When someone is referred into the National Referral Mechanism (NRM), the government system for identifying and supporting survivors, the first assessment should simply ask: are there reasonable grounds to suspect this person may be a victim of modern slavery?
In recent years, that bar has been raised.
The Nationality and Borders Act 2022 (NABA 2022) increased the requirement to ‘reasonable grounds to believe’ and introduced a requirement for ‘evidence of objective factors’. Despite the requirement for evidence since being deemed unlawful, decision-makers have continued to deny entry to support on these grounds.
In 2025, more than 9,000 negative reasonable grounds decisions were issued. The most common reason for such decisions was that the referral contained insufficient information to meet the standard of proof required.
Evidence beyond reach
Survivors are expected to provide evidence that is often impossible to gather in the early days after exiting exploitation. Consequently, many survivors of modern slavery have been denied support and protection, which can lead to re-trafficking and prevent law enforcement from pursuing traffickers.
Modern slavery is a hidden crime. It relies on coercion, fear and control. Traffickers deliberately leave little trace. They restrict access to phones, bank accounts and documents. They isolate them from anyone who might help. Yet survivors have been asked to prove what was designed to be invisible.
A negative decision for a survivor can significantly harm their recovery. It means they are denied access to the support they deserve and they can suffer re-traumatisation from reliving events and articulating them on the search for evidence. As with other forms of abuse, denial of recognition by authorities can add additional layers of harm. Many survivors report fears of not being believed if they exited their exploitation.
The pressure on professionals to act immediately
First responders, organisations like Unseen that are authorised to refer someone into the NRM, are in many cases the first professionals a survivor speaks to about their exploitation, whether before or after escaping exploitation.
When first responders identify someone who may be a victim, they face an immediate dilemma. Outside the NRM, there is often no guaranteed, dedicated place of safety. There is no automatic right to specialist accommodation or financial support. For many people, entry into the NRM is the only route to secure safe housing and basic stability.
That means first responders often need to act quickly. If they delay making a referral in order to gather more information, the person in front of them may remain homeless, at risk, or within reach of their exploiter. A swift referral can be the difference between safety and returning to harm.
However, speed comes at a cost. At the point of referral, survivors may be exhausted, fearful of authorities, or still under threat from traffickers. Trust takes time to build. Details of exploitation often emerge gradually, not in a single conversation. Evidence may take time to produce, especially if reliant on external agencies. Yet once the referral is made, there may be only a short window to submit further supporting information before a reasonable grounds decision is reached.
In effect, the system asks first responders to provide detailed evidence at precisely the moment when it is hardest to obtain – before safety is secured, trust is established, and trauma can be safely disclosed.
First responder lottery
The outcome of their reasonable grounds decision may also be determined by the first responder agency that makes their referral. Awareness of modern slavery and the first responder duty to refer survivors into the NRM remains low. There is no mandatory training for professionals that hold this duty. Survivor engagement skills such as cultural awareness and trauma informed practice are not widespread.
Different agencies have access to varying sources of information and some hold individual powers that may assist in the development of evidence, where others do not.
In short, the increased thresholds of belief and evidence at reasonable grounds stage were introduced to a system that was not equipped to meet the previous, lesser requirements.
Overturned decisions reveal a broken system
As negative decisions at the reasonable grounds stage have increased, so too have requests for reconsiderations. Since 2023, the percentage of reconsidered reasonable grounds and conclusive grounds decisions resulting in a positive decision were higher than the percentage of initial positive decisions in that period. A conclusive grounds decision is the final determination made by the UK government on whether someone is officially recognised as a victim of modern slavery or human trafficking.
This points to a troubling reality: the system is turning away genuine survivors before they even have a chance to access support. People who have already endured exploitation are being refused help because the bar for evidence is too high, too rigid, or impossible to meet immediately after trauma.
Those exploited overseas face even greater hurdles. Many arrive in the UK without documentation, with supporting evidence lost or destroyed along the way. Professionals here cannot easily access records, legal systems, or information from other countries, making it far harder to corroborate a survivor’s story.
At the same time, survivors with fewer resources struggle to navigate a complex system that demands precise detail and documentation. Limited English, little formal education, lack of family or social support, and unfamiliarity with UK systems all intersect to create further barriers. The very people most at risk – often those traffickers deliberately target – are the ones least able to provide the evidence the system requires.
Closing the door on reconsideration
An update from the Home Office on modern slavery statutory guidance on reconsideration requests in September 2025 worsened the predicament for some survivors. Victims from countries signed up to Council of Europe Convention on Action Against Trafficking in Human Beings (ECAT) and the European Convention on Human Rights (ECHR) can no longer request a reconsideration of a negative reasonable grounds or conclusive grounds decision. This removes the last opportunity some victims have to challenge these negative decisions and secure the stability needed to support their recovery.
When the identification process fails, protection fails. Without recognition as a survivor, access to safe housing, specialist support, and recovery services is denied. That leaves individuals exposed, vulnerable to re-trafficking, and stuck in cycles of harm – while the system remains unaware of the full scale of exploitation.
The economic cost of modern slavery
Failing to address exploitation is not only morally wrong – it also undermines our economy. The socio-economic cost of modern slavery on the UK is £60bn a year.
When victims are turned away, exploiters continue to operate. That means more investigations, more policing, and more victims in the future.
The longer someone remains stuck in modern slavery, the deeper the trauma. Extended trauma leads to longer recovery times, placing sustained pressure on mental health and physical health services. Early support is far less costly than long-term crisis care.
The increase in the number of requests for reconsiderations at a reasonable grounds stage acts as a drain on Home Office resources. It generates increased costs for legal aid as survivors often need a solicitor or legal adviser to analyse the original decision and determine whether it can be challenged.
In short, refusing protection does not save money. It stores up greater expense for the future.
Stand with us
Our Restoring belief, reducing criminality report provides further information and context on how increased evidence thresholds have prevented survivors from being identified and accessing support.
We are calling for:
- Legislators to restore the original ‘reasonable grounds to suspect’ test – one based on suspicion rather than proof. The first-stage decision should prioritise safety and access to support where exploitation is credible, not require evidence that survivors cannot realistically provide in the earliest days after trauma.
- Pre-NRM places of safety to be rolled out so that people have time to disclose information safely and gather evidence.
- First responders to be adequately trained so they can accurately and consistency identify and support survivors.
With your support, we can ensure decision-makers hear what is happening on the ground. We can push for a system that protects victims properly, holds exploiters to account, and uses public money wisely.
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Learn more about what you can do to support Unseen’s fight to end modern slavery.