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How Far Off Is The 15 July Anti-Trafficking Deadline For Capitals

The Hague: With six weeks left until the 15 July transposition cut-off, member states are still scrambling to plug the rewrite of the EU’s anti-trafficking directive into national law. The revised text entered into force on 14 July 2024 and gave capitals a two-year window to install new coordinator structures, criminal-law upgrades and victim-protection guarantees. Two years on, only a minority of member states have filed transposing acts in full, and Commission officials have begun preparing the standard mid-year sweep that follows any directive deadline.

Three blocks of obligations are doing most of the work. The first is the mandatory criminalisation of the knowing use of services of trafficking victims — a provision that was optional under the 2011 framework and is now mandatory, which has forced rewrites of national criminal codes in capitals where the offence sat in administrative law or was simply absent. The second is the explicit recognition of online recruitment as a trafficking modality, which obliges police and judicial authorities to investigate and prosecute platforms and intermediaries with the same toolset they use for offline cases. The third is the non-prosecution principle, expanded to cover administrative offences related to prostitution, begging, loitering and undeclared work where a victim has been compelled into the conduct.

The non-prosecution rule is the one that has drawn the most pushback. GRETA, the Council of Europe expert body that monitors trafficking policy, told its March plenary that the existing non-punishment provision is unevenly applied across European jurisdictions, and that victims still routinely face criminal or administrative consequences for acts directly tied to their exploitation. The revised directive lays out a tighter test, but rolling that into magistrates’ courts and police prosecution offices is a longer task than rewriting the code book.

Coordinator structures are the more visible deliverable. Every member state is required to designate a national anti-trafficking coordinator with formal authority across police, prosecution, social services and migration agencies, plus a formal referral mechanism that routes presumed victims into care from any first point of contact. The Netherlands, Sweden and Romania have offices that already approximate this design and need essentially administrative updates. Other capitals have been creating the coordinator role from scratch and have run into resourcing fights between justice and interior ministries over which side carries the office and its budget.

Civil-society groups have been pressing the Commission to publish an infringement list quickly once the 15 July date passes. Their argument is that prior trafficking directives slipped into a long enforcement tail and that the rewrite’s victim-centred improvements will not materialise unless the Commission applies pressure early. The Commission has not committed to a public timetable, but the Migration and Home Affairs DG has been signalling that letters of formal notice are likely to start landing in August.

Running behind all of this is the new EU Strategy on Combatting Trafficking in Human Beings, on which the Commission opened a call for evidence in December. The strategy will not be a legal instrument, but it will set Commission priorities for funding, training and operational support, and capitals that miss the transposition deadline will start the strategy cycle a step behind those that delivered on time.