Report: More than Words: How Definitions Impact on the UK’s Response to Child Trafficking and Exploitation

Every child who has been exploited deserves access to the right support and care. In 2024 alone nearly 6,000 children were referred to the National Referral Mechanism (NRM) in the UK, the framework for identifying victims of modern slavery. These children may never choose to the word “exploitation” to speak about their experiences. They may not describe what happened to them as trafficking, or criminal exploitation, or modern slavery. But professionals must be able to recognise these things.

When we talk about child trafficking and exploitation, definitions are not just legal constructs. The words we choose matter. They shape how we understand harm, how we identify victims, how we respond, and how children are cared for. The language we choose can open doors to protection and justice, or it can leave children unseen and unsupported.

As the Independent Anti-Slavery Commissioner, I am deeply concerned that confusion over definitions in UK law and policy is hindering the identification and protection of child victims of exploitation. This can and should be a simple fix. That is why this report is important.

This report highlights the inconsistent definitions and terminology surrounding child exploitation across the UK, particularly concerning Child Sexual Exploitation (CSE) and Child Criminal Exploitation (CCE). These inconsistencies are harming children by affecting safeguarding, policing, and prosecution efforts. It underscores how fragmented language around child trafficking and exploitation leads to confusion, leaving children vulnerable and under protected.

This report challenges harmful stereotypes. Modern slavery and trafficking are often mistakenly seen as issues affecting only foreign nationals, when UK nationals are equally at risk. Gender bias also plays a role, with boys overlooked as victims of sexual exploitation and girls facing harmful stereotypes. Alongside this, there is still a dangerous assumption that exploitation only occurs outside the family, which risks ignoring cases where children are exploited by relatives.

There must be more consistent practices. While international law recognizes that children cannot consent to exploitation, this law is interpreted differently across the UK. In England and Wales, consent is considered irrelevant only when arranging travel for exploitation. Whereas Scotland and Northern Ireland there is clearer protection by fully acknowledging that a child can never consent. This inconsistency puts children at risk.

Children should not be treated the same as adults. The Modern Slavery statutory guidance currently applies adult standards to children, creating confusion about the necessary evidence to classify a child as a victim. Many children are misidentified, denied support, or even treated as offenders due to the narrow legal definitions and lack of clarity in how cases are assessed. It is also important that we treat older adolescents at 16-and-17 years old as adults, they are still children.

Moreover, systemic gaps in identifying child victims of exploitation persist, with over half of professionals reporting struggles to secure support due to legal definitions. This suggests children are being failed not due to lack of exploitation, but because their experiences don’t fit rigid frameworks or lack “credible” evidence.

These inconsistencies are not just technical - they shape policy and, most importantly, children’s lives. Definitions influence how children are identified, the support they receive, and which systems respond. Without clarity, it is harder to collect reliable data, understand prevalence, or design effective interventions. A lack of shared understanding risks children being misidentified, overlooked, or left unprotected.

Being formally identified as a victim of trafficking should open the door to vital support: safe housing, legal advice, healthcare, education, and help navigating the criminal justice system. For unaccompanied children, it also means access to a legal guardian and the presumption of childhood where age is uncertain. Crucially, it means recognising that no child should be punished for crimes they were forced to commit. These are not optional extras; they are essential for recovery, dignity, and justice.

I recognise the complexity of defining exploitation. But the message is clear: the current system is not working. We must strike a balance, definitions must be clear enough to drive action, yet flexible enough to reflect emerging harms.

That is why this report sets out a clear path forward. The Government should introduce a statutory definition of child exploitation - one that encompasses all forms of abuse, aligns with international law, and centres children’s voices. A clear definition would bring coherence to the UK’s legal framework and give professionals the clarity they need to identify and protect victims.

Policy alone is not enough. Protecting children requires a joined-up, cross-government approach, underpinned by a UK-wide child exploitation strategy. Crucially we must listen to those with lived experience and work closely with frontline professionals, law enforcement, and legal experts. As Commissioner, I am committed to acting on these findings. The time to act is now.

You can read the full report here