced.
Post-Brexit Sponsorship Schemes
Under the UK’s post-Brexit sponsorship scheme and tightened immigration rules migrant workers in Scotland are now facing increasing and overlapping risks from tied visas, care-sector exploitation, and fraudulent recruitment schemes.
When a migrant’s legal right to reside in the UK depends on a single employer, this constitutes a tied visa system. This structure creates a precarious position of vulnerability by creating conditions that enable exploitation and, in severe cases, human trafficking – the most prominent being the care worker visa route.
The care worker visa route was introduced in February of 2022 to plug critical staffing shortages in social care, exacerbated by the end of free movement after Brexit. It relaxed immigration rules by expanding the existing health and care worker visa to include entry-level workers in low-paid jobs for the first time. Independent investigative reporting has since exposed how the care worker visa route is linked to horrific exploitation and fraud.
The independent antislavery commissioner, Eleanor Lyons, verified that more than 470 UK care providers have had their licenses revoked amid concerns of abuse and exploitation. Around 39,000 workers are said to have been affected in total with 1 in 4 care agencies losing their licenses to suspected fraud between February 2022 and December 2024. Currently, the Home Office reports that whilst the 2022 introduction of the Health and Care Worker visa has indeed reduced social care vacancies, there is insufficient cross-government collaboration to prevent exploitation, take enforcement action and safeguard affected people.
The effect on migrant workers has been costly, both emotionally and financially. In some cases, workers have sold property, quit jobs at their home to afford the extortionate recruitment fees after “being promised a life” in the UK, only to discover the job did not exist. Another case involves a man from North Indian, who paid £16,000 to work in a UK care home only to return home in debt when the Home Office took action against his employer, breaking his visa sponsorship. Organisations like the Works Rights Centre and Unseen are calling for urgent reform from UK ministers, identifying a record 918 potential victim of modern slavery and human trafficking related exploitation in the care sector in 2023 alone. A proposed regulated hiring abroad licensing scheme and introduction of tougher penalties have all been mentioned but not implemented.
Others like Migrants at Work and Migrant Network Rights have collected further migrant workers lived experiences to emphasise this exploitative dependency. Findings demonstrated that migrants cannot often change employers without losing their immigration status within the 60-day limit on finding a new sponsoring employer. Specifically, tied visa-schemes and bilateral agreements have enabled ‘legal’ pathways to be utilised by exploitative employers, recruiters, and potential criminals. This exploitation is also seen in the agricultural sector, with migrant workers reporting excessive recruitment fees, long hours, poor housing, debt bondage, deportation risks all constituting the recognised conditions for modern slavery. As a result, many have been found overworked or left without work entirely, with sponsors collecting illegal recruitment fees, falling foul of the Fraud Act 2006 which aims to prevent human exploitation, articulated in the 1956 Slavery Convention.
Immigration Precarity, the EU Settlement Scheme, and Labour Exploitation
Alongside sponsorship-related exploitation, immigration precarity linked to the EU Settlement Scheme – the post-Brexit scheme allowing EU, EEA and Swiss citizens resident in the UK before 31 December 2020, and their eligible family members, to secure lawful status – has also created conditions that increase vulnerability to labour exploitation.
Prior to changes introduced by the Home Office in August 2023, individuals were issued Certificates of Application after applying, even where they were not eligible; in most cases, applications were made in good faith following incorrect advice from employers, community networks, or unregulated immigration advisers. Many understood the ability to generate a renewable share code as evidence of a temporary right to work, without realising this permission existed only while an application was pending. It was only after they got a refusal and seek advice that they learnt they were not eligible to apply and likely not able to stay under any other immigration route. While those who seek advice are often warned that life without status will be extremely difficult, it remains unclear how many people have remained in the UK in these circumstances. Some individuals, including women facing domestic abuse or other serious vulnerabilities, have reported that returning to their country of origin was not a viable or safe option, further increasing their exposure to precarious living and working conditions.
A further source of vulnerability arises in cases involving late applications, where individuals may be legally entitled to apply but have spent extended periods without status due to lack of awareness, misinformation, or complex personal circumstances. During this time, many rely on informal or cash-in-hand work in sectors such as construction, agriculture, or cleaning, where fear of enforcement and lack of labour protections increase exposure to underpayment, unsafe conditions, and exploitation.
Fake recruitment scenarios
In addition to inherent structural issues, migrant workers are subject to endangering fraudulent sponsorship schemes. Criminals have impersonated legitimate UK care recruiters charging migrants thousands of pounds for job offers and Certificates of Sponsorship that simply do not exist, leaving workers in debt before they even arrive. These scams often originate in migrants’ home countries, with agents advertising fake work visas via social media or messaging apps to deliberately mislead people into paying exorbitant fees. These exploitative methods prey on limited understanding of human trafficking, governmental distrust, and migrant workers limited legal pathways. In 2024, nearly 6,000 trafficking victims rejected support from the National Referral Mechanism (NRM), evidencing stark distrust between immigration enforcement and migrants. Respondents also claimed fear of traffickers, having received support elsewhere, and wanting to put the experience of being trafficked behind them.
Phishing attacks targeting the Home Office’s Sponsorship Management System have also been used to issue fraudulent sponsorships, with employment marketed to jobseekers for £15,000–£20,000. Meanwhile, some newly licensed sponsor organisations with little capacity for genuine employment create further avenues for deception and exploitation.
This combination of tied visas, debt, and fraudulent recruitment traps migrants in a cycle of vulnerability, discouraging them from reporting exploitation and facilitating trafficking-like conditions even further. Migrant Rights Network accordingly states there are no current ways for migrants to safely report exploitative practices without experiencing repercussions either by their sponsors or the Home Office.
Moving Forward
Faced with such unprecedented scale of human trafficking and exploitation in Scotland, awareness, legal frameworks, and civil society interventions are critical tools to identify, protect, and support those affected. Scotland’s commitment to the Human Trafficking and Exploitation (Scotland) Act 2015, alongside international obligations such as the Palermo Protocol, demonstrate that trafficking can be addressed with coordinated action.
By strengthening labour protections, ensuring migrant workers can access their rights without fear, and fostering trust between authorities and vulnerable communities, systemic vulnerabilities can be reduced.
Crucial civil society organisations like Migrant Help UK, JustRight Scotland, and Trafficking Awareness Raising Alliance (TARA), frontline practitioners, and informed policymakers are actively preventing exploitation, supporting survivors, and holding perpetrators accountable. Looking forward, embedding survivor-centred approaches, reforming visa schemes, and enhancing transparency and accountability across recruitment and care sectors can reduce modern slavery conditions.
As such, case workers and civil society organisations must continue to be equipped not only to recognise and respond to trafficking and exploitation but also to educate migrant communities about their rights, entitlements, and available protections to prevent exploitation before it occurs.
We at Citizens Rights Project believe that whilst challenges remain, collective commitment to human rights’ informed protection and justice offers a path free from coercion, abuse, and fear. Strengthening labour protections, safeguarding access to rights regardless of immigration status, and supporting early, informed identification by frontline practitioners is therefore vital.
Personal safeguarding
- To reduce risk, we encourage migrants to verify sponsor licences via the UK Government list: Register of licensed sponsors: workers – GOV.UK
We advise workers to never pay upfront recruitment fees, only apply for visas through official Home Office channels, and to seek advice from the trusted organisations listed below.
- If you are based in Scotland and need help with your immigration status, always check that they solicitor or immigration adviser are registered with the Law Society of Scotland or the Immigration Advice Authority (IAA), as unregistered advisers may be operating illegally.
Trusted Organisations
- JustRight Scotland: 0141 406 5350
- Trafficking Awareness Raising Alliance (TARA): 0141-276-7724 (24/7)
- Migrant Help (Scotland) 0141 8847900 / 0141 2128553 (Out of Hours)
- CrimeStoppers: Anyone can call with a tip – 0800 555111
- Modern Slavery Helpline: 0800 0121 700
- Police: Emergency 999 | Tip or advice 101
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