Vietnam: Human Trafficking – A legal analysis of Asylos’ 2026 Report

Introduction

1. Asylos recently released an updated version of its report in June 2026, “Human Trafficking in Vietnam: patterns of exploitation, risk factors, and access to support” (“the Asylos report”). It builds upon the 2020 Asylos and ARC Foundation Country Information report on Vietnam, which was the subject of an earlier note available at the Garden Court Chambers website.
2. The purpose of this note is two-fold:
   – To provide a practitioner-focused analysis of the most relevant takeaways from the 2026 report; and
   – To identify any gaps in the existing Home Office Country Policy Information Note (“CPIN”). At the time of writing, the current version of the relevant CPINs are the “Vietnam: Trafficking” version 6.0, published February 2025 (“the Trafficking CPIN”), which cross refers to the “Vietnam: Fear of illegal moneylenders)” (“the Illegal Moneylenders CPIN”) version 3.0, published February 2025^[2] for cases involving debt bondage.
   – In light of the substantial and more recent evidence contained in the Asylos report, we suggest that the Trafficking CPIN is now out of date and requires revision to reflect the current evidence concerning patterns of trafficking, risk of re-trafficking, the practical availability of state protection, and internal relocation. Practitioners should take care to ensure that real consideration is given to including the Asylos report in representations for asylum claims, and identify why, on their client’s particular facts, the evidence shows that the elements of their protection claim is made out.

Context: a known cohort at risk of exploitation and serious harm

4. Asylum practitioners will understand Vietnamese nationals are and continue to be a cohort known to be at risk of exploitation and harm from traffickers. The risks to Vietnamese victims have been identified in cases like TDT v SSHD [2018] EWCA Civ 1395, CP (Vietnam) v SSHD [2018] EWHC 2122 (Admin) and VCL and AN v United Kingdom App No 77587/12 and 74603/12 (16 February 2021).

5. Data published by the Home Office for this year confirms this continues to be the case. Official statistics of National Referral Mechanism (NRM) statistics and duty to notify report for potential victims of modern slavery for the period 2024-2025 shows that Vietnamese nationals are among the top three nationalities for NRM referrals (surpassed only by UK and Eritrean nationals)^[3].

6. For that very reason, it is essential that asylum practitioners and decision makers remain up to date on the key developments in the country information so that claims are properly prepared and decided. The reported cases cited above give just a glimpse of the serious harm and long-term damage that can impact Vietnamese victims not properly identified and protected, which range from suspected re-trafficking when going missing from local authority care or being released from immigration detention without safe accommodation, or being wrongly criminalised for conduct bound up with exploitation. Victim identification, protection and recovery support will likely play a key role in minimising risk of future harm, including both in the UK and in Vietnam.

Summary of the Asylos report

7. Vietnam remains primarily a source country for trafficking, with exploitation increasingly shaped by economic insecurity, deceptive recruitment, and the emergence of new recruitment methods, including via the internet^[4]. There is no one profile, but what comes out strongly from the evidence is that trafficking affects women and men, adults and children alike, as traffickers find new and innovative ways to exploit existing vulnerabilities.
8. Key findings include:

• Trafficking is diverse and increasingly technology-facilitated: Vietnamese nationals are exploited in forced labour, sexual exploitation, forced marriage, domestic servitude, begging, street work, fishing, garment work, organ trafficking and forced criminality^[5]. The COVID-19 pandemic created economic vulnerabilities that made people more susceptible to human trafficking in Vietnam^[6]. The fastest growing concern is in forced online scamming in Cambodia, Myanmar, Laos and the Philippines, where victims are recruited through fake job offers to commit fraud^[7].
• Organised criminal groups are increasingly responsible for trafficking, making detection and dismantling more difficult: The report describes a growing and more sophisticated criminal approach to trafficking^[8]. The clearest growth is in organised, transnational networks operating scam compounds in Cambodia, Myanmar, Laos and the Philippines, which typically recruit Vietnamese nationals through false job offers and force them into online fraud, often within guarded compounds^[9]. The report also links trafficking with migrant smuggling, cyber-enabled fraud, money laundering, illegal money lending, extortion and debt collection^[10]. Criminal networks can use legitimate-looking businesses, recruitment agencies, transport and logistics firms, financial channels, and online lending schemes to facilitate or conceal offending^[11].
• Trafficking routes include the UK and Europe: Although the Vietnam-China corridor remains central (particularly for forced marriage, sexual exploitation and labour exploitation), other significant destinations include other parts of Asia, the Middle East, and Europe, including the UK^[12]. Vietnam is also used as a transit point in some regional trafficking^[13].
• Deception often begins through trusted networks and online platforms: Traffickers often recruit through false work offers, social media, gaming sites, and family / friend / local networks (including via acquaintances)^[14]. In forced criminality cases, nearly all identified victims in one dataset were recruited through fraudulent job offers^[15]. Control mechanisms identified include debt, confiscation of official/identity documents, isolation, threats, violence and restriction of communication^[16].

Risk of re-trafficking on return

9. As described by Lord Justice Underhill in TDT at §82:
   “being a past victim of trafficking and being at real and immediate risk of being (re-) trafficked are very closely inter-related.”

10. The Asylos report highlights that re-trafficking risk is driven by primarily the same unresolved pressures that led to the original vulnerability to exploitation: debt, poverty, insecure work, trauma and limited access to meaningful long-term support^[17].

11. Whilst there is no one driver of risk, and no uniform experience for every returnee, a useful starting point might be understanding that:
“Loss of livelihoods because of trauma and lack of support can lead to repeat migration, despite the risks, as there is still need to earn an income…”
(Overseas Development Institute 2023, cited at page 232).

12. Main drivers of re-trafficking identified include:
    – Debt and economic pressure: Survivors may return with unpaid recruitment fees or debt accrued through migration, sometimes involving informal moneylenders or trafficking-linked networks^[18]. Pressure to repay debt, protect family assets, or support dependants can push people into repeat migration (including for the purpose of unsafe, exploitative labour e.g. as migrant workers) leading to repeated victimisation^[19].
    – Insecure / unsafe livelihoods: Unemployment and unstable income after return are repeatedly identified as key risks. For example, some returned survivors reportedly illegally crossed the border again to seek work because they lacked jobs, exposing them to renewed exploitation^[20].
    – Trauma, stigma and isolation: Trauma can undermine a survivor’s ability to work and reintegrate, while stigma around trafficking, sexual exploitation, mental health, or perceived failure abroad discourages disclosure and help-seeking^[21]. A gender-sensitive analysis is relevant: for example, trafficked men may feel pressure to appear financially successful and downplay their experiences^[22].
    – Repeated recruitment and victimisation through deception: Traffickers continue to exploit job insecurity through false work offers^[23]. This is especially visible in scam-compound trafficking: 98% of victims in one Blue Dragon dataset had been recruited through fake job offers^[24].

13. Although there is no one profile of person susceptible to modern slavery, the report does identify several groups facing heightened risk:
– Returnees from trafficking or labour exploitation abroad, especially those who are not formally identified, are at risk^[25].
– Women and adolescent girls particularly in remote or low-opportunity areas continue to be at risk, particularly where there is poverty, debt, stigma and weak local services, or are from ethnic minority communities^[26].
– Men and young adults are likewise at risk and tend to be exploited in forced criminality or labour exploitation, including through the emerging online scam operations^[27]. Male victims may be overlooked, as services have historically focused on women and children^[28].
– Children affected by family instability, including those in single-parent households; those left behind by migrant parents; those migrating with parents; or who have experienced family violence and/or abuse^[29]. The report notes evidence of family-linked vulnerability but no comprehensive national programme specifically for the children of trafficked returnees^[30].

14. Protection gaps also compound the risks to returning victims, as set out below.

Sufficiency of Protection

15. Bagdanavicius [2003] EWCA Civ 1605 establishes that, despite generally sufficient state protection, an applicant may have a well-founded fear of persecution where the authorities know or ought to know of case-specific risks but are unlikely to provide the additional protection reasonably required (Auld LJ at [§55(vi)]).

16. SA (political activist – internal relocation) Pakistan [2011] UKUT 30 (IAC), applying Bagdanavicius, confirms that a judge must assess both general sufficiency of protection and whether the appellant’s circumstances permit adequate protection ([§6]). Past persecution and any previous lack of protection must inform whether there are good reasons to expect recurrence ([§11]). In trafficking cases, the issue is therefore not only whether the state will prosecute traffickers, but whether it will protect victims from re-trafficking.

17. The Asylos report shows a consistent pattern: whilst Vietnam has developed a legal framework for combatting trafficking, that framework does not translate into effective protection for victims in practice. Six key themes are evident:
    • Protection is largely ‘on paper’ at present, with systemic implementation gaps on the ground,
    • Corruption within and the complicity of state actors undermines both the pursuit of traffickers and victim’s safety with regards to protection from re-trafficking,
    • Access to state or NGO support depends on formal identification, which is a complicated and unevenly applied process
    • Where support exists, it is unequal along gender lines, with male victims receiving little to no support, as well as varying by geographical region,
    • Support is also poorly resourced, even if it exists, and
    • Weak reintegration and prevention efforts leave returning victims in conditions which render them vulnerable to re-trafficking.

18. We examine those themes in detail below.

State Protection and the Criminal Justice System

19. Legal Framework: In Vietnam, Articles 21 and 41 (Clauses 1 and 2) of Decree 162/2025/ND-CP (regulations on the Law on Human Trafficking Prevention and Combat 2024, in force from 1 July 2025) set out a general framework in which adult and child Vietnamese trafficking victims are entitled to legal support and assistance to purportedly prevent re-trafficking^[31]. Article 150 of the Vietnamese Penal Code criminalises labour and sex trafficking of adults, with penalties of 5-10 years’ imprisonment and fines of 20-100 million Vietnamese dong^[32]. Article 151 of the Penal Code criminalises labour and sex trafficking of children under 16, with penalties of 7-12 years’ imprisonment and fines of 50-200 million Vietnamese dong.

20. However, the Asylos report makes clear that measures pertaining to child victims are only partially compatible with international standards or practices^[33]. A new Juvenile Justice Law was passed in 2024, which expanded protection and rehabilitation services for child victims of crime, including human trafficking, but the government had not implemented the law by the end of the USDOS reporting period for their 2025 report^[34]. Additionally, 16-17 years olds in Vietnam are regarded as adults, so fall outside the scope of child-specific provisions^[35].

21. Therefore, whilst new laws have been enacted, their measures are yet to be implemented and delivered. The 2025 USDOS report confirms that the 2024 anti-trafficking law had not yet been implemented nor had the NRM been updated by the end of the reporting period^[36]. This demonstrates that the legal framework and definitions as they apply to victims of trafficking in Vietnam are not sufficiently robust on paper or in practice, nor compliant with international legal standards.

22. Enforcement gaps: Indeed, there are significant gaps in law enforcement’s approach to implementing these provisions. A 2023 ODI report noted that there were several problems with implementing Vietnam’s legal and policy response, including the limitations of law enforcement in detecting and preventing trafficking, which undermines improvements in legislation, an inconsistent application in the law, and difficulty in pursuing cases swiftly^[37]. The 2025 USDOS Trafficking in Persons report findings include: inadequate resources or capacity to collect evidence from overseas, difficulties prosecuting and adjudicating trafficking cases in border provinces due to limited capacity in rural areas, investigations and prosecutions into trafficking allegations can be hindered by insufficient cooperation with neighbouring countries, and authorities face difficulties adapting to changing victim profiles linked to labour trafficking in online scam operations.

23. Corruption and complicity: With regards to conviction rates, the USDOS noted in its 2025 report that whilst the Vietnamese government prosecuted 291 alleged traffickers in 2024, an increase in numbers from 2023, and convicted 246 traffickers, the government did not report “any investigations, prosecutions, or convictions of government employees complicit in human trafficking crimes.” Neither did the authorities “vigorously prosecute previous claims of labor trafficking in state-owned or licensed labor export companies…” ^[38]. This is in a context where, as Professor Christoph Bluth noted in one 2024 source, there is evidence of criminal activity penetrating senior levels of the police force and government, including border guards who have received substantial bribes from traffickers. It is described as an “endemic” problem, and that “despite official efforts to combat it, the law enforcement agencies are unable to meaningfully deal with it as even anti-corruption officials accept bribes on a large scale and law enforcement frequently are in collusion with criminal gangs and profit from their activities”^[39].

24. In the USDOS 2024 report, an example is given of one case reported in 2021, where a labour attaché and staff member were alleged to have directly facilitated the forced labour of several Vietnamese nationals in Saudi Arabia. However, the investigation was ended in 2022 with no charges, citing a lack of evidence, and the official was re-instated^[40]. The 2025 Global Organised Crime Index provides “State-embedded actors facilitate multiple criminal markets, including… human trafficking… higher-ranking officials are more commonly implicated in human trafficking and financial crimes. Corruption extends from local commune authorities – who have allegedly extorted trafficking victims… – to diplomats and police accused of concealing trafficking operations or exploiting stranded citizens”^[41]. Therefore, the complicity of state actors in trafficking networks and in enabling traffickers to evade justice is prevalent and widespread. Simultaneously, the report demonstrates that anti-corruption measures are ineffective; as such state-level complicity in trafficking in Vietnam operates with impunity.

25. A research article from 2024 by Dr Daniel Silverstone and Dr Hai Thanh Luong observes that whilst Vietnam has sought to cooperate with foreign states to combat trafficking, including the UK, it is difficult for the UK to do this effectively “because Vietnamese state actors have been implicated” in trafficking cases^[42]. Additionally, the 2023 USDOS said of the efforts to improve protections for Vietnamese workers through labour agreements with other countries that “the government did not exercise sufficient oversight of contract and recruitment processes under the auspices of some of these bilateral agreements”^[43]. The evidence shows that Vietnam’s international cooperation and multilateral efforts to combat trafficking are marked by weaknesses in oversight and accountability.

Access to Support and Shelter

26. Victim identification barriers: Almost all state support in Vietnam is gated by formal identification as a victim of trafficking. However, the Asylos report demonstrates that victim identification processes are not fit for purpose. Victim identification data is said to be unreliable and duplicative, according to the 2025 USDOS report^[44]. Whilst the government maintained an NRM, “some local officials’ unfamiliarity with anti-trafficking protocol and policies, insufficient interjurisdictional cooperation, and limited social worker capacity continued to hinder its systematic and effective implementation.” Whilst the Vietnamese government had increased protection efforts in 2022, as of 2023 it “continued to lack proactive screening, particularly among high-risk groups and victims of cyber scam operations…”^[45]. Indeed, the USDOS 2023 report stated that: “The victim identification process remained overly cumbersome and complex, requiring approval from multiple ministries before victims could be formally identified and assisted”^[46]. These challenges have likely persisted, given the government had not implemented the 2024 anti-trafficking law nor updated its NRM by the end of the 2025 perioding period^[47]. This renders effective victim identification even more challenging.

27. Furthermore, if a victim returns on their own and does not report to the Vietnam police, there is no formal identification of their trafficking status and as a result, few victims in this context receive support from the government, according to the 2023 ODI report^[48]. The importance of identification processes for protection is underscored in the 2024 USDOS report, but due to the complicated formal identification process and fear of reprisal/punishment, many Vietnamese victims choose not to initiate this process, which “left them without access to most protection services” ^[49]. The processes to formally identify a returnee as a victim are long and complicated, and typically a victim of trafficking is only identified when criminal proceedings are initiated. Yet “[t]his is difficult when the perpetrator is an employer in a destination country, which is beyond the jurisdiction of Vietnamese law enforcement agencies, and when labour migration becomes trafficking in countries where no offences are identified. Even if trafficking is identified, it is extremely difficult to conduct investigations, collected evidence and pursue prosecutions in the destination country. Whilst the process is underway, potential victims are unable to access shelter and support, which undermines their reintegration”^[50].

28. The Asylos report also records the response of an anonymous expert they interviewed in November 2025, who explained that access to support depends on formal victim certification and the onus remains on police to identify victims, however, they struggle to do so and focus on sexual exploitation; despite the prevalence of labour exploitation^[51]. The expert concluded: “In practice many don’t access support, because they don’t get a victim certificate, and there is very small scale support. On the whole the level of support is not very adequate to support trafficking victims”^[52]. The result of these weaknesses is clear: protective support depends on victim identification; however, identification is convoluted and depends on a police-led criminal process which is often not pursued in the most prevalent types of cases, and consequently a significant proportion of victims without certification are left without protection.

29. Gendered and age-related gaps: With regards to support facilities, the 2023 USDOS report highlights that 57 of the 425 social support facilities across Vietnam assisted trafficking victims. However, none provided services for men or child victims exclusively. Four dedicated trafficking shelters existed for women and children, whilst men were placed in separate accommodation. NGOs reported that within this provision “the government lacked adequately trained or experienced social workers to provide appropriate support to trafficking victims, and observers reported front-line workers, judges, teachers, and medical professionals were poorly trained to address child protection issues, including human trafficking”^[53]. An anonymous expert, who interviewed by Asylos in November 2025, explained that whilst in principle there are some government forms of support, there are systemic gaps: shelters are short-term, there are very limited available places, and in practice they are geared towards women and children; leaving male victims without access to material support. This is reflected in the 2025 DFAT report, which notes that in-country sources said “support services for male victims of trafficking were lacking in comparison”^[54].

30. A 2023 ODI and Australian Aid country report explains that assistance from NGOs were “initially designed to support women and children, whereas victims of labour exploitation are primarily men, specific support for labour trafficking, and particularly support to male victims, is still limited”^[55]. As a 2020 academic article notes, “[t]here is a gendered dimension to the victim support regime operating in Vietnam, whereby it is easier for women to be recognised as victims of trafficking and receive support, but much more difficult for men”^[56]. The later source material demonstrates that this still rings true. According to a 2025 Blue Dragon report (an NGO providing support services to victims of trafficking), there is a lack of support for the increasing number of male survivors of trafficking into forced criminality in Vietnam^[57]. It is also unclear to what extent unaccompanied minors are offered specific assistance by the authorities^[58],

31. Inadequate service provision: Even for those who can access trafficking services, for instance women and children, there remain real problems with adequacy and effectiveness of this support. The quality of support, care and training of staff “appear to be inadequate” according to the 2024 USDOS report^[59]. As the same report notes, “…the quality of care provided to trafficking victims varied widely depending on geography, a victim’s circumstance, and the strength of local civil society; NGOs reported the support victims received was often inadequate, especially in remote and poorer provinces…” and concerns had been raised that the government “did not have minimum quality standards for protection services administered by service providers…”^[60] The report goes onto comment on some provinces’ hesitancy to fund support services, due to a conflict of interest between provincial budget constraints and the need to protect victims^[61].

32. A 2025 UN Human Rights Committee report noted that Vietnam still faces several significant challenges to supporting victims of trafficking, including: limited numbers of shelters which do not cover all regions, insufficient financial and specialised human resources, especially in psychological support and long-term rehabilitation, a lack of unified coordination mechanism between local authorities and organisations receiving and monitoring victims after they leave reception and support centres, and no long-term mechanisms to support foreign victims^[62]. Even where NGOs attempt to fill the gaps, the 2025 USDOS report noted that there have been “[s]ystemic delays in the government’s approval and licences and operations” which has “challenged NGOs working in Vietnam, including those working on anti-trafficking activities”^[63]. The same source notes that victims who did not meet a minimum poverty threshold were excluded from some support services^[64]. Therefore, access to protective services is uneven and inconsistent, which is compounded for victims living in remote and poorer provinces, who are in turn likely to be more vulnerable to traffickers.

33. Re-integration failures: Articles 30, 42, 44 and 45 of Vietnam’s Law of Human Trafficking Prevention and Combat 2024 provides for: the reception and verification of victims returning from abroad, the provision of essential needs support and medical assistance if necessary, social assistance and victim support, support for reintegration, and help for child victims^[65]. However, a 2024 academic article by Dr Maja Grundler notes that “protection through reintegration support may not be such a straightforward matter after all.”, citing the unreported case of TSN v SSHD [2019] UKUT (IAC) PA/07665/2017, in which the Upper Tribunal had found the appellant had received money under the Facilitated Returns Scheme on a previous return to Vietnam, but he had been re-trafficked in any event. As such, the lack of effective re-integration programmes and assistance in housing, education, health, employment, and trauma, “plays an important part in re-trafficking”^[66]. As Mimi Vu, Co-Founder & Vice-Chair of the Vietnam International Safe Labour Alliance observed when interviewed for the Asylos report in November 2025, re-integration support is not comprehensive, there are administrative hurdles victims face to be eligible for education or social assistance support, and due to victims’ complex and multifaceted psychological needs, this effectively means the services available are not fit for purpose^[67].

34. Dr Hai Luong reported to Asylos in March 2026 that: “Women and children returning to low-opportunity areas face debt, unstable income, and stigma, increasing risk of repeat migration and re-recruitment. The 2024 anti-trafficking law offers non-punishment, support, and legal aid, but by the end of 2025, implementation lagged due to cumbersome NRM, an unfinalized screening toolkit, and limited frontline capacity, especially in rural/border regions. Weak reintegration in housing, education, livelihoods, and trauma care is linked to higher re-trafficking, worsened by tight provincial budgets and minimal support, often conditional on certification. NGO aid helps, but unevenly, Overall, limited social protection and unresolved debts heightens risks, especially for ethnicity minority women and adolescent girls in report areas”^[68]. For men, the issue is clearly compounded given the lack of specific and effective support provision outlined above.

35. Evidence from Mimi Vu, interviewed by Asylos in November 2025, made clear that there is a “huge gap in prevention”, because Vietnam’s framework lacks a comprehensive integrative approach and fails to provide sufficient resources and organisations to ensure victim identification and assistance. The source concludes that Vietnam’s lack of focus on “preventing trafficking in the first place beyond awareness-raising campaigns, instead of getting to the root causes, is one that impacts the risk of someone getting re-trafficked or re-exploited because they’re still in the same conditions that they were beforehand…”^[69]

36. Another source, Thoi Nguyen, stated in March 2026 that: “…returnees may face challenges in accessing formal reintegration support… In cases where individuals are not formally recognised as victims, including where age was previously disputed, they may receive limited or no targeted assistance upon return. Support, if available, may include short-term accommodation, basic financial assistance, or referral to local authorities, but longer-term reintegration support is often limited and unevenly implemented across regions”^[70]. The Special Rapporteur on the Right to Development similarly noted the lack of reintegration support and services for victims of trafficking for the purposes of labour exploitation after a visit in 2023^[71].

37. The Asylos report paints a clear picture: the Vietnamese state fails to effectively address the root causes of trafficking through re-integration support and prevention efforts. As a result, returning victims face the same conditions which render them vulnerable to re-trafficking. There are many indicators which heighten this risk including: age, gender, victim recognition or status, socio-economic background, geographical location, and the nature of trafficking e.g. forced criminality and labour exploitation. Overall, the evidence shows that protection is insufficient for most victims in Vietnam.

Internal Relocation

38. Internal relocation will often be of limited utility as a means of avoiding re-trafficking because the risk faced by trafficking survivors is frequently not, or not only, a localised one. The Asylos report consistently identifies economic precarity, debt, insecure work, social marginalisation, trauma and limited access to adequate support as significant risk factors for trafficking and re-trafficking^[72]. Those vulnerabilities are not geographically bounded and may persist wherever the individual resides.

39. The Asylos report also describes trafficking methods that increasingly transcend geographical boundaries. Traffickers use Facebook, Telegram and Zalo to identify, groom, recruit and exploit victims, and social media has become central to modern trafficking methods^[73]. Digital channels provide anonymity and a wide reach across geographic and social boundaries, allowing traffickers to target victims remotely and coordinate recruitment in real time^[74]. Traffickers use the internet and social media not only to recruit victims, but also to control them and to expand trafficking operations^[75].

40. Accordingly, the risk of re-trafficking may arise not because an individual remains physically proximate to a previous trafficker, but because the characteristics that rendered them vulnerable to trafficking remain unchanged. Relocation to another province does not, without more, address debt, social isolation, trauma, economic insecurity or lack of support. Nor does it necessarily place the trafficking victim beyond the reach of trafficking practices that operate through online and social networks.

41. A related concern relates to residence registration and access to public services, Mimi Vu explained to Asylos that one of the principal challenges facing returning trafficking survivors is the need to re-establish residence registration. Many returnees have no remaining home or continuing family ties and lack essential documents, including birth certificates and identity papers. This creates uncertainty as to the province in which they can register. Critically, Ms Vu explained that: “without their national ID card and a registration home in a province, they can’t get their social health insurance card“^[76].

42. The report supports that evidence by reference to a 2020 International Organization for Migration (IOM) study, which concluded that migrants’ legal and residential status remains an important determinant of access to health insurance. Those without residential status may be unable to obtain voluntary health insurance or change the hospital registered on their health-insurance card. Migrants also reported a lack of health and social-welfare support at their destinations. Respondents explained:

“A lot of people don’t have health insurance. The main reason is they haven’t got identity cards, they’ve been away from their place for too long or they cannot get ID cards and household registration to register for health insurance“^[77].

43. These barriers are especially important for trafficking victims requiring mental-health treatment. Ms Vu explained that access to mental healthcare is affected not only by stigma, but also by the accessibility and availability of appropriate care.^[78] Trafficking-related trauma, mental ill-health and other untreated vulnerabilities may themselves increase susceptibility to renewed exploitation. If a trafficking victim is unable to access appropriate healthcare after relocating, vulnerabilities that contributed to the original trafficking remain unaddressed.

The Home Office CPINs

44. The Trafficking CPIN does not reflect the full or current evidential position, in part because it relies on an evidence base available as of November 2024, whereas the Asylos report incorporates material up to June 2026, including expert evidence and recent developments in trafficking patterns and Vietnam’s protection framework. In particular, the CPIN does not adequately address the growth of trafficking into online scam operations, the central role of technology in recruitment and control^[79].

45. The position of male victims is also underdeveloped. The CPIN acknowledges that trafficking affects men and that support for male victims is “particularly limited”, but its assessment states that victims within Vietnam are “predominantly women and children” and provides no substantive analysis of the distinct risks faced by men and boys. The Asylos report presents a much fuller picture. Men and young adults are increasingly recruited into labour exploitation and forced criminality, particularly scam-compound operations, while the victim-support system remains historically oriented towards women and children subjected to sexual exploitation. Male survivors may be less readily identified, face pressure to present their migration as economically successful, and have substantially less access to appropriate accommodation, psychological assistance and reintegration support.

46. The Trafficking CPIN also understates the risk of re-trafficking on return. Its conclusion at §§3.1.2 and 3.1.11 relies substantially on the absence of published statistics and documented cases. However, that absence must be considered alongside the evidence of failures in victim identification, screening, reporting and follow-up. As explained at §§7-37 above, the report identifies continuing debt, insecure livelihoods, trauma and limited access to support as significant drivers of renewed exploitation. The absence of reliable data cannot therefore safely be treated as evidence that re-trafficking is uncommon.

47. Similarly, the conclusion at Trafficking CPIN §4.1.1 that the state is generally willing and able to provide effective protection places undue weight on the formal existence of laws, policies and services. The Asylos report demonstrates a substantial gap between provision on paper and implementation in practice, including systemic barriers to victim identification, limited frontline capacity, uneven access to support, inadequate specialist provision and particularly limited protection for male victims.^[80] The relevant question is whether the particular survivor will be identified and obtain effective protection, not merely whether a legislative or institutional framework exists.

48. The evidence in the Asylos report further makes plain that the broad proposition at CPIN §5.1.1, that internal relocation to Hanoi or Ho Chi Minh City may provide protection from re-trafficking, is wrong or at least requires substantial qualification. It assumes that the relevant risk can be avoided through geographical separation. However, where the risk arises from continuing vulnerability to exploitation, rather than solely from a particular trafficker operating in the home area, relocation does not itself remove or materially reduce that risk. This is consistent with Underhill LJ’s analysis in TDT, cited at §9 above^[81].

49. The Trafficking CPIN itself implicitly recognises this limitation at §5.1.2, where it states that a victim may be able to escape a “localised threat of re-trafficking”, depending on “the nature of the threat and how far the threat would extend”. That important qualification sits uneasily with the proposition at §5.1.1. The report indicates that, in many cases, the relevant risk is not geographically confined because it derives from persistent vulnerability and trafficking methods that operate across provincial boundaries and through online networks.^[82]

50. Finally, the Trafficking CPIN continues to rely, in its analysis of risk, protection and internal relocation, on Nguyen (Anti-Trafficking Convention: Respondent’s duties) [2015] UKUT 170 (IAC): §§3.1.6–3.1.7, 4.1.4 and 5.1.4. Although the CPIN acknowledges that Nguyen is not country guidance, its findings were based on limited evidence dating from 2010–2014 and are now substantially overtaken by the evidence assembled in the 2026 report.

51. The Trafficking CPIN does, however, continue to correctly recognise at §6.1.1 that claims of this nature are unlikely to be certifiable as clearly unfounded.

By Emma Fitzsimons, Eva Doerr and Zehrah Hassan

Garden Court Chambers, October 2026

Download the notes and references here.