Human Trafficking in European Workplaces: Why Labor Inspectors and Police Are Joining Forces

HUMAN TRAFFICKING

Across Europe, the fight against human trafficking is increasingly moving into places that do not look like conventional crime scenes. Restaurants, construction sites, farms, factories, transport companies, hotels and temporary employment agencies are becoming important points of investigation as authorities try to identify exploitation that can remain concealed inside apparently legitimate businesses.

On September 2, 2026, Europol and the European Labour Authority (ELA) signed a new Working Arrangement designed to strengthen cooperation against labor exploitation, trafficking in human beings, fraud and related organized crime. The agreement matters because it formally connects two parts of the enforcement system that may encounter the same exploitation from very different directions: police investigating criminal networks and labor inspectors examining wages, working hours, contracts, recruitment practices and working conditions.

The premise behind the agreement is relatively simple. A worker being severely underpaid, housed in unacceptable conditions, charged impossible recruitment debts or prevented from leaving a job may initially appear to be experiencing a labor-law violation. In some cases, however, those conditions are evidence of something more serious: a system of coercion designed to keep a person working for someone else’s profit.

Europol itself has warned that labor exploitation can be treated solely as a labor-law issue, allowing indicators of trafficking and organized crime to go undetected. Bringing labor authorities and criminal investigators closer together is therefore an attempt to identify what may be hiding behind the employment records, wage violations and workplace conditions inspectors encounter every day.

What This Article Covers

• Why Europol and the European Labour Authority have strengthened cooperation in September 2026.
• How human trafficking can be concealed inside otherwise ordinary workplaces and businesses.
• Why labor inspectors can play an important role in identifying forced labor and trafficking.
• Which industries European authorities are currently examining most closely.
• Why migrant workers and people recruited across borders can face particular risks.
• What recent EU trafficking and workplace inspection data show.
• Why enforcement must protect workers as well as investigate employers and criminal networks.

Key Takeaways

• Europol and the European Labour Authority signed a new Working Arrangement on September 2, 2026, to strengthen cooperation on labor exploitation and human trafficking.
• EU authorities increasingly recognize that serious labor exploitation can first present itself as an employment violation rather than an obvious trafficking crime.
• Eurostat recorded 9,678 registered trafficking victims in the EU in 2024, including 3,391 people trafficked for forced labor or services.
• Cross-border enforcement actions have targeted agriculture, hospitality, construction, transport, manufacturing and temporary employment intermediaries, among other sectors.
• The European Commission says Member States carried out almost 600,000 targeted inspections in high-risk sectors during 2024, although enforcement and worker protection remain uneven.
• Effective inspections require more than detecting illegal employment. Workers need realistic routes to report exploitation, recover unpaid wages and access protection without fear.
• Stronger cooperation matters because criminal groups can exploit legitimate business structures and operate across several jurisdictions simultaneously.

Why This Story Matters Now

The September agreement between Europol and ELA does not create Europe’s first joint action against labor exploitation. What it does is formalize and deepen a model of cooperation that European authorities have already been testing through coordinated inspections and investigations.

Europol says the arrangement will provide a framework for exchanging strategic information, strengthening connections with national labor inspectorates and developing further cooperation. Acting Europol Executive Director Jürgen Ebner said criminal networks can operate across borders while using legitimate business structures to facilitate exploitation and conceal criminal profits. The concern is therefore not simply that individual employers might violate employment rules, but that apparently ordinary commercial activity can sometimes provide the infrastructure through which organized exploitation operates.

Recent operations illustrate why authorities are taking that possibility seriously. In a Europe-wide action against labor exploitation reported in November 2025, authorities from 32 countries worked together across sectors including agriculture, gastronomy and temporary employment. Europol said 54 people were arrested, 404 potential trafficking victims were identified and 93 suspected perpetrators were identified. Police forces worked alongside border guards, tax authorities, labor authorities and labor inspectorates, with Europol and ELA supporting the operation.

The approach has continued into 2026. In June, ELA coordinated its first dedicated week of action focused on temporary employment agencies and other labor intermediaries. Enforcement authorities from 14 EU Member States examined 70 companies and almost 2,800 workers.

This is the context in which the September agreement should be understood. Europe is not suddenly discovering that forced labor exists. It is increasingly trying to connect information that historically may have sat in different institutions, so that an unusual pay arrangement noticed by an inspector, a fraudulent company structure identified by a tax authority and intelligence about a trafficking network held by police can potentially be understood as parts of the same case.

Human Trafficking Does Not Always Look Like a Trafficking Crime

Popular understanding of human trafficking can still be dominated by images of kidnapping, physical confinement or people being moved secretly across borders. Those situations can occur, but trafficking is much broader. It involves exploitation through means including force, fraud, coercion, deception or abuse of vulnerability, and a person does not have to cross an international border to be trafficked.

For readers unfamiliar with the terminology, Not For Sale’s broader guide to what human trafficking is explains the relationship between trafficking, forced labor, debt bondage and other forms of modern-day slavery. Read: What is human trafficking?

In workplace trafficking, the employment itself can provide the mechanism of control. A person may accept what appears to be a legitimate job and discover only later that the conditions are entirely different from those promised. Recruitment fees can produce debts that become impossible to repay. Wages can be withheld. Identity documents can be taken. Accommodation, transportation and employment can all be controlled by the same intermediary. Threats may involve dismissal, homelessness, violence, immigration consequences or retaliation against relatives rather than a locked door.

That is one reason labor inspectors can matter so much. They are already looking at the details through which exploitation can become visible: who is actually working at a business, who employs them on paper, whether they are being paid correctly, how many hours they are working, where they are living and whether the apparent employment relationship matches reality.

The EU Agency for Fundamental Rights and ELA published specific guidance for workplace inspectors in 2025, emphasizing their role in detecting exploitation, speaking with workers, identifying warning signs, referring people to support and helping workers pursue unpaid wages or complaints. The guidance focuses particularly on people working outside their country of nationality, who may face additional vulnerabilities arising from language, unfamiliarity with national labor protections or dependence on an employer or intermediary.

Why Ordinary Businesses Can Conceal Serious Exploitation

The significance of the current European approach is that it challenges the idea that trafficking exists only within visibly criminal economies. Europol specifically warns that organized criminal networks can exploit legitimate business structures.

A restaurant may serve customers normally while workers behind the scenes are being underpaid or controlled. A construction project may look indistinguishable from hundreds of others while layers of subcontracting obscure who recruited and pays particular workers. A transport company can move legitimate goods while employment arrangements cross several jurisdictions. A farm may depend on seasonal labor recruited through intermediaries operating far from the eventual workplace.

None of those circumstances alone proves trafficking. Most employment violations are not human trafficking, and it is important not to collapse every case of underpayment, undeclared work or poor employment practice into a trafficking allegation. The challenge for authorities is identifying the threshold where labor abuse becomes coercive exploitation and determining whether an individual employer, intermediary or wider criminal structure is responsible.

That distinction is precisely why cooperation matters. A labor inspector can recognize violations that would not necessarily trigger a major police investigation on their own. Police and Europol, in turn, can identify connections between businesses, individuals, financial flows or recruitment networks that a workplace inspection conducted in isolation might never reveal.

The Data Show Why Forced Labor Cannot Be Treated as Marginal

The latest Eurostat figures reinforce the importance of the issue. In 2024, authorities across the EU registered 9,678 victims of human trafficking. Among victims for whom the form of exploitation was recorded, 4,219 were trafficked for sexual exploitation and 3,391 for forced labor or services. Forced labor therefore represented 37 percent of recorded forms of exploitation.

The profile of trafficking is also highly international, but not exclusively so. Eurostat data show that in 2024, 28 percent of registered trafficking victims held the citizenship of the country that reported them, 8 percent came from another EU Member State and 64 percent were citizens of countries outside the EU. The figures are an important reminder that trafficking can affect both people moving across borders and those exploited within their own countries.

Registered cases should not be interpreted as the total number of people experiencing trafficking. Trafficking is inherently difficult to measure because people may not identify themselves as victims, may fear authorities or traffickers, or may never encounter a service capable of recognizing their situation. Changes in official numbers can also reflect changes in detection and reporting rather than changes in the underlying prevalence of exploitation.

That makes the ability to identify cases inside workplaces particularly significant. Every labor inspection potentially reaches an environment in which people who would never independently report a trafficking crime may nonetheless come into contact with public authorities.

Where European Authorities Are Looking

European enforcement activity has increasingly concentrated on sectors characterized by labor-intensive work, subcontracting, cross-border recruitment or large numbers of migrant and temporary workers.

The European Commission’s 2026 review of the Employers Sanctions Directive identifies agriculture, construction, transport, wholesale and retail, accommodation and food services, and manufacturing among the sectors prioritized by Member States because of risks relating to undeclared work and employment of third-country nationals. The report also notes that immigration and law-enforcement authorities participate systematically in inspections in almost all Member States, while tax, social security, customs and anti-fraud bodies may also be involved.

The scale is considerable. The Commission reported in May that Member States conducted almost 600,000 targeted inspections in high-risk sectors in 2024. At the same time, it acknowledged significant differences between national systems and said further work was needed to strengthen prevention, detection and coordination.

Separate ELA operations demonstrate how cross-border that enforcement can become. Inspections during 2025 involved authorities examining construction, manufacturing and hotel, restaurant and catering businesses across multiple Member States, while investigations following those inspections concerned issues including undeclared work, illegal employment, working time, remuneration and the posting of workers across borders.

Road transport has provided another example. In 2026, coordinated activity involving authorities in Belgium, the Netherlands and Lithuania examined the employment and posting arrangements of drivers working across national borders, with police and labor authorities exchanging information between countries.

These investigations do not mean that every infringement identified constitutes trafficking. They show instead why the workplace has become an increasingly important intelligence environment. The same inspection capable of finding unpaid wages or an incorrect employment declaration may also expose the conditions through which a vulnerable worker is being controlled.

Labor Intermediaries Are Becoming an Important Part of the Picture

One particularly significant area of scrutiny is the chain between the worker and the company where the work ultimately takes place. Recruitment agencies, temporary employment companies, subcontractors and other labor intermediaries can perform legitimate and important functions in Europe’s labor market, particularly when workers are recruited across borders.

Complexity, however, can also reduce transparency.

A worker may be recruited in one country, employed on paper by a company in another, housed by an intermediary, transported to a workplace elsewhere and perform labor for a business that did not directly recruit them. When several companies sit between the individual worker and the ultimate beneficiary of the labor, responsibility can become harder to trace.

ELA’s decision to coordinate a dedicated action week on temporary employment agencies and other labor intermediaries in June 2026 reflects growing attention to this part of the system. Fourteen Member States participated, checking 70 companies and nearly 2,800 workers.

Recruitment becomes particularly dangerous when workers incur debt to secure employment or when promises made before migration differ substantially from the conditions they encounter after arrival. Not For Sale’s trafficking glossary explains how excessive recruitment fees, withheld wages and document confiscation can function as mechanisms of control rather than simply poor employment practice. Read the Human Trafficking Terms and Definitions glossary

Who Is Most at Risk?

There is no single profile of a person vulnerable to labor trafficking, and migrant status should never be treated as synonymous with exploitation. Millions of people move for work legally and safely throughout Europe.

Risk rises when workers have fewer practical choices and fewer ways to challenge an employer. That can include people with insecure immigration status, workers recruited in languages they do not fully understand, individuals whose accommodation depends on the employer, people carrying recruitment debt, workers unfamiliar with their legal rights and those whose ability to remain in a country is closely connected to their employment.

The EU Agency for Fundamental Rights has repeatedly highlighted the particular challenges faced by third-country workers. Its guidance emphasizes that migrant workers, including people in irregular situations, still hold core employment rights, while practical access to those rights can be difficult.

The European Commission’s latest assessment exposes some of those difficulties. Although EU rules provide mechanisms through which irregular migrant workers can recover unpaid wages, the Commission found that Member States did not systematically report data on workers pursuing back payments between 2021 and 2024. It also cited barriers including legal costs, complex procedures, difficulties producing evidence and inadequate safeguards against return in some circumstances. Even where workers successfully establish that wages are owed, insolvency, asset transfers and shell or letterbox companies can make recovery difficult.

This creates an important challenge for the new enforcement model. Finding exploited workers is only part of the task. Authorities also need systems in which people can speak openly about the conditions they have experienced and pursue justice without believing that coming forward will simply create another threat to their security.

The Strength of Joint Inspections, and the Protection Question They Must Resolve

Bringing labor inspectors and law enforcement together offers clear investigative advantages. Different agencies hold different pieces of information, possess different powers and recognize different indicators. Cooperation can make it easier to see the full structure behind exploitation rather than dealing only with the individual violation visible at one workplace.

There is also a tension that must be handled carefully. A worker who fears deportation, loss of housing or retaliation may not immediately distinguish between an official who has arrived to protect labor rights and one responsible for immigration enforcement. If workers do not trust that disclosure will lead to protection, the presence of multiple enforcement agencies may not automatically produce better victim identification.

The Commission’s own evidence on barriers to complaints makes this more than a theoretical concern. Enforcement therefore needs to be designed around worker protection as well as detection. Access to interpreters, confidential interviews away from employers, understandable information about rights, clear referral procedures and meaningful access to unpaid wages and legal assistance can determine whether an inspection merely identifies paperwork violations or uncovers coercion behind them.

The distinction matters because someone experiencing trafficking is not simply evidence in a prosecution. They are a worker whose wages may have been stolen, whose immigration or housing position may be precarious and whose ability to leave exploitation depends on credible alternatives being available.

Europe Has Strengthened the Law as Well as Enforcement

The operational changes are taking place alongside an evolving EU legal framework. Amendments to the EU Anti-Trafficking Directive entered into force in July 2024, with Member States required to transpose the new rules into national law by July 15, 2026.

Meanwhile, the European Commission is evaluating the Employers Sanctions Directive, which governs measures against employers of third-country nationals staying irregularly in the EU. The evaluation is examining prevention, inspections, sanctions, worker protection, cross-border enforcement and information sharing, including the relationship between illegal employment and trafficking for labor exploitation. The Commission has already acknowledged that implementation differs significantly between Member States and that inspection coverage in higher-risk sectors remains uneven.

The September Europol-ELA agreement therefore forms one part of a much wider question confronting Europe: whether laws, workplace enforcement, immigration systems and organized-crime investigations can operate together effectively enough to identify exploitation without leaving workers trapped between them.

What Still Needs to Change

More inspections will not automatically produce less trafficking. Their effectiveness depends on where inspections happen, how workers are interviewed, whether agencies recognize trafficking indicators and what happens to workers after exploitation is identified.

Europe also needs to follow responsibility beyond the physical workplace. Subcontracting chains, recruitment businesses and temporary employment structures can make it difficult to identify who ultimately controls the worker or profits from abusive conditions. Enforcement that stops at the company name displayed outside a factory, restaurant or warehouse risks missing the economic architecture behind the exploitation.

Worker protection also needs to become measurable. Authorities can count inspections, businesses checked, arrests and investigations relatively easily. It is harder, but equally important, to determine whether exploited workers recover unpaid wages, obtain secure accommodation, access legal support and are able to move into safe employment.

The Commission’s 2026 findings show why that matters. Europe already has legal protections intended to provide complaint mechanisms and back payments, yet practical access remains inconsistent. A successful anti-trafficking strategy must therefore ask not only how many exploitative employers have been identified, but whether people have genuinely been able to leave the conditions that made exploitation possible.

What Not For Sale’s Perspective Adds

For Not For Sale, the significance of this development lies in recognizing trafficking as a systems problem rather than a crime that becomes visible only at the moment of rescue. Modern-day slavery can be embedded in ordinary economic activity when vulnerable workers, opaque recruitment structures, weak oversight and commercial pressure intersect.

That is why labor rights and human rights cannot be separated cleanly. Not every workplace violation is trafficking, but severe exploitation can grow inside systems where underpayment, insecure employment, recruitment debt and lack of accountability have been allowed to become normal.

Not For Sale has explored this relationship in its work on ethical labor and human rights, including the role businesses and supply chains can play in either increasing vulnerability or creating safer economic alternatives. Read: Human rights, labor rights and ethical business

The objective should not be to treat every vulnerable worker as a passive victim. It should be to increase the choices available to people. Effective enforcement can remove abusive employers and criminal actors from the equation, but prevention also means creating labor markets in which workers can understand their rights, change employers, recover wages, access support and build livelihoods without dependence on exploitative intermediaries.

What Readers Can Do

People are unlikely to identify trafficking by looking for a single dramatic sign. Concern should arise from patterns of control: a worker who appears unable to leave employment, has wages withheld, owes an unexplained debt to a recruiter or employer, does not control their identity documents, lives in employer-controlled accommodation under coercive conditions, appears closely monitored or gives indications that threats are being used to keep them working.

Suspicion is not proof, and members of the public should not confront an employer or suspected trafficker themselves. Where there is immediate danger, contact the relevant emergency services. Concerns about workplace conditions can also be raised through national labor inspectorates, police or recognized trafficking-support organizations.

Businesses have another responsibility. Companies can examine how temporary staff are recruited, whether recruitment fees are charged, how subcontractors demonstrate compliance, whether workers can raise concerns independently and whether purchasing practices create pressure that can be passed down the supply chain. The question is not simply whether a company’s own employees are treated properly, but how much it knows about the people whose labor sits further down the chain.

The most important aspect of Europe’s latest anti-trafficking development is not that police officers and labor inspectors will increasingly stand in the same workplace. It is the recognition behind that decision.

Human trafficking does not always announce itself as human trafficking. It can appear first as an unpaid wage, an irregular contract, a worker sleeping in accommodation controlled by an employer, a false recruitment promise or a company structure that seems unnecessarily difficult to understand.

On their own, each of those signs may have another explanation. Together, they can reveal a system of control.

Europe’s challenge now is to make sure its institutions are capable of joining those pieces before exploitation becomes deeper and harder to escape. The new Europol and European Labour Authority agreement gives investigators another mechanism for doing so. Its real measure of success will be whether the people hidden inside those ordinary workplaces are identified, protected and given a genuine route out.

FAQ’s

Why are Europol and the European Labour Authority working together?

Europol and the European Labour Authority signed a Working Arrangement on September 2, 2026, to strengthen cooperation against labor exploitation, human trafficking, fraud and related organized crime. The agreement is intended to improve strategic information exchange and connections between law enforcement and national labor inspectorates.

How can human trafficking happen inside an ordinary workplace?

Trafficking can occur when force, fraud, coercion, deception or abuse of vulnerability is used to exploit someone’s labor. A workplace may appear legitimate from outside while workers experience withheld wages, recruitment debt, threats, document confiscation or other forms of control.

Is every serious labor-law violation human trafficking?

No. Underpayment, undeclared employment or violations of working-time rules do not automatically constitute trafficking. Investigators must establish whether exploitation involves the elements required under applicable trafficking law, including the means used to recruit or control a person and the purpose of exploitation.

Which European industries are considered higher risk?

European enforcement activity has focused on sectors including agriculture, construction, transport, manufacturing, accommodation, food services and other labor-intensive industries. Authorities have also increased scrutiny of temporary employment agencies and labor intermediaries.

How common is trafficking for forced labor in the EU?

Eurostat recorded 3,391 registered victims trafficked for forced labor or services in the EU in 2024, accounting for 37 percent of victims for whom the form of exploitation was reported. Registered victims represent detected cases and should not be interpreted as the total prevalence of trafficking.

Why are migrant workers particularly vulnerable to labor exploitation?

Risk can increase when workers depend heavily on an employer or recruiter for immigration status, housing, transportation or information. Language barriers, recruitment debts and limited knowledge of employment rights can also make it harder to leave abusive employment or seek help.

What role can labor inspectors play in identifying trafficking?

Labor inspectors can identify employment irregularities, speak directly with workers, examine wage and working-time records and recognize indicators that a labor violation may involve coercion or exploitation. European guidance increasingly encourages inspectors to connect potential victims with appropriate support services.

Why does cross-border cooperation matter?

Recruitment, employment, subcontracting and financial activity can take place in different countries. Sharing information allows authorities to connect evidence across jurisdictions and determine whether apparently separate workplace violations form part of a wider exploitation network.

Can trafficking victims recover unpaid wages?

EU law contains protections designed to enable certain migrant workers to recover unpaid wages, but the European Commission reports significant practical barriers and limited data on successful recovery. Legal costs, evidential difficulties, complex company structures and enforcement problems can all obstruct claims.

What should someone do if they suspect workplace trafficking?

If someone appears to be in immediate danger, contact emergency services. Other concerns can be reported to the appropriate national labor inspectorate, police service or specialist trafficking organization. People should avoid confronting suspected traffickers themselves, as doing so could place workers at greater risk.