Civil society has a critical role in strengthening EU trafficking referral systems

A new policy paper from the EU Anti-Trafficking Hub highlights the important role of civil society organizations in identifying, referring and supporting victims of trafficking, while examining how National Referral Mechanisms (NRMs) are developing across the European Union.

Financed by the European Commission, the paper finds that significant progress has been made in formalizing and strengthening NRMs across the 27 EU Member States, but also identifies important gaps in how these mechanisms operate in practice, including uneven early detection, limited access to longer-term support, and weaknesses in cross-border referral. Civil society organizations (CSOs) have long called for more effective NRMs, provided practical support, advocated for clear agreements among stakeholders, pushed for wider access to protection services, and developed expertise in these areas, making their experience and insights invaluable to the continued development of identification and referral frameworks.

NRMs are now established in most EU Member States and are increasingly supported by written procedures, standard operating protocols, and multidisciplinary approaches to identification, referral and assistance. This reflects significant progress towards the requirements of the revised EU Anti-Trafficking Directive, which requires states to formally establish one or more of these mechanisms and appoint national focal points responsible for the early identification of presumed victims, as well as the provision of assistance, support, and cross-border referral where appropriate.

However, the paper also highlights considerable differences across countries in terms of the legal basis, institutional arrangements, and practical implementation of NRMs. The existence of a formal framework does not necessarily translate into consistent practice, with differences in the clarity of institutional responsibilities, enforceability of procedures, and stability of arrangements. This is particularly significant for early identification, with less visible forms of trafficking, such as labour exploitation, child trafficking, and forced criminality, remaining under-detected. Furthermore, the European Commission recently announced infringement procedures against 20 Member States for failing to communicate their complete transposition of the Directive before the July deadline.

The paper further identifies challenges in the provision of long-term support. While standards of emergency assistance have improved, longer-term support, including extended accommodation, residence stability for third-country nationals, and durable reintegration can, in practice, remain conditional on cooperation with authorities, legal proceedings, or formal identification decisions. Monitoring and data collection systems are likewise developing across the EU, but tend to focus on victims identified or criminal justice outcomes rather than on how referral mechanisms themselves are functioning.

Within this context, CSOs emerge as an important component of effective NRMs. The analysis finds they are routinely involved alongside law enforcement, migration and asylum services, social and child protection bodies, labour inspectorates, and other actors, with civil society playing a particularly important role in early identification, victim support, accommodation, and cross-border continuity of care. Their involvement, however, is not always formally anchored, and cooperation can remain dependent on project-based funding or informal arrangements, raising questions about sustainability and continuity.

The same is true of cross-border referral, which the paper identifies as an area requiring further development. Cooperation already takes place through law enforcement channels, international organizations, and NGO networks, but national focal points are at different stages of development across the EU, with procedures, communication channels and follow-up mechanisms also remaining uneven. While CSOs can play an important role in bridging these gaps, drawing on established cross-border relationships and frontline knowledge, their contribution is strongest as part of a clear and functioning referral system.

The paper’s recommendations include clearer and more enforceable frameworks, greater clarity around the roles of different actors, stronger cooperation with civil society, improved early detection across all forms of exploitation, sustained access to victim support, fully operational cross-border referral structures, better monitoring and data systems, and more consistent training for frontline professionals. The development of effective NRMs is not simply a question of establishing formal structures, but of ensuring that those structures work across sectors and borders, and that the knowledge and experience of civil society organizations is reflected in how they operate.

With thanks to La Strada International for their contributions to this feature

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