ENoMW Submission
Significant challenges persist in asylum and reception settings across the European Union, particularly in relation to the identification and protection of women victims of trafficking and sexual exploitation.
Main challenges stem from gaps between policy commitments and operational realities. Frontline implementation faces structural barriers that prevent safe disclosure, accurate identification, and durable protection. Identification frameworks frequently rely on sex-neutral approaches that obscure how exploitation manifests in practice, resulting in the systematic under-identification of women experiencing exploitation.
Barriers to Safe Disclosure and Protection
Women victims of trafficking and sexual exploitation may be unable to disclose due to trauma, fear of retaliation, stigma, dependency on exploiters, or distrust of authorities. Systems structured around rapid screening do not adequately reflect the dynamics of coercion and control. Frontline procedures often prioritise speed and administrative processing over trauma-informed engagement.
Protection is often perceived as conditional on procedural compliance, immigration status, or engagement with authorities. This discourages disclosure and limits access to durable safety.
Misclassification and Sex-Neutral Frameworks
Forms of harm including reproductive exploitation through surrogacy, forced marriage, and exploitation in prostitution systems are frequently treated as general vulnerability rather than trafficking-related risk.
A significant concern is the tendency to subsume trafficking for sexual exploitation under general labour exploitation frameworks. This leads to the misclassification of exploited women as irregular economic migrants who entered voluntarily. This pattern is particularly acute for displaced Ukrainian women fleeing armed conflict, who are rarely assessed as trafficking victims and are instead characterised as having made a choice.
Implementation of the Pact and Anti-Trafficking Directive (2024)
The implementation of the Pact on Migration and Asylum and the revised Anti-Trafficking Directive (2024) creates an opportunity to embed trafficking identification and protection more systematically.
However, for this opportunity to be effective, trafficking responses must be operationalised as protection measures, not treated as add-ons to migration procedures. This requires:
- Clear firewalls ensuring that disclosure does not trigger detention or return;
- Trauma-informed and sex-specific screening;
- The meaningful integration of specialised women’s and migrant-led organisations.
Strengthening trafficking identification in asylum procedures is not an administrative adjustment but a necessary step to ensure that protection systems respond effectively to the realities of coercion, control, and sex-based exploitation.
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