Dr. Petya Nestorova
Executive Secretary Convention on Action against Trafficking in Human Beings
(GRETA and Committee of the Parties)
DG II - Council of Europe 67075 Strasbourg Cedex, France
8 June 2026
Re: Ireland’s Independent National Rapporteur on Trafficking in Human Beings update to the fourth evaluation round of implementation of the Council of Europe Convention on Action against Trafficking in Human Beings by Ireland
Dr Nestorova, a chara,
I write to you from the Irish Human Rights and Equality Commission, in our capacity as Ireland’s Independent National Rapporteur on Trafficking in Human Beings. I write further to, and in order to supplement, our response to the questionnaire dated July 2025 for the Group of Experts on Action against Trafficking in Human Beings’ fourth evaluation of Ireland’s implementation of the Council of Europe Convention on Action against Trafficking in Human Beings.
By way of general context, we are increasingly concerned about the lack of progress in key areas to combat human trafficking in Ireland and potential backsliding including in critical areas, such as provision of appropriate accommodation to victims. This is manifested in a number of areas that have emerged in 2026 and include the following:
- The continued failure to implement a statutory National Referral Mechanism
We welcomed the legislation introducing a new statutory NRM in July 2024 (albeit with reservations, including the lack of clarity on statutory entitlements for presumed and identified victims).1 However, the NRM has still not materialised and there is no clarity as to when and how it will be operational.
The current system for identification and support remains problematic and insufficient to identify and support victims and those at risk. The issues with this system have been well documented throughout the years and recognised by the State. From our stakeholder engagement in 2026, we are aware of delays in identification and a lack of a transparent and consistent process of identification. We are therefore increasingly concerned about the ongoing failure to implement the statutory NRM, which is recognised to be essential to addressing serious and long-standing issues in identification and support of victims of trafficking.
We welcome the continued engagement of Department of Justice as the National Anti-Trafficking Coordinator with the National Rapporteur and specialist Non-Governmental Organisations. However, we remain concerned about the lack of coordinated engagement, with no Human Trafficking Stakeholders Forum meetings convened since December 2024. These are due to be convened on a quarterly basis, and at a minimum twice a year, according to the Third National Action Plan.2
We understand that the delays to the implementation of the statutory NRM have been impacted by capacity constraints within the relevant Department and a wider prioritisation of implementation of the EU Migration and Asylum Pact. We have communicated and published multiple concerns regarding the approach to human trafficking within the transposition of the EU Pact on Migration and Asylum – including around screening and processes for identifying and supporting victims, approaches for child victims, and critically, alignment with any forthcoming NRM. We remain concerned more broadly regarding the continued conflation of immigration and asylum systems with trafficking systems in Ireland.
2. The State plans for transposition of the strengthened obligations under the amended EU Anti Trafficking Directive
We have concerns regarding the minimalist approach to transposition of the strengthened obligations under the amended EU Anti Trafficking Directive, which we consider fails to adequately transpose the amended Directive. The proposed legislation ‘General Scheme: Criminal Law (Sexual Offences, Domestic Violence and International Instruments) Bill 2025’ does not contain the necessary legislative changes as required by the amended Directive and there are gaps in the General Scheme to provide for proper transposition. These include an ongoing lack of clarity on victims’ statutory entitlement to assistance which remains unaddressed in the proposed legislation General Scheme.
From a procedural perspective, there was a lack of adequate pre-legislative scrutiny from an Anti-Human Trafficking aspect, with the focus on other considerations of the Bill. While IHREC requested, and was able, to provide a pre-legislative observations report(within a very tight timeframe just prior to the GRETA visit in December last year), we were not then invited to the Joint Committee on Justice, Home Affairs and Migration meeting for pre-legislative scrutiny
on 20 January 2026. To our knowledge, no other key stakeholders and specialists from Anti- Human Trafficking were involved in the pre-legislative process.
3. Accommodation for Victims of Trafficking – a problematic and worsening situation
Key stakeholders have recently flagged a worsening of the accommodation situation for victims of trafficking since December 2025.
In early 2026, we were notified of an urgent issue whereby victims of trafficking, particularly those who are not in the International Protection system, are facing barriers in their access to any safe accommodation. Stakeholders provided details of serious difficulties experienced by the victims they are supporting or acting for in securing any accommodation. The information provided indicates a change of previous practice and a lack of coordinated supports and process between relevant statutory bodies responsible for provision of accommodation with negative impacts on certain affected VOTs.
As National Rapporteur, we have long documented concerns regarding victims’ access to safe and appropriate accommodation. This includes concerns regarding the suitability of International Protection Accommodation Service accommodation and the barriers to victims accessing other accommodation types, including social housing and homeless accommodation. This situation has reportedly worsened, with some victims having no guaranteed access to safe accommodation. Legislative reform is also anticipated which appears likely to further restrict access and impact negatively, and potentially disproportionately, on victims of trafficking.3
In relation to accommodation issues and the legal obligations on the State, we note that the amended 2024 Directive under Article 11 requires the State specifically to ensure that “shelters and other appropriate interim accommodation” shall be provided in “sufficient numbers”, be “easily accessible” and must provide “adequate and appropriate living conditions with a view to a return to independent living” and be equipped to accommodate the specific needs of children (Article 11(5a)). Article 11(5) corresponds broadly with the language of Article 12(1)(a) of the Council of Europe Convention on Action against Trafficking in Human Beings, which refers to “appropriate and secure accommodation”. Ireland’s National Action Plan also contains clear commitments actions in relation to the provision of adequate accommodation. Article 6 of the Palermo Protocol similarly specifies the need for provision of appropriate housing to victims and other implementing measures to provide for their physical, psychological and social recovery.
Thank you for your attention to these matters, which we hope can further inform GRETA’s fourth evaluation monitoring of the implementation of the Council of Europe Convention on Action against Trafficking in Human Beings in Ireland.
We are available to provide further information should that be of assistance.
Le dea-mhéin,
Deirdre Malone Director
Footnotes
1 IHREC (07July 2024) Commission welcomes new legislation that will support victims of trafficking
2 Government of Ireland (2023) National Action Plan to prevent and combat Human Trafficking 2023 – 2027, Action 4.1, 4.1.1
3 In 2024, IHREC published legislative observations on the General Scheme of the Housing (Miscellaneous Provisions) Bill. The Bill is expected to be published shortly.