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Lawyer warns employers as modern slavery reports hit record high

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The figures, released on Thursday, show the highest quarterly total since the National Referral Mechanism (NRM) was established in 2009.

The Home Office received 6,414 referrals of potential victims of modern slavery during the three-month period, representing a 13 percent increase compared with the previous quarter (5,689) and a 35 percent increase compared with the same quarter in 2024 (4,752). Officials said this was the largest number of referrals ever recorded in a single quarter.

Of the total, 81 percent (5,165) were sent to the Single Competent Authority (SCA) for consideration and 19 percent (1,249) were referred to the Immigration Enforcement Competent Authority (IECA). The bulletin confirmed that the rise continues an upward trend that began in 2021 and that the number of cases remains at its highest since records began.

Lawyer warns that employers must act

Alasdair Hobbs, an employment partner with London-based firm Excello Law, told HRreview that the statistics should prompt urgent action across the business community.

“These record-breaking figures – with 6,414 potential victims referred in just three months, a 35% increase year-on-year – should serve as a wake-up call to all employers,” he said.

“Modern slavery isn’t just an overseas issue or confined to certain sectors. With the highest quarterly referrals since the NRM began in 2009, it’s clear that exploitation is happening in UK workplaces and supply chains right now, and employers have both a legal and moral duty to be vigilant.”

He added that under the Modern Slavery Act 2015, “larger businesses must publish annual statements on their efforts to ensure slavery-free supply chains, but obligations extend to all employers.

“Companies need robust due diligence processes, not just tick-box exercises. With referrals surging 13% in a single quarter, it’s evident that many employers may still be missing the warning signs in their own operations.”

Labour exploitation remains most common

The Home Office bulletin records that labour exploitation was the most frequently reported type of abuse in the third quarter, accounting for 38 percent (2,456) of all referrals. The total number of people referred for labour exploitation was the highest on record, surpassing the previous quarter’s 1,968.

For adults, labour exploitation represented 47 percent (2,181) of all cases, while for children it was 21 percent (380). The bulletin notes that criminal exploitation was the most common category among child victims, at 47 percent (850), followed by sexual exploitation at 22 percent (400).

The report states that some cases may involve multiple forms of exploitation, while others are recorded as “not specified or unknown” due to incomplete data.

Increase in UK nationals identified

The Home Office figures also show that the UK was the single most common nationality among people referred in the quarter, accounting for 20 percent (1,312) of all potential victims. It was followed by Eritrean nationals (16 percent; 1,044) and Somali nationals (10 percent; 662).

The number of referrals for UK, Eritrean and Somali nationals were all the highest since the NRM began. Among British potential victims, the majority (74 percent) were children at the time of referral.

The government said the rise in UK-national victims likely reflects increased awareness and better identification by frontline authorities, but also warned that exploitation in the UK remains widespread.

Where exploitation is happening

Potential victims reported that exploitation took place both in the UK and overseas. In Q3 2025, 35 percent (2,253) said their exploitation occurred exclusively in the UK, while 57 percent (3,667) said it took place entirely overseas.

Among UK-based cases, the areas most frequently reported were Greater London (618 referrals), West Midlands (209) and Greater Manchester (145). For overseas exploitation, the most common countries named were Libya (2,038), Sudan (385) and Somalia (294).

The bulletin advises caution in interpreting these figures, as individuals may report multiple locations of exploitation.

More reports from government agencies

The latest data also record a rise in the number of referrals made by government departments. In the quarter, 62 percent (3,966) came from government agencies, up from 57 percent in the previous period.

The UK Visas and Immigration service was the single largest source of referrals, accounting for 47 percent (1,859), followed by Home Office Immigration Enforcement (18 percent; 730). Local authorities were responsible for 19 percent (1,248), while police forces and Regional Organised Crime Units accounted for 15 percent (973).

Non-governmental and third-sector organisations submitted 4 percent (227) of referrals. Officials said this was the largest number of referrals from both government agencies and local authorities ever recorded in a single quarter.

Progress in clearing backlog of decisions

The bulletin shows that the number of cases awaiting a final decision has continued to fall. At the end of September 2025, 9,107 cases were awaiting a conclusive grounds decision, down from 11,645 at the end of the previous quarter and 29,275 at the end of 2022.

Of those, 8,650 were handled by the SCA and 457 by the IECA. The average waiting time for a conclusive grounds decision was 141 days, compared with 304 days in the previous quarter.

During the same period, the Home Office issued 6,470 reasonable grounds decisions (of which 64 percent were positive) and 6,708 conclusive grounds decisions, 68 percent of which were positive. Both figures were the highest totals for a single quarter since the NRM began.

Record Duty to Notify reports

The Home Office also received 2,001 Duty to Notify (DtN) reports concerning adult potential victims who did not consent to be referred into the NRM. This was the highest number recorded since the DtN system began in 2015.

The most common nationalities in these DtN reports were Eritrean (31 percent; 620), Sudanese (10 percent; 205) and Albanian (6 percent; 125). Labour exploitation was the most frequently reported abuse type (48 percent; 965 reports).

Legal and HR observers say the figures underline the importance of employer awareness and due diligence across recruitment, outsourcing and supply chains. With both referrals and DtN reports at record levels, the latest bulletin suggests that the problem of modern slavery remains far from contained.

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