By 15 July, Member States must transpose the revised Anti-Trafficking Directive 2024 into national law. Articles 11(4) and 11(5) require the establishment of National Referral Mechanisms (NRMs) and to formalise these by laws, regulations or administrative provisions, next to the appointment of a national focal point for cross-border victim referrals. Hereto, states should establish minimum standards for the detection, early identification, and assistance to (presumed) victims, in cooperation with relevant support organisations. Article 11(3) further provides that assistance and support must not be conditional on a victim’s willingness to cooperate in criminal proceedings.
With the transposing deadline approaching, La Strada International is calling for close involvement of CSOs, especially specialised anti-trafficking NGOs, including its’ members, in the strengthening, implementing, coordination and monitoring of NRMs and focal points, towards adequate protection and support for all victims of human trafficking.
CALL TO ACTION
Without meaningful civil society involvement, formal NRMs and national focal points risk failing to effectively protect and support trafficking victims. La Strada International calls on the European Commission and Member States to ensure the revised EU Anti-Trafficking Directive delivers effective NRMs and focal points through structured cooperation with civil society.
In particular we demand States to:
- Ensure formal inclusion of specialised civil society organisations in the strengthening, implementing, coordination and monitoring of NRMs and national focal points, by defining specific roles and responsibilities for anti-trafficking NGOs, next to trade unions, workers’ organisations and other CSOs, as required by Articles 11 and 20 of the revised EU Anti-Trafficking Directive. NGOs play an important role in information provision, specialised accommodation, psychosocial counselling, legal assistance, long-term reintegration support, outreach, detection and (cross-border) referrals. However, cooperation with specialised anti-trafficking NGOs is not always formally embedded in legislation or policy and often relies on project-based funding or informal arrangements.
- Formally recognise specialised anti-trafficking NGOs as frontline actors in victim detection, identification, and referral alongside public authorities, ensuring their assessments carry appropriate weight, including in cross-border cases. Victims of human trafficking rarely self-identify and often avoid contact with authorities due to fear, trauma, mistrust or a lack of awareness of their rights. Specialised NGOs are often the first point of contact for (potential) victims, therefore Member States should formally recognise their role withing formal referral and identification frameworks.
- Ensure NRMs and focal points address gaps in identification, referral, and support remain operational through political transitions and crises, and adapt to evolving forms of exploitation.
- Establish safe, confidential, non-punitive, gender and child-sensitive, victim-centred reporting and referral mechanisms for all victims regardless of status, including vulnerable foreign nationals, without fear of detention, sanctions or adverse immigration consequences. Access to identification, protection and support must not be dependent on cooperation with criminal proceedings.
- Offer unconditional support to victims of trafficking, by creating a “social pathway” independent of cooperation in criminal proceedings.
- Strengthen cross-border referral systems by building on existing NGO-led and multidisciplinary pathways, ensuring trust-based, victim-centred cooperation. Their primary focus should be to coordinate and facilitate structured communication and cross-border referrals between national systems in order to ensure continuity of protection and assistance across jurisdictions.
- Harmonize focal points’ mandates across the EU, to ensure effective cross border victim protection and introduce mutual recognition of victim status across EU Member States.
- Make training on NRMs and referral procedures mandatory and regular for all stakeholders, including CSOs.
- Ensure sustainable, long-term funding for NRMs and national focal points, including adequate support for CSOs, beyond project-based funding. Current short-term, fragmented or insufficient funding undermines continuity of care, limits capacity and weakens anti-trafficking responses.
- Conduct regular independent evaluations of NRMs and focal points, led or mandated by independent National Rapporteurs, focusing on impact on victim protection and rights. Although substantial data are collected on trafficking offences, victims and offenders, less attention is given to evaluating the functioning of NRMs and focal points themselves. Monitoring should assess whether coordination and referral procedures are applied consistently across sectors and regions, whether minimum standards for detection and identification are met, and whether support measures deliver meaningful outcomes for victims beyond procedural compliance.