More needs to be done to tackle the problem of human trafficking in the United Kingdom, an international monitoring group says in a report published today.

The Council of Europe’s group of experts on action against trafficking in human beings, known as GRETA, says it “remains concerned that victims of trafficking are prosecuted and convicted for offences that they were compelled to commit as part of their exploitation”.

Some of them were not identified as victims of trafficking, the report says. Others who had been identified as victims were denied the defence in the Modern Slavery Act 2015 — or its equivalents in Scotland and Northern Ireland.

The monitoring group refers to claims that among the victims of trafficking was Shamima Begum, who left London as a 15-year-old schoolgirl in 2015 and, as the courts put it, “aligned” herself with Islamic State — resulting in the loss of her British citizenship. Today’s report says:

While GRETA is not in a position to assess this case, it recalls that the non-punishment provision applies not only to criminal convictions, but also to civil or administrative forms of punishment, such as deprivation of nationality.

The group “once again urges the UK authorities to make additional efforts to comply with the non-punishment provision”. It says the authorities should

continue providing further training and guidance to law enforcement officers, prosecutors, judges and lawyers on the application of the non-punishment provision, which address the subtle ways by which victims can be compelled to commit offences, including through debt bondage, and how to consider them in the context of the statutory defence.

All 46 members of the Council of Europe, including the UK, have ratified its Convention on Action against Trafficking in Human Beings. So have two non-member states, Belarus and Israel.

Today’s report stresses that there have been positive developments in the UK since previous inspections. But despite the progress achieved, it says several issues continue to give rise to concern.

GRETA urges action in three areas:

Legal assistance and free legal aid. The UK authorities should ensure the provision of legal assistance to possible victims of human trafficking during the identification process and prior to entering the national referral mechanism, guarantee access to free legal aid across the UK and in a timely manner and ensure that free legal aid is available for the procedure before the criminal injuries compensation schemes.

Compensation. The UK authorities should make efforts to facilitate access to compensation for victims of human trafficking, in particular by ensuring that the “illegality defence” does not prevent victims of trafficking who are undocumented workers from accessing compensation from the employers and that victims of labour exploitation can obtain compensation of more than two years owed in the national minimum wage, as well as by enabling victims of trafficking to effectively exercise their right to state compensation within reasonable time.

Non-punishment provision. The UK authorities should make additional efforts to comply with the non-punishment provision, including by ensuring that it can be applied to all offences that victims of trafficking were compelled to commit, removing the requirement to apply the “reasonable person” test in the framework of the statutory defence of child victims and ensuring that the allocation of the burden of proof does not substantially hinder the application of the non-punishment provision.

The report published today is based on fieldwork carried out as long ago as December 2024. It was approved for publication by GRETA in July last year. The UK authorities were then invited to make comments and some of these were incorporated into a revised version that was finalised in November 2025.

Further comments from the UK were invited by the end of January 2026. These were submitted on 13 February and approved last Friday for inclusion in a 12-page annex to today’s report.

Although the report has now been released for publication, I cannot yet find a copy of it online. I shall add links to this piece on my website when the text is available and add any responses I see from the Home Office and the devolved governments.