The European Disability Forum (EDF) welcomes the preparation of an EU Anti-Trafficking Strategy 2026-2030. EDF represents more than 100 million persons with disabilities in Europe and works to ensure their full inclusion and the respect of their human rights, as guaranteed by the UN Convention on the Rights of Persons with Disabilities (CRPD).
Persons with disabilities face a heightened risk of being trafficked and exploited, yet they remain largely invisible in policy and practice. The 2024 OSCE paper “Invisible victims: The nexus between disabilities and trafficking in human beings” and the 2025 UN Special Rapporteur Briefing Paper: Trafficking in persons and the rights of persons with disabilities demonstrated that disability can be both a cause and a consequence of trafficking, as traffickers often target people who experience dependency, isolation, poverty or institutionalisation. EDF’s 2022 position paper on combating trafficking of persons with disabilities reached similar conclusions, stressing that systemic discrimination, lack of access to education, employment and community-based support, and continued segregation in institutions create an environment putting persons with disabilities at higher risk of exploitation. Persons with disabilities living in conflict and war contexts are even more exposed to the risk of being victims of trafficking and exploitation. Despite this evidence, there is still no systematic recognition or protection of victims with disabilities in the EU.
The revised Anti-Trafficking Directive acknowledges persons with disabilities as part of vulnerable groups, but this has not been translated into meaningful actions. The European Commission’s 2025 Fifth Progress Report mentions persons with disabilities only once, and no concrete measures have been developed to ensure their rights and protection. The forthcoming Strategy should correct this omission and fully integrate the rights of persons with disabilities in all its objectives and actions. It must be firmly based on the CRPD, particularly Articles 13 on access to justice and Article 16 on freedom from exploitation, violence, and abuse. The UN CRPD Committee’s 2025 recommendations to the EU are also relevant to the strategy, requiring the EU to explicitly prohibit rape, forced sterilisation and other forms of gender-based violence against persons with disabilities; to ensure the participation of their representative organisations in all relevant strategies; and to combat violence and abuse in institutional settings through independent monitoring.
The revised Victims’ Rights Directive has introduced stronger obligations to provide procedural accommodations, accessibility, and reasonable accommodation for victims with disabilities. These guarantees should be fully reflected in the anti-trafficking framework to ensure equal access to justice, protection, and redress. Assistance and support services must be accessible in practice. Helplines, shelters, reporting mechanisms and legal aid cannot exclude victims because of physical, communication or cognitive barriers. This is also required by Article 11(1) of the revised Anti Trafficking Directive.
Prevention also requires addressing structural factors that increase the risks of trafficking. Institutionalisation, poverty, exclusion from education and employment, and lack of independent living support all make persons with disabilities more vulnerable. Ending institutionalisation and promoting inclusion in community life are essential components of any prevention strategy, including for people who newly arrived in the EU. The disability perspective must be included in all prevention measures undertaken by Member States as required by Article 18(2) of the Anti-Trafficking Directive. Within the context of migration, the EU Asylum Agency should develop guidance on applicants with disabilities to improve assessment, identification of trafficking victims and access to support, due to the compound discrimination and risks faced by asylum seekers, refugees and migrants with disabilities.
It is also important to note that persons with disabilities are not a homogenous group and may experience multiple or intersecting forms of discrimination because of their gender, age, ethnicity etc., which may increase their risk of being trafficked, and which should be addressed in anti-trafficking efforts.
Women and girls with disabilities are at particular risk of sexual exploitation and trafficking, both in institutions and private settings,[1] often linked to practices such as forced contraception and sterilisation.[2]The EU must explicitly ban forced sterilisation across Europe and ensure that anti-trafficking efforts include specific measures addressing sexual exploitation of women with disabilities.
The new strategy should increase training of professionals from a disability perspective, as required by Article 18b of the Anti-Trafficking Directive. Disability awareness and accessibility must become standard elements of training for police officers, judges, prosecutors, social workers, asylum officers, and other professionals likely to encounter victims. Organisations of persons with disabilities should be actively involved in designing and delivering such training and in monitoring the implementation of the Anti-Trafficking Directive.
Finally, the absence of data disaggregated by disability remains one of the biggest barriers to understand how persons with disabilities are affected by trafficking and to monitoring progress. The EU should require data collection by disability, gender, age and migration status, and conduct a dedicated an EU study on trafficking among vulnerable groups, including persons with disabilities. This would enable more targeted and effective prevention measures.
To summarise, EDF calls on the EU to include the following key actions in its Anti-Trafficking Strategy 2026-2030:
- Mainstream disability rights across the entire Strategy, ensuring full alignment with the UN Convention on the Rights of Persons with Disabilities (CRPD), particularly Articles 13 on access to justice and Article 16 freedom from exploitation, violence and abuse.
- Reflect the guarantees of the revised Victims’ Rights Directive in anti-trafficking measures, ensuring accessibility, procedural accommodation, and reasonable accommodation for victims with disabilities throughout the reporting and justice process.[3] Ensure accessibility of all victim support services, including shelters, helplines, legal aid, and reporting mechanisms, both physically and in communication.
- Organise targeted disability-sensitive training for all professionals likely to encounter victims of trafficking, including police, judges, prosecutors, asylum officers, healthcare and social workers, developed with representative organisations of persons with disabilities and migrants’ organisations. Emphasis should be placed on accessibility for persons with disabilities and on procedural accommodation, clearly distinguished from reasonable accommodation.[4]
- Explicitly ban forced sterilisation across the EU and include measures to combat sexual trafficking and exploitation of women and girls with disabilities.
- Conduct a dedicated EU study on the trafficking of vulnerable groups, including persons with disabilities and support Member States to collect data disaggregated by disability.
- Adopt EU Asylum Agency Guidance on applicants with disabilities to improve prevention, identification and support for trafficking victims in migration and asylum contexts, as well as harmonisation and cross-border collaboration between countries.
[1] See Duke Law International Human Rights Clinic/UN Special Rapporteur on the Rights of Persons with Disabilities/UN Special Rapporteur on trafficking in persons, especially women and children, Briefing Paper: Trafficking in persons and the rights of persons with disabilities, 2025, page 5.
[2] Disability Rights International documented institutionalisation and sterilisation of women with disabilities, giving an example of one institutions where sexual abuses and exploitation of women with disabilities was taking place (see recording UN side event on the nexus between trafficking and the rights of persons with disabilities, 2025, at 35:00 onwards).
[3] Article 13 of the CRPD requires Parties to the Convention to “ensure effective access to justice for persons with disabilities on an equal basis with others, including through the provision of procedural and age-appropriate accommodations”. Procedural accommodations must always be provided to ensure equal and fair access to justice. It is not limited to a proportionality test. See CRPD Committee General Comment No 6 on equality and non-discrimination. Para 25(d): “’Procedural accommodations’ in the context of access to justice should not be confused with reasonable accommodation; while the latter is limited by the concept of disproportionality, procedural accommodations are not.” Para 51: “An illustration of a procedural accommodation is the recognition of diverse communication methods of persons with disabilities standing in courts and tribunals.”
[4] See footnote 1.