COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the EU Strategy on Combatting Trafficking in Human Beings 2021- 2025
Date: 2021-04-14
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU Member State, EU strategy, children's rights, fight against crime, help for victims, human rights, international cooperation, organised crime, trafficking in human beings, women's rights

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.4.2021  COM(2021) 171 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the EU Strategy on Combatting Trafficking in Human Beings          2021- 2025  
 
 
1.  Introduction 

Trafficking in human beings destroys individuals’ lives by depriving people of their dignity, 
freedom  and  fundamental  rights.1  It  is  often  a  violent  crime  committed  by  organised  crime 
networks. It should have no place in today’s society.  

Yet,  trafficking  in  human  beings  is  a  global  phenomenon.  It  happens  in  every  country  and 
every  region.  It  continues  to  happen  in  the  European  Union,  too.  According  to  the  latest 
available  data,  between  2017  and  2018,  there  were  more  than  14  000  registered  victims2 
within the European Union.3 The actual number is likely to be significantly higher as many 
victims  remain  undetected.4  Nearly  half  of  the  victims  of  trafficking  within  the  European 
Union  are  EU  nationals  and  a  significant  number  of  them  are  trafficked  within  their  own 
Member  State.  The  majority  of  the  victims  in  the  EU  are  women  and  girls  trafficked  for 
sexual  exploitation.  Almost  every  fourth  victim  of  trafficking  in  the  EU  is  a  child.5  The 
majority of traffickers in the EU are EU citizens and nearly three quarters of perpetrators are 
men. This crime brings high profits to criminals and carries with it enormous human, social 
and economic costs. In the EU, the economic cost is estimated to be up to EUR 2.7 billion in 
a single year.6 

Figure 1 Repartition of registered victims by form of exploitation in the EU in 2017 and 2018 

Figure 2 Repartition of registered victims by sex in the EU in 2017 and 2018 

1 See Article 83(1) of the Treaty on the Functioning of the European Union and Article 5(3) of the Charter of 
Fundamental Rights of the European Union.  
2 63.7% of identified victims and 36.3% of presumed victims. 
3 All EU-27 level data on victims in the document concerns years 2017 and 2018. Source: Data Collection on 
Trafficking in Human beings in the EU (2020); COM(2020) 661 final, 20.10.2020. 
4 COM(2020) 661 final, 20.10.2020 and SWD(2020) 226 final, 20.10.2020. 
5 Article 2(6) of Directive 2011/36/EU defines the term ‘child’ meaning any person below 18 years of age. 
6 Study on  the economic, social and human costs of trafficking in human beings within the EU (2020); at: 
https://ec.europa.eu/anti-
trafficking/sites/antitrafficking/files/study_on_the_economic_social_and_human_costs_of_trafficking_in_huma
n_beings_within_the_eu.pdf. 

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Combatting  trafficking  in  human  beings  has  long  been  a  priority  for  the  European  Union.7 
Over  the  years,  progress  has  been  made  in  many  respects.  Cooperation  among  key  actors, 
including at political level, between law enforcement and judicial authorities, in both national 
and  transnational  contexts,  led  to  prosecutions  and  convictions  as  well  as  improved 
identification,  assistance  and  support  to  victims.  Awareness  raising  campaigns,  education 
programmes and training initiatives were carried out to reduce the risks of people becoming 
victims of trafficking. Studies and reports increased knowledge about the phenomenon, thus 
contributing to developing adequate response strategies.8 

Despite  the  progress  achieved,  trafficking  in  human  beings  remains  a  serious  threat  in  the 
European  Union,  endangering  thousands  of  individuals  every  year,  particularly  women  and 
children. Traffickers prey on social inequalities as well as economic and social vulnerability 
of  people,  which  have  been  exacerbated  by  the  Covid-19  pandemic,  making  it  easier  for 
perpetrators to find victims. The pandemic also hindered victims’ access to justice, assistance 
and support, and hampered the criminal justice response to the crime.  Moreover, traffickers 
moved to a new business model of online recruitment and exploitation of victims,9 making it 
more difficult for law enforcement and the judiciary to respond.  

This  strategy identifies  key priorities with  the objective of combatting trafficking in  human 
beings more effectively. It proposes concrete actions, which will be developed in full respect 
of  fundamental  rights,  to  identify  and  stop  trafficking  early  on,  to  go  after  criminals  by 
turning trafficking from a low-risk and high-return crime to high-risk and low-return crime, 
and to protect the victims and help them rebuild their lives.  

Since  trafficking  in  human  beings  is  a  particularly  serious  form  of  organised  crime,  this 
strategy is  closely  interlinked with  the  EU Strategy to Tackle Organised  Crime 2021-2025. 
While the holistic priorities and key actions of the strategy against organised crime apply to 
trafficking  in  human  beings,  this  strategy  responds  to  the  specific  aspects  of  the  crime  of 
human trafficking. 

2.  Comprehensive  response  to  combatting  trafficking  in  human  beings  –  from 
prevention through protection of victims to prosecution and conviction of traffickers 

Trafficking  in  human  beings  is  a  complex  criminal  phenomenon.  Traffickers  abuse  the 
vulnerable situation of individuals to gain profit. On the demand side, businesses, employers, 
users  and  consumers  benefit  from  the  exploitation  of  victims  through  services,  labour  and 
products. Throughout the trafficking chain, victims suffer severe short-  and long-term harm 
that  requires  immediate  assistance,  support  and  protection  as  well  as  a  re-integration 
perspective for a better life for them.  

The complexity of the trafficking phenomenon calls for a comprehensive response. There is 
a need for overarching legal, policy, and operational initiatives to combat human trafficking 
in  a  coherent  and  wide-ranging  manner  –  from  prevention  to  conviction  of  criminals  while 

7 See EU Strategy towards the Eradication of Trafficking in human beings 2012-2016 COM(2012) 286 final, 
19.6.2012; and Reporting on the follow-up to the EU Strategy towards the Eradication of trafficking in human 
beings and identifying further concrete actions; COM(2017) 728 final, 4.12.2017. 
8 Regular EU-wide data collection takes place with support from Eurostat on victims and their characteristics 
and  on  perpetrators,  including  prosecutions  and  convictions.  All  EU  publications  included  are  available  at: 
https://ec.europa.eu/anti-trafficking/publications. 
9  See  for  example:  ICAT,  COVID-19  pandemic  and  its  impact  for  victims  and  survivors  of  trafficking  in 
persons;  UNODC,  Impact  of  the  Covid-19  Pandemic  on  Trafficking  in  Persons  -  Preliminary  findings  and 
messaging based on rapid stocktaking. 

2 

 
 
                                                           
emphasising the protection of victims at all stages, taking into account in particular women 
and child victims as well as trafficking for sexual exploitation. 

Legislation is one of the most powerful tools at our disposal because it allows to define the 
crime, set sanctions and common objectives to prosecute criminals, and protect the victims. 
The  EU  Anti-trafficking  Directive10  has  been  the  backbone  of  the  EU’s  efforts  in 
combatting human trafficking. The European Commission has monitored and supported the 
transposition and implementation of the Directive in Member States bound by it.11 In its 2016 
Transposition  Report12,  the  Commission  found  that  while  Member  States  made  substantial 
efforts  to  transpose  the  Directive,  there  is  still  room  for  improvement  as  regards  the 
prevention,  protection,  assistance  and  support  measures  to  victims,  including  child  victims. 
The Commission requested further information in 2019 from Member States with regard to 
the  findings  of  its  2016  report.13  In  parallel,  the  Commission  has  been  supporting  Member 
States to implement effectively the Directive. In this context, the Commission developed the 
knowledge  base,14  provided  guidance15  and  funded  dedicated  actions,  including  for  cross-

10  Directive  2011/36/EU  of  the  European  Parliament  and  of  the  Council  of  5 April  2011  on  preventing  and 
combating trafficking in  human beings and protecting its victims, and replacing Council Framework Decision 
2002/629/JHA, OJ L 101, 15.4.2011.  
11 Denmark is not bound by the Anti-trafficking Directive. 
12 COM(2016) 722 final, 2.12.2016. 
13See on implementation: COM(2020) 661 final, 20.10.2020; SWD(2020) 226 final, 20.10.2020. 
14 Through regular contributions to the European Commission’s progress reports adopted every second year and 
studies,  for  example:  the  Study  on  reviewing  Member  States’  national  and  transnational  referral  mechanism 
(2020), the Study on the economic, social and human costs of trafficking in human beings (2020); the Study on 
the gender dimension of Trafficking in human beings (2016). 
15 For example: A guide to enhance child protection focusing on victims of trafficking (2019); Guidelines for the 
identification of victims (2013); Handbook on guardianship for children deprived of parental care (2014). 

3 

 
 
 
                                                           
border  cooperation  initiatives.16  The  Commission’s  work  with  the  EU  network  of  National 
rapporteurs  and  equivalent  mechanisms  and  the  EU  Civil  Society  Platform  against 
Trafficking  in  human  beings17  has  also  supported  the  implementation  of  the  Directive.  The 
correct and complete transposition and full implementation of the Directive will remain the 
Commission’s  priority  to  ensure  that  traffickers  do  not  benefit  from  diverse  approaches 
across Europe and that victims receive adequate protection within the EU regardless of where 
they are. The Commission will continue to support Member States in the implementation of 
the  Directive  and  will  use  its  powers  conferred  by  the  Treaties,  including  infringements  as 
appropriate. 

The monitoring of the implementation of the Directive in Member States, conducted by the 
Commission in inter alia two-yearly progress reports18 as well various stakeholders’ reports19 
indicate  that  the  decade  old  instrument  may  not  be  fit  for  purpose  any  longer.  Despite 
prevention  initiatives  undertaken,  the  demand  for  using  exploited  victims’  services  has  not 
been  reduced.  The  impunity  of  perpetrators  in  the  EU  persists,  and  the  numbers  of 
prosecutions and convictions of traffickers remain low.20 The minimum rules established for 
victims may not take sufficiently into account their actual needs. Therefore, there is a need to 
evaluate the implementation of the Directive and if necessary, based on the outcome of this 
evaluation, propose revising it to make it fit for purpose.21  

At  policy  and  operational  level,  it  is  crucial  to  ensure  cross-border,  regional  and 
international  cooperation, including by  developing  and sharing  knowledge and information, 
as  well  through  interoperability  of  information  systems.  These  practices  make  enforcement 
and  judicial  authorities  better  equipped  to  obstruct  criminals  and  to  support  victims.  While 
criminal networks move across borders – through countries of origin, transit and destination – 
investigating  and  prosecuting  crimes  is  the  competence  of  Member  States  within  their 
jurisdiction. Cross-border cases of trafficking in human beings are difficult to investigate as 
they require resources, coordination and good communication between relevant authorities.22 
Law  enforcement  also  need  capacity,  tools  and  structured  cooperation  to  tackle  the  digital 
modus  operandi  of  traffickers.  EU  agencies,  such  as  Europol  and  Eurojust,  have  been 
facilitating  close  cooperation  and  coordination  between  national  authorities  for  successful 
operational actions to bring criminals to justice and to identify and protect victims.  

When  victims  are  repatriated  or  return  voluntarily  from  the  country  where  they  were 
exploited to their countries of origin, timely cooperation between relevant actors for targeted 
assistance,  support  and  integration  measures  are  necessary  both  at  the  departure  and  at  the 
arrival  point.  Such  processes  to  enable  victims’  access  to  their  rights  in  cross-border  cases 
can  be  facilitated  by  transnational  referral  mechanisms,  i.e.  platforms  for  cross-border 

16 See regular calls for proposals under the Internal Security Police and the Asylum, Integration and Migration 
Fund; and the Study on the Comprehensive Policy review  of anti-trafficking projects funded by the European 
Commission (2016). 
17 https://ec.europa.eu/anti-trafficking/intensifying-coordinated-response/intensifying-coordinated-response 
18 COM(2020) 661 final, 20.10.2020. 
19  For  example,  European  Parliament  resolution  of  10  February  2021  on  the  implementation  of  Directive 
2011/36/EU  on  preventing  and  combatting  trafficking  in  human  beings  and  protecting  its  victims; 
2020/2029(INI).  
20 6 163 prosecutions and 2 426 convictions in EU-27 in 2017-2018. 
21 European  Parliament  resolution  of  10  February  2021  on  the  implementation  of  Directive  2011/36/EU  on 
preventing and combatting trafficking in human beings and protecting its victims; 2020/2029(INI). 
22  Eurojust Report on Trafficking in human beings, Best practices and issues in judicial cooperation (2021). 

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cooperation  of  relevant  public  authorities  and  civil  society  involved  in  following  up  on  the 
identification, assistance and protection of trafficked victims.23 

To better take into account these cross-border and transnational challenges, the Commission 
will  fund  and  coordinate  a  set  of  actions  to  further  improve  the  policy  and  operational 
work to combat trafficking in human beings.24 The actions will aim to enhance exchanges of 
best  practices, including on cross-border cooperation between  law enforcement and judicial 
bodies; to facilitate advisory services by practitioners to reinforce multi-agency cooperation 
and  coordination  at  national  and  transnational  level;  to  help  further  enhance  support  to 
victims and their referral in Europe and beyond; and to promote awareness-raising, research 
and  data  analysis  by  supporting  cooperation  between  relevant  national  bodies,  for  example 
data institutes and observatories. This set of actions will de facto serve as a knowledge and 
expertise hub for Member States and other stakeholders. 

Providing  appropriate  funding  has  facilitated  joint  investigations  and  prosecutions  by 
national  authorities,  increased  capacity  of  law  enforcement  and  other  authorities,  created 
broad  alliances  across  stakeholders  for  a  multi-agency  and  multi-disciplinary  approach  to 
combatting the crime. It also enabled victim support and integration in Europe and in partner 
countries.25  

The priorities under this strategy will be supported by appropriate funding in order to achieve 
tangible impact and provide appropriate responses to different forms of exploitation. In 
addition  to  actions  directly  managed  by  the  Commission,  the  Commission  will  advise 
Member  States  to  prioritise  their  anti-trafficking  actions  in  national  programmes  under  the 
Asylum,  Migration  and  Integration  Fund,  the  Internal  Security  Fund,  and  the  Border 
Management  and  Visa  Instrument  in  line  with  the  priorities  of  this  Strategy,  taking  into 
account  the  national  context  and  needs.  Horizon  Europe  security  research  funding  will 
contribute to the priorities of this strategy as well. The Technical Support  Instrument could 
also be used to support the implementation of this Strategy by the Member States. 

In  order  to  tackle  the  situation  in  countries  of  origin  and  transit  to  Europe  and  outside, 
thematic and geographical EU funding will be mobilised along the priorities of this strategy, 
giving  specific  attention  to  (i)  the  gender  dimension,  (ii)  donor  coordination,  (iii)  local 
ownership  and  (iv)  support  to  civil  society  organisations  and  local  actors  and  activists;  (v) 
addressing the special protection needs of children in migration.26 

Key actions: 

The Commission will: 

-  Further  support  Member  States  in  implementing  of  the  Anti-trafficking  Directive, 
including  through  dedicated  funding,  in  particular  as  regard  the  gender  specific  and 
child sensitive aspects; 

23 See  examples  in:  Study  on  Reviewing  the  functioning  of  National  and  Transnational  Referral  Mechanism 
(2020),  TACT  project  developed  by  the  International  Organisation  for  Migration  (IOM).  For  the  Baltic  Sea 
States’ transnational referral mechanism: https://bsr-trm.com//. 
24 These actions will be funded under the Internal Security Fund. 
25 Study  on  the  Comprehensive  policy  review  on-trafficking  projects  funded  by  the  European  Commission 
(2016). 
26  See  reference  to  the  particular  vulnerability  of  children  in  migration  to  traffickers  in  the  Commission 
Communication on the protection of children in migration, COM(2017) 211 final, 12.4.2017.  

5 

 
 
 
                                                           
-  Ensure  the  effective  implementation  of  the  Anti-trafficking  Directive  as  a  matter  of 
priority  by  using  its  powers  conferred  by  the  Treaties,  including  infringements  as 
appropriate; 

-  Launch  a  study  for  the  evaluation  of  the  Anti-trafficking  Directive,  and  based  on  the 

outcome of the evaluation, consider reviewing the directive; 

-  Ensure appropriate funding to combat trafficking inside and outside the EU.  

3.  Reducing demand that fosters trafficking 

Ultimately,  organised  crime  groups  operate  based  on  the  basic  economic  principle  of  high 
demand  driving  their  activities.  Demand  fosters  all  forms  of  exploitation  of  people  in 
vulnerable situations, which traffickers take advantage of, in particular,  in  high risk sectors 
and high risk environments.27 This in return brings huge revenues to organised crime groups 
and to those who take advantage and profit from the exploitation of the bodies, services and 
labour  of  trafficked  victims.  The  estimated  global  annual  profit  from  trafficking  in  human 
beings  amounted  to  EUR  29.4  billion  in  2015.28  In  the  EU,  in  one  single  year,  criminal 
revenues  of  trafficking  for  sexual  exploitation,  which  is  the  most  prevalent  purpose  of 
trafficking, are estimated at about EUR 14 billion.29 This amount does not take into account 
trafficking for labour and other forms of exploitation. Reducing demand in an effective way 
is  therefore essential to  deprive traffickers of their financial gain  and thus  ensuring that the 
crime does not pay. 

Discouraging  demand  as  part  of  prevention  measures  is  addressed  in  the  Anti-trafficking 
Directive,  which  invites  Member  States  to  consider  criminalising  the  knowing  use  of 
services exploited from trafficked persons. However, the final decision is left to Member 
States.  This  has  led  to  a  diverse  legal  landscape  across  the  EU  where  employers  and  users 
face  different  consequences  where  they  employ  or  use  the  bodies,  labour  and  services  of 
trafficked people. The increasing number of victims30 indicate a worsening situation and calls 
for  a  stronger  and  harmonised  response  to  reduce  illicit  demand  for  exploited  services  of 
trafficked victims. Given the serious and extensive nature of this crime across the EU and the 
differing legal landscapes, which hamper efforts to reduce demand, the criminalisation of the 
knowing use of exploited services and products from victims should be thoroughly analysed. 
As  part  of  the  evaluation  of  the  Anti-trafficking  Directive,  the  Commission  will  therefore 
carry out an assessment on the possibility having minimum EU rules that criminalise the use 
of exploited services of trafficking victims.  

Awareness raising campaigns on the risks of trafficking are important means to detect and 
prevent  the  crime.  They  help  make  the  public,  employers  and  users  of  services  of  victims 
aware  of  trafficking.  Such  campaigns  are  best  conducted  in  cooperation  with  relevant  civil 

27 In  the case of sexual exploitation, prostitution, escort  services,  massage parlours, bars and  nightclubs are 
high risk environments. In the case of labour trafficking, such environments can include: agricultural sector, 
construction, hospitality, cleaning sector, domestic  work,  forestry, textile and garments, food manufacturing 
For  more  details:  COM(2020)  661  final,  20.10.2020  and  SWD(2020)  226  final,  20.10.2020;  Fundamental 
Rights  Agency,  Severe  labour  exploitation:  workers  moving  within  or  into  the  European  Union  (2015)  and 
European Migrant Smuggling Centre, 4th Annual report, Europol 2020. 
28  Europol 
at: 
https://www.europol.europa.eu/publications-documents/trafficking-in-human-beings-financial-business-model 
29 Study on Mapping the risk of serious and organised crime infiltration in legitimate businesses, March 2021, 
DR0221244ENN, https://data.europa.eu/doi/10.2837/64101. 
30 In EU-27: 13461 in 2015 and 2016 and 14 145 in 2017 and 2018. 

business  model, 

(2015),  The 

trafficking 

financial 

human 

beings 

in 

6 

 
 
 
                                                           
society  organisations.  The  Commission  will  therefore  organise  a  communication  campaign, 
together  with  Member  States  and  civil  society,  targeting  high-risk  sectors  and  high-risk 
environments, including for sexual exploitation.  

Labour  exploitation  concerns  15%  of  all  victims  of  trafficking  within  the  European  Union, 
with an increasing number of victims remaining undetected. To bring these numbers down, 
the criminal justice response to trafficking for labour exploitation should be strengthened. 
In  this  context,  national  authorities  should  be  encouraged  to  intensify  joining  efforts  with 
labour inspectors and/or social partners and EU agencies, in particular with Europol, and 
within  its  remit  with  the  European  Labour  Authority,  to  carry  out  concerted  and  joint 
inspections in high risk sectors to identify victims and their exploiters. Enhanced cooperation 
between  Member  States’  relevant  authorities  and  other  actors  through  the  European 
Platform  tackling  undeclared  work,31  soon  within  the  European  Labour  Authority,  will 
help  build  know-how  and  showcase  transferable  practices,  including  to  identify  victims 
trafficked  for  labour  exploitation.  Fostering  the  development  of  public-private  initiatives 
with  businesses  in  high  risk  sectors  and  high  risk  environments,  also  by  involving  the 
regional  and  local  level,  will  support  efforts  to  increase  the  detection  of  trafficking  victims 
and the reporting of the crime to authorities. 

Employers  can  also  contribute  to  reducing  demand  for  serviced  of  exploited  victims  of 
trafficking.  Finding  employment  in  the  EU  without  the  required  legal  status  is  one  of  the 
main  drivers  for  smuggling  as  well  as  trafficking  to  the  EU.32  The  Employers’  Sanctions 
Directive33 prohibits the employment of irregularly staying third-country nationals, including 
victims  of  trafficking  in  human  beings.  It  lays  down  minimum  standards  on  sanctions  and 
other measures to be applied in the Member States against employers who infringe upon the 
Directive. This  year, the Commission will assess how to strengthen the effectiveness of the 
Directive and evaluate the need for further action.  

Businesses  in  certain  sectors  –  such  as  hospitality,  garment,  fishing,  agriculture  and 
construction – may rely on the workforce of people who are in a vulnerable situation. They 
therefore  have  an  important  part  to  play  and  should  take  measures  against  human  rights 
violations. This includes discouraging demand by ensuring that anti-trafficking objectives are 
incorporated  in  their  policies,  which  can  be  achieved  through  responsible  management  of 
global  supply  chains  of  products  and  human  rights  due  diligence.  The  Commission’s 
upcoming legislative initiative on sustainable corporate governance, providing for a duty of 
diligence by companies, is one of the key EU initiatives to promote respect for human rights. 
Public  institutions  also  have  a  role  to  play  in  ensuring  that  public  procurement  incentivise 
transparency  and  due  diligence  in  supply  chains.  The  upcoming  Commission  guide  on 
socially  responsible  public  procurement  will  provide  indications  on  how  to  pursue  these 
objectives.  In  this  context,  the  Council  called  on  Member  States  for  the  effective 
implementation of the UN Guiding Principles on Business and Human Rights and the UN 

31 https://ec.europa.eu/social/main.jsp?catId=1299&langId=en. 
32 For definitions and inter-relation between trafficking and smuggling, see Report: Smuggling and trafficking: 
rights and intersections, https://ec.europa.eu/anti-
trafficking/sites/antitrafficking/files/smuggling_and_trafficking._rights_and_intersections_1.pdf 
33 Directive 2009/52/EC of the European Parliament and of the Council of 18 June 2009 providing for minimum 
standards on sanctions and  measures against employers of  illegally staying third-country nationals,  OJ L 168, 
30.6.2009. 

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Sustainable Development Goals to overcome child and forced labour and human trafficking 
in global supply chains.34 
As  part  of  the  new  EU  trade  policy,35  the  Commission  will  promote  sustainable  and 
responsible  value  chains  on  mandatory  due  diligence,  including  effective  action  and 
enforcement  mechanisms  to  ensure  that  forced  labour  does  not  find  a  place  in  the  value 
chains of EU companies.  The EU will also work to step up efforts to ensure EU companies’ 
supply  chains  are  free  from  child  labour.  The  Commission  will  provide  guidance  to  raise 
awareness among EU business in taking the appropriate measures, based on risk, in line with 
international due diligence guidelines and principles.  

Key actions: 

The Commission will: 

-  Assess the possibility of modifying the provisions of the Anti-Trafficking directive on 

criminalising the use of exploited services from victims of trafficking; 

-  Assess  how  to  strengthen  the  effectiveness  of  the  Employers’  Sanctions  Directive 

including when it comes to the protection of victims of trafficking; 

-  Put  forward a legislative proposal  on sustainable corporate  governance to foster long-

term sustainable and responsible corporate behaviour; 

-  Provide guidance on forced labour due diligence in line with international due diligence 

guidelines and principles; 

-  Organise  a  prevention  campaign,  conducted  together  with  Member  States  and  civil 

society organisations, targeting high-risk sectors and high-risk environments.   

The Commission invites Member States to:  

-  Continue focussing in their criminal justice responses and prevention initiatives on all 

forms of exploitation, including on trafficking for sexual exploitation;  

-  Fully  use  the  support  of  relevant  EU  agencies  (such  as  Europol,  Eurojust,  Cepol  and 
Frontex) and enhance capacity building of their operational actors, including to identify 
potential victims of trafficking; 

- 

Improve  the  capacity  of  labour  inspections  and/or  social  partners  and  facilitate  multi-
agency  cooperation  for  identifying  trafficked  victims  for  labour  exploitation  and  for 
bringing perpetrators to justice; 

-  Cooperate with  EU agencies, in  particular with  Europol,  and  within its remit  with the 

European Labour Authority, to combat labour exploitation; 

-  Develop further public-private initiatives with businesses in high risk sectors and high 

risk environments;  

-  Promote initiatives on due diligence in the global supply chain of products. 

34  See  SWD(2017)  147  final,  24.4.2017;  the  Commission’s  Guidelines  on  non-financial  reporting  enhance 
business  transparency  on  social  and  environmental  matters  (C/2017/4234;  OJ  C  215,  5.7.2017,  p.  1–20); 
European Parliament  Motion for a Resolution on Sustainable corporate governance (2020/2137(INI); Council 
Conclusions on Human Rights and Decent Work in Global Supply Chains ,13512/20, 1 December 2020. 
35 Commission Communication on Trade Policy Review - An Open, Sustainable and Assertive Trade Policy, 
COM(2021) 66 final, 18.2.2021. 

8 

 
 
 
                                                           
4.  Breaking the criminal model to halt victims’ exploitation  

Organised  crime  groups  that  traffic  people  are  well-structured  and  professional  criminal 
networks,  operating  also  internationally.  They  work  with  specialised  tasks,  including 
recruitment, 
transport,  provision  of  clients,  guarding  of  victims,  or  organising 
accommodation and food for victims. Violence, threats, manipulation and deception are used 
to recruit and exploit victims. These groups are often involved in migrant smuggling, money 
laundering, corruption, document fraud, drugs and other serious crimes that support their core 
activities.36 Micro networks’ operate mainly in the field of sexual exploitation where pimping 
is carried out in small groups of up to five people or individually.  

The  European  Commission’s  data  collection  makes  EU  level  data  on  trafficking  available 
since 2008. Improving further data recording and data reporting across EU Member States 
on  traffickers  and  on  victims,  their  nationality,  gender,  age  and  forms  of  exploitation,  will 
help better target and inform policies. Additional cooperation between national data institutes 
could facilitate and improve data reporting. It could involve other pieces of information such 
as trafficking-related criminal activities and information on trafficking routes. 

4.1 Effective operational means against the criminal business model 

Organised crime groups specialised in trafficking increasingly exploit legal businesses (such 
as  hotels,  nightclubs  and  massage  parlours)  in  their  operations,  for  example  by  recruiting 
workers, engaging in a contractual relationship in the country of origin and transferring them 
to  the  country  of  exploitation.37  To  disrupt  the  criminal  business  model  of  trafficking, 
Member States are encouraged to employ the tools and approaches specified in relation to the 
priority  of  the  EU  Strategy  to  Tackle  Organised  Crime  2021-2025  on  removing  profits  of 
organised crime and preventing infiltration into the legal economy and society. This includes 
the  systematic  use  of  financial  investigations  in  law  enforcement  investigations  as  well  as 
developing and implementing a  robust framework to  identify, seize and  confiscate criminal 
assets.38  Moreover,  recovered  assets  can  be  used  for  compensating  victims  and  for  victim 
support  as  well  as  for  trans-border  law  enforcement  counter-trafficking  activities,  which  is 
already encouraged through the Anti-trafficking Directive. 
Member States’ operational actions, with the support of EU agencies, bring concrete results39 
within  the  framework  of  the  European  Multidisciplinary  Platform  against  Crime  Threat 
(EMPACT).40  Europol 
financial 
investigations and supports effective cross-border operational cooperation, also through joint 
investigation teams and joint action days. 

facilitates  Member  States’ 

intelligence-lead  and 

36  SWD(2020)  226  final,  20.10.2020,  EMSC  Annual  Activity  Report  (Europol,  2019),  UNODC,  Global 
Report  on  Trafficking  in  Persons,  2020  (2021),  Study  on  Mapping  the  risk  of  serious  and  organised  crime 
infiltration in legitimate businesses. 
37 Study on Mapping the risk of serious and organised crime infiltration in legitimate businesses. 
38  See  Council  conclusions  on  enhancing  financial  investigations  to  fight  serious  and  organised  crime, 
8927/20, 17 June 2020. 
39 For example in 2019, such actions resulted in 825 arrests, 8 824 suspects and 1307 potential victims, 
including 69 identified children, 94 identified or dismantled organized crime groups (OCGs) and EUR 1,5 
million of assets frozen in bank accounts, companies and web domains, at: 
https://www.consilium.europa.eu/media/44281/information-note-empact.pdf; 
https://newsroom.consilium.europa.eu/videos/127612-empact-2019-results-20200602 and 
https://data.consilium.europa.eu/doc/document/ST-7623-2020-INIT/en/pdf. 
Since 2010, trafficking in human beings has been an EU crime priority within the framework of the EU policy 
cycle on serious and organised crime. 

9 

 
 
 
                                                           
4.2  Tackling  the  culture  of  impunity  by  building  capacity  for  a  robust  criminal  justice 
response 
The low numbers of prosecutions and convictions of traffickers41 still mean that trafficking is 
a  low-risk  and  high-profit  crime.  To  break  the  trafficking  chain,  a  robust  criminal  justice 
response is crucial in order to carry out effective investigations, prosecution and convictions, 
taking into account, inter alia, the gender specific nature of the crime. This requires building 
expertise and assigning specialised experts and departments or units for trafficking in human 
beings among the competent authorities at national and local level. 

Criminal activities are evolving fast. This calls for law enforcement and the judiciary to keep 
pace with skills, capabilities and knowledge about available tools, services and technologies. 
The EU Strategy to Tackle Organised Crime 2021-2025 defines the objectives,  actions  and 
actors  for  improving  access  to  skills,  knowledge  and  operational  expertise.  In  this  context, 
with a view to breaking the criminal model for trafficking victims for exploitation, capacity 
building efforts should be strengthened.  

Systematic training of law enforcement and justice practitioners on specific elements of 
the  crime  as  well  as  with  multi-stakeholder,  simulation-based  practical  exercises  to  test 
procedures  in  handling  trafficking  cases  will  increase  professionalism  and  coordination  in 
dealing  with  the  cases  and  will  ensure  appropriate  follow-up.  Such  training  activities  are 
encouraged to focus on the specific features of trafficking for different forms of exploitation 
(sexual,  forced  labour,  forced  criminality,  forced  begging,  child  trafficking),  the  complex 
dynamics  between  trafficking  in  human  beings  and  other  illicit  activities,  methods  for 
detecting the crime and its financial aspects, the role and use of internet and social media, as 
well  as  on  developing  skills  in  managing  investigations  and  moving  them  towards 
prosecutions  (evidence  gathering,  interviewing  victims,  victim  protection,  transnational 
cooperation). In addition to specialised training for law enforcement working on trafficking 
cases, training other law enforcement officers working in other crime areas as well as training 
for the judiciary is necessary to increase the detection, reporting and to improve handling of 
trafficking cases. 

To take into account victims’ perspective and needs, training should take place in a multi-
stakeholder environment, including, among others, law enforcement, judicial authorities, civil 
society,  social  workers,  child  protection  practitioners,  education  and  health  care  providers. 
Specific  attention  should  be  dedicated  to  capacity  building  of  police,  labour  inspectors, 
border  guards,  prosecutors  and  judges  on  how  to  work  with  victims  during  criminal 
proceedings,  on  detecting  signs  of  being  a  victim  of  trafficking  and  on  referring  victims  to 
support  services,  in  line  with  applicable  procedures.  Cases  involving  child  victims  of 
trafficking  require  trained  officials  who  are  aware  of  the  particular  vulnerabilities  of  child 
victims  and  who  are  well  trained  on  children  rights  and  protection  needs  during  criminal 
proceedings. 

Training  of  justice  professionals  on  the  available  instruments  of  judicial  cooperation  in 
criminal  law  will  contribute  to  intensifying  cooperation  between  law  enforcement  and 
judicial  authorities  as  well  as  other  relevant  actors,  such  as  labour  inspectors  or  social 
partners. 

The Commission will fund and coordinate capacity building measures for law enforcement in 
cross-border  and  transnational  cooperation,  such  as  simulation  exercises.  In  addition,  the 

41 There were 6 163 prosecutions and 2 426 convictions in the EU in 2017-2018 for the offences of trafficking 
in human beings. COM(2020) 661final, 20.10.2020. 

10 

 
 
                                                           
Commission  will  facilitate,  together  with  Eurojust,  the  creation  of  a  focus  group  of 
specialised prosecutors against trafficking in human beings, with a view to intensify judicial 
cooperation. These actions will create opportunities for further law enforcement and judicial 
cooperation and will also lead to the development of guidance for their work. 

4.3 Tackling the digital business model of traffickers 

Organised  crime  groups  swiftly  adapt  their  modus  operandi  and  business  model  to  the 
changing patterns of demand. During the Covid-19 pandemic, traffickers increasingly moved 
online  for  every  phase  of  trafficking.  They  use  the  digital  space  in  the  recruitment  and 
exploitation  of  victims,  organisation  of  their  transport  and  accommodation,  advertising 
victims  online  and  reaching  out  to  potential  clients,  controlling  victims,  communicating 
between  perpetrators  and  hiding  the  criminal  proceeds.42  Technology  has  broadened 
criminals’ ability to traffic human beings for different types of exploitation, particularly for 
sexual,  but  also  for  labour  exploitation,  the  removal  of  organs,  illegal  adoption  of  children 
and  forced  marriages.  Children  are  at  particular  risk  of  falling  victim  to  traffickers  online. 
While criminals have managed to take advantage of the latest capacities offered in the digital 
era,  law  enforcement  faces  major  challenges  keeping  pace,  including  detecting  signs  of 
exploitation  in  the  increasing  magnitude  of  online  advertisements  and  obtaining  crucial 
digital evidence.43  

The challenges created by  the  digital age for law enforcement and judicial  bodies  in  the 
fight  against  trafficking  in  human  beings  should  be  addressed  in  line  with  the  horizontal 
priority of the EU Strategy to Tackle Organised Crime 2021-2025 related to the modern law 
enforcement  response  to  technological  developments.  Europol  can  support  stepping  up  the 
detection  of  internet  content  used  by  traffickers.  Making  the  best  use  of  technology  and 
relying on digital evidence can alleviate the situation of victims in criminal proceedings. For 
example, there would be less need to rely on victims’ testimony if other types of evidence are 
found and victims would avoid the trauma of facing their traffickers in court. 

Further to the already existing obligations for platforms to remove illegal content under the e-
Commerce  directive,  as  reinforced  by  the  proposal  for  the  Digital  Services  Act44,  the 
Commission will conduct a dialogue with relevant internet and technology companies to 
reduce  the  use  of  online  platforms  for  the  recruitment  and  exploitation  of  victims.  The 
Commission  will  also  accompany  possible  similar  dialogues  to  be  conducted  by  Member 
States  at  national  level.  Internet  service  providers  and  related  companies  are  part  of  the 
solution to support anti-trafficking efforts with identification and removal of online material 
associated  with  exploitation  and  abuse  of  trafficked  victims45.  Cooperation with  the  private 
sector  is  therefore  encouraged  to  harness  innovation  and  expertise  for  the  development  of 
technology-based  solutions  to  support  prevention  and  combatting  of  trafficking  in  human 
beings. Prevention and awareness-raising activities on the safe use of the internet and social 
media, among others, could further contribute to mitigating the risk of child trafficking. 

Key actions:  

42  Europol,  ‘The  challenges  of  countering  human  trafficking  in  the  digital  era’  (2020).  See  also  COM(2020) 
661final, 20.10.2020 and SWD(2020) 226final, 20.10.2020 and European Parliament resolution of 10 February 
2021 on the implementation of Directive 2011/36/EU on preventing and combatting trafficking in human beings 
and protecting its victims, 2020/2029(INI)).). 
43 Europol, 2021 EU Serious and Organised Threat Assessment Report (EU SOCTA),12 April 2021 
44 https://ec.europa.eu/digital-single-market/en/digital-services-act-package. 
45 COM(2020) 661 final, 20.10.2020. 

11 

 
 
 
                                                           
The Commission will: 

- 

- 

Improve  data  recording  and  data  collection  on  trafficking  in  human  beings  to  ensure 
reliable and comparable information for tailor made policies; 

Facilitate the creation of a focus  group of specialised prosecutors  against trafficking  in 
human beings; 

-  Enhance the coordination of law enforcement services in cross-border and international 
cases  and  support  multi-stakeholders  coordinated  responses,  including  via  funding  of 
simulation exercises; 

-  Enhance  law  enforcement  and  judicial  cooperation  between  Member  States  through 

concrete operational projects under the Internal Security Fund; 

-  Conduct  a  dialogue  with  the  private  sector  and  digital  industries  and  promote  the 

exchange of best practices with support from EU agencies.  

Member States are invited to: 

- 

Improve their national data recording and data collection on trafficking in human being; 

-  Make  full  use  of  existing  instruments  for  operational  cooperation,  such  as  joint 
investigation teams, with support from Europol and pursue operational cooperation in the 
framework of EMPACT; 

- 

- 

Systematically exchange data on investigations on human trafficking with the support of 
Europol; 

Improve  digital  capabilities  of  law  enforcement  and  expertise  to  keep  up  with 
technological developments. 

5.  Protecting,  supporting  and  empowering  the  victims,  especially  women  and 

children 

Trafficking  in  human  beings  is  a  grave  violation  of  fundamental  rights,  which  causes  great 
suffering  and  long-lasting  harm  to  the  victims.  In  addition  to  the  comprehensive  actions  of 
the EU Strategy on victims’ rights (2020-2025)46 and the comprehensive EU strategy on the 
Rights of the Child47, this Strategy proposes measures to improve the situation of victims of 
trafficking  in  human  beings.  Trafficking  for  sexual  exploitation48  –  which  is  the  most 
prevalent  form  of  exploitation  –  is  a  form  of  gender-based  violence,  rooted  in  gender 
inequalities.  Several  factors  increase  the  vulnerability  of  women  and  girls  to  trafficking, 
including  gender  inequality,  poverty,  social  exclusion,  ethnicity,  and  discrimination.49  The 
data  at  the  EU  level  highlights  the  gender  dimension  of  the  crime.  Nearly  three  quarters 
(72%) of all victims in the EU and 92% of the victims trafficked for sexual exploitation are 
women  and  girls.  Nearly  a  quarter  of  all  victims  of  trafficking  are  children.  Most  of  the 
child victims are EU citizens and trafficked for sexual exploitation,50 Children in migration, 

46  Commission  Communication  on  the  EU  Strategy  on  victims’  rights  (2020-2025),  COM(2020)  258  final, 
24.6.2020. 
47 Commission Communication on the EU Strategy on the rights of the child, COM(2021)142final, 24.3.2021. 
48 In 2017-2018, 60% of all registered victims had been trafficked for sexual exploitation.  
49 European Parliament resolution (2020/2029(INI)). 
50  In  2017  and  2018:  78%  of  child  victims  were  girls;  60  %  of  child  victims  were  trafficked  for  sexual 
exploitation  and  three  quarters  (75%)  of  all  child  victims  in  the  EU  were  EU  citizens.  Trafficking  and 

12 

 
 
 
                                                           
 
and  in  particular  unaccompanied  migrant  children,  are  also  particularly  vulnerable  to 
traffickers.51    The  proposed  action  takes  these  patterns  into  account  and  addresses  the 
situation of other vulnerable groups, and the intersection between them, including LGBTIQ 
people,  persons  with  disabilities52  and  people  from  ethnic  minority  backgrounds,  such  as 
those belonging to marginalised Roma communities. Young women and minors from Roma 
communities are especially vulnerable to exploitation and trafficking53 due to several socio-
economic factors such as multi-dimensional poverty, antigypsyism, low levels of education, 
precarious housing conditions, social exclusion and discrimination.54  

Figure 3 Repartition of registered victims of trafficking by EU and non-EU citizenship in the EU in 2017 and 2018 

Early  identification  of victims  is  crucial  to  promptly  assist,  support  and  protect  victims  of 
trafficking  in  human  beings  and  enables  police  and  prosecution  authorities  to  better 
investigate and punish traffickers.  Frontline officers, such as border  guards, police officers, 
social  workers  and  inspector  services  are  crucial  in  this  respect.  The  involvement  of  civil 
society  organisations  in  the  identification  of  victims  and  their  referral  for  support  is  a 
challenge,  just  as  the  lack  of  training  of  professionals  in  cross-border  victims’  support 
cases.55  

To  improve  the  current  situation,  the  proactive  early  identification  of  victims  must  be 
followed  by  strong  support  in  addressing  victims’  need.  However,  ensuring  assistance, 
support and protection to victims remains a challenge. Victims often encounter difficulties 
in accessing their rights. Their specific needs and circumstances, depending on the forms of 
exploitation  they  were  subjected  to,  their  sex  and  age,  are  not  systematically  taken  into 
account.  Accessing  compensation  for  trafficking  victims  is  hampered  by  many  difficulties, 
including  by  the  complexity  of  the  proceedings.56  Victims  should  also  not  have  to  fear 
retaliation  and  secondary  victimisation  during  criminal  proceedings,  when  they  report  the 

exploitation  of  boys,  especially  for  sexual  exploitation,  including  children  in  migration,  is  recalled  to  be  an 
under-reported phenomenon at EU level. 
51  See  Commission  Communication  on  the  protection  of  children  in  migration,  COM(2017)  211  final, 
12.4.2017. 
52 As concerns persons with disabilities who are also particularly vulnerable to human trafficking, violence and 
abuse, the Strategy for the Rights of Persons with Disabilities 2021-2030, (COM(2021) 101 final), 3.3.2021 will 
pursue actions in the area of safety and protection. 
53 
https://csd.bg/fileadmin/user_upload/publications_library/files/22588.pdf. 
54 The  Commission adopted on 7 October 2020 the  EU Roma strategic framework  for equality, inclusion and 
participation to ensure effective equality, socioeconomic inclusion and promote participation of Europe’s largest 
ethnic minority; COM(2020) 620 final, 7.10.2020. It aims to combat poverty, antigypsyism and discrimination.  
55 Study on Reviewing the functioning of National and Transnational Referral Mechanism (2020). 
56 SWD(2020) 226 final, 20.10.2020. 

Communities’ 

Trafficking 

Vulnerable 

(2015); 

among 

‘Child 

Roma 

13 

 
 
 
                                                                                                                                                                                     
crime.57 They should not be penalised for crimes they were compelled to commit during their 
exploitation.58  They  should  be  treated  as  rights  holders,  without  prejudice  or  bias. 
Furthermore,  opportunities  for  the  victims  to  rebuild  their  lives  also  remain  limited  as  re-
integration and rehabilitation programmes need to be further developed and opportunities for 
durable solutions, such as inclusion into the labour market, are scarce.59  

The Commission will support Member States’ efforts in improving the early identification 
of victims, as well as their referral to assistance, support and protection services, taking into 
account their special needs and the forms of exploitation to which they have been subjected. 
Special  attention  should  be  paid  to  child  victims  and  children  at  risk  of  trafficking,  with 
systematic  reporting  and  alerts  on  missing  children  for  an  early  identification,  referral 
procedures tailored to child victims, speedy appointment of guardians and effective free legal 
aid.  The  Commission  will  promote  activities  such  as  gender-sensitive  and  child-rights 
based  training  for  professionals  likely  to  come  into  contact  with  victims  (such  as  law 
enforcement,  judiciary,  labour  inspectors,  immigration  and  asylum  officers,  border  guards, 
social  workers,  victims  support  or  healthcare  staff),  developing  guidelines,  toolkits  and 
exchanging  best  practices  among  practitioners  to  improve  national  structures  and 
cooperation  for  the  identification,  assistance  and  support  of  victims,  including  national 
referral mechanisms.  

In  accordance  with  the  Anti-trafficking  Directive,  Member  States  have  taken  measures  to 
establish appropriate mechanisms aimed at the early identification, assistance to and support 
for victims, so called referral mechanisms. The European Commission carried out a study on 
national  and  transnational  mechanisms  in  Member  States60.  The  study  identified  areas  for 
further 
improvements:  detecting  potential  victims;  making  available  appropriate 
accommodation,  notably  for  child  victims;  strengthening  cooperation  among  all  actors, 
including civil society organisations; and better monitoring of impact and results of measures 
in  all  phases  of  the  referral.  Taking  into  account  existing  national  and  transnational 
cooperation, the Commission will enhance actions to improve victims’ support and referral in 
the  cross-border  context,  towards  the  objective  of  setting  up  a  European  referral 
cooperation  mechanism,  with  the  support  of  relevant  EU  agencies  (such  as  the  European 
Asylum Support Office, Fundamental Rights Agency, European Institute for Gender Equality 
and Cepol).  
Support to Member States  is  also offered by the ten EU agencies61 who signed the joint 
statement of commitment to work together against trafficking in human beings in 2018. The 
Commission coordinates their cooperation, in line with their respective mandates, to address 
challenges related to victims of trafficking. They will jointly report on their respective roles 
and  actions  to  make  Member  States  more  aware  of  the  Agencies’  potential  in  helping  the 

57 See also the objectives of the EU Strategy on Victims Rights 2020-2025; COM(2020)258 final, 24.6.2020. 
58 See European Court of Human Rights recently ruling related to the non-punishment of victims, V.C.L. and 
A.N. v the United Kingdom of 16 February 2021. 
59 Study on Reviewing the functioning of National and Transnational Referral Mechanism (2020). 
60 Ibid. 
61 The Heads of the European Asylum Support Office (EASO), European Police Office (Europol), European 
Agency for the operational management of large-scale IT systems in the area of freedom, security and justice 
(eu-LISA), European Monitoring Centre for Drugs and Drug Addiction (EMCDDA), EU Judicial Cooperation 
Unit (Eurojust), European Institute  for Gender Equality (EIGE), European Border and Coast Guard Agency 
(Frontex), EU Agency for Fundamental Rights (FRA), EU Agency for Law Enforcement Training (CEPOL), 
and the European Foundation for the Improvement of Living and Working Conditions (Eurofound) signed a 
Joint Statement of commitment to work together against trafficking in human beings. 

14 

 
 
                                                           
early identification and protection of victims and to encourage Member States to work closer 
with the agencies in this area. 

To address trafficking at the local  and regional and transnational levels and to benefit from 
available  European  funding  instruments,  the  Commission  will  encourage  cooperation 
between relevant national and local authorities and regions, cities and municipalities. The 
Commission will seek closer cooperation with the European Economic and Social Committee 
and  the  Committee  of  the  Regions  and  respective  partners  to  fight  trafficking  in  human 
beings. The partnership on integration, signed by the Commission and the Committee of the 
Regions62, will provide support for the integration of all migrants, including non-EU victims 
of trafficking.  

Victims  of  trafficking  should  have  access  to  appropriate  and  safe  accommodation  that 
allows  them  to  escape  from  traffickers  and  that  is  adapted  to  their  specific  needs  and 
circumstances. Safe shelters are needed for children, women and men. Same-sex shelters that 
also provide trauma-focussed support can effectively help victims’ recovery.  In this respect, 
the Commission will enable targeted funding support for shelters for victims of trafficking – 
including specialised facilities for women and child victims of trafficking – via the Asylum, 
Migration and  Integration Fund and  Internal  Security  Fund, in  accordance with  the specific 
eligibility conditions and scope of each of the Funds. 

Social,  economic  and  educational  measures  are  essential  for  victims  to  re-integrate  into 
society. The Commission will facilitate and promote programmes supporting victims in their 
recovery  and  re-integration  such  as  health,  psychological  or  legal  specialised  services,  and 
facilitating access to education and economic opportunities. The Commission will encourage 
Member  States  to  put  in  place  community-led  and  peer-mentoring  programmes  involving 
victims of trafficking, offering opportunities for education, employment and empowerment.  

Victims  who  are  not  EU  citizens  face  additional  difficulties.  The  particular  situation  of 
victims of trafficking requires specific consideration when issuing residence permits. Under 
current  EU  rules,  the  granting  of  a  residence  permit  can  be  conditional  upon  the  victim’s 
cooperation  in  the  criminal  proceedings.63  In  addition,  there  are  inconsistencies  across 
Member States in the application of reflection periods for victims who are not EU citizens64, 
during which assistance to victims is ensured. Member States should pay particular attention 
to the specific situation of trafficked victims in the context of transferring non-EU citizens to 
the  country  where  they  first  arrived65.  Victims  can  become  accessible  to  traffickers  and  be 
exposed  to  risks  of  being  re-trafficked.  In  addition,  for  children  in  migration,  specific 
safeguards should be put in place to ensure that their rights are respected, throughout relevant 

62https://ec.europa.eu/home-affairs/news/european-commission-committee-regions-partnership-integration_en 
63 See Articles 6 and 8 of Council Directive 2004/81/EC of 29 April 2004 on the residence permit issued to third-
country nationals who are victims of trafficking in human beings or who have been the subject of an action to 
facilitate  illegal immigration,  who cooperate  with the  competent authorities, OJ  L 261, 6.8.2004. Civil society 
organisations have highlighted the gap between the numbers of victims who are not EU citizens and the number 
of residence permits issued under the Directive. 
64 Under the 2004 Residence Permit Directive, third-country nationals concerned are granted a reflection period 
allowing them to recover and escape the influence of the perpetrators of the offences so that they can take an 
informed decision as to whether to cooperate with the competent authorities (reflection period). 
65 Regulation (EU) No 604/2013 of the European Parliament and of the Council of 26 June 2013 establishing the 
criteria  and  mechanisms  for  determining  the  Member  State  responsible  for  examining  an  application  for 
international protection lodged in one of the Member States by a third-country national or a stateless person, OJ 
L 180, 29.6.2013. 

15 

 
 
                                                           
procedures.66 The Action Plan on Integration and Inclusion 2021-202767 provides measures, 
including for victims of trafficking. 

The  EU  Anti-trafficking  Directive  sets  minimum  requirements,  including  on  the  support 
and  protection  of  victims.  The  Commission  will  assess  how  the  above  identified  concerns 
related to  the Anti-trafficking Directive  can  be better addressed, including  through  a strong 
gender dimension68 in supporting and protecting victims, the non-punishment of victims for 
crimes  they  were  compelled  to  commit,  and  in  relation  to  the  2004  Council  Directive  on 
residence permit for victims of trafficking.69  

Key actions:  

The Commission will: 

-  Enhance capacity building and sharing of best practices for the identification of victims 
of  trafficking,  in  particular  among  vulnerable  groups,  including  through  dedicated 
funding for training of police, social workers, inspector services, border guards; 

-  Facilitate  re-integration  and  victim  empowerment  programmes  and  exchanges  on  best 

practices in this regard; 

-  Enhance cooperation towards a European referral mechanism; 

-  Enable  targeted  funding  support  to  specialised  shelters  for  victims  of  trafficking, 
including  specialised  facilities  for  trafficked  women  and  children  via  the  Asylum, 
Migration and Integration Fund and Internal Security Fund; 

-  Ensure funding in non-EU partner countries to non-governmental organisations, migrant 
resource centres for supporting victims, including their psychosocial, taking into account 
gender and child-specific needs; 

-  Develop close cooperation with the European Economic and Social Committee and  the 
Committee of the Regions in order to multiply the impact of anti-trafficking actions with 
social and economic partners and on local and regional level;   

-  Enhance  partnerships  with  non-EU  countries  to  ensure  that  victims’  rights  are 
guaranteed during all the steps of the return process and that they receive specific, tailor-
made assistance and protection upon return, including specific safeguards for children.   

The Commission invites Member States to: 

-  Promote gender sensitive and child rights based training for officers and all practitioners 

likely to come into contact with victims. 

-  Promote awareness-raising activities targeting frontline professionals in high-risk sectors 

and high-risk environments where victims of trafficking are exploited; 

-  Create  safe  environments  for  victims  to  report  their  crimes  without  a  fear  of  being 
prosecuted for acts they were forced to commit by the traffickers, and without a fear to 

66  Commission  Communication  on  “Enhancing  cooperation  on  return  and  readmission  as  part  of  a  fair, 
effective and comprehensive EU migration policy, COM(2021) 56 final, 10.2.2021. 
67  Commission  Communication  on  the  Action  plan  on  Integration  and  Inclusion  2021-2027,  COM(2020)  758 
final, 24.11.2020. 
68  The  Commission  is  following  up  on  the  commitments  of  the  EU  Gender  Equality  Strategy  2020-2025 
COM(2020)  152  final,  5.3.2020  including  by  proposing  a  legislative  initiative  on  combatting  gender-based 
violence against women and domestic violence. 
69 Council Directive 2004/81/EC, OJ L 261, 6.8.2004. 

16 

 
 
                                                           
be  exposed  to  secondary  victimisation,  intimidation  or  retaliation  in  the  context  of 
criminal proceedings; 

- 

Improve the functioning of  National Referral Mechanisms; 

-  Provide  training  to  health  care  workers  on  diversity  management  and  the  needs  of 
victims  of  trafficking  in  human  beings  who  are  migrants,  under  the  EU  health 
programmes;  

-  Enable funding for community-led and peer-mentoring empowerment programmes. 

6.  International dimension 

In 2020, 534 different trafficking flows were identified globally and more than 120 countries 
reported  victims  from  more  than  140  different  countries  of  origin.70  Trafficking  is  a 
transnational  crime,  and  half  of  the  victims  identified  in  the  European  Union  are  non-EU 
citizens, mainly from  Africa, Western Balkans and Asia.71 In low income countries, half of 
the person victims of trafficking are children, the majority of them forced into child labour.72 
The  EU  must  therefore  also  step  up  its  efforts  to  address  economic  grievances  and  help 
families  and  communities  to  become  more  resilient  to  negative  coping  mechanisms.  The 
priorities  of  this  strategy,  including  breaking  the  criminal  business  model  of  traffickers, 
reducing demand, and protecting and empowering victims should therefore fully apply in the 
context of the EU’s external policies.  

Victims  are  also  trafficked  in  mixed  migration  flows  to  the  EU  via  all  routes.  Migrant 
smuggling  is  often  intertwined  with  other  forms  of  organised  crime,  such  as  trafficking  in 
human  beings.  The  current  global  and  regional  migration  situation  heightens  the  risks  of 
trafficking,  with  traffickers  abusing  asylum  procedures,  including  by  legalising  their  own 
status and that of their victims73. The EU Action Plan against Migrant Smuggling under the 
new Pact on Migration and Asylum74 will contribute to disrupting traffickers’ business in 
moving victims for exploitation to Europe and fight smuggling networks. Furthermore, a key 
strand of the Pact is establishing and deepening partnerships with countries of origin, transit 
and  destination.  It  is  therefore  essential  to  advance  international  cooperation  and 
partnerships  by  making  best  use  of  external  policy  instruments,  cooperation  tools  and 
funding75 in order to share information and criminal intelligence on trafficking, related crimes 
and  criminal  networks.  Closer  cooperation  of  Member  States  with  non-EU  countries  is 
facilitated and supported by a wide range of  EU foreign policy instruments, including the 
Global  Strategy for the EU Foreign and Security Policy, the Action Plan on Human Rights 
and Democracy 2020-2024, the EU Gender Action Plan for external action (2021-2025), the 
Joint  Communication “Towards a comprehensive strategy  with  Africa”.  In addition,  for the 
EU’s enlargement process and neighbourhood policy, other instruments are relevant such as 
the  EU  Western  Balkans  Strategy,  the  Joint  Communication  “Eastern  Partnership  Policy 

70 UNODC, Global Trafficking in Persons report, 2020 (2021). UNODC used the term “flow” as a combination 
of one origin country and one destination where at least 5 victims were detected during the period considered. 
For flows, the 2018 (or most recent) data was used as the reference year. For countries where 2018 data were 
not available, the most recent data from 2019, 2017 or 2016 were used. 
71 Data collection on trafficking in human beings in the EU (2020). 
72 Global Trafficking in Persons report, 2020. 
73 European Migrant Smuggling Centre 4th Annual Activity report, Europol, 2020.   
74 Commission Communication on a New Pact on Migration and Asylum, COM(2020)609 final, 23.9.2020. 
75 For example through the Neighbourhood, Development and International Cooperation Instrument. 

17 

 
 
 
                                                           
beyond  2020  Reinforcing  Resilience-  an  Eastern  Partnership  that  delivers  for  all”  and  the 
Joint  Communication  “Renewed  partnership  with  the  Southern  Neighbourhood-A  new 
Agenda  for  the  Mediterranean”.  The  EU’s  approach  to  external  security  within  the 
framework  of  the  Common  Foreign  and  Security  and  the  Common  Security  and  Defence 
Policy  is  essential.  The  civilian  and  military  missions  under  the  Common  Security  and 
Defence Policy lead efforts to disrupt organised criminal networks involved in smuggling of 
migrants and trafficking in human beings.76 Closer cooperation with justice and home affairs 
agencies  in  this  field,  as  stipulated  in  the  civilian  Common  Security  and  Defence  Policy 
Compact77, is also of crucial importance. 

These  instruments  are  key  to  promote  closer  cooperation  between  EU  Member  States  and 
countries  of  origin  and  transit  of  victims.  Systematic  engagement  of  EU  delegations  in 
specific  countries  will  be  facilitated  and  close  cooperation  with  Common  Security  and 
Defence Policy missions and operations will be sought,  where relevant  and applicable.  The 
European External Action Service will continue to play a key role in enhancing strategic and 
operational  cooperation  with  third  countries  and  international  organisations,  by  making  full 
use  of  its  external  tools,  such  as  the  high  level  dialogues  and  the  network  of  Counter-
Terrorism/Security  experts  in  EU  delegations.  The  cooperation  with  UN  agencies  and 
international  organisations,  such  as  the  United  Nations  Office  on  Drugs  and  Crime  and  the 
International  Organization  for  Migration,  reinforce  actions  at  global  level,  particularly  with 
countries of origin and transit. 

The  Commission  supports  Member  States  and  non-EU  partner  countries 
the 
implementation  of  the  United  Nations  Convention  against  Transnational  Organized  Crime 
and the Trafficking in Persons Protocol, to which the EU and its Member States are parties. 
The EU and its  Member States are also  part of the recently launched review mechanism of 
the implementation of the UN Trafficking in Persons Protocol. The Commission will pursue 
closer  cooperation  with  relevant  actors  in  relation  to  the  UN  Protocol,  including  but  not 
limited to the Inter-Agency Coordination Group against Trafficking in Persons of the United 
Nations. The Commission will also work closely with the Council of Europe and its Group 
of  Experts  on  Action  against  Trafficking  in  Human  Beings78  in  line  with  the  identified 
priorities of this strategy. 

in 

External  actions  should  take  into  account  the  relevant  Sustainable  Development  Goals  of 
the  United  Nations  focussing  on  trafficking  in  human  beings.79  In  this  context,  the  EU’s 
trade  policy  promotes  sustainable  development  goals,  including  human  rights  and 
employment  standards.  The  Commission  will  consider  whether  current  international 
standards against trafficking in human beings could be better reflected in the implementation 
of trade agreements and their enforcement notably via the more assertive use of the essential 
elements clause. 

76 For example, the EUBAM Libya mission and the operation EUNAVFOR MED IRINI. 
77  On  19  November  2018,  the  Council  and  the  Member  States  adopted  conclusions  on  the  establishment  of  a 
(CSDP)  compact.  See  Council  Conclusions: 
civilian  Common  Security  and  Defence  Policy 
https://www.consilium.europa.eu/en/press/press-releases/2018/11/19/civilian-common-security-and-defence-
policy-eu-strengthens-its-capacities-to-act//. 
78 Council Conclusions on EU priorities for cooperation with the Council of Europe 2020-2022, 9283/20.  13 
July 2020. 
79 SDG 5.2 (violence against all women and girls); SDG 8.7 (forced labour and human trafficking) and SDG 
16.2 (violence against and torture of children). 

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The  Commission  welcomes  the  recently  adopted  EU  Global  Human  Rights  Sanctions 
Regime,80  which  allows  the  European  Union  to  target  individuals,  entities  and  bodies 
responsible  for,  involved  in,  or  associated  with  serious  human  rights  violations  and  abuses 
worldwide. The sanctions regime enables the Council to impose travel bans, asset freezes and 
the  prohibition  to  make  funds  or  economic  resources  available  to  listed  individuals  and 
entities. 

Key actions: 

The Commission will: 

-  Adopt an EU Action Plan against Migrant Smuggling (2021-2025); 

-  Step up cooperation with non-EU countries of origin and transit of victims as well as with 

international and regional partners, including international organisations; 

-  Use the dedicated human rights and security dialogues in engaging with partner countries; 

-  Enhance  cooperation  with  the  Council  of  Europe  and  its  Group  of  Experts  on  Action 

against Trafficking in human beings; 

-  Support the European External Action Service’s systematic engagement of EU delegations 
in  specific  countries  by  regular  and  targeted  communication,  action  and  exchange  of 
information. 

The Commission invites Member States to:  

-  Enhance  information  sharing  and  criminal  intelligence  on  trafficking  and  related  crimes 
and  criminal  networks;  and  facilitate  cross-border  and  international  operational  and 
judicial  cooperation  in  countries  affected  by  trafficking  notably  in  the  Western  Balkans, 
countries in the Neighbourhood, Africa, the Middle East, and South-East Asia, including 
with support from EU agencies, such as Europol and Eurojust. 

7.  Conclusion 

Trafficking  in  human  beings  is  a  serious  and  complex  crime,  which  mostly  affects  women 
and children. It brings enormous revenues to criminals while causing tremendous suffering to 
victims and high costs to our society. Despite progress made over the last decade to reinforce 
the  Union’s  response  against  trafficking  in  human  beings,  the  threat  of  being  trafficked 
remains  high  for  any  vulnerable  person.  Trafficking  in  human  beings  impacts  the  fabric  of 
society,  rule  of  law  and  sustainable  development  in  EU  Member  States  and  in  our  partner 
countries. 

With  this  strategy,  the  Commission  sets  out  a  renewed  commitment  and  a  strong  policy 
framework  to  protect  vulnerable  individuals  from  being  trafficked,  to  empower  victims,  to 
bring perpetrators to justice, and to safeguard our communities. Women and children are at 
the centre of this commitment. 

80 Council Decision (CFSP) 2020/1999 of 7 December 2020 concerning restrictive measures against serious 
human  rights  violations  and  abuses;  OJ  L  410I  ,  7.12.2020;  and  Council  Regulation  (EU)  2020/1998  of  7 
December  2020  concerning  restrictive  measures  against  serious  human  rights  violations  and  abuses;  O.J.L-
410 I, 7.12.2020. 

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The priorities and actions set out in this strategy will be implemented in the period from 2021 
to 2025. Meanwhile, the Commission will be ready to react swiftly to any new developments 
or  trends  based  on  continuous  monitoring  and  analysis  of  how  trafficking  in  human  beings 
evolves – in the EU and beyond. Together, the EU and its Member States must stay ahead of 
criminals, users and exploiters of victims. 

The Commission is committed to the timely and effective implementation of this strategy. As 
combatting  trafficking  in  human  beings  needs  the  engagement  of  all,  the  Commission  will 
work closely with all partners to maximise the impact of the foreseen actions. The EU anti-
trafficking  coordinator  will  help  ensure  coordination  and  coherence  among  EU  institutions, 
EU agencies, Member States and international actors, in the implementation of this strategy. 
Joining  forces  in  the  fight  against  trafficking  in  human  beings  is  essential  for  ensuring 
European security, protecting vulnerable people and the economy, and for the safeguarding of 
the rule of law and fundamental rights.  

The  Commission  will  also  systematically  monitor  and  report  on  the  implementation  of  this 
Strategy, including to the European Parliament and the Council.  

20