Tribunal decisions

The decision

NCN: [2026] UKUT 00315 (IAC)

LR (Male VOTs) Albania CG

IN THE UPPER TRIBUNAL
IMMIGRATION AND ASYLUM CHAMBER

Heard at Field House

THE IMMIGRATION ACTS

Heard on 9-13 March,18-20 March and 27 July 2026
Issued on 13 August 2026

Before

DEPUTY CHAMBER PRESIDENT PLIMMER
UPPER TRIBUNAL JUDGE BLUNDELL
UPPER TRIBUNAL JUDGE LANDES

Between

LR
(ANONYMITY ORDER MADE)
Appellant
and

THE SECRETARY OF STATE FOR THE HOME DEPARTMENT
Respondent

Representation:
For the Appellant: Zane Malik KC, Tom Tabori and Paul Erdunast of counsel, instructed by Thompson & Co Solicitors (Tooting)
For the Respondent: William Hansen (up to 20 March 2026), Karen Reid (for the hearing on 27 July 2026) and Gemma Ralph of counsel, instructed by the Government Legal Department

Order Regarding Anonymity

Pursuant to rule 14 of the Tribunal Procedure (Upper Tribunal) Rules 2008, the appellant is granted anonymity. No-one shall publish or reveal any information, including the name or address of the appellant, likely to lead members of the public to identify the appellant. Failure to comply with this order could amount to a contempt of court.

(1) Profile. There is no typical profile for Albanian male victims of trafficking (‘VOTs’). Certain common themes are encountered amongst those who have been trafficked. Often they tend to: be teenagers or young adults; come from less affluent or marginalised backgrounds; have received a limited education; have experienced domestic violence or neglect. However, male VOTs might become vulnerable to trafficking for a variety of reasons, and come from all parts of Albania and from varied social backgrounds.

(2) Risk factors. The following non-exhaustive list of risk factors may lead an Albanian male to become a VOT:
(i) Lower socio-economic status including homelessness
(ii) Lower levels of education and difficulty in securing legitimate employment
(iii) Ill health, whether physical or mental, including addiction
(iv) Originating from Northern Albania or a rural area
(v) Age, with younger men and teenagers being more vulnerable
(vi) A lack of a family or other support network, whether by reference to blood feud, criminality or adverse childhood experiences
(vii) Belonging to a minority ethnic group or having an LGBT identity

(3) It is important to bear in mind that the presence of multiple factors may compound or increase risk but one risk factor may be sufficient to make a person a VOT.

(4) Modus operandi. Male VOTs are lured or forced into trafficking in a variety of ways including (but not limited to) the following: a young male finds himself in financially straitened circumstances, accepts an offer of claimed lucrative employment in the UK, only to discover en route or on arrival that he is to be exploited and forced to work in difficult and unlawful conditions, whether as a result of debt bondage, family pressures or because of threats to his safety or that of his family.

(5) Social media plays an increasing role in the initial recruitment process. Organised Criminal Networks (‘OCNs’) are likely to play a role in such trafficking, although it will be for an individual decision maker to consider the nature and extent of that role in a case in which it is disputed. Trafficking by means of abduction is not commonplace.

(6) Risk on return. An individual who escapes from a situation of trafficking or otherwise manifests an unwillingness to be involved in drug-related or other criminality may be at risk on return to Albania. He might be at risk of re-trafficking and/or reprisal at the hands of his original traffickers or at risk of re-trafficking at the hands of another.

(7) It is not possible to quantify the risk of re-trafficking in any given case, whether at the hands of the original traffickers or at the hands of another. In considering the extent of any such risk, a decision maker who is satisfied that an individual has been the subject of past persecution or the threat thereof will consider that fact to be a serious indication of the risk of future harm unless there are good reasons to consider that it will not be repeated (paragraph 339K of the Immigration Rules refers).

(8) In considering the risk of re-trafficking or reprisal from the original traffickers, it will be necessary for decision-makers to consider:
(i) The circumstances of the individual and in particular his vulnerabilities, together with the reintegration assistance which is likely to be provided to the individual on return to Albania. In considering vulnerability to re-trafficking by deception, it will be relevant to consider that an individual who was previously duped by a trafficker will be aware of the risks associated with offers of the kind.
(ii) What is known about the original traffickers, in particular:
(a) the size of the operation and its level of organisation;
(b) any threats which have been made or acted upon in the past, including in relation to debt bondage;
(c) any connection to family members and acquaintances;
(d) any links to the community / area the individual and his family members originate from;
(e) the extent to which the individual has tangible evidence against an Organised Crime Group (‘OCG’) which might jeopardise its future operations
(f) the passage of time (because a significant period without interest or threat may indicate a lack of ongoing interest).

(9) In assessing the risk of re-trafficking at the hands of a different actor, decision makers should take account of the individual’s original risk profile and vulnerabilities and the extent to which this has changed or is likely to do so. In considering vulnerability to re-trafficking by deception, it will also be relevant to consider that an individual who was previously duped by a trafficker will be aware of the risks associated with offers of the kind.

(10) Aids and obstacles to reintegration. There is no shelter provision for individual adult male VOTs. A returning adult male VOT who is not able or willing to return to their family must rely upon accommodation in the rented sector with the assistance of NGOs. Such support is provided after initial identification as a VOT by an NGO and without the need for a formal declaration of that status.

(11) The normal offer of rented accommodation from an NGO is limited to six months, but the occasional need for longer term help is likely to be able to met. Whilst the NGOs current capacity for male VOTs is relatively limited, there are clear indications that should there be a need to increase capacity, support is scalable with the necessary funding and lead-in time to recruit and train additional staff. The NGOs are widely acknowledged to be supportive and to assist VOTs proactively and positively and without discrimination.

(12) Once a VOT leaves the rented accommodation provided by NGOs, they are required to obtain a formal declaration of their status in order to access the support provided by the Albanian state. Such declarations must be obtained by attending an interview with a specialised police officer and a social worker. There is a comprehensive and detailed framework of provision to support recognised VOTs with reintegration including the National Referral Mechanism (‘NRM’) and Standard Operating Procedure (‘SOP’) as well as some support in employment, limited financial assistance, livelihood skills, housing and access to healthcare.

(13) The institutional framework is bolstered by initiatives undertaken by NGOs who will assist male VOTs to access state or municipal reintegration support, but also run their own support programmes including fulfilment of basic needs, housing support, financial aid to start a small business and psychological counselling.

(14) For each reintegration measure available, there are practical challenges associated with access to the measure. Whilst VOTs are a priority group for social housing and rent subsidies, and NGOs will assist the VOTs to access what is available, there are many other priority need categories and state and municipal funding may simply not be available for such programmes.

(15) In addition, VOTs may encounter a range of obstacles to access these aids to integration. Prevailing social mores discourage an adult male VOT from seeking reintegration support. As a result of the support offered by the NGOs, however, it will generally be reasonable to expect an adult male VOT to identify himself as such on return, so as to access the support available from NGOs and, subsequently, the Albanian state. An adult male VOT may however be able to establish that it would be unreasonable to expect him to access that support on account of particular vulnerability, including genuinely-held subjective fear, mental health problems, disability or membership of an ethnic minority group.

(16) Sufficiency of protection. The Albanian government has made significant further efforts to improve its response to trafficking and VOTs and there is a general sufficiency of protection for an adult male VOT. However, this will not be effective in every case and his particular circumstances must be considered.

(17) Whether an adult male VOT will be able to access sufficient protection from the authorities will depend upon his individual circumstances and the additional protection his particular circumstances reasonably require. In conducting this assessment the factors under the two main headings of vulnerability and information relevant to traffickers, should be considered.

(18) Vulnerability to re-trafficking increases with lower social status, economic standing and education; with disability or health (particularly mental health) concerns; for ethnic minority communities, particularly Roma; for those from remote / rural parts of Albania; for those who are younger; for those without a support network; and for those with a history of domestic violence in the family. However, given the support provided by the NGOs together with the institutional framework, it will generally be reasonable for an adult male VOT to engage with the identification process, which then enables them to access the protective and rehabilitative support available. There may be specific individual factors going beyond a general reluctance to engage in an individual case. These must be considered on a case-by-case basis. The information relevant to the traffickers as summarised above must also be considered.

(19) An adult male VOT assessed to require the additional protection of shelter accommodation to avoid re-trafficking and/or reprisal, will not be able to access it but careful consideration must be given to whether on the facts of the individual case, rented accommodation with associated reintegration and security support would be sufficient.

(20) Internal relocation. The safety and reasonableness analyses must take account of all relevant circumstances, including the vulnerabilities and mitigations in the place of relocation. In general, the support available to adult male VOTs who are not at risk of reprisal or re-trafficking suggests that internal relocation will not be unduly harsh.

(21) An adult male VOT who requires a shelter to be safe in his home area, is unlikely to be safe anywhere else.

(22) Where an adult male VOT is not at such risk so as to require a shelter, but is still being sought by his traffickers, internal relocation to anywhere outside the bigger cities is unlikely to be safe. Whether a person would be safe from their trafficker in Tirana or one of the other bigger cities such as Durres, Vlore, Elbasan and Shkoder will depend on how actively a man is being sought, the reach and intent of the traffickers, their connections if any with the authorities in that area and their vulnerabilities.

(23) Vulnerabilities are relevant at the safety analysis stage because they play a role in the ability to access rehabilitation and support. Where rehabilitation is not possible or unlikely, the risk of re-trafficking increases.

(24) Reintegration is more accessible in Tirana due to the lack of availability of social housing or rental support from the authorities in other areas.

(25) Particular Social Group (‘PSG’). Albanian male VOTs share a common background and, because they are perceived as different by surrounding society, have a distinct identity in Albania. They are therefore members of a PSG both pre and post Nationality and Borders Act 2022. There must be a causative link between the fear of persecution and the membership of the PSG.

DECISION AND REASONS

1 – 3 Introduction

4 – 6 The appellant’s claim

7 – 10 Procedural history

11 – 12 Country guidance issues

13 – 18 Hearing

19 – 64 Legal framework
20 General statutory framework
21 – 24 Standard of proof
25 – 43 Sufficiency of protection
44 – 54 Internal relocation
55 – 64 Particular Social Group

65 – 103 Background material

104 – 184 Expert evidence
110 – 133 Mr Carswell
134 – 149 Dr Davy
150 – 167 Professor Dalakoglou
168 – 184 Ms Trimi

185 – 362 Country guidance analysis
185 Issue 1 – Typical profile of male VOTs
186 – 197 Issue 2 – Risk factors
198 - 209 Issue 3 - Recruitment
210 – 232 Issue 4 – Relevance of Organised Crime Gang involvement
210 – 232 Issue 5 – Nature and extent of risk on return
233 – 285 Issue 6 – Aids and obstacles to reintegration
286 – 329 Issue 7 – Sufficiency of protection (systemic)
286 – 329 Issue 8 – Sufficiency of protection (individual factors)
330 – 346 Issue 9 – Internal relocation (general viability)
330 – 346 Issue 10 – Internal relocation (individual factors)
347 – 362 Issue 11 – Particular Social Group

363 Country guidance

364 – 402 The appellant’s individual circumstances
364 – 365 Hearing on 27 July 2026
366 – 375 The appellant’s account
376 – 377 The preserved findings
378 – 385 Findings of fact
386 – 402 Evaluation of prospective risk

403 Conclusion

Decision

ANNEX: List of Sources

Introduction
1. All three members of the panel have contributed substantially to this decision. We have continued the anonymity order made by the First-tier Tribunal as the requirements under the Refugee Convention in this particular case outweigh the demands of open justice. No party sought to argue otherwise.
2. On 4 June 2026 we issued country guidance findings, with directions for a further hearing in order to give the appellant an opportunity to provide updated evidence and to hear from both parties on the application of the country guidance findings to this appellant’s case. We now provide our decision allowing the appellant’s appeal for the detailed reasons we provide below, together with our country guidance findings.
3. The Upper Tribunal and its predecessor have given country guidance on female victims of trafficking (‘VOTs’) from Albania on two occasions in the last twenty years. AM & BM (trafficked women) Albania CG [2010] UKUT 80 (IAC) was issued in February 2010 and TD & AD (trafficked women) Albania CG [2016] UKUT 92 (IAC) was issued in February 2016. At that time the majority of human trafficking from Albania to other European countries was of women for the purpose of sexual exploitation. In recent years, however, the dial has shifted and more Albanian males have been trafficked to the United Kingdom (‘UK’) for the purpose of forced labour. A recurrent feature in such cases is that the VOTs are forced to work in the drugs trade, often within ‘county lines’ operations or in cannabis cultivation. This case was convened in order to give country guidance on the risk to male VOTs on return to Albania and other related questions.
The appellant’s claim
4. The appellant is an Albanian national who was born on 27 May 2005. He is originally from the outskirts of Tirana. In November 2021, aged 16, he left Albania with his abusive father and travelled to Belgium for medical treatment. The appellant escaped from his father whilst in Belgium. He fell in with a group of Albanian men who had befriended him, only to discover that he was to be exploited by them. They forced him to work without pay in a warehouse until December 2021. Arrangements were made during this time to sell the appellant to another group, who were to put him to work in cannabis cultivation in the UK.
5. The appellant managed to escape from his traffickers en route to the UK. He entered this country concealed in a lorry on 5 January 2022. He was apprehended by a group of Albanian males, but he managed to escape from them also, after which he spoke with the police and disclosed his experiences. He was duly assisted to make a claim for international protection. That claim was refused by letter dated 14 February 2023.
6. The respondent accepted that the appellant was a victim of domestic violence and of trafficking. His claim was refused on the basis that he could obtain a sufficiency of protection within Albania and that it did not engage the Refugee Convention.
Procedural history
7. The appellant’s appeal to the First-tier Tribunal was determined on 25 March 2024. The appeal was dismissed on international protection grounds. The judge accepted that the appellant’s mother had been receiving telephone calls of a threatening nature from his traffickers and that they might well seek to pursue him were he to be returned to Albania. The judge nevertheless dismissed the appeal on the basis that the appellant could obtain sufficient protection in Albania. The appeal was allowed on Article 8 ECHR grounds, however, on account of specific vulnerabilities which, the judge found, meant that the appellant was unable to manage. The judge considered that the appellant would not receive support to address those difficulties in Albania and that there would accordingly be very significant obstacles to his reintegration into his country of nationality.
8. The appellant sought and was granted permission to appeal against the dismissal of the appeal on international protection grounds. The appeal to the Upper Tribunal was heard on 6 December 2024. It was agreed at that hearing that the First-tier Tribunal’s dismissal of the appeal on international protection grounds was vitiated by legal error and should be set aside. It was also agreed that the appeal would be a suitable vehicle for giving country guidance on the subject of Albanian male VOTs. In accepting that there was a need for country guidance on the subject, the respondent indicated that there was a “significant number” of such appeals. The respondent further noted that official statistics showed that the number of Albanian males referred to the UK authorities as potential VOTs was 4,107 in 2022 and 3,463 in 2023. The statistics for Albanian females were 502 and 588 in the same years. Official statistics also indicated a significant increase in the number of Albanian nationals who had claimed asylum in 2023 as compared to 2022: 5,536 and 2,340 respectively.
9. In October 2024, the respondent issued the appellant with a biometric residence permit, thereby confirming that he had been granted leave to remain on Article 8 ECHR grounds. We were told that the respondent has granted the appellant leave to remain in the UK until March 2027. The appellant served a notice under s.104(4B) of the Nationality, Immigration and Asylum Act 2022 (‘NABA’), confirming that he wished nevertheless to pursue his appeal on international protection grounds only.
10. The appeal was carefully case managed. We need not provide any summary of that process beyond the fact that a list of country guidance issues was agreed in May 2025.
Country guidance issues
11. The list of issues prepared by the parties and approved by the Upper Tribunal in May 2025 was as follows:

[1] Is there a typical profile for an Albanian trafficked male? If so, what is it?
[2] What are the risk factors that may lead an Albanian male to become a VOT?
[3] How are Albanian males lured or forced into trafficking?
[4] In particular, insofar as involvement in drug-related or other criminality is a factor which may lead to a male becoming a VOT, (i) how, in what circumstances and by whom are such potential VOTs recruited; (ii) to what extent does an unwillingness to become involved in such criminality place a potential recruit at risk of persecution or serious harm, (iii) to what extent is a returned male VOT at risk of re-trafficking or other serious harm from organised criminal gangs?
[5] What is the nature of the risk on return for Albanian male VOTs, from (i) the original traffickers and (ii) others? Is it limited to re-trafficking or are there other material risks which might lead to persecution or serious harm? What influence does the passage of time have on the nature of the risk?
[6] Once an Albanian male has become a VOT, what are the aids to reintegration on return for an Albanian male VOT and what are the obstacles? In particular, how are VOTs that have been trafficked by organised criminal gangs perceived on return?
[7] Is there a systemic sufficiency of protection in Albania for returning male VOTs, having regard (inter alia) to:
(a) s.34 of NABA;
(b) the willingness and ability on the part of Albanian state to provide through its legal system a reasonable level of protection from ill-treatment;
(c) the systemic ability to deter and/or to prevent re-trafficking of male VOTs, as opposed to just punishment of it after the event;
(d) the legislative framework affecting male VOTs and its implementation;
(e) how corruption in Albania affects the systemic ability to deter and/or to prevent re- trafficking of male VOTs.
[8] If there is, what are the factors that bear on whether returned Albanian male VOTs will be able to access sufficiency of protection from the authorities?
[9] Is internal relocation a viable alternative for returned Albanian male VOTs, having regard (inter alia) to:
(a) s.35 of NABA;
(b) the effectiveness of any re-integration services offered by the Albanian State, NGOs and civil society organisations to male VOTs;
(c) the relevance of the article 8 ECHR “very significant obstacles to integration” test in paragraph PL 5.1 of Appendix Private Life of the Immigration Rules.
[10] If there is, what are the factors that bear on whether internal relocation is viable and reasonable?
[11] Are Albanian male VOTs a Particular Social Group (‘PSG’), having regard (inter alia) to s.33(2)-(5) of NABA? If so, are they are at risk of persecution on account of such membership, and what bearing does their constituting a PSG have on questions 6 and 7 – 10 above?
12. That list of issues was prefaced by a note which made it clear that the Upper Tribunal intended to consider the situation of men and boys who were VOTs from Albania. In the event, we have decided to focus primarily on the situation of adult male VOTs returned to Albania. We reached that decision because the parties and the experts made scant reference to the situation of minor VOTs from the large body of material before us. In the circumstances, we have amended the list of issues to reflect our primary focus on adult male VOTs for the purposes of issues 5-11, but retained male VOTs for issues 1-4. For the avoidance of doubt, references below to “male VOTs” in issues 1 – 4 include men and boys; issues 5 – 11 address adult male VOTs only.
Hearing
13. The initial hearing took place over the course of seven days in March 2026, reflecting an agreed consolidated bundle which spanned 17,410 pages in its final iteration. There was also a sizeable bundle of authorities and lengthy skeleton arguments.
14. The first five days were occupied with oral evidence from four expert witnesses (Mr Colin Carswell, Dr Deanna Davy and Professor Dimitris Dalakoglou for the appellant and Ms Anila Trimi for the respondent) and one witness of fact (Ms Hannah Pooley, a civil servant) who was called by the respondent.
15. We then heard submissions from Mr Hansen for the respondent on day six and submissions from Mr Malik KC and both of his juniors on day seven, before reserving our decision. When deliberating we noted that the appellant’s appeal was heard by the First-tier Tribunal over two years ago, in February 2024. We must of course apply the preserved findings but we reached the view that we needed to be made aware of any updated evidence relevant to the evaluative judgment on prospective risk we must make, applying the country guidance findings – see Whipple LJ’s observation at [24] of EI v SSHD [2025] EWCA Civ 556, that the assessment of risk on return is “an evaluative judgment, applying the concept of risk (which is itself part law and part fact) to the primary facts as found”. We noted the judge’s conclusions about whether the appellant would be able to manage without assistance, or manage in a place of relocation without assistance, were at least partly tied to his age at the time. This is clear from the references to the appellant being “a little over 18” and young people maturing at different ages. The appellant is now more than two years older than he was at the date of the hearing before the judge. We also noted that the judge accepted that the traffickers had threatened the appellant through his mother. In particular, by the time of the appellant’s mother’s report to Mr McCrossan in 2022, she said she had received a lot of threatening phone calls from the appellant’s traffickers.
16. We are now four years on. Both parties initially suggested that we should decide the appellant’s appeal on the limited evidence peculiar to him, as available to the judge in 2024 and upon which the preserved findings are based. However, the difference between the parties’ positions on prospective risk at the hearing before us was stark. The appellant contended that there was no general sufficiency of protection for adult male VOTs in Albania, that any OCG would pose a risk to a person it had trafficked and the passage of time would make little or no difference. By contrast, the respondent contended there was a general sufficiency of protection, the risk from the traffickers was highest at the point of separation and diminished over time, the risk of re-trafficking was low and there was a comprehensive package of measures which aided support, if family support was not available. As will become clear, we have reached detailed findings on the country background evidence, which are not wholly along the lines submitted to us by either party. We refer at many points to the need for careful fact-finding in respect of such matters as an individual’s vulnerabilities and the motivation and interest of his traffickers in pursuing him. In this context, it appeared to us to be particularly unsatisfactory that we have no updated evidence about the current interest of the traffickers in pursuing this appellant or his current vulnerabilities.
17. For these reasons, we decided that it would be consistent with the overriding objective to hold a further hearing focussed upon this appellant’s position. We also considered the guidance in AEB v SSHD [2022] EWCA Civ 1512; [2023] 4 WLR 12, Begum (remaking or remittal) Bangladesh [2023] UKUT 46 (IAC); [2023] Imm AR 558 and Majera v SSHD [2025] EWCA Civ 1597. Given the limited scope of the issues which remain for decision in this appellant’s case, we saw no proper basis to remit the appeal to the First-tier Tribunal, and decided that the proper course was to remake the decision in this tribunal. We therefore provided the parties with our country guidance findings and directions on 4 June 2026, and then at a further hearing on 27 July 2026 we heard evidence from the appellant and submissions from both parties on the application of the country guidance findings to the appellant’s case. We reserved our decision, which we now provide with reasons.
18. We intend to describe and consider the parties’ submissions during the course of our analysis, issue by issue, and then when determining the appellant’s individual case, rather than attempting to provide a lengthy and inevitably incomplete summary at this stage. We note, however, that there was substantial agreement between the parties on the first three issues but less agreement on the remaining issues.
Legal framework
19. The parties were not entirely agreed on the law. For that reason, and because of the coming into force of NABA, it is necessary to set out the legal framework in some detail, and to resolve some of the disputes about it, before proceeding to apply that framework to the evidence.
General statutory framework
20. This appellant claimed asylum on 1 February 2022. It follows that NABA does not apply to this appeal. NABA applies only in relation to a claim for asylum made on or after 28 June 2022. However, this country guidance has been prepared for a wider audience than the appellant and will be predominantly applied to asylum claims made on or after 28 June 2022. We therefore address the legal framework for both pre-NABA claims and by reference to the relevant NABA provisions: s.32 (well-founded fear and standard of proof), s.34 (sufficiency of protection), s.35 (internal relocation) and s.33 (definition of a PSG).
Standard of proof
21. S.32 of NABA describes the approach to be taken when determining whether an asylum seeker's fear of persecution is well-founded, for the purposes of Article 1(A)(2) of the Refugee Convention, and provides as follows:

(1) In deciding for the purposes of Article 1(A)(2) of the Refugee Convention whether an asylum seeker's fear of persecution is well-founded, the following approach is to be taken.
(2) The decision-maker must first determine, on the balance of probabilities—
(a) whether the asylum seeker has a characteristic which could cause them to fear persecution for reasons of race, religion, nationality, membership of a particular social group or political opinion (or has such a characteristic attributed to them by an actor of persecution), and
(b) whether the asylum seeker does in fact fear such persecution in their country of nationality (or in a case where they do not have a nationality, the country of their former habitual residence) as a result of that characteristic.
(See also section 8 of the Asylum and Immigration (Treatment of Claimants, etc) Act 2004 (asylum claims etc: behaviour damaging to claimant's credibility).
(3) Subsection (4) applies if the decision-maker finds that—
(a) the asylum seeker has a characteristic mentioned in subsection (2)(a) (or has such a characteristic attributed to them), and
(b) the asylum seeker fears persecution as mentioned in subsection (2)(b).
(4) The decision-maker must determine whether there is a reasonable likelihood that, if the asylum seeker were returned to their country of nationality (or in a case where they do not have a nationality, the country of their former habitual residence)—
(a) they would be persecuted as a result of the characteristic mentioned in subsection (2)(a), and
(b) they would not be protected as mentioned in section 34.
(5) The determination under subsection (4) must also include a consideration of the matter mentioned in section 35 (internal relocation).
22. JCK (s.32 NABA 2022) Botswana [2024] UKUT 00100 encapsulates these into five questions. This is said to require first determining on the balance of probabilities whether:

(i) Taking the appellant’s claim at its highest, there is a convention reason?
(ii) The Appellant fears persecution for that convention reason?
And if so, then determining whether it is reasonably likely that:
(iii) The Appellant would be persecuted for that Convention reason;
(iv) There would not be sufficient protection available; and
(v) The Appellant could not internally relocate.
23. The parties did not invite us to depart from the approach in JCK. In this case potential complexities that might result from the JCK approach did not arise. As we have said, the appellant’s past has been accepted and those findings preserved. Our main focus is upon the assessment of prospective risk on return to Albania for accepted adult male VOTs. There can be no doubt that the reasonable degree of likelihood standard continues to apply in considering that question. S.32(4) states that “the decision-maker must determine whether there is a reasonable likelihood” that upon return the asylum seeker would be persecuted for a Convention reason and they would not be protected as mentioned in s.34, and the determination under s.32(4) must also include a consideration of internal relocation.
24. The application of the lower standard of proof has been explained by reference to a long line of authorities in MAH (Egypt) v SSHD [2023] EWCA Civ 216 at [49]-[56], including Karanakaran v SSHD [2000] 2 All ER 449. Mr Malik invited us to adopt the suggestion made by Singh LJ at [51] of MAH that it is not entirely accurate to refer to a standard of proof because an asylum applicant does not in fact have to prove anything and it could be more accurately described as an “assessment of risk”. Whilst we respectfully agree with Singh LJ’s observation in that paragraph, nothing he said suggested that it is not for the asylum seeker to show that he is at risk. His point was that this is a calculation which looks to the future, rather than a past matter which can be proven in the conventional sense. We note in any event that MAH was a pre-NABA case and the Court of Appeal did not have to grapple with NABA and the clear requirement to determine different aspects of the claim by different standards of proof. For NABA asylum claims, the relevant statutory wording should be applied. Whilst this has been described in some of the authorities in different ways, where the lower standard of proof applies, we prefer to use the language of s.32(4): “reasonable likelihood”. Neither party suggested that this should be interpreted any differently than it has been in pre-NABA claims, as summarised in MAH (Egypt), and we direct ourselves accordingly.
Sufficiency of protection
25. The pre-NABA law on sufficiency of protection is to be found in the Refugee or Person in Need of International Protection (Qualification) Regulations 2006 (‘the 2006 Regs’):

3. Actors of persecution or serious harm
In deciding whether a person is a refugee or a person eligible for humanitarian protection, persecution or serious harm can be committed by:
(a) the State;
(b) any party or organisation controlling the State or a substantial part of the territory of the State;
(c) any non-State actor if it can be demonstrated that the actors mentioned in paragraphs (a) and (b), including any international organisation, are unable or unwilling to provide protection against persecution or serious harm.
4. Actors of protection
(1) In deciding whether a person is a refugee or a person eligible for humanitarian protection, protection from persecution or serious harm can be provided by:
(a) the State; or
(b) any party or organisation, including any international organisation, controlling the State or a substantial part of the territory of the State.
(2) Protection shall be regarded as generally provided when the actors mentioned in paragraph (1)(a) and (b) take reasonable steps to prevent the persecution or suffering of serious harm by operating an effective legal system for the detection, prosecution and punishment of acts constituting persecution or serious harm, and the person mentioned in paragraph (1) has access to such protection.
(our emphasis)
26. The 2006 Regs were introduced in order to implement Council Directive 2004/83/EC of 29 April 2004 on minimum standards for the qualification and status of third country nationals (‘the Qualification Directive’) but that is no longer part of domestic law from 31 December 2020. Reg 4(2) adopted the same wording as Article 7 of the Qualification Directive, save that after “serious harm” (highlighted in bold above) the Qualification Directive includes the words “inter alia”, which are omitted from reg 4(2). As observed in NA and VA (protection: Article 7(2) Qualification Directive) India [2015] UKUT 00432 (IAC) at [13], any difference is slight, partly because “inter alia” lays emphasis on the word “generally”.
27. The test in reg 3 is replicated in s.31 of NABA:

For the purposes of Article 1(A)(2) of the Refugee Convention, persecution can be committed by…any of the following (referred to in this Part as “actors of persecution”)—
(a) the State,
(b) any party or organisation controlling the State or a substantial part of the territory of the State, or
(c) any non-State actor, if it can be demonstrated that the actors mentioned in paragraphs (a) and (b), including any international organisation, are unable or unwilling to provide reasonable protection against persecution.
28. The test in reg 4 is replicated in s.34 of NABA, which addresses protection from persecution as follows:

(1) For the purposes of Article 1(A)(2) of the Refugee Convention, protection from persecution can be provided by—
(a) the State, or
(b) any party or organisation, including any international organisation, controlling the State or a substantial part of the territory of the State.

(2) An asylum seeker is to be taken to be able to avail themselves of protection from persecution if—
(a) the State, party or organisation mentioned in subsection (1) takes reasonable steps to prevent the persecution by operating an effective legal system for the detection, prosecution and punishment of acts constituting persecution, and
(b) the asylum seeker is able to access the protection.
(our emphasis)
29. As set out above, s.32(4)(b) requires the decision maker to determine whether there is a reasonable likelihood that if the asylum seeker were to be returned “they would not be protected as mentioned in s.34”.
30. Domestic jurisprudence pre-dating the 2006 Regs addresses the issue of protection from non-State agent persecution in some depth. The majority of the House of Lords in Horvath v SSHD [2000] UKHL 37; [2001] 1 AC 489 made it clear that the standard of protection is “not that which would eliminate all risk”; rather it is “a practical standard”, Lord Hope at 500G-H. As Lord Clyde said at 510, absolutely guaranteed immunity would be beyond any realistic practical expectation. At 511A-B Lord Clyde quoted with approval the formulation of Stuart-Smith LJ in the Court of Appeal: “…there may be various sound reasons why criminals may not be brought to justice and that the corruption, sympathy or weakness of some individuals in the system of justice does not mean that the state is unwilling to afford protection”.
31. On behalf of the SSHD, Mr Hansen drew our attention to Lord Clyde’s observation at 516D: “…the sufficiency of state protection is not measured by the existence of a real risk of an abuse of rights but by the availability of a system for the protection of assistance and a reasonable willingness of the state to operate it”. Mr Malik submitted that merely having a system available would not constitute sufficient protection and relied upon the reasoning of the Court of Appeal in R (Bagdanavicius) v SSHD [2003] EWCA Civ 1605; [2004] 1 WLR 1207, wherein Auld LJ set out three important principles relevant to the approach to sufficiency of protection at [55](4)-(6). Mr Hansen did not in any way resile from the principled approach outlined in Bagdanavicius. Indeed, the SSHD’s skeleton describes Bagdanavicius as providing a “helpful distillation of the relevant principles on sufficiency of protection” and Mr Hansen expressly relied upon the three principles in his oral submissions.
32. The three Bagdanavicius principles directly relevant to sufficiency of protection are these:

(i) Sufficiency of protection means willingness and ability on the part of the state to provide through its legal system a reasonable level of protection from ill treatment of which the asylum claimant has a well-founded fear.
(ii) The effectiveness of the system is to be judged normally by its systemic ability to deter and /or to prevent the form of persecution of which there is a risk, not just punishment of it after the event.
(iii) Where there is systemic sufficiency of protection an asylum claimant may still have a well-founded fear of persecution “if he can show that the state know or ought to know of circumstances particular to his case giving rise to his fear but are unlikely to provide the additional protection his particular circumstances reasonably require”.
33. The House of Lords in Bagdanavicius v SSHD [2005] 2 WLR 1359 neither approved nor disapproved of those principles, albeit Lord Brown at [27] highlighted the need to take “reasonable measures to make the necessary protection available”. The Bagdanavicius principles set out by Auld LJ have nevertheless been consistently applied by this Tribunal, including in AW (sufficiency of protection) Pakistan [2011] UKUT 00031 (IAC) at [23]-[24] and TD & AD at [114]. Those principles have also been cited by the Court of Appeal with approval, in cases such as ZV (Lithuania) v SSHD [2021] EWCA Civ 1196 at [16]. We are satisfied that these principles remain relevant to our application of the pre-NABA and NABA tests. Neither party submitted otherwise.
34. The first Bagdanavicius principle is straightforward and can be found in the wording of the first limb of the respective tests in reg 4(2) and s.34(2)(a), i.e. the State is required to take “reasonable steps to prevent the persecution by operating an effective legal system for the detection, prosecution and punishment of acts constituting persecution”.
35. We note for completeness that in Noune v SSHD [2000] EWCA Civ 306 the Court of Appeal held that it would be an error of law for a decision-maker to interpret Horvath to mean that where the law enforcement agencies are doing their best and not being generally inefficient or incompetent this was enough to disqualify the potential victim from being a refugee – see Schiemann LJ at [28]. That being said, we note Mr Malik’s reliance on the reference to the margin of appreciation that should be afforded to States in NA and VA (supra) at [16] and [17] and Banomova v SSHD [2001] EWCA Civ 807 at [35]. However, in our view the guiding light must be the Horvath “practical standard”, which does not demand “best” or “gold-standard” practice. What is critical, as Auld LJ explained at [35] of R (Dhima) v IAT [2002] EWHC 80 (Admin); [2002] INLR 243, is:

… a combination of a willingness and ability to provide protection to the level that can reasonably be expected to obviate the real risk of serious harm from non-state agents. What is reasonable protection in any case depends therefore on the level of risk, without that protection for which it has to provide.
36. The second Bagdanavicius principle addresses matters beyond a strictly defined law enforcement system i.e. detection, investigation, prosecution and punishment. Where the protection sought is against re-trafficking on the part of non-State agents, the effectiveness of the system must also be assessed by its systemic ability to deter and / or to prevent re-trafficking or reprisals. With this in mind, the reintegration and support framework for VOTs alongside the law enforcement system must be considered. Whilst Mr Hansen emphasised the law enforcement approach to sufficiency of protection, he accepted that the reintegration and support provisions for VOTs remained relevant, and that reintegration support might be required before it can be said that the state is providing sufficient protection for Convention purposes. That approach is consistent with the approach adopted by both parties to the evidence and submissions: we heard detailed country expert evidence and lengthy submissions on the reintegration and support provisions for VOTs in Albania.
37. The third Bagdanavicius principle underlines that which is not in dispute - the question is not solely whether the authorities are able and willing to provide protection but also whether they are capable of providing protection to the particular individual. The SSHD laid emphasis on the third principle’s bearing on the important principle of surrogacy. Mr Hansen drew our attention to numerous references to the surrogacy principle in Horvath including Lord Hope’s observation at 495C that the Refugee Convention purpose “which is of paramount importance for a solution of the problems raised by the present case is that which is to be found in the principle of surrogacy”. As Simon Brown LJ later pointed out in Svazas v SSHD [2002] EWCA Civ 74, [2002] 1 WLR 1891 at [53] “The ultimate question in all cases is whether or not the asylum seeker can establish the need for surrogate protection by the international community for want of sufficient protection in his home state.”
38. Against that background, Mr Hansen submitted that if the State does not know that a person is a VOT “either because the individual has not been identified as such, or has not sought protection from the authorities”, then it will be difficult to demonstrate that the state “ought to know” the person is a VOT and may require additional protection due to particular circumstances. Mr Hansen also relied on the observation of Gloster LJ at [69] of MI (Pakistan) and MF (Venezuela) v SSHD [2014] EWCA Civ 826, that it was important that MI never sought protection. This is because it was not in dispute that there was a general sufficiency of protection and MI’s case turned on his particular circumstances in accordance with the third Bagdanavicius principle. In response it was submitted on behalf of the appellant that sufficiency of protection can be measured by the number of those who seek it. We address the role identification plays below.
39. The wording of reg 4(2) and s.34(2)(b) clearly requires the asylum seeker to be able to “access protection”. This demands a careful consideration of the particular circumstances of the individual and any additional protection their “particular circumstances reasonably require”. The particular circumstances will include factors that heighten risk and the fact that a returned VOT has already been the subject of past trafficking and in some cases past persecution (although not necessarily in Albania). Past serious harm or persecution in Albania is a relevant factor when considering whether particular circumstances give rise to the need for additional protection – see AW (sufficiency of protection) at [37]. We address the factors that heighten the risk for adult male VOTs returned to Albania later on in this decision.
40. It was submitted on behalf of the appellant that corruption is a relevant factor undermining access to state protection in Albania. The mere existence of corruption does not mean that the state is unwilling or unable to provide sufficient protection. Where there is evidence of corruption, this requires specific factual and contextual evaluation to determine whether its presence undermines the system in place and the ability to offer reasonable protection generally and to the particular individual. This is because there is a spectrum of corruption in States, different in nature, level, extent and ability / willingness to address it. This must be considered alongside the nature and degree of risk of serious harm by non-state actors. There are examples which go in different directions, each turning on the evaluation of the underlying evidence. In AZ (Trafficked women) (Thailand) [2010] UKUT 118 the Tribunal concluded there was insufficient state protection for AZ and women in her situation [161] because of the prevalence of unpunished corruption in Thailand. This can be contrasted with HD (Trafficked women) Nigeria CG [2016] UKUT 00454 (IAC), wherein the Tribunal concluded that despite corruption being a pervasive problem at all levels of the government in Nigeria, this did not mean that VOTs are at risk of being re-trafficked, absent specific risk factors. In BF (Tirana) (gay men) Albania (CG) [2019] UKUT 0093 (IAC) the Tribunal noted the corruption in Albania but concluded that there was an effective system of protection should an openly gay man face a risk of harm.
41. Both parties drew our attention to AD v Sweden app. No. 22283/21; [2024] Imm AR 1024 (7 August 2024), which considered the issue of corruption in Albania. The ECtHR noted the reports of continuing problems relating to corruption and influence from criminal organisations and concluded that corruption continued to be a widespread problem in Albania and that further efforts were needed to address this [69]. The Court also surveyed recent reports outlining the positive steps taken by Albania to improve the capability and integrity of law enforcement authorities at [70] before reaching this conclusion at [71]:

In the light of these reports, which post-date the decisions in the domestic proceedings, the court considers that the Albanian authorities’ capacity to protect their people cannot be regarded as insufficient for the general public in Albania nor can it be regarded as generally insufficient for all persons who are targeted by criminal organisations…
42. We agree with Mr Malik’s submission that AD v Sweden does not establish a new point of law or principle. He urged us to attach limited weight to the factual conclusions because the Court did not have the benefit of the extensive country background including expert evidence, that is available to us. Mr Hansen submitted that the decision was “a seminal decision in the field” and that it was of “widespread application” or a direct “read across”. We are satisfied that it is appropriate to attach weight to the factual conclusions reached by the ECtHR, albeit they are not binding and we consider that Mr Hansen went too far in describing AD v Sweden as he did. We consider the ECtHR’s factual conclusions below, alongside all the detailed and extensive evidence available to us.
43. BF (Tirana) makes it clear at [41] that whilst NGOs cannot be said to be actors of protection, it is permissible to take into account their role as advocates and watchdogs on behalf of the gay community. As we shall go on to outline, in Albania the government provides NGOs with the funding to play a much wider role in supporting VOTs, including identification, assessment of need, housing, support services and reintegration. These services are funded by the State and both parties confirmed that in those circumstances no issues of concern regarding the role played by civil society actors / NGOs, as identified by the CJEU in SSHD v OA Case C-255/19; [2021] Imm AR 775, arise in this case.
Internal relocation
44. Pre-NABA, the relevant provisions as to internal relocation were set out at paragraph 339O of the immigration rules. The relevant paragraphs were as follows at the date the appellant claimed asylum:

(i) The Secretary of State will not make:
(a) a grant of refugee status if in part of the country of origin a person would not have a well-founded fear of being persecuted, and the person can reasonably be expected to stay in that part of the country; or
(b) a grant of humanitarian protection if in part of the country of return a person would not face a real risk of suffering serious harm, and the person can reasonably be expected to stay in that part of the country.
(ii) In examining whether a part of the country of origin or country of return meets the requirements in (i) the Secretary of State, when making a decision on whether to grant asylum or humanitarian protection, will have regard to the general circumstances prevailing in that part of the country and to the personal circumstances of the person.
(iii) (i) applies notwithstanding technical obstacles to return to the country of origin or country of return.
45. So far as humanitarian protection is concerned, the Immigration Rules make virtually identical provision in respect of internal relocation post-NABA.
46. In respect of refugee status, s.35 of NABA provides:

(1) An asylum seeker is not to be taken to be a refugee for the purposes of Article 1(A)(2) of the Refugee Convention if—
(a) they would not have a well-founded fear of being persecuted in a part of their country of nationality (or in a case where they do not have a nationality, the country of their former habitual residence), and
(b) they can reasonably be expected to travel to and remain in that part of the country.
(2) In considering whether an asylum seeker can reasonably be expected to travel to and remain in a part of a country, a decision-maker—
(a) must have regard to—
(i) the general circumstances prevailing in that part of the country, and
(ii) the personal circumstances of the asylum seeker;
(b) must disregard any technical obstacles relating to travel to that part of that country.
47. It is important not to conflate the question of whether the proposed place of relocation is safe for the asylum seeker (in the sense that the person would not have a well-founded fear of persecution there) with whether it is reasonable for the asylum seeker to stay there. The reasonableness analysis only arises if there is no well-founded fear of persecution in the place of proposed relocation.
48. So far as the safety analysis is concerned, the burden is on the appellant in the usual way to the reasonable likelihood standard - see s.32(4) and (5) of NABA. The Court of Appeal in Aziz v SSHD [2003] EWCA Civ 118 directly considered the contention that if an applicant could show a real risk of torture in his home area, the burden then switched to the respondent and firmly rejected it.
49. So far as the reasonableness analysis is concerned, the appropriate approach is set out in Januzi v SSHD [2006] UKHL 5, [2006] 2 AC 416, AH (Sudan) v SSHD [2007] UKHL 49, [2008] 1 AC 678 and SC (Jamaica) v SSHD [2022] UKSC 15; [2022] 1 WLR 3190 (although that case concerned internal relocation in the context of Article 3 ECHR, rather than in the context of the Refugee Convention, the respondent conceded that the same test applied). In Januzi Lord Bingham gave guidance on the proper approach at [21] as follows: “the decision-maker, taking account of all relevant circumstances pertaining to the claimant and his country of origin, must decide whether it is reasonable to expect the claimant to relocate or whether it would be unduly harsh to expect him to do so…there is…a spectrum of cases. The decision-maker must do his best to decide, on such material as is available, where on the spectrum the particular case falls … All must depend on a fair assessment of the relevant facts.” It is clear from Januzi that whether the individual can “reasonably be expected to stay”(pre-NABA) or “travel to and remain” (post-NABA) is to be assessed by the standards generally prevailing in the country of nationality, rather than in the place of asylum.
50. The relevant authorities were recently reviewed by the Court of Appeal in ASJ (Somalia) v SSHD [2025] EWCA Civ 282. Lewis LJ said this at [28]:

There is a danger of overanalysing and over-refining the relevant test. As Lord Bingham observed in relation to questions of internal relocation in AH (Sudan) at paragraph 5, “the difficulty lies in applying the test, not in expressing it”. The decision-maker must decide whether it would be unduly harsh, and so unreasonable, to expect the person claiming protection to relocate internally within his country of origin. In answering that question, the decision-maker must have regard to all the relevant circumstances of the person claiming protection and his country of origin as explained in Januzi and AH (Sudan), see the quotations set out at paragraphs 11 and 12 above. That has been described as a “holistic assessment, encompassing all relevant considerations” (see per Underhill LJ in AS (Afghanistan) v Secretary of State for the Home Department [2019] EWCA Civ 873, [2019] 1 WLR 5345 at paragraph 68). Having considered all the circumstances, it must decide whether it would be unduly harsh, and so unreasonable, for the person to relocate internally within his country of origin.
51. Lewis LJ went on to express the following obiter conclusion at [41]:

…as a matter of principle, consideration of internal relocation is an aspect of whether a person can establish that any fear of persecution is well-founded within Article 1A of the Refugee Convention (see the observations of Lord Bingham at paragraph 7 of his judgment in Januzi). If that is correct, then, strictly, the burden is on the appellant to show to a reasonable degree of likelihood that internal relocation would be unduly harsh and so unreasonable. In practice, however, decisions of internal relocation are unlikely to be determined or influenced by considerations of the burden of proof. The appropriate approach is that set out in Januzi, AH (Sudan), and SC (Jamaica). The question the decision-maker has to decide is whether it would be unduly harsh, and so unreasonable, for a person to relocate internally within his country of origin. That will involve the decision-maker considering all the relevant circumstances. In the light of the view that the decision-maker forms of the circumstances, the decision-maker will then decide whether internal relocation is unduly harsh, bearing in mind that that is a high threshold to cross.
52. It is against this background that we approach the parties’ submissions on the burden of proof concerning the reasonableness analysis. Mr Hansen submitted, that as was decided in MB (internal relocation – burden of proof) Albania [2019] UKUT 00392 (IAC), the burden of proof was on the appellant to prove why internal relocation within Albania would be unreasonable or unduly harsh, but within that burden the evaluation exercise should be holistic. Mr Malik submitted that following Karanakaran, no question of the burden or standard of proof arose; it was simply a holistic assessment. He referred us to the very last paragraph of Sedley LJ’s judgment, in which he said this:

It follows that on the critical issue of internal relocation in the present case, no question of the burden or standard of proof arises. The question is simply whether, taking all relevant matters into account, it would be unduly harsh to return the appellant to Colombo.
53. Mr Malik submitted that the relevant paragraph of Karanakaran was not brought to the attention of the Upper Tribunal in MB. In fact the Upper Tribunal did direct themselves to it at [23] (albeit within a quotation from the Court of Appeal in SC (Jamaica)). Moreover the Court of Appeal in Aziz, having referenced Karanakaran, concluded at [25] that the burden was on an appellant to establish that it would be unduly harsh to relocate.
54. We respectfully agree with the obiter conclusion of the Court of Appeal in ASJ at [41]. The burden is on the appellant to show to a reasonable degree of likelihood that internal relocation would be unduly harsh and so unreasonable. In practice, however, decisions of internal relocation are unlikely to be determined or influenced by considerations of the burden of proof, and will involve considering all the relevant circumstances. Focussing on the burden of proof or the standard of proof may lead the decision maker to fail to evaluate the circumstances as a whole by becoming overly concerned about whether they are sure of certain of particular circumstances within the overall assessment. If a holistic assessment is conducted properly then the answer will usually be apparent from the outcome of that assessment – relocation either will or will not be unduly harsh. No doubt this is why the Upper Tribunal in MB at [25] said that an overemphasis on the overall burden of proof can be a distraction from the holistic assessment and the Court of Appeal said in ASJ that decisions of internal relocation were unlikely to be determined or influenced by considerations of the burden of proof.
Particular Social Group
55. The relevant pre-NABA position is set out in Article 10 of the Qualification Directive and reg 6(1)(d) of the 2006 Regs, which state:

a group shall be considered to form a particular social group where in particular:
- members of that group share an innate characteristic, or a common background that cannot be changed, or share a characteristic or belief that is so fundamental to identity or conscience that a person should not be forced to renounce it, and
- that group has a distinct identity in the relevant country, because it is perceived as being different by the surrounding society.
56. The respondent maintains that both limbs of that test must be made out and that Upper Tribunal decisions such as DH (Particular Social Group: Mental Health) Afghanistan [2020] UKUT 233 (IAC) are wrong insofar as they suggest to the contrary. Mr Hansen made five main points:

(i) The conjunctive test fits with the language of the Qualification Directive and the 2006 Regs namely the use of the word “and”;
(ii) The CJEU has consistently interpreted the two conditions as cumulative rather than alternative. WS v Intervyuirasht organ na Darzhavna agentsia za bezhantsite pri Ministerskia savet (Case C-621/21) [2024] 4 WLR 67 was a recent example of this line of jurisprudence, see [40] regarding the need to satisfy “two cumulative conditions”;
(iii) The observations relied on in Fornah v SSHD [2007] 1 AC 412 were obiter;
(iv) As discussed in AZ at [134] referring to the lengthy discussion in SB (PSG – Protection Regulations – Reg 6) Moldova CG [2008] UKAIT 00002, the context of the society in question was important; and
(v) Shah and Islam v SSHD [1999] 2 AC 629 lays emphasis on the PSG being defined by discrimination, which according to Mr Hansen could only be the case if the conjunctive test were applied.
57. We reject those submissions and consider that the definition of a PSG in the 2006 Regs is to be read disjunctively, in line with the approach in EMAP (Gang violence – Convention Reason) El Salvador CG [2022] UKUT 00335.
58. Article 10 is a minimum standard and it is open to States to take a more generous approach, reading the two requirements disjunctively, so that the “and” at the end of the first part of Article 10 (1) (d) should be read as “or”. The rationale for such an approach is set out fully in DH at [46]-[75], and is supported by the obiter dicta of four members of the Appellate Committee in Fornah, who concluded that the proposition that both elements must be satisfied is inconsistent with international authority. The panel in EMAP at [106]-[111] explained why, despite the fact that their Lordships’ opinions in Fornah were obiter, they were highly persuasive. In short as the panel noted at [106], the observations in Fornah were:

…. made in the context of an appeal which was wholly concerned with the definition of ‘particular social group’, and in which their Lordships were referred to all of the relevant international authorities. UNHCR was an intervener in the case, and as Lord Bingham notes, their opinion in favour of a disjunctive reading amounted to a “very helpful distillation” of the effect of those authorities…
59. We acknowledge that the recent case-law of the CJEU continues to interpret the relevant clause in the Qualification Directive conjunctively, but we have not been referred to any case in which the CJEU considered the definition in the light of international jurisprudence. It follows that for some groups there will be no need to consider evidence relating to the specific society in question, when considering whether a person is a member of a PSG, a clear example being membership of a family. The emphasis in Shah and Islam was indeed that women in Pakistan were a PSG because they suffered discrimination, but that does not mean that every group (for example, a family group) must be defined by discrimination to be a PSG.
60. S.33(2) of NABA clearly requires the application of a conjunctive test (our emphasis):

(2) A group forms a particular social group for the purposes of Article 1(A)(2) of the Refugee Convention only if it meets both of the following conditions.
(3) The first condition is that members of the group share-
(a) an innate characteristic,
(b) a common background that cannot be changed, or
(c) a characteristic or belief that is so fundamental to identity or conscience that a person should not be forced to renounce it.
(4) The second condition is that the group has a distinct identity in the relevant country because it is perceived as being different by the surrounding society.
61. When considering this subsection, it should be noted that society as a whole does not have to recognise the common background of the group because ss.(4) simply requires the group to be perceived as different. The definition of a PSG does not require the group to have a common background (for example), be perceived as different by society and, separately, be perceived as having a distinct identity. Neither does the subsection require that the group is perceived as being different because it has a distinct identity. Some groups may have a very obvious distinct identity which everyone recognises, but a group may be stigmatised or discriminated against without their distinct identity being recognised by society as a whole.
62. In Bundesamt fur Fremdenwesen und Asyl v AN C-217/23, whilst finding that a member of a family at risk of blood feud was not a member of a PSG, the CJEU explained that the group is perceived as being different by the surrounding society because of the social, moral or legal norms prevailing in the country of origin. Proof of perception of a group as different at the level of surrounding society may be provided from specific evidence which could include even general stigmatisation affecting members of the group in question and having the effect of marginalising them from the surrounding society [37].
63. In EAV v SSHD [2025] EWCA Civ 1677 the Court of Appeal emphasised that a causal link had to be established between the membership of a PSG and the risk of being re-trafficked. EAV was a female national of the Philippines. A conclusive grounds decision had been made in her favour that she had been trafficked for the purposes of domestic servitude from the Philippines to Saudi Arabia and from there to the UK. EAV claimed that on return to the Philippines she would be driven by economic necessity to seek employment in the Middle East and would therefore be at risk of being re-trafficked. The Court of Appeal found that what would drive EAV’s behaviour on return would be economic pressure, rather than her membership of a PSG. Her status as a former victim of trafficking was not a reason why she was at risk of being exploited were she to seek to work abroad again. The First-tier Tribunal judge who had allowed EAV’s asylum appeal had failed to identify what it was about EAV’s personal circumstances which made her different from any other impoverished person in the Philippines who was driven by economic need to seek employment abroad. There was no finding by the First-tier Tribunal Judge that EAV was any more vulnerable to exploitation than any other impoverished female in the Philippines because she had been exploited in the past.
64. In K v SSHD [2006] UKHL 46; [2007] 1 AC 412 at [17] and [18], Lord Bingham reiterated rejection of the ‘but for’ test in Shah and Islam v SSHD [1999] 2 AC 629, and held that it is enough that the Convention ground relied on is an effective reason. It is important to recall that persecutory conduct may have more than one motive. So long as one motive is a Convention reason, the causation requirement is satisfied. It is therefore not necessary that the Convention ground of being a member of a PSG is the sole reason for the fear. That approach is consistent with s.32(4), which sets out the causation requirement - would they be persecuted as a result of the PSG characteristic?
Background material
65. The focus of the submissions made on both sides was on the extensive written and oral evidence which we received from the four expert witnesses identified above. We will turn to their evidence shortly. Before we do so, however, we make reference to some of the background material which is included in the core bundle in order to provide some context. We do not intend to detail all the evidence here, and what follows is merely an outline of the reports prepared by relevant actors in recent years. A full list of all the reports considered is contained in the annexe to this decision.
66. We note that there is a Country Information and Policy Note entitled Human Trafficking and dated July 2024 (‘the CPIN’). Amongst other sources, the CPIN draws on the Home Office’s Report of a Fact-Finding Mission to Albania: Human Trafficking, dated December 2022 (‘the FFM report’).
67. The United Nations High Commissioner for Refugees (‘UNHCR’) published its Guidance Note on Albania in February this year (‘the 2026 UNHCR Guidance’). This is designed to provide a high-level overview of the protection needs of asylum seekers from Albania and is not specifically directed to trafficking-related claims. It describes organised crime, including the trafficking in human beings as a “serious issue” in Albania. At [15], the 2026 UNHCR Guidance lists seven categories of individuals who might be in need of international protection. The second category and associated commentary is in these terms:

Survivors of trafficking and persons at risk of being (re-)trafficked: Human trafficking is a serious problem in Albania, with 700 victims identified between 2020 and 2024. From a gender perspective, women and girls make up the majority of victims and are trafficked for purposes of sexual exploitation; by age, 67 per cent of those trafficked are children (girls and boys), with boys often forced into begging or criminality. Those living in poverty or belonging to marginalized groups are at heightened risk, including Roma and Egyptians, individuals of diverse SOGIE [Sexual Orientation, Gender Identity and Expression], people with disabilities, and Albanian returnees, as well as refugees and migrants. Since the Council of Europe’s first evaluation in 2011, “significant gaps remain in the effective investigation, prosecution and punishment of trafficking cases,” and the number of convictions are low. Formerly trafficked individuals experience community-level stigma and social exclusion during their reintegration processes, particularly survivors of sex trafficking. Both authorities and service providers have documented cases of trafficking survivors being subjected to re-trafficking.
68. The Council of Europe’s Group of Experts on Action against Trafficking in Human Beings (‘GRETA’) has produced four reports on Albania in accordance with Article 38 of the Convention on Action against Trafficking in Human Beings (‘the Trafficking Convention’). The fourth and most recent report was published on 18 June 2025 and covers the period from October 2020 to March 2025. That report focussed on “vulnerabilities to human trafficking and measures taken by States Parties to prevent them, detect and support vulnerable victims, and punish the offenders” and on “the use of information and communication technology (ICT) to commit human trafficking offences”. Appended to Ms Trimi’s report, we also have the Albanian government’s responses to GRETA.
69. There is also background material before us from the United Nations Children Fund (‘UNICEF’). Three of those reports bear the name of one of the experts before us, Dr Davy. The first, published with the UK Government and IDRA Research and Consulting in December 2020, was a First wave survey study on youth knowledge, attitudes and practices with regard to human trafficking, in four regions in Albania. The second, entitled Trafficked by Someone I Know, was published in May 2022. The third, entitled Economic reintegration of trafficking survivors in Albania, was published by UNICEF and IDRA in July 2022.
70. Amongst the other material before us are reports from the Organisation for Security and Cooperation in Europe (‘OSCE’), the United Nations Office on Drugs and Crime (‘UNODC’) and NGOs including Freedom House. We note also that we have three reports prepared by Garden Court Chambers, including Albania: Is It Really a Safe Country for the Purposes of Certification and Trafficking (2024) and Organised Crime in Albania (2025).
71. The United States Department of State has published its annual Trafficking in Persons (’TIP’) report since 2001. TIP reports have been cited in every country guidance decision on trafficking and the reports are generally viewed as providing a balanced and up-to-date analysis of anti-trafficking efforts in the 188 countries and territories covered. Each of the expert witnesses before us made reference to the TIP reports for Albania in their written and oral evidence and neither side sought to suggest before us that it provided anything other than a useful overview of the current situation in Albania.
72. The TIP reports categorise countries into four tiers. The 33 countries in Tier 1 are deemed by the US Department of State to meet the minimum standards set out in the Trafficking Victims Protection Act (‘TVPA’) for the elimination of trafficking. The 106 countries in Tier 2 are deemed not to meet the TVPA standards fully but to be making significant efforts to do so. There is also a Tier 2 “watchlist” of 25 countries which do not meet the standards and are making significant efforts to do so but where significant concerns nevertheless arise. The 20 countries in Tier 3 are deemed not to meet the TVPA standards and not to be making significant efforts to do so.
73. Albania, in common with Norway and Switzerland, is placed in Tier 2. It has been a Tier 2 country for many years, although it was placed on the watchlist in 2008: AM & BM refers, at [117]. The executive summary of the 2025 report is as follows:

The Government of Albania does not fully meet the minimum standards for the elimination of trafficking but is making significant efforts to do so. The government demonstrated overall increasing efforts compared with the previous reporting period; therefore, Albania remained on Tier 2. These efforts included investigating significantly more trafficking cases and convicting traffickers for the first time since 2021. The government identified more victims, increased funding for the government-run shelter and NGO-run shelters, and provided legal assistance to significantly more victims compared with the previous reporting period. The government adopted and funded the 2024-2025 NAP and regularly sought the input of survivors in its anti-trafficking efforts. However, the government did not meet the minimum standards in several key areas. Local police and district prosecutors did not have the specialized experience and capacity to investigate and prosecute trafficking cases and pursued cases as crimes with lesser penalties, such as “exploitation of prostitution.” The government did not provide adequate personnel or financial resources to the NGO-managed mobile victim identification units (MIU), despite identifying most of the victims every year. Authorities inappropriately charged victims of sex trafficking with commercial sex offenses committed solely as a direct result of being trafficked. Similarly, due to inadequate implementation of victim identification SOPs among women in commercial sex, migrants, and asylum-seekers, the government did not take effective measures to prevent the inappropriate penalization of potential victims solely for unlawful acts committed as a direct result of being trafficked. The government lacked resources to provide victims with long-term services, and the national coordinator and the Office of the National Anti-Trafficking Coordinator (ONAC) rarely convened coordinating meetings for the NRM and Responsible Authority.
74. As will be apparent from that short summary, the TIP report is relatively high level and does not attempt to distinguish throughout between the situation of male and female VOTs. That is a difficulty which we have encountered throughout our consideration of this case. There is a lack of solid data in a number of important respects and where data does exist it is often not disaggregated so as to distinguish between male and female VOTs. One example will serve at this point to illustrate the difficulty. The respondent submitted before us that the risk of re-trafficking in any given case is only between 2-5%. We will examine that submission in detail below; for the moment, we need only refer to the statistic upon which it was based. In an interview cited in the FFM report in 2022, an NGO stated that of the 117 VOTs they had assisted in the preceding two years, six were re-trafficked: four men and two women. But those figures are meaningless when one attempts to calculate the percentage of male VOTs who were re-trafficked in the period in question. As Mr Erdunast observed in his closing submissions, the denominator is unknown. If the NGO assisted four men during the relevant period, then 100% of the men were re-trafficked. If, at the other extreme, the NGO assisted 115 men, then under 4% were re-trafficked. We simply cannot know.
75. It is for that reason that the parties and the experts devoted considerable time to considering the specific situation of male VOTs. Whilst we are grateful to them for those efforts, the fact remains that much of the background material to which we have been directed is not disaggregated in the way that we have described above. Amongst the material which gives detailed consideration to the position of male VOTs, however, there was one report which was cited extensively by the experts and the respondent’s CPIN: the Asylos Report on Trafficking from April 2024, which sought to expand upon their 2019 report entitled Albania: Trafficked Boys and Young Men.
76. Asylos research on Afghanistan was before the Upper Tribunal in AS (safety of Kabul) Afghanistan CG [2018] UKUT 118 (IAC) and its research has been relied upon by the European Union Agency for Asylum (formerly the European Asylum Support Office). The 2019 and 2024 reports were evidently the subject of considerable research, which included interviews with interlocutors including Dr Schwandner-Sievers, Professor of Applied Anthropology at Bournemouth University, whose evidence was accepted without significant demur in AM & BM. The Asylos reports are also cited extensively in the respondent’s July 2024 CPIN on human trafficking in Albania. In common with the parties, therefore, we consider that the 2019 and 2024 reports provide helpful background evidence on the situation of male VOTs in Albania, and we note the following aspects of those reports by way of introduction to our consideration of the detailed and voluminous expert evidence. Whilst the summaries are lengthy, we should note that the two reports are 319 pages and 239 pages respectively, and what follows is intended to capture the essential conclusions in each.
77. The 2019 report noted that although Albania was a key country of origin for VOTs, there was very little literature or research on the trafficking of young men or boys. Interlocutors broadly agreed that the same factors applied to males and females when considering whether they were at risk of trafficking. The report highlighted the increased susceptibility of ethnic minorities and the Roma and Egyptian communities in particular. Those on the ground had emphasised the role played by violence, dysfunctional family environments and homelessness in exposing young males to a risk of trafficking. Other relevant risk factors included place of origin; youth; a lower level of education; and the presence of mental or physical disabilities. There was some support for the view that LGBT individuals were at greater risk. It was necessary to consider the intersecting vulnerabilities in order to reach a considered view.
78. Asylos considered that males might be trafficked by criminal networks or by family members, acting alone or in concert. Interlocutors made reference to criminal exploitation by gangs involved in the supply of drugs, including “county lines” operations, and cannabis cultivation. The gangs were noted to target the most vulnerable males, often in rural areas, including those who were in need of money to support themselves and family members. A variety of recruitment methods were known to be used; children were provided with housing or money to buy food, whereas adult males were targeted for exploitation after seeking help to migrate to seek legitimate work. There was some reference to kidnapping as a means of recruitment. Other sources referred to traffickers using social media and posing as travel agents for those who did not consider themselves to have a future in Albania. Some spoke about the complicity of family members in the process of trafficking. Extreme violence was sometimes used in order to break the victim and to make them compliant with the traffickers’ demands. Those who were trafficked to the UK were often put to work in drug supply, cannabis production and car washes.
79. Asylos considered the effectiveness of the Albanian legal framework as it stood in 2019, noting that the framework for combating trafficking had been further developed and that sanctions had been made harsher, but that further effort and legislation was required. There remained an implementation gap between the strong legislative and policy framework and the practice in reality. The identification of VOTs and a weak system for the protection of children were identified, amongst other problems. The report also noted that victims continued to be punished judicially for acts committed as a result of being trafficked. The conviction rate for trafficking offences remained low but some measures had been taken to ensure effective investigation of such offences. The reasons for the perceived implementation gap were said to include a lack of adequate training in law enforcement personnel; reluctance on the part of victims; and a lack of familiarity with the “new concept” that men and boys could be trafficked. Concerns about the suitability of prosecutors and the lack of effective witness protection continued, and corruption amongst the police and the judiciary was noted to be a barrier to implementing legislation. Despite investment and training, corruption was thought to lead to a culture in which boys and young men believed that they could not rely on access to state support as a victim of trafficking.
80. The framework for the protection of victims, including the National Referral Mechanism (‘NRM’), was considered to be good but there were said to be problems concerning the protection of unaccompanied children, including the fact that only one shelter provided protection and integration services for children. Only four individuals returned from abroad had been identified as VOTs. The Standard Operating Procedures (‘SOP’) were well established and were under review in light of stakeholder comments. The failure to identify young men as VOTs was thought to be attributable to social norms on vulnerability, a focus on female victims and a misunderstanding of forced labour. Despite that, there had been an increase in the number of trafficked males identified as such. There remained a gap between the number of Albanian nationals referred to the NRM in the UK and the number of people accessing support services for trafficked persons in Albania. Dr Schwandner-Sievers was quoted as remarking on the absence of accurate figures, with government agencies wishing to minimise the scale of the problem and NGOs who “really wanted the problem to be a problem” so as to ensure their continued funding. A number of sources commented that there were cultural difficulties over the identification of male VOTs, not least of which was a common reluctance on the part of the victim to self-identify as such as a result of cultural norms and low trust in the authorities.
81. The report detailed the steps that had been taken to prevent trafficking, including various awareness raising programmes in the community, particularly during October, which is anti-trafficking month in Albania. There was, however, a lack of preventative measures specifically targeted at boys or young men, and the Albanian authorities were said to consider the issue to be one of irregular migration rather than human trafficking. Whilst Albania had dedicated child protection units, they were subject to various limitations including a lack of a clear structure; the Albanian concept of masculinity and the preparedness of young males to seek support; and the absence of adequate residential care and funding.
82. Section 8 of the Asylos report concerned shelters and reintegration programmes for trafficked boys and young men. It detailed the shelter provision for women and children before noting that GRETA had observed in 2016 that there were no shelters available for male VOTs, who were instead rented accommodation by an NGO called Different & Equal. 18 male victims received such assistance from that NGO in 2014. GRETA recommended that the number of places available in shelters should be increased “to cater for the rise in identified victims, including male victims.” The GRETA report also noted that VOTs received a limited amount of public funds after they left a shelter, although they were notably reluctant to do so due to the stigma attached to victims. There had been improvements, however, in enabling victims to receive access to free healthcare. A report by Different & Equal indicated that it had assisted 17 male trafficking victims in 2017, which included counselling and vocational support in addition to payments for rented accommodation. A source had suggested that the services available to males were the same (but for the shelters) as those available to females, and that they could be provided across the country. There were psychologists, case managers, lawyers and teachers involved. Whether those services were available was necessarily contingent upon the identification of a victim as such, and some interlocutors reported disbelief on the part of the Albanian authorities that men and boys had been trafficked. The report considered the security arrangements for males who were placed in rented apartments, noting that security concerns would be addressed to the police. Dr Schwandner-Sievers expressed the view (as she did in AM & BM) that a returnee could not live anonymously in Albania because people there attempted to “situate you socially”. She opined that a person who was relocated to a rented flat in a city without pre-existing social contacts would be “very conspicuous and attract attention and suspicion”.
83. The GRETA report noted that children under the age of 16 could be accommodated in a shelter run by the NGO called Tjeter Vizion (‘Another Vision’) in Elbasan, but that the preferred approach was to return the victim to their family. The service was provided for girls and boys, and there were 34 spaces available. Capacity was an issue, and those who sought shelter after the centre was full would be referred to an orphanage. After attaining their majority, males would be supported in rented apartments in the city in which they decided to live. The report noted a number of difficulties to reintegration, with information provided by Different & Equal and others suggesting that VOTs often faced stigma when identified as such, and that finding permanent employment was difficult, particularly outside Tirana.
84. Section 9.2 concerned the risk of re-trafficking and began by noting that there was limited information on its prevalence. That which had been located “only relates to the situation for women and girls”. Different & Equal had suggested that maybe 4-5% of female service users had been re-trafficked. A lack of family support exposed victims to a risk of severe poverty, which in turn exacerbated the risk of re-trafficking. Despite the absence of data, other sources had expressed concern about the risk of re-trafficking for men and boys. One interlocutor expressed concern about the reach of organised crime and its direct links to the police. Dr Schwander-Sievers opined that the risk of re-trafficking would be “extremely high”. She noted that level of risk was “an economic thing … a class thing”. Other sources spoke about the beneficial effect of proper support on the risk of re-trafficking.
85. The 2024 Asylos report draws on research conducted between March 2021 and December 2023. It had consulted a range of interlocutors, including Dr Schwandner-Sievers, NGOs providing shelter and reintegration services in Albania, and those who had received services from two of the NGOs: Vatra Psycho-Social Centre (‘Vatra’) and Different & Equal. The report also drew upon reports published by UNICEF, two out of three of which were written by Dr Davy.
86. The 2024 Asylos report noted that there was limited statistical data on the full phenomenon of trafficking in Albania, and that the statistics which were available related to those who had been formally identified as VOT and those who had received services as such. The TIP report for 2023 stated that there had been 110 potential victims and two official victims identified by the government and NGOs: 32 women, 4 men, 48 girls and 26 boys. 27% of assisted cases were boys or men. A high proportion were Roma or Egyptian but Albanians were increasingly identified. Those with disabilities were increasingly vulnerable to trafficking. Whilst one source had said that trafficking in males was very widespread, the General Directorate of State Police had identified no male victims in 2021. Sex trafficking (of both genders) was more common than forced labour. Of the 35 potential labour trafficking victims identified in 2022-2023, 26 related to forced begging. 14 of the 110 individuals had been forced into criminality.
87. At page 15 of the summary report, Asylos provided a list of 15 factors associated with the risk of trafficking. We will not reproduce that list here, but we will return to it in considering our answer to the second issue before us. Drawing extensively on Dr Davy’s 2022 report entitled Trafficked by Someone I Know, Asylos concluded that traffickers were often associated with organised crime. Family members played a varied role. Financial gain was the main motivating factor and false promises and deception related to job opportunities and relationship were a common recruitment tactic. Once in an exploitative situation, the need to maintain the family often prevented children from escaping. Debt bondage, amongst other methods of control, was noted to be a phenomenon. Traffickers had increasingly turned to online methods to target individuals.
88. As in 2019, Asylos noted that Albanian men who had been trafficked were often reluctant to seek assistance as a result of stigma rooted in the patriarchal nature of Albanian society. It was said that they might not recognise themselves as a VOT when they had been subjected to forced labour, which was not a well-recognised form of trafficking in Albanian society. Concern had been expressed by one interlocutor about the stigma which trafficked men and boys might encounter on the part of professional networks, state authorities and their own communities.
89. At 2.1, the 2024 Asylos report set out the international treaties on human trafficking which Albania had ratified. It then noted that there was no distinct or unified domestic law against trafficking, and that there was an initiative underway to draw up such a piece of legislation. The legislative framework did however cover all forms of trafficking and the SOP had been adopted by a Decision of the Council of Ministers in 2018. There was a specific offence of child trafficking. Various bodies, including an Anti-Trafficking Task Force, had been brought into existence to counter trafficking and monitor the effectiveness of the NRM. There were Regional Anti-Trafficking Committees, which were responsible for trafficking prevention activities. Other state prevention efforts cited included government training delivered in cooperation with NGOs and international organisations, to police officers, judges, prosecutors, and victim coordinators on anti-trafficking issues; a new investigative sector created in the border and migration police aimed at preventing cross-border illegal activity including human trafficking; and international cooperation to combat organised crime. Reference was again made to anti-trafficking month; awareness raising campaigns and the National Action Plan, the effectiveness of which was under review by the Ministry of the Interior with the assistance of UNICEF. Trafficking prevention measures were limited by a range of factors including funding and communication difficulties.
90. The report noted that the functioning of the NRM was guided by a Cooperation Agreement which had been updated in June 2023. Potential VOTs could be identified by state or NGO actors, whereas the formal interview for recognition as a VOT was undertaken by police and social services. Albania had mobile identification units in nine regions of the country, operated by social workers, NGOs and police officers.
91. There was no clear consensus among those consulted by Asylos as to whether individuals who had been identified as VOTs within the UK NRM would automatically be recognised as such by the Albanian NRM upon return. Some respondents opined that recognition in Albania would be automatic if there had been recognition in the UK, others disagreed. But a shelter representative noted that few such referrals had been received, and concluded that those identified abroad either remained there or did not approach services on return. There was a lack of clarity about cooperation between the two countries regarding victim identification, although assisted voluntary returns are referred into the Albanian NRM.
92. The report noted that the justice system had been reformed and that the Special Structure against Corruption and Organised Crime (‘SPAK’) now had jurisdiction over trafficking cases with an organised crime nexus. Those without such a nexus were handled by the General Prosecutor’s Office and the District Courts. Those involved had been given training on anti-trafficking issues. There was limited agreement concerning the effectiveness and activity of the police in the anti-trafficking context. Whilst there is a witness protection scheme in Albania, more steps were needed to ensure the protection of witnesses and their families. Statistics suggested to one interlocutor that there was an extremely low conviction rate for trafficking and a need for institutions either to restructure or have more proactive police policies in place.
93. The 2024 Asylos report concluded that the legislative framework related to VOTs was yet to be implemented effectively and that there was a gap between the law and its implementation. Identified challenges included a lack of capacity to prosecute trafficking cases successfully at district courts; a lack of availability and access to free legal aid; lack of professionalism and funding as challenges to accessing legal aid; and issues related to judicial punishment of victims. Interlocutors also highlighted the need for strengthened legal provisions relating to the social assistance available. Significant improvements were said to be needed to ensure full implementation of the relevant legal framework in relation to child trafficking. A range of limitations were said to hamper the Albanian justice system and its ability to protect victims. Amongst the list of limitations were lenient sentences being handed to traffickers and threats or intimidation by the trafficker.
94. There was widespread reporting of inadequacies in the identification of potential VOTs and VOTs. The police had not been proactive in doing so, and most potential victims were identified by the mobile identification units, which were underfunded and lacked permanent resources. Doubt was expressed about the quality of the training given to police officers about the identification of victims of trafficking.
95. Internal relocation for VOTs was considered to be beset by difficulty. Reference was made to the small size of Albania and the “information flow” which could make a victim conspicuous in a new location and enable their former traffickers to find them. Other issues included stigma and finding work without a social network in the place of relocation. A wide range of factors were said to be relevant to the risk of re-trafficking. A number of instances of reprisals were also given; reprisals against family members were reported to be a “recurrent theme”.
96. Corruption was said to continue despite improvements in recent years. Corruption was reported in the police, the judiciary and other state institutions. There continued to be evidence of political figures having links to human trafficking operations. The ongoing incidence of corruption lowered trust in the police and caused a fear of disclosing trafficking due to the actual or perceived involvement of the authorities.
97. Asylos reported that there is one specialised state-run shelter and three specialised NGO-run shelters for VOTs. Together, they form the National Coalition of Anti-Trafficking Shelters (‘NCATS’). There was little agreement on the capacity of the shelters, with one source stating that NCATS’ total capacity was for 71 individuals, whilst another suggested that the state shelter could itself accommodate up to 100 people. Asylos quoted the figures provided to the Home Office during its 2022 FFM report, which indicated that each NGO shelter could sleep between 15-25 individuals. The length of stay in the shelters varied according to need but the expectation was that stays would run to months, whereas the reintegration support provided thereafter would be longer. Different & Equal stated that support might be provided for between two and five years.
98. Interlocutors consulted by Asylos agreed that there was no shelter specifically for males, although one suggested that the state-run shelter could accommodate men. The general approach was to support males in rented accommodation. The state-run shelter, Different & Equal and Vatra were said to provide shelter for women and girls, whereas Another Vision also provided shelter for boys under the age of 18.
99. Reintegration services were provided by the four shelters of the NCATS. The state run shelter was said to be for more acute cases of need. A range of services are provided, including accommodation, food and financial support, counselling and health care, mediation, educational and vocational support and training, and grants for setting up microbusinesses. There were resource constraints, however, and delays in transferring funds. The state run and NGO shelters suffered from a high staff turnover as a result of minimum wage salaries and burnout. The lack of reintegration assistance for boys and men was noted alongside difficult labour market conditions and weak social protections provided by the state. The three NGO shelters received some funding from the government but were also required to seek donor funds to cover the majority of their operating costs. Concerns about the funding of the shelters continued.
100. Outside the services offered by the shelters, VOTs would be entitled to state support if certain conditions were met. VOTs would need to have been declared as such in order to qualify for monthly financial assistance. Housing assistance and rent subsidies might also be available in larger cities. The National Agency for Employment and Skills prioritised employment for vulnerable groups, which included VOTs. Again, however, victims would have to have been identified as such in order to access such support and only a limited number of women (and no men) had sought this support. A number of initiatives founded by the NGO members of the NCATS had provided employment opportunities to victims in diverse fields including as hairdressers, call-centre operatives and mechanics, although barriers to employment including stigma and perceived security issues were noted to remain. There was also some concern that victims were paid less than the minimum wage, and that access to employment through nepotism placed victims in difficulty when attempting to establish themselves in a new area. The generally high unemployment rate contributed to these difficulties.
101. VOTs are entitled to free public healthcare once they had obtained their legal identity papers. Where free provision was not available in this way, shelters had provided assistance. Mental health support was also provided to VOTs by the shelters. Men and boys were able to receive mental health support outside the shelters through Vatra’s legal clinic. In acute cases, men might be referred to psychiatric hospitals. There was noted to be a scarcity of mental health support outside the shelters, and psychologists were reportedly not available through the public health care system.
102. The report noted that victims would need to declare themselves to be VOTs to the state agency in order to access economic assistance. The fear of identifying as a VOT as a result of societal prejudice and stigmatisation was said to be a barrier to such access. This was noted to be a theme which had emerged from the research. The process of applying for such support was said to be lengthy and bureaucratic. State benefits were not always available due to resource constraints, and no housing support was available in smaller municipalities. Concerns were expressed about the quality and duration of support, and whether the amount of financial support provided by the state was adequate to cover the basic costs of living. One interlocutor suggested that around £350 per month was required to cover basic living expenses, whereas the state support is £70 (9000 Lek). Most considered that it was not worth applying for this, and that they would be “better off working”. Concern was expressed about victims’ ability to fend for themselves and about the risk of homelessness in these circumstances.
103. Before we turn to the expert evidence, we must note one additional point about non-disaggregation of data. We have already indicated that much of the data does not distinguish between male and female VOTs. Even where that distinction is made, the information might not be entirely relevant to the analysis which we are required to undertake. It is clear that internal trafficking within Albania is a real issue, and that it particularly takes the form of enslaving children to engage in forced begging. The phenomenon appears to be most commonplace amongst ethnic minority communities, and the Roma in particular. That is obviously a matter of serious concern for the government of Albania and features prominently in the work of the mobile identification units to which we refer below. But the situation of that cohort is of little relevance to the transnationally trafficked male VOTs under consideration in this case, and the failure to disaggregate the two groups in much of the background material presents us with a further challenge in drawing our conclusions.
Expert evidence
104. There is no joint expert in this case. The expert evidence before us is voluminous. Each expert provided a lengthy report. Each was posed a considerable number of written questions by the opposing party. Each of the reports was cross-referenced to background material which was provided as an addendum to the expert’s report. We heard evidence from the experts over the course of a week. Ms Trimi gave evidence via video-link from New York, and we started the third and fourth days of the hearing slightly later so as to accommodate the time difference.
105. It obviously follows that we cannot sensibly attempt to summarise all of the evidence provided orally and in writing by the expert witnesses. To do so would lengthen this decision unnecessarily and reduce the assistance which it provides to those involved in determining protection claims brought by adult male Albanian VOTs. For the avoidance of doubt, however, the panel spent considerable time immersed in the sea of expert evidence before, during and after the hearing, and the lack of reference to a particular part of an expert’s evidence, or the evidence upon which they drew in formulating their opinions, is no indication that that material has been left out of account in reaching our conclusions on the evidence as a whole.
106. The appellant relied on evidence from three expert witnesses: Mr Colin Carswell, Dr Deanna Davy and Professor Dmitris Dalakoglou. The respondent relied upon the evidence of one expert: Ms Anila Trimi. At this stage of our decision, we will make reference to the qualifications of the experts and provide a brief and necessarily incomplete outline of their evidence before explaining the weight we have decided to attach to the evidence of each expert. We have obviously borne in mind the totality of their evidence in considering the country guidance issues.
107. Guidance on expert witnesses was recently given by the Court of Appeal in H (Children: Expertise of Witness) [2026] EWCA Civ 249. At [11], the President of the Family Division, Lewison and Peter Jackson LJJ considered the following to be a satisfactory definition of an expert witness:

An expert is a person who, through specialist training, study, or experience, is able to provide a court, tribunal, or hearing with relevant scientific, technical, or professional information or opinion, based on skills, expertise, or knowledge, that is likely to be beyond the experience and knowledge of the representing lawyers, judge, jury or panel.
108. We can state at the outset that we considered each of the experts tendered by the parties to meet that definition within their respective fields. As we will explain below, however, there were occasions during their oral and written evidence when we considered some of the experts to have stepped outside the field of their real expertise, and to have given evidence which was potentially outdated, or out of kilter with the preponderance of other opinion. In assessing the weight to be given to their evidence, we have been assisted by the guidance given by the Tribunal in LP (LTTE area – Tamils – Colombo – risk?) Sri Lanka CG [2007] UKAIT 76, at [36]-[40] in particular. We do not propose to repeat the entire section as the guidance was encapsulated in this paragraph from the judicial headnote:

The weight to be given to expert evidence (individual or country) and country background evidence is dependent upon the quality of the raw data from which it is drawn and the quality of the filtering process to which that data has been subjected. Sources should be given whenever possible.
109. In the appellant’s skeleton argument and closing submissions, it was submitted that his legal team had selected the experts “mindfully”, with each of the experts occupying “a particular focus relevant to the 11 questions posed”. We will therefore begin our consideration of each of the appellant’s experts by referring to what is said (by his legal team) to be their particular focus.
Mr Carswell
110. Mr Carswell was described in the appellant’s closing submissions as an expert on trafficking and organised crime networks (‘OCN’) on the ground. He was said to have “deep practical experience as an ex-senior police officer”. The appellant’s counsel reminded us that Mr Carswell had reviewed the Albanian SOP, and that he had delivered training on the investigation of human trafficking to Albanian police officers and psychologists.
111. Mr Carswell was asked by the appellant’s solicitors to set out his professional background and experience, including a detailed account of his experience concerning Albania. He did so over the course of the next seven pages of his report. What follows is only an outline of those 30 paragraphs.
112. Mr Carswell served as a police officer between 1989 and 2020. He retired at the rank of Superintendent. He had extensive experience of OCN, particularly during the latter stages of his career. By way of example, he was commended by the Director of Europol for leading a complex investigation into the trafficking of children from Eastern Europe and received an award in 2010 from the then Prime Minister for work in combatting child trafficking. Those commendations followed his work as the tactical lead of Operation Golf, which was at the time the largest human trafficking investigation ever undertaken in Europe. His expertise in the field of child trafficking was recognised in various ways, including his giving evidence to the joint committee on the Modern Slavery Bill in 2014. As a Superintendent in South London, he was the senior officer responsible for reducing youth violence and was particularly active in combatting “County Lines” drug dealing operations. He provided advice to the Home Office and the Foreign and Commonwealth Office on combatting international organised crime and trafficking.
113. Having left the police, Mr Carswell took a Master’s degree in Human Trafficking, Migration and Organised Crime at St Mary’s University. Having secured his degree, he went on to lecture on the same course at St Mary’s. In 2023, he acted as a special advisor to the Home Affairs Select Committee on subjects related to human trafficking. Mr Carswell assists the Council of Europe and OSCE in anti-trafficking initiatives. He is a member of the Interpol Human Trafficking Expert Group. In those roles, he has delivered training in ten different countries, including Albania, over the last five years. He was appointed by OSCE Albania to develop and deliver a programme of anti-trafficking training to the Albanian School of Magistrates and Security Academy. He wrote a “Training of Trainers” Guide which was published by the OSCE. To do so, he studied the Albanian SOP and the Albanian police handbook. He went to Albania to deliver the training over the course of a week. In 2024, he undertook two further pieces of anti-trafficking work for the OSCE in Albania, culminating in in-person training of police officers from around the country. During that process, he was supported by the head of human trafficking and smuggling prevention from the Albanian Police.
114. Mr Carswell has given expert evidence in more than 150 cases, including 30 or more which concerned the trafficking of Albanian males. He personally interviewed the majority of those individuals. He has also peer reviewed approximately 20 such reports written by others. His evidence has, we are told, been presented and accepted in criminal trials, extradition hearings and in proceedings in the Family Division of the High Court.
115. Beyond outlining his considerable experience, Mr Carswell was asked seventeen questions by the appellant’s solicitors. He answered those questions over the course of an 88 page report. There is no summary in the report itself. In order to assist the reader to understand the essence of his conclusions, therefore, what follows is our own summary of the report, with the response to each question distilled as concisely as possible. It is necessarily an incomplete precis of a detailed set of conclusions, but we have obviously considered the report as a whole before reaching our own conclusions in this appeal.
116. Mr Carswell explained that human trafficking is generally accepted to involve three components: the act, the means and the purpose. He stated that human trafficking for sexual exploitation and forced labour (often including the supply and production of drugs – cannabis in particular) is a serious issue within Albania and abroad and that it was often linked to organised crime. Organised crime in Albania was a significant and longstanding issue. OCGs were known to be involved in drug production and human trafficking and the widespread corruption in Albania’s governmental and law enforcement apparatus was of direct benefit to such groups. Whilst initiatives had yielded improvements in recent years, the influence of OCNs in Albania remained a serious concern. Debt bondage was commonly used as a means of coercion in trafficking relationships. Albanian males were deceived by the false promise of a legitimate job on arrival in the UK, only to find themselves in an exploitative situation in which they were required to repay a debt supposedly incurred for their unlawful carriage to the UK. Links between those operating in the UK and in Albania would ensure the repayment of the debt by making credible threats to the victim’s family in Albania.
117. Mr Carswell opined that inherent environmental and situational vulnerabilities could increase an individual’s susceptibility to trafficking. Relevant factors might include poverty, adverse childhood experiences, discrimination and cognitive issues, although victims might disguise such factors by presenting a “tough persona”. He considered that socio-economic challenges and limited job opportunities were particular identifiable factors amongst trafficked Albanian males, and that all but one of the risk factors identified in TD & AD applied equally to Albanian males.
118. Mr Carswell considered there to be a credible risk of re-trafficking for any VOT. If a VOT was not provided with adequate support to address their vulnerability, they would be at significantly increased risk of re-trafficking. Those who were held responsible for real or perceived debts were particularly vulnerable. Those who were removed from the UK might be at significantly increased risk of re-trafficking unless there was accessible and effective rehabilitation. Mr Carswell did not consider that the passage of time would reduce, mitigate, or remove the threat to an individual who was subject to debt bondage or the risk of re-trafficking. Instead, his experience was that males who had managed to escape would be physically punished and then put to work once more by the gang, regardless of the passage of time. In one such case, two years had passed between escape and violent recapture.
119. Mr Carswell considered that the effects of human trafficking upon the victim could be physical and psychological and could last for many years. Mental health problems had been observed in a significant number of cases. Victims often delayed in presenting themselves to the authorities as such. In addition, there were numerous reasons why a VOT might not identify themselves as such to the Albanian authorities: internal or external stigma, a belief that the police are corrupt or will not help them and a sense that to do so would be pointless. The Albanian authorities were however under an obligation to investigate human trafficking, which is a serious crime. The manual which he had written for the Albanian police at the behest of the OSCE and the training which he had subsequently delivered set out the ways in which such crimes should be investigated. He had written an additional guide in 2024 and there was now a Joint Migration Taskforce between the UK and Albania. Despite such initiatives, there remained “stubbornly low numbers of convictions for trafficking offences in Albania”. Until the rate of conviction was significantly increased, Albania would be failing to counter human trafficking effectively and victims would not be adequately protected.
120. Mr Carswell stated that he had not been directly involved in any Albanian police investigations into human trafficking. He considered that he was nevertheless able to offer a view on the ability of the police to protect a male VOT from re-trafficking or reprisal. The low risk of conviction was relevant to that question. Mr Carswell considered that inadequate training and an inadequate number of officers dedicated to investigating such crimes were relevant to the conviction rate. Corruption was also relevant. Although he acknowledged improvements in Albania since TD & AD, Mr Carswell noted that there were no shelter facilities for male VOTs and the level of state protection for males was “severely lacking”. Mr Carswell suggested in answer to the final question posed by the appellant’s solicitors that internal relocation within Albania was unlikely to provide a victim with safety, although the reach and connections of the OCG and the level of support provided to the victim were both relevant considerations. He considered Albanian OCGs to be “highly adept” at locating those who had escaped from them. He considered the suggestion in the CPIN that “male victims are likely to be able to relocate” to be an oversimplification of the situation, and a case-by-case analysis was instead required.
121. Mr Carswell was asked 118 written questions by the respondent, generating answers which spanned a further 60 pages. We will not attempt to summarise the answers to those questions, although we have obviously studied them carefully. Mr Carswell was cross examined for most of the first day of the hearing by Mr Hansen. Again, we do not propose to attempt a summary of his oral evidence.
122. The appellant submitted that Mr Carswell presented as an assured and knowledgeable witness who had given reasonable concessions and spoke from a base of experience, both as a senior police officer and an established expert witness who had interviewed numerous victims. He had worked with the Albanian police and was demonstrably up-to-date with the way in which OCGs operated on the ground.
123. The respondent submitted, on the other hand, that Mr Carswell’s evidence was significantly out of kilter with the other evidence. One notable example was his conclusion that there was limited use of technology in the recruitment of trafficking victims. Another was his evidence that victims were always trafficked to the UK rather than being exploited after arrival. The other experts agreed that there was no “one size fits all” model. The respondent submitted that Mr Carswell’s real expertise was in policing in the UK and that his engagement with Albania was very limited. His opinions were often unsupported by ‘hard data’, which was what the Tribunal should really be interested in.
124. We were impressed by Mr Carswell’s professional experience of OCGs and by the knowledge of trafficking which he had accrued since his retirement from the police in 2020. His expertise in the field has been recognised in this country and abroad, at the highest levels, and he spoke from a position of knowledge and authority on those two subjects. We accept his considerable experience in dealing with Albanian OCGs and VOTs within the UK.
125. However, in our judgement his knowledge about the situation on the ground in Albania is more limited, reflective of the limited time he has spent in the country and the fact that his academic studies were focused on trafficking generally, rather than Albania specifically. In fairness to Mr Carswell, we note that he accepted at the very start of cross-examination that he is not an Albanian country expert. He went on to accept that he was also not an expert on Albanian law but to explain that he instead considered himself to be a trafficking expert, and that his experience of modern slavery and OCGs in the UK was of equal application in the Albanian context. As he put it, the “reality is that OCGs have the same hallmarks”. We note he has given training for the Albanian police, as a result of which he spent some time with the head of the anti-trafficking unit, but we considered him to have a relatively limited knowledge of the situation of male VOTs within Albania.
126. We consider Mr Hansen to have gone too far when he suggested to Mr Carswell that “vast swathes of what is necessary for you to understand is outside your expertise”. He was tendered as an expert with significant expertise in organised crime and trafficking and he undoubtedly has that, whether or not he might have over-reached in certain respects and erred in others, as set out below.
127. We do not accept the respondent’s submission that Mr Carswell gave incorrect evidence about the use of social media by traffickers. It is clear that this phenomenon exists and that there has been a “dramatic increase in online trafficking over the last three years”: [1.3] of the Asylos 2024 report refers. But Mr Carswell did not suggest otherwise; he accepted in his oral evidence that there was “always a focus on digital recruitment” in the modern world, but that he had not seen the use of such technology in any of the thirty cases in which he had been personally involved as an expert. He was not “demonstrably wrong” about this phenomenon, as Mr Hansen sought to suggest in his closing submissions; he had just not encountered it amongst those he had personally interviewed.
128. Nor do we accept the submission that Mr Carswell denied that Albanian males who intended to enter the UK illegally to work subsequently found themselves exploited by those who had promised to arrange their journey. When Mr Hansen put to him that he entirely refuted the idea that irregular migration could transition to exploitation, Mr Carswell’s response was that the victim “started off with the intention of being an economic migrant” but that the gang intended to exploit them and “sells them a lie”. That description of a typical modus operandi chimes with the description which appears throughout the background material.
129. Mr Carswell attached great significance in his evidence to the interviews he had undertaken with male VOTs from Albania. As we have recorded above, he has undertaken 30 or so such interviews and has peer reviewed 20 reports written by other experts. We were concerned by Mr Carswell’s tendency to accept what he had been told in those interviews as empirical fact upon which he could safely base his conclusions. Whilst he told us that he had concluded that two interviewees were lying to him, he seemed generally to have proceeded on the basis that what he was told was likely to be true despite the fact that those he had interviewed stood to benefit from the outcome of the interview. Those he interviewed were involved in immigration, criminal or extradition proceedings and sought Mr Carswell’s assistance in defeating the attempts of the authorities to expel or prosecute them. Mr Carswell missed the point when, in answer to a question from the panel, he said that he was not “beholden to the defence” in such cases. He was obviously an independent expert before the Crown Court, as he is before the Immigration and Asylum Chamber, but that is not the point. The point is that those being interviewed had every reason to present their situation in a trafficking context, and Mr Carswell seemed not to have reflected on that, and had instead taken their accounts as an intrinsically reliable base for his subsequent analyses. In answering the eighth question which was posed to him by the appellant’s solicitors, for example, Mr Carswell drew on what he had been told by those he had interviewed when assessing the risk that a gang would continue to pursue them on return to Albania:

In many of these cases the victim has personally informed me that it doesn’t matter if they face a custodial sentence in the UK and are then returned to Albania, or are returned to Albania immediately as a victim, in both eventualities the levied debt will still be owed to the gang, and the gang is likely to find them and either exact revenge on them for not paying, or re-traffic them.
130. We were concerned that Mr Carswell appeared not to have reflected on the fact that such an individual might be seeking to mislead him in order to secure an advantage in their immigration, extradition or criminal proceedings. We considered that research undertaken in Albania, whether with VOTs or with those who work with them, was more likely to produce reliable data from which to draw conclusions informative in this country guidance assessment.
131. We were also concerned that there was a tendency at times to focus on the negative, rather than trying to present a balanced account of the situation on the ground. Mr Carswell expressed serious concerns in his report about the extent of corruption in Albania and the effect of such corruption on the conviction rate for trafficking offences. At no point in his report, however, did he mention the judicial vetting process which was noted in the European Commission’s report on Albania in October 2024 to have led to significant improvements in the functioning of the judiciary. That omission was put to him in writing and in cross-examination and he was unable to explain why he had made no reference to these improvements, accepting (to his credit) that it was a possibility that he was simply unaware of the point.
132. Mr Carswell’s tendency to focus on the negative was also apparent in his reference to there having been 312 instances of corruption at the Morine border crossing into Kosovo. We note that these events were described at [10.9.5] of the CPIN. As Mr Hansen suggested to Mr Carswell during his oral evidence, however, the CPIN continues to note that successful prosecutions were brought against the officers concerned, whereas that fact was omitted from Mr Carswell’s analysis. Mr Hansen was also correct in his suggestion to Mr Carswell that he had made no reference in his report to Albania’s 2024-2025 National Action Plan to Combat Trafficking in Persons. Whilst that report might be said to be aspirational in what it said about the country’s future plans, its significance in this case lies in the fact that it records that the overall implementation rate of the 2021-2023 plan was 89% for the period 2021-2023, with 43 measures fully implemented, 6 partially implemented and 6 not implemented. That was relevant to Mr Carswell’s conclusion that the Albanian state was failing to counter human trafficking effectively, and should have been considered in his report.
133. Ultimately, therefore, we were impressed by Mr Carswell’s professional background and the depth of his knowledge about organised crime and trafficking. We were less impressed with his knowledge of the protection available to male VOT in Albania. As outlined above, this reflects the nature and extent of Mr Carswell’s experience.
Dr Davy
134. Dr Davy was described in the appellant’s closing submissions as “an academic expert specifically on trafficking. Her PhD and academic research are in human trafficking.” She was described as the lead researcher for UNICEF Albania and she was noted to have written a number of articles, funded by the UK government, which were cited by GRETA, the Home Office’s CPINs and all of the other experts in the case.
135. Dr Davy is an Australian citizen who has lived and worked in the UK since 2019. A full copy of her CV appears in the bundle but we are able to take the following summary of her qualifications and experience from the first page of her report of 26 August 2025:

The expert is a trafficking in persons researcher with over a decade of experience. She completed a PhD on the subject of child trafficking in Southeast Asia in 2014 and since this time has worked in research roles (trafficking in persons, and migration) for various United Nations agencies (United Nations Children’s Fund (UNICEF); United Nations Office on Drugs and Crime; International Organization for Migration; United Nations Development Programme), government agencies, non-government organisations, and universities in various regions of the world. For approximately 2.5 years she was employed as an international Consultant (trafficking in persons) for UNICEF in Albania, and led the design and implementation of several major studies on trafficking in persons in Albania, including a study on victims who are trafficked by someone they know; a study on economic reintegration of trafficking victims; and a multi-wave trafficking in persons knowledge, attitudes and practices survey of Albanian youth. In addition to the PhD she has also completed an LLM Human Rights and Humanitarian Law, a Master of Evaluation, a Master of International and Community Development, and a Bachelor of Arts/Education.
136. Dr Davy summarised her own conclusions at [60]-[66] of her report. We consider this to be an accurate summary of her conclusions and we therefore replicate it in full:

[60] The appellant is now a young man who experiences mental health issues, has physical limitations, low education, few decent livelihood options, and no supportive family environment. He would be at heightened risk of abuse and re-trafficking if he were to be returned to his family.

[61] The appellant displays the same risk factors identified in TD and AD. He is from a poor family, has low education, mental health issues, a disability, and comes from an abusive family. He has no supportive family environment, and no other protective factors are evident. His family has received threats from his traffickers.

[62] There are major barriers for male victims (adults and children) in receiving adequate reintegration support and protection in Albania. The first is the lack of state funding for support. While on paper at least, the state prioritises trafficking survivors as a special group that has rights to reintegration support, in reality this support is ad hoc depending on the funding available to state agencies at any given time. Support is largely geared towards female victims, as men and boys are not considered in Albanian society as possible victims. The second major barrier is the duration of time it takes for paperwork to be processed and support received. The third is stigma - survivors have to present themselves at each state agency when they wish to receive support (for example, financial assistance) with a statement from an organisation that they are a trafficking victim and a host of other documentation. There is no privacy in these offices, with multiple staff and others in the queue being able to hear the victim’s conversation. Male victims will face challenges in getting the declaration as there is only one NGO in Albania that is able to support adult male victims. Male victims would likely face invasive questions, scrutiny regarding their victim status, and discriminatory attitudes from the state agency personnel. Male survivors (adults and older male children) are not likely to present themselves to such state services to receive reintegration assistance because of patriarchal attitudes in Albania regarding men, and the desire to hide their status as a victim of trafficking.

[63] There are no shelters for trafficked men in Albania. The appellant may, if he presents himself to the Albanian government as a victim of trafficking, receive a referral to the one NGO in the country that can provide housing assistance; however, he will likely experience discrimination if he were to do so, and the duration of the time that the NGO could support his housing is questionable. It would likely only be a short-term arrangement.

[64] The appellant could quite easily be found by his traffickers due to the traffickers knowing his family name, and Albania being a country where it is easy to locate individuals through social networks. Due to the ongoing presence of the same vulnerability factors that were present at the point of his initial trafficking, he is also highly vulnerable to trafficking by other individuals or groups.

[65] Corruption continues to undermine state protection against trafficking in persons and organised crime in Albania. Relocation is not a safe option for the appellant. As the appellant experiences the same risk factors identified in TD and AD, he will be at risk of re-trafficking on return, and will not have a sufficiency of protection in the event of relocation. His fear of the organised crime group will act as another major inhibitor in terms of his accessing state protection.

[66] The appellant has been trafficked in the recent past. Such past exploitation is a good indicator for future exploitation. I conclude that in the continued ongoing presence of the risk factors that were present at the point of his initial trafficking, the reality that his traffickers will be able to locate him and have already threatened his family, and the absence of state protection for male victims and the immense hurdles and discrimination that he would have to surmount and experience in order to access any form of state protection, that the appellant would be at real risk of re-trafficking throughout Albania upon his return to the country.
137. Dr Davy was asked 156 written questions by the respondent. She provided detailed responses to those questions. We heard oral evidence from Dr Davy for most of the second day of the hearing. She was cross-examined at length by Ms Ralph and re-examined briefly by Mr Tabori.
138. It was submitted by the respondent that Dr Davy had relevant expertise and insight but that she was notably out of date in several respects. She was clearly wrong in her evidence that there was only one psychiatrist in Albania. It was accepted that she was genuinely trying to help the Tribunal with her evidence, although it was apparent that most of her prior research focussed principally on female victims of trafficking. For the appellant, it was submitted that Dr Davy obviously had particular knowledge and expertise in international human trafficking and the reintegration support which was available to victims. It was also submitted that she had both stood her ground and offered reasonable concessions, thereby demonstrating her objectivity. We were invited to accept her evidence in full.
139. We were generally impressed with Dr Davy’s evidence, and did not consider it to have been significantly undermined by any of the questions put to her orally or in writing. It is apparent that she undertook detailed research when she was working for UNICEF and she has in the past written major studies on trafficking, reintegration and support in Albania. As was submitted by the appellants, it is notable that her name appears regularly in the wide canvass of background material which is before us. As we have already noted, there was extensive reference to her evidence in the Asylos reports in 2019 and 2024. There are also numerous references to her body of work in the CPIN. She is evidently recognised on the international stage as an expert on trafficking and reintegration within Albania and we were assisted by her evidence.
140. Ms Ralph understandably pursued a line of cross examination about the amount of time that Dr Davy had spent in Albania. She responded that she had spent ten days there, over the course of two visits, both of which were after her 2022 report for UNICEF was published. She had been based in Tirana and had travelled to Shkoder. Ultimately, however, the respondent did not make a submission that the weight to be attached to Dr Davy’s evidence should be reduced because of the limited time she had spent in Albania. Had that submission been made, we would have rejected it. It is clear from Dr Davy’s evidence that she had extensive contact with the three NGO members of the NCAT, and that she had their full cooperation in undertaking her research for UNICEF. The fact that that research was undertaken by video link does not serve to lessen the weight which we are prepared to attach to Dr Davy’s evidence. For the same reason, we did not consider Dr Davy’s frank admission that she had not directly spoken to any VOTs to reduce the weight which we should attach to her evidence; her research through the NGOs and (to a lesser extent) the state shelter provided an ample evidence base for her research for UNICEF.
141. It was put to Dr Davy that she was engaged in “victim advocacy”. The implication of the question was that she was not impartial in her evidence. Dr Davy’s answer to that question was characteristically reflective; she stated that she had adopted a “somewhat neutral position”. She said “Advocate, I guess you could say that”, although she quickly added that she was not biased but “sympathetic” towards VOTs.
142. We wish to make it clear that we did not detect anything in what was said or written by Dr Davy which indicated that she was other than impartial. The respondent’s concession that she was genuinely attempting to assist the Tribunal with her evidence was properly made. We were struck by Dr Davy’s answer to Ms Ralph’s suggestion that she was not an expert on Albanian male VOTs. Dr Davy said that she was a “somewhat humble researcher” and that she considered the label “expert” to be troubling. She said that she had broad experience on Albania, spanning two and a half years, but that she was not an expert on the very specific subject area suggested by Ms Ralph. We considered this to be a measured and realistic response and, in common with Dr Davy, we rather doubt that anyone could properly claim to be an expert on such a niche subject. But Dr Davy had an extended period of intense focus on the phenomenon of trafficking in Albania, and on the country’s response to it, and her access to state and NGO workers was facilitated by her working for the United Nations. Applying the litmus test in Re H, it is quite apparent that she has relevant knowledge beyond the experience and knowledge of the representing lawyers and judges in the case.
143. However, there were certain limitations in Dr Davy’s knowledge and experience. She frankly accepted that the focus of her UNICEF research was on female VOTs, and that only one of the victims spoken to by the NGOs was male. (She recalled immediately that he was training to be a chef.) Whilst she spoke with great authority about the situation of female VOTs, therefore, her knowledge about the specific situation of male VOTs was admittedly not as extensive. We note that Dr Davy also accepted that her report entitled Trafficked by Someone I Know was not particularly relevant to the situation of male VOTs. She had herself inserted such a caveat at the very end of the report and she maintained it in her oral evidence, observing that only a “pretty low number of males” had been consulted and that she had asked the NGOs why that was thought to be so. They had informed her that the lack of participation was on account of a fear of data sharing and societal stigma. Nevertheless, as Dr Davy went on to explain, her extensive conversations with the NGOs had considered the position of males, so she considered there to be a rational, if limited, evidence base for her conclusions.
144. We also accept the specific point made against Dr Davy’s report in the respondent’s closing submissions. It was apparent from an early stage in her oral evidence that she knew a great deal about the position in 2022 but rather less about the position in 2026. As we will come to consider, the passage of time is potentially of significance, not least because the legal framework in Albania has been further strengthened since 2022.
145. Whilst Dr Davy had consulted a wide range of up-to-date sources including, for example, the TIP report and the 2024 Asylos report, she had not made contact with the NGOs with whom she previously had such close contact. She had not made contact with UNICEF, and she was unaware that it had commissioned and published a further KAP Survey in 2025 until Ms Ralph referred her to a letter from the British Embassy in Tirana which made reference to that survey. When Ms Ralph noted that Ms Trimi had made contact with relevant actors in Albania for the purpose of researching her report, Dr Davy stated that she was unaware that she was able to do that. She accepted that she was therefore unaware, until she had read Ms Trimi’s report, that the NRCVT had provided accommodation for male VOTs in 2025. Again, we considered this to demonstrate that her knowledge of the situation on the ground was not as up-to-date as it was in 2022.
146. A further example of Dr Davy’s lack of knowledge about the current position in Albania was provided when Ms Ralph asked her about the provision of social housing for VOTs. She initially maintained that VOTs were not receiving social housing despite what the law said, but she added that the position “might have changed in the last couple of years” but that she knew about the position in late 2022. We also noted that Dr Davy’s knowledge was either wrong or outdated when she suggested that there was only one psychiatrist in the whole of Albania; other sources suggest that there are 46. That number is drawn from the World Health Organisation’s Mental Health Atlas, published on 8 October 2021, and is quoted in various other places, including Professor Dalakoglou’s report. When it was suggested to Dr Davy that the evidence suggested that there had recently been a greater focus on mental health provision, she responded that she hoped matters had improved but that it had not been good in 2022.
147. We also noted that Dr Davy was asked by Ms Ralph whether she accepted that the Home Office was very interested in stemming human trafficking from Albania. She responded that she knew that to be so in 2022, but that she was not aware of the current position.
148. Ultimately, therefore, we considered there to be merit in the respondent’s submission that Dr Davy was not entirely abreast of matters as they currently stand in Albania. That is not a criticism of her; it is merely a reflection of the fact that her first-hand knowledge of matters has waned somewhat since its zenith in 2022. That is wholly unsurprising, as the geographical focus of her professional work has moved away from Albania, and indeed from Europe, since 2022. Her more recent professional focus, between September 2021 and May 2025, has been on the Greater Mekong Subregion, Fiji, Southeast Asia and North Africa.
149. Finally, we note that Dr Davy admitted the limitations of her own expertise in two important respects. She was not put forward as an expert on the operations of OCGs, or Albanian OCGs, and she accepted when pressed about her written responses to the respondent’s questions that she thought she had answered beyond her experience. That was a realistic acceptance, and it necessarily reduces the weight which we are able to attach to Dr Davy’s evidence on that subject. The same is true of Dr Davy’s frank acceptance during her oral evidence that she is not an expert on judicial standards or police corruption in Albania.
Professor Dalakoglou
150. Professor Dalakoglou was instructed by the appellant as “a leading academic expert on Albania, its society, politics and migration (which includes trafficking).”
151. In common with Dr Davy, Professor Dalakoglou provided a helpful summary of his professional background and relevant experience at the start of his report. It is in the following terms:

[1.1] I am a British citizen and currently serve as a Full Professor of Social Anthropology and Sociology of Development at Vrije Universiteit Amsterdam. My academic career spans more than two decades and is largely grounded in intensive empirical fieldwork research in Albania.

[1.2] I have published widely on Albanian society, politics, and migration e.g. monographs (see Dalakoglou 2017, Manchester University Press), world-leading peer-reviewed journals (e.g. Journal of the Royal Anthropological Institute, American Ethnologist, Mobilities) and edited volumes. I am among the most frequently cited scholars in Balkan and Eastern European studies, with a particular expertise in Albania.

[1.3] I hold a PhD in Anthropology from University College London, focused on Albanian society, as well as an MA in Migration and Ethnic Studies from the University of Amsterdam, a BA (Hons) in Social Policy and Social Anthropology and I have followed postdoc studies in Political Economy at the Graduate Center of the City University of New York, Center for Culture, Place and Politics. My academic appointments have included prestigious international fellowships, such as the Seeger Fellowship at Princeton University and Visiting Fellowship at the Centre of Global Political Economy of Sussex University.

[1.4] I have served for several years as a Country-of-Origin Expert on Albania, preparing expert reports and providing evidence for the UK Courts and Tribunal Service. I have further provided evidence to the United Nations Human Rights Council Complaint Procedures, and courts in the United States, the Netherlands, Ireland, and Greece.
152. Professor Dalakoglou also provided an account of his key findings. We are grateful to him for doing so, and reproduce that short section of his report in full. Again, we have obviously considered the body of the report in full, but it assists the reader to understand the key conclusions, as expressed in the Professor’s own words.

[1] Independent monitoring bodies report involvement of organised criminal networks in trafficking and forced labour in Albania; several sources also document instances of official complicity, which undermines protection in practice.

[2] While Albania has laws, referral mechanisms, and anti-trafficking institutions on paper, their practical effectiveness is extremely limited. Prosecutions and convictions of traffickers are rare, corruption in police and judiciary is systemic, and services remain heavily dependent on underfunded NGOs.

[3] Identification and support for male victims, particularly those trafficked for labour or criminal exploitation, lag significantly behind that for women and children. There is no dedicated male shelter; adult men are often placed in short-term, donor-funded NGO flats.

[4] Housing costs, especially in Tirana and coastal cities, far outstrip average wages. Affordable social housing is virtually non-existent, and rent subsidies are inaccessible in practice. Employment is dominated by informal, low-paid, and insecure work, with nearly 57% of the workforce outside formal protections.

[5] Mental health services are scarce, underfunded, and geographically concentrated in major cities. Out-of-pocket costs and informal payments (bribes or gifts) are widely reported. Stigma against men with mental health issues remains high, further limiting access.

[6] NGO-run micro-grants, training, and shelter initiatives exist but are small-scale, unstable, and short-term. Without housing, mentoring, and social protection, reintegration programmes frequently fail.

[7] Albania’s small size, dense social networks, mandatory digital address registration, and widespread corruption make relocation insecure and impractical. Trafficking networks operate nationwide, and victims are highly traceable. For individuals without family support, relocation is neither safe nor reasonable.
153. Professor Dalakoglou was asked 199 written questions by the respondent, the answers to which were provided over the course of an additional 69 pages, augmented by a document which Professor Dalakoglou had written entitled “Memo on the Nature and weight of the Expert Evidence”. As with the other experts, we do not intend to attempt a summary of the questions and responses, or of the evidence given orally throughout the whole of the fifth day of the hearing.
154. The respondent submitted that the Professor had relevant knowledge about Albania but not about the phenomenon of human trafficking, and criticised his evidence as follows. He had advised the OSCE on democratisation and he was clearly extensively published and cited but he had written nothing about human trafficking. His book “The Road” was not about human trafficking. He had a complete lack of knowledge about centrally important matters such as the Albanian NRM. The “identification gap” about which he spoke was not borne out by the other evidence in the case. Advocacy was apparent in his report and orally. His evidence always highlighted the negatives and omitted the positives. He decried the value of case studies in favour of ethnographic research. His conclusions were partial, repetitive and of limited assistance to the tribunal and he was, Mr Hansen submitted, “completely divorced from the granular detail.”
155. For the appellant, it was submitted that the Professor was inexperienced at giving oral evidence. It was accepted that he was initially defensive and reluctant to give short answers but it was submitted that he had changed his approach after being given guidance on answering questions. It was submitted that he had a deep understanding of Albania and its society and structures. The suggestion that he was repetitive was without merit; he repeated what he considered to be the most important points. The suggestion that he had used Generative Artificial Intelligence (‘AI’) software (a point which Mr Hansen sought to develop at length in cross-examination) to write his report was rejected – the content of the report in fact showed the opposite.
156. We did not consider there to be merit in a number of the points which were made against Professor Dalakoglou by the respondent.
157. Mr Hansen pursued a suggestion in cross-examination that the Professor’s report was not his own work, and that it had been generated in whole or in part by generative AI. We do not consider there to have been any proper foundation for such a serious allegation. There were essentially three bases upon which the allegation was founded: the appearance of the same phrases repeatedly within the report; Professor Dalakoglou’s failure to mention the 2025 TIP report; and the appearance of the phrase “to my opinion”.
158. None of those points begins to found a suggestion that the Professor used AI to write his report. There is certainly a degree of repetition in the report but, as he explained, that is because he considered there to be a degree of overlap and repetition in the questions he was asked by the appellant’s solicitors. The second and third points made by Mr Hansen actually suggest that the report was not written by AI, which would have been more likely to cite up-to-date material and use proper English. The Professor explained that he had overlooked the more recent TIP report and that although he is a British citizen, English is not his first language. Whilst the failure to consider the most recent TIP report will affect the weight which we give to the Professor’s report, it does not begin to suggest that he used AI. We do not propose to say much about the use of the phrase “to my opinion”; we very much doubt that the question should even have been raised with an academic who was writing in his second language, and we note that it was an expression which he went on to use in his oral evidence.
159. Nor did we consider there to be merit in Mr Hansen’s suggestion that the Professor was engaged in advocacy for the appellant. That suggestion was founded upon the conclusion, expressed at the end of the report, that the appellant cannot rely on effective state protection: “NGOs may offer temporary help, but this is short-term and insecure.” Neither the appearance of that conclusion nor the way in which it is expressed gives any basis for the suggestion that Professor Dalakoglou is engaged in advocacy in his report. As he explained in his oral evidence, that was his conclusion on the facts of the appellant’s case, having surveyed the evidence.
160. Mr Hansen also cross-examined the Professor on his “pro-migrant advocacy” but we were not directed at that point or in his submissions to anything in the evidence which suggests that the Professor is generally pro-migration or anti-immigration control. Again, if (as we suspect) that was a suggestion that the Professor lacked impartiality, there is no basis in the evidence for such a serious suggestion.
161. At the start of cross-examination, Mr Hansen also suggested to Professor Dalakoglou that both Balkan Studies and Eastern European Studies were “huge areas”. The Professor agreed with that, but noted that these were recognised fields of ethnographic and anthropological research; that common themes emerged from such studies; and that his own focus was on Albania. We considered that to be an entirely satisfactory response to the question.
162. We were more concerned by certain other points which emerged clearly from cross-examination. The most serious concern arose when Mr Hansen challenged the Professor about his assertion that there were “identification gaps” in relation to male VOTs. Mr Hansen noted that the Professor had not appended either the SOP or the NRM to his report, despite having produced six thousand pages of appendices. The Professor accepted that he had not, but confirmed that he knew both documents and was aware of them. Mr Hansen asked him what the SOP and the NRM said about the consent of the victim. The Professor stated that he could guess, and did so.
163. He was asked to explain the two stages involved in identifying a VOT (i.e. from potential VOT to actual or “identified” VOT). The Professor said that he could not remember but that he thought the first step was for the individual to ask the authorities. Mr Hansen showed him the NRM, and asked him to note that the first step was conducted by the parties to the NRM, not by the victim themselves. The Professor said that Mr Hansen had asked him about victims, not potential victims, and that the two were very different. We considered that to be an evasive answer – Mr Hansen’s earlier questions were evidently directed at the first step in the whole process, about which the Professor seemed unaware, despite his subsequent insistence that he did understand the process.
164. The Professor was then asked to consider the GRETA report, which made reference to the improvements to the NRM which had been made in 2023. He was asked to explain the key improvements which had been made since the 2005 version of the NRM. He made a vague reference to there having been efforts to update it to the European standard and was asked by the panel to be more specific. He vaguely answered that the new version contained a more up to date and detailed mechanism and that there were efforts to implement it but that it remained to be seen whether it made a difference because training was still underway. We regret that we formed the clear impression that the Professor had scant knowledge of the improved NRM and that he was trying to avoid a direct answer to the question, which would have revealed that lack of knowledge.
165. We accept the respondent’s submission that there were omissions from the Professor’s report. As we have already mentioned, he did not make reference to the TIP report for 2025; there was only reference, at p34 of his report, to a summary of that report complied by the European Country of Origin Information Network. Mr Tabori noted when he re-examined the Professor that the TIP report was only published three days before the report was sent to the appellant’s solicitors but that rather misses the point. The TIP report is an annual event and is widely regarded as a benchmark document. Any knowledgeable academic writing on the subject of trafficking in a particular country would be aware of that and would have taken the trouble to ensure that they consulted it in full before finalising the report. The Professor also notably failed to make reference to the various awareness-raising initiatives which are described in the background material. When confronted with that omission, he obfuscated, suggesting that it was only NGOs who were attempting to raise awareness of trafficking issues and that the State had not done so. Mr Hansen suggested to him, correctly, that the state had been undertaking extensive awareness-raising for some time, whereupon the Professor shifted his stance, maintaining that there had been “limited but improving” awareness-raising by the state. When the relevant material was then placed in front of him by Mr Hansen, he shifted again, maintaining that there was no mention of male VOT. The pattern here, as before, was that the Professor was confronted with a problem in his report, whereupon he attempted to shore up the deficiency.
166. We note and accept the respondent’s submission that Professor Dalakoglou is not named anywhere in the 17,000 pages before us, apart from his own report. In that respect, he is in a very different position to Ms Trimi and Dr Davy, who feature prominently in background material which relates to the periods in which they were both heavily involved in anti-trafficking measures or scrutiny within Albania. That perhaps understandably reflects upon his broader-based expertise on the prevailing conditions in Albania. We also accept that the Professor’s reports rely on undisclosed interviews with un-named interviewees, which lessens the weight which we can properly attach to them in accordance with the guidance in LP (Sri Lanka) (supra) at [39]-[41]
167. The Professor is a respected authority on society, politics and migration in Albania. We accept that the Professor’s expertise on the prevailing conditions in Albania that form the background to this case, covers areas that may explain or overlap with the phenomena of trafficking in and from Albania. However, ultimately, we found his evidence to be more relevant to the broader reasons why Albanians become VOTs or re-trafficking. His evidence was of limited assistance to us in relation to the prospective protection mechanisms in place upon return to Albania, for those adult males accepted to be VOTs.
Ms Trimi
168. The respondent’s single expert, Anila Trimi, is based in New York, where she has lived and worked since 2019. She currently works as an investigator for the New York State Justice Centre for the Protection of People with Special Needs, where she has been since 2021. She also works as an independent consultant on action against human trafficking and child abuse, and has done so since 2019.
169. From October 2017 to March 2018, she was the Regulatory and Compliance Director for Public Order and Security in Tirana, as well as being the Acting General Secretary of the Ministry of Interior. That role included, amongst other duties, monitoring the National Strategy against Trafficking in Human Beings and heading the Responsible Authority for the Identification, Referral and Protection of Victims and Potential Victims of Trafficking. Before that, she was the Director of the Anti-Trafficking Unit in Tirana and then the General Director for Anti-Trafficking and Asylum.
170. Ms Trimi worked for the Albanian State Police between June 2001 and April 2015, for the final nine years of which she was the Chief Commissar of the Illicit Trafficking Sector of the Organised Crime Directorate. Before then, she had roles in child protection and foreign dignitary protection. She has a Masters degree in Global Crime, Justice and Security Studies from the University of Edinburgh but her first degree is in law from the University of Tirana.
171. Ms Trimi’s research for the purpose of this hearing differed from the appellant’s experts, in that she sent a series of questions to a number of anti-trafficking actors and she attached their answers to her questions to her report. Her sixty page report concluded with a summary of her conclusions which we reproduce in full:

Albania's approach to identifying and protecting traﬃcked males involves a comprehensive and multi-agency approach that is grounded in both national legislation and international standards. Although there is no singular proﬁle for traﬃcked Albanian males, there are consistent patterns that emerge in reports and investigations. Minors or young men from impoverished, marginalized, or unstable family environments, who have a history of school dropout, working in informal labor, unsafe migration, or being exposed to violence and neglect are often victims. These vulnerabilities may be exploited by traﬃckers to force victims into begging, criminal activities, and labor traﬃcking, both domestically and abroad.

Recruitment processes for male VoT are similar to those for female VoT. Evidence indicates that men are predominantly recruited by individuals within their social circles including acquaintances, relatives, or fellow villagers, rather than by strangers. Additionally, social media platforms have increasingly played a pivotal role in the recruitment of individuals, particularly men, into activities related to the production and distribution of narcotics, including both street-level distribution and the indoor cultivation of cannabis.

Available information on risks from organized crime upon return remains limited and largely based on media reports and testimonies of returnees focusing on re-engagement with criminal networks to secure re-emigration through other channels.

Albania demonstrates a structured and increasingly coordinated approach to preventing and deterring the re-trafficking of male VoTs, combining state-led initiatives with strong engagement from civil society. The MoI has undertaken national awareness raising activities aimed at improving identification and coordination among institutions.

Albania has established a comprehensive legal and policy framework to support the reintegration of returnees, including VoTs. A number of assessment reports recognize [sic] country’s progression in strengthening anti-traﬃcking law enforcement eﬀorts and its eﬀorts to protect victims of traﬃcking including the signiﬁcant increase of the social fund for the service providers.

Overall, reintegration services for VoTs in Albania have demonstrated positive and tangible results, particularly when assistance is provided in a comprehensive and coordinated manner that includes accommodation, assistance for employment, psychosocial support, and legal aid. Such integrated approaches have contributed to victims’ empowerment and long-term stability.

However, several challenges continue to limit their eﬀectiveness, including limited and/or donor-dependent funding, social stigma, the lack of sustainable employment opportunities and the lack of any long-term monitoring mechanisms. While current interventions play a vital role in empowering victims and facilitating reintegration, greater eﬀorts are needed to enhance their sustainability, expand geographic coverage and strengthen institutional ownership so as to meet Tier 1 standards.
172. Ms Trimi was asked 32 written questions by the appellant’s representatives, prompting answers which spanned a further 16 pages. Ms Trimi then gave evidence before us during the third and fourth days of the hearing. As we have already noted, we agreed to hear from her slightly later in the day to accommodate the time difference between London and New York.
173. The appellant submitted that Ms Trimi had “done her best to help the Tribunal” but that she had a lack of recent experience in a full-time anti-trafficking capacity. The appellant noted that Ms Trimi had not set foot in Albania since 2019 and submitted that her expertise was therefore largely out of date. She had accepted that she was not an expert in shelters or in relation to the effectiveness of other reintegration or protection aids. Her expertise was in relation to the framework which she had written, in respect of which she was not properly impartial. She had sought responses from NGOs because she accepted that she could not “just do it from my knowledge”. She was more appropriately categorised as a witness of fact and the Tribunal was invited to approach her evidence on that basis. She had also made comments about economic migrants exploiting the asylum and trafficking systems of the UK, which were irrelevant and were said to betray a lack of objectivity.
174. For the respondent, it was accepted that Ms Trimi had not been to Albania for seven years but it was submitted that she had invaluable experience “at the coalface”. She remained a consultant in the field despite her current employment and she has her finger on the pulse. She was on first name terms with the NGO interlocutors and was clearly trusted implicitly. She was a model expert who acknowledged her limitations and did not engage in advocacy. The suggestion that she was marking her own homework should be rejected as she was evidently content to be critical when appropriate.
175. We reject some of the appellant’s criticisms of Ms Trimi’s evidence, and we do not entirely accept others.
176. We reject the suggestion that she is not an impartial witness because she co-authored the Albanian SOP and referred to it in her oral evidence as a “good document”. As Ms Trimi made clear in her oral evidence, she was not the sole author of that document and it was the product of considerable work which involved a number of governmental and non-governmental stakeholders. This case, in any event, is primarily about the effectiveness of that framework as regards male VOT, and there is no real sense in which Ms Trimi was invited to “mark her own homework”.
177. Nor did we detect any tendency on Ms Trimi’s part to seek to give the framework or its implementation a clean bill of health; as Mr Hansen submitted, she was entirely content to criticise where criticism was warranted. The most obvious example of that was Ms Trimi’s readiness to agree with Mr Malik’s suggestion that the absence of a dedicated male shelter represented a “significant gap” in the state provision for male victims. In response to a subsequent question, she was content to accept Mr Malik’s suggestion that she had consequently been wrong to suggest in her report that male and female victims receive equal services.
178. Ms Trimi was also content to agree with Mr Malik’s suggestion that it generally takes “much longer” for a VOT to reintegrate into the community than the 3-6 months for which they were provided with assistance by NGOs such as Different & Equal. She also accepted that the SOP makes no specific provision for those who are accepted in the UK to be VOTs and then subject to an enforced return to Albania. Ms Trimi also readily accepted that corruption remains a problem in Albania. These responses reflected the tenor of her evidence as a whole, in that she was evidently not seeking to maintain that the anti-trafficking system in Albania was perfect, and she was prepared to make realistic concessions in response to questions put by Mr Malik. We reject the suggestion that she was not impartial by reference to her previous employment.
179. We also reject the suggestion that Ms Trimi’s decision to make reference to articles in The Sun and the Daily Telegraph (about Albanians willingly coming to the UK to work in intensive cannabis grows) gives an indication that she is less than impartial. Mr Malik suggested to her that her reference to these articles was outside her instructions and indicated a degree of cynicism on her part. We reject the suggestion that Ms Trimi was merely on a frolic of her own when she made reference to this material. The question that she was asked was to do with the circumstances in which potential VOTs were recruited and the lengthy answer which she gave covered the spectrum of cases in which people were deceived by traffickers or family members. She went on to consider the growing phenomenon of social media recruitment but she noted, in covering that topic, that there had also been some reports of Albanian criminals using social media platforms to recruit knowing participants into such illicit activity. We note that similar evidence was given by Dr Hoxhaj of University College London to the Home Affairs Select Committee in 2022. We do not consider that Ms Trimi was demonstrating cynicism or partiality in answering this question; she was attempting to give a full account of the ways in which individuals are recruited. She might have lost sight of the focus of this case – which only concerns VOTs – but we consider that to have been merely a slip in her focus.
180. We do not entirely accept the submission that Ms Trimi’s opinions are deserving of less weight because she has not had recent experience of the situation on the ground in Albania since 2019. It is clear that she has not been to Albania for seven years. It is also clear that her full-time employment has not concerned VOT from Albania since that time. Her lack of recent hands-on work with VOTs was the subject of the second written question which was put to her by the appellant’s representatives. She gave a detailed response in which she provided details of the various trafficking-related training she had received between 2021 and 2024. In response to the tenth question posed by the appellant’s representatives, she detailed the part time work she had done in relation to human trafficking in Albania since 2019. Her response, which we need not detail in full, revealed that she had acted as a consultant, expert and trainer in various initiatives throughout that period, often at the invitation of the OSCE. Most recently, between 18 June and 30 November 2025, she was engaged as an expert to “lead the development of the NRM work plan chapters focused on multi agency cooperation in the NRM to prevent and investigate technology-facilitated human trafficking”. Whilst we accept, therefore, that Ms Trimi’s expertise might not be as honed as it was when she was on the ground in Albania before 2019, she is still recognised in Albania as a leading figure in the development of anti-trafficking measures. As Mr Hansen submitted, her ability to contact various key stakeholders in Albania for the purpose of researching her report is a clear indication of the regard in which she continues to be held.
181. Nor do we accept the submission that Ms Trimi should be considered to be a witness of fact rather than an expert witness on account of her reliance on the answers she gathered from NGOs operating in Albania. Evidently, by reference to her training and her extensive professional experience at the heart of Albanian anti-trafficking initiatives, she has knowledge which is beyond that of the lawyers and the tribunal. The fact that she made contact with a range of relevant actors in an attempt to ensure that her report reflected the situation on the ground serves, in our judgment, to enhance the weight which should be given to her report. The fact that her report is based partly upon her own knowledge and partly on that research does not remove her from the category of expert witness and place her in the category of a witness of fact. So much is clear from the judgment of the Supreme Court in Kennedy v Cordia [2016] UKSC 6; [2016] ICR 325 at [39]-[44].
182. We were more concerned by another matter which arose during Ms Trimi’s oral evidence. It concerns a figure to which we have already referred and to which we will also need to return. It is the assertion at [5.9] of Ms Trimi’s report that “the risk of re-trafficking is low, and I would not disagree with the CPIN assessment of 2-5%”. As we have already observed, there are difficulties with the figures in the CPIN, based as it is on a single source which makes no distinction between males and females. In his cross-examination of Ms Trimi, however, Mr Malik focused on two further difficulties with the figure. The first was that the assessment of future risk is necessarily fact-specific and unquantifiable in the abstract. The second is that none of the source material which Ms Trimi cited before accepting that figure, was rationally capable of supporting it. We agree with both of those observations, and it was a matter of concern for us that Ms Trimi felt able to agree with the CPIN in this respect.
183. Overall, therefore, we considered that Ms Trimi was a knowledgeable and capable expert witness who had participated in Albania’s anti-trafficking systems at the highest level. We considered that she was no longer involved in that system on a day-to-day basis but that she had continued to participate as a consultant and that she had augmented her own knowledge by undertaking valuable research with actors on the ground. Whilst we had some concerns about the methodology in her report, we were generally assisted by it and have attached weight to it accordingly.
184. Having made reference to the background material and to the expert evidence, we turn to our analysis of the issues, as refined to focus in particular on the situation of adult male VOTs.

Country guidance analysis
Issue 1 – Is there a typical profile for a male VOT from Albania? If so, what is it?
185. There is substantial agreement between the parties on this issue. They agree that there is no typical profile for Albanian trafficked males. Certain common themes are encountered amongst those who have been trafficked. Often they tend to: be teenagers or young adults; come from less affluent or marginalised backgrounds; have received a limited education; have experienced domestic violence or neglect. However, male VOTs might become vulnerable to trafficking for a variety of reasons, and come from all parts of Albania and from varied social backgrounds.
Issue 2 – What are the risk factors that may lead a male from Albania to become a VOT?
186. In this respect, there is also a good measure of agreement between the parties. It is for that reason that it is not necessary for us to subject the evidence on this subject to the degree of fine analysis which is appropriate for a contested issue. The parties agree, as do we, that the list of factors set out in TD & AD applies to men as it does to women, with the exception of the fourth factor (presence of an illegitimate child).
187. The respondent sought to highlight the strong culture of economic migration from Albania, as highlighted in the UNHCR Guidelines at [15]. We bear that context in mind but as Mr Hansen clarified, this country guidance is not aimed at addressing abusive or false asylum claims, and its focus is upon accepted male VOTs.
188. We accept the evidence given by Mr Carswell about the way in which VOTs are selected by their traffickers. He was asked by Mr Hansen about the way in which many Albanian males evidently travel illegally to the UK without becoming victims of modern slavery, whereas others who make the same journey using the same ‘agents’ find themselves exploited. He explained that the individuals who arrange such journeys will select the most vulnerable individuals to exploit because it is the will of those individuals which is more easily subverted.
189. The experts agree that the sources of such vulnerability are many and varied and that they can be complex and overlapping, as submitted at [24] of the appellant’s closing submissions.
190. Socio-economic factors play an important role. We have been particularly assisted by section 2 of Ms Trimi’s report in that respect. In common with the evidence given by Stephanie Schwandner-Sievers to Asylos, each of the respondents to Ms Trimi’s questionnaires highlighted poverty as a key vulnerability. The experts agree that Albanian men and boys are responsible for maintaining their families and a male from a family with low social or economic standing (the first of the TD & AD factors) is more likely to find himself in an exploitative situation than one who is well off.
191. Education is the second of the TD & AD factors (the level of education of the victim and his family) and is related to the first, in that a male with a better standard of education is more likely to be able to find legitimate employment and less likely to accept the lure of false promises of lucrative legitimate employment in the UK, whether made in person or online.
192. Health. There was also broad agreement between the parties and the experts that the person’s state of health, and particularly their mental health, is relevant. Again, when seen through the eyes of the trafficker, the logic is straightforward and undeniable, in that a person who is suffering with poor mental or physical health is likely to be less able to resist the demands which are ultimately made when the promise of regular employment in the UK transpires to have been false. The third risk factor in TD & AD applies equally to males as it does to females.
193. The fourth factor concerns the presence of an illegitimate child and is not relevant to males.
194. Area of origin. It is important to emphasise, as we have above, that trafficked males come from all over Albania. The area of origin is important, however, because of the way in which it relates to the other risk factors. Those from the rural and conservative north of Albania are less likely to have access to regular employment or a good standard of education. They are also more likely to be involved in blood feuds or ostracised from their families because of the kanun-related concept of honour which continues in such areas.
195. Age. We accept that younger males are more vulnerable than older males, for the simple reason that they are often more easily controlled by those who would seek to exploit them. This may include family members or personal contacts who take advantage of their relationship and the innocence of the young person. Again, this factor goes hand-in-hand with the others. A teenager from an affluent family with a high level of education is less likely to be interested in, or susceptible to, the false promises of lucrative employment abroad made by a trafficker. A young man who received inadequate care or domestic violence, and who might have left school prematurely is likely to be even more vulnerable, and to succumb to such overtures.
196. Support network. Such support is often but not always provided by the family. A male who has no supportive network around him is more likely to be vulnerable, particularly where this factor operates alongside the others to which we have already referred.
197. In their closing submissions, the appellant’s representatives sought to extend the list of factors significantly, from six factors to a total of 13. In the final iteration of the submission (as delivered orally by Mr Erdunast), we were invited to add factors including poverty, blood feud, adverse childhood experiences, ethnic minority membership (particularly Roma or Egyptian), homelessness, drug addiction or previous criminality, limited employment opportunities and (possibly) LGBT identity. We agree with Mr Hansen, that there is a significant degree of overlap between the factors suggested by the appellant and those which are already found in TD & AD. The shorter list reflects the main risk headings and is more likely to be of assistance to decision makers. In our judgment, the better course is to adopt the TD & AD risk factors with minor amendment. We therefore set out below a non-exhaustive list of risk factors that may lead an Albanian male to become a VOT. It is important to bear in mind that the presence of multiple factors may compound or increase risk but one risk factor may be sufficient to make a person a VOT.

(i) Lower socio-economic status including homelessness
(ii) Lower levels of education and difficulty in securing legitimate employment
(iii) Ill health, whether physical or mental, including addiction
(iv) Originating from Northern Albania or a rural area
(v) Age, with younger men and teenagers being more vulnerable
(vi) A lack of a family or other support network, whether by reference to blood feud, criminality or adverse childhood experiences
(vii) Belonging to a minority ethnic group or having an LGBT identity
Issue 3: How are males from Albania lured or forced into trafficking?
198. In his closing submissions, Mr Hansen argued that the ways and means by which Albanian males are lured or forced into trafficking are “infinitely variable”. Whilst that is necessarily right, we consider there to be a common thread which runs through the evidence. A common pattern is that a young Albanian male who finds himself in financially straitened circumstances accepts an offer of claimed lucrative employment in the UK, only to discover en route or on arrival that he is to be exploited and forced to work in difficult and unlawful conditions, whether as a result of debt bondage, family pressures or because of threats to his safety or that of his family. Beyond that, we consider it undesirable to attempt to specify or define the way in which the journey from Albania to the UK transforms from one which often begins in a consensual way to one which is exploitative. In deference to the research before us, however, we note the following.
199. We have read and heard a good deal of evidence about the way in which a male VOT is introduced to a trafficker. We were referred extensively to Dr Davy’s May 2022 paper for UNICEF entitled Trafficked by Someone I Know but that paper largely concerned female VOTs. 30 people were interviewed, of whom 27 were female and 3 male. In any event, that study cannot properly be cited as evidence which suggests that most VOTs were trafficked by someone they knew, since the final criterion for inclusion in the study was “Having been trafficked by someone that they have a close connection to”. Putting that paper to one side, therefore, we see in the other evidence that male VOTs might be introduced to the trafficker by a family member or an OCG, whether knowingly or unknowingly, but that traffickers also recruit by making offers of employment, directly or by social media. We accept the evidence that even where OCGs do not directly recruit, their involvement in the process is often not far removed, given their wide-ranging reach and inter connectedness with communities.
200. The appellant’s representatives adopted Mr Carswell’s suggestion that Albanian males are always trafficked by OCGs but we considered him to be somewhat dogmatic in his evidence on this subject. He seemingly proceeded on the basis that a family member who supplied a VOT to an OCG for the purposes of trafficking was necessarily a part of that OCG, thereby adopting a criminal law “joint enterprise” approach. Other evidence suggests, however, that a range of actors might be responsible for trafficking a VOT. One of the NGOs interviewed for the 2022 FFM report, for example, reported that it was “sad to say that traffickers can be close family or relatives, so a cousin for example”.
201. The reality, in our judgment, is that the male VOTs interviewed by Mr Carswell, who are representative of the cohort under consideration in this case, are likely to have been trafficked by or with the assistance of an OCG. That is because a family member or other acquaintance would be unlikely on their own to have the wherewithal to bring them to the UK unlawfully or to instal them in a criminal enterprise such as an intensive cannabis grow. Other types of VOT considered in the evidence (female VOTs trafficked for sexual exploitation or ethnic minority children trafficked internally for forced begging, for example) might well have been trafficked simply by someone they know, to borrow Dr Davy’s expression.
202. We note and accept that Albanian OCGs are well established in Albanian communities and for this reason where initial contact for trafficking comes via a family member or acquaintance, this may soon lead to OCG involvement. It is unnecessary and undesirable to attempt to set out the myriad of ways in which that might take place. Mr Carswell gave an example of a family member introducing a potential VOT to a person who had made an offer of seemingly legitimate work during a conversation in a pub or restaurant. The initial introduction to the trafficking OCG by the family member might be well-meaning, as in that case, or it might be made in the knowledge of the fate which awaits the victim, as was seemingly so in this appellant’s case. Having considered the evidence as a whole, we consider that Albanian males who are trafficked to the UK are likely to have been trafficked by or with the assistance of an OCG.
203. What is not routinely encountered in the case of male Albanians is trafficking by way of abduction. Ms Trimi said that coercion/ kidnapping at the hands of OCGs happens but features less as a means of recruitment. The experts were broadly agreed on that, although we note at least one example in the background material of a victim who said that he was abducted and forced to work on a construction site and then in a cannabis farm in the UK in order to repay a debt: Underground Lives: Albanian Survivors of Modern Slavery, Hestia (2020).
204. The appellant’s representatives also invited us to accept that recruitment typically starts in Albania and transit across borders is facilitated by the OCG, often through a trafficking hub such as Brussels, with an endpoint in the UK. Again, the evidence does not lead us to draw such a definitive conclusion. Mr Carswell gave evidence that he had seen this pattern emerge from the interviews he conducted but no such common themes emerge from the rest of the evidence. Until the introduction of the European Travel Information and Authorisation System (‘ETIAS’) in late 2026, Albanian nationals may travel through the Schengen area without restriction. Mr Carswell had seen cases in which the individual was provided with a passport by an OCG but they may, of course, have their own passport which would enable them to travel. We are unable to be prescriptive about the ways in which people are recruited or transported. However, as we have already set out, we consider the appellant’s representatives to be correct when they submit that recruitment often involves false promises of employment. Mr Carswell, Dr Davy, Ms Trimi and the other background material spoke with one voice on that subject. One of the NGOs (Mary Ward Loreto) contacted by Ms Trimi stated that, in many cases, “recruitment began with what appeared to be a legitimate job offer or assistance for emigration”. Mr Carswell had not personally seen instances of such recruitment taking place online but the remaining evidence, as cited at [33] of the appellant’s skeleton argument and throughout Ms Trimi’s report, is clear about the increasing scale of that phenomenon. We consider it to be wholly unsurprising that recruitment of young people is increasingly facilitated via the social media platforms on which young people spend “significant amounts of time - often unsupervised”, as Dr Davy put it in her 2022 report for UNICEF. As one of the NGO spokespersons put it in an interview with Asylos in 2024: “TikTok is booming with these recruitment pages.”
205. Debt bondage is commonly encountered as a means of coercive control: 8.1.11 of the CPIN, citing UNICEF’s Evaluation report of November 2022. The experts largely agreed with that. But the ways in which it is brought to bear on a male VOT are many and varied. VOTs may be told that they owe money for their passage to the UK. They may be given goods or drugs for which a charge is subsequently imposed, or the traffickers might even claim that drugs for which the VOT was responsible have been stolen, thereby increasing their debt. Mr Carswell spoke to that phenomenon in his report, as did Mary Ward Loreto’s response in the 2022 FFM report, as cited in the 2024 Asylos report. The evidence also speaks to the role of moneylenders in Albania, who are likely (according to Mr Carswell) to belong to an OCG. Victims may be offered work in the UK in order to repay a debt incurred in Albania, only to discover that the debt has increased as a result of their journey. The appellant submitted that the level of the cost of the journey is not given at the point of recruitment. Whilst there is some evidence to suggest that many people do not understand the actual or purported cost of the journey to the UK, it is not possible to state as a rule that none will understand that cost. Some will understand that they have a debt to repay for transportation, only to discover that the way in which they are to repay it is not what they had expected.
206. We accept that violence is also used to subjugate VOTs once they are under the control of the trafficker. Violence may be actual or threatened, and against the VOT himself or family members in Albania. The evidence given by Mr Carswell and Dr Davy in that respect chimed with the other background evidence before us, including an example given by Mary Ward Loreto in which a trafficking gang in the UK showed the victim photos of his mother and sister being raped in order to ensure that he did not denounce the gang.
207. We also accept that other methods of control might be used, including the confiscation of personal items such as mobile phones (thereby giving the traffickers access to the family’s contact details); the manipulation of the victim’s sense of (financial) obligation to their family; and the threat of reporting an individual who is unlawfully in the UK to the Home Office.
Summary
208. Male VOTs are lured or forced into trafficking in a variety of ways including (but not limited to) the following: a young male finds himself in financially straitened circumstances, accepts an offer of claimed lucrative employment in the UK, only to discover en route or on arrival that he is to be exploited and forced to work in difficult and unlawful conditions, whether as a result of debt bondage, family pressures or because of threats to his safety or that of his family.
209. Social media plays an increasing role in the initial recruitment process. OCNs are likely to play a role in such trafficking, although it will be for an individual decision maker to consider the nature and extent of that role in a case in which it is disputed. Trafficking by means of abduction is not commonplace.
Issue 4. In particular, insofar as involvement in drug-related or other criminality is a factor which may lead to an Albanian man becoming a VOT, (i) how, in what circumstances and by whom are potential VOTs recruited; (ii) to what extent does an unwillingness to become involved in such criminality place a potential recruit at risk of persecution or serious harm; and (iii) to what extent is a returned male VOT at risk of re-trafficking or other serious harm from organised criminal gangs.
Issue 5. What is the nature of the risk on return for adult male VOTs, from (i) the original traffickers and (ii) others. Is it limited to re-trafficking or are there other material risks which might lead to persecution or serious harm? What influence does the passage of time have on the nature of the risk?
210. We consider that these questions can properly be addressed together. Although we are grateful for the separate submissions made by each party orally and in writing on the issues, there is evidently a good deal of overlap.
211. Issue 4(i) has been answered above. Recruitment into the cultivation and supply of illegal drugs in the UK is often by way of deception, with an individual being duped into believing that they will be able to secure lucrative legitimate employment, only to discover en route or on arrival that they are to work in drug supply or cannabis production. As we have said, recruitment takes place through social media, personal contacts and OCGs.
212. There was some disagreement between the experts regarding the extent to which Albanian men might willingly be brought to the UK to work in the drugs trade. Ms Trimi made reference to articles in the British press (The Daily Telegraph and The Sun) which drew on social media recruitment campaigns which made it quite clear that the role to be undertaken upon arrival in the UK was illegal. We note also the written evidence given by Dr Andi Hoxhaj of University College London to the Home Affairs Select Committee in December 2022. Dr Hoxhaj highlighted the Albanian tradition of migration, known as ‘kurpet’, and the high moral value associated with it. He made reference to Albanian OCGs “offering a free ride to the UK in exchange for employment in cannabis farming or other illegal and criminal activities for 12-18 months”.
213. For his part, Mr Carswell suggested that no one would willingly work in the harsh conditions of an intensive cannabis grow and that the ‘business model’ of the traffickers was one in which they maximised profits by the use of debt bondage and coercion rather than offering the gardeners a profit share or any other role other than menial work in very unfavourable conditions.
214. We agree with Mr Malik’s closing submission that the point does not really arise in this case. That is because we are concerned with accepted VOTs and a person who willingly comes to the UK to work in a shtepi barri (the colloquial Albanian term (as used by Ms Trimi in her evidence) for a property adapted for growing cannabis) will not generally fall within that bracket. We therefore make only the following observations. Where the point arises for consideration, it will be for the decision maker to decide whether the individual is a willing participant or a VOT. There are likely to be few willing participants in the light of the very harsh working and living conditions expected of gardeners, as described by Mr Carswell. The nature and extent of initial vulnerabilities will be particularly relevant when assessing whether the participant genuinely consented to be a gardener. It is also important to recognise that a person who was initially a willing participant might become a VOT as circumstances change including subsequent exploitation.
215. As for issue 4(ii), we largely accept Mr Carswell’s evidence that the success of the ‘business model’ described above, is contingent upon the OCG maintaining a climate of fear, which may include threats to the individual and their family members and/or enforcing debt bondage demands, whether in the UK or in Albania. A person who leaves, or attempts to do so, or who refuses to participate in the criminal activity in question is unlikely to be permitted to do so. Mr Carswell gave an example of one of his interviewees who had been beaten with a baseball bat and stabbed with a screwdriver after he had escaped. More importantly, as we have described above, the background material also contains examples of the most deplorable acts of violence being perpetrated by OCGs against the families of those deemed to be non-compliant.
216. In undertaking any assessment of prospective risk on return for an adult male VOT, it is obviously necessary to consider paragraph 339K of the Immigration Rules, the commonsense of which was underlined by the policing analogy which Mr Carswell gave in his oral evidence. He suggested that a house which had been burgled because of security vulnerabilities would remain at risk of burglary until the vulnerabilities had been addressed. Mr Hansen made a contrary submission, encapsulated in his suggestion that a victim who had been duped by a trafficker in the past would be less likely to fall for the same tricks again because they would be “once bitten, twice shy”.
217. It is also necessary to recognise that the risk upon return to an adult male VOT is of three potential types. There are two types of potential risk from the original traffickers: re-trafficking and reprisal. There is, in addition, a potential risk from other traffickers. It is necessary for a decision maker to consider each type of risk, taking particular care to address the personal characteristics of the VOT and what is known about the original traffickers.
218. The appellant’s representatives invited us to conclude that a returned male VOT “is in general at real risk of re-trafficking” unless the vulnerabilities that led them to be trafficked in the first place have been addressed. We set out our conclusions on that submission below. In summary, we accept the submission, but with qualifications.
219. We do not accept that a person who has escaped from a trafficking situation will necessarily be at risk from their original traffickers. Some trafficking outfits will be truly transnational and will be well equipped to pursue those who have escaped from them, whereas others will be smaller organisations who would be less able to do so. On the other hand, smaller organisations may have closer connections and knowledge of certain families, communities and parts of Albania. Some traffickers will have made individual threats to the VOT and/or to their family. They might have visited or harmed family members so as to reinforce any such threat. Some will have made it clear that a sizeable debt remains, others might not have done so, or may have indicated that a debt was all but paid off. These and all relevant considerations must be considered when assessing the existence of any risk of re-trafficking or reprisal at the hands of the OCG.
220. In considering the risk of re-trafficking for the purposes of issues 4 and 5(i), we find ourselves in some difficulty because of the challenges with aggregated data. It is clear, as we have already explained, that there is a particular problem in Albania with Roma children being trafficked by their family members for begging. Returning such a child to their family sadly brings with it a likely risk of re-trafficking which is reflected in the background material. In TD & AD, the Tribunal stated that “re-trafficking is a reality” for female VOTs and we recognise that female VOTs who are not rehabilitated may find that they have no choice but to submit to trafficking again in order to survive and / or prevent reprisals either to themselves or family members. Again, that risk to females is reflected in the material before us. We were not directed to any background material which directly concerned the wider incidence of re-trafficking amongst Albanian male VOTs who had been returned to Albania from abroad. We are therefore particularly reliant upon the country expert evidence, which must be considered together with the detailed country background evidence before us. There was stark disagreement between Ms Trimi and Mr Carswell in this respect.
221. Ms Trimi adopted the respondent’s suggestion in the CPIN that the risk of re-trafficking in any given case is low, and no more than 2-5%. As we have endeavoured to explain above, that figure is apt to mislead. It refers to the number of male and female VOTs who were re-trafficked from one service provider during a two year period, as summarised by one service provider. It cannot, on any logical view, support an assertion that the risk of re-trafficking for any given individual is 2-5%. The extent of that risk must depend on a thorough assessment of the facts; it is not possible to quantify the risk in any given case or more generally. We were somewhat surprised that Mr Hansen maintained the contrary stance when we pressed him on the point.
222. Mr Carswell maintained that the risk to a VOT on return was likely to be higher than that which they had originally faced unless their underlying vulnerabilities had been addressed. At [42]-[47] of their closing submissions, the appellant’s representatives adopted that stance, which they supported with reference to a number of points. They submitted that a victim’s personal circumstances might have worsened, particularly if they had been prosecuted since they were trafficked, thereby decreasing their chances of securing legitimate employment in Albania. There might also be additional vulnerability on account of mental or physical health problems resulting from the trafficking. The original gang might be “intimately familiar” with their vulnerabilities, enabling them to “tailor” their approach to the victim. The gang might also hold the individual responsible for a debt, and Mr Carswell was aware of gangs keeping lists of debtors.
223. There is now, and has been for some time, a steady stream of returns of accepted male VOTs from the UK. We were informed that 100 confirmed male VOTs were returned from the UK to Albania in 2025. It is tempting to observe in the light of that number (which is a fraction of the overall number of returns from across the EU) that there is no groundswell of concern amongst the NGOs that those who are returned are being sought out and re-trafficked by organised criminal groups. Mr Hansen made that very submission in closing; there was, he submitted, no evidence of systematic pursuit by OCGs. The difficulty with that process of reasoning is that very few returned male VOTs make themselves known to the Albanian authorities or to the NGO actors within the NRM. Those individuals do not frequently appear on the radar of the available service providers, as a result of which there would be no record of any subsequent re-trafficking. The same point was made by Dr Davy in response to the respondent’s question 84.
224. Having considered the evidence as a whole, it is necessary for the enquiry into the risks of re-trafficking and/or reprisals associated with adult male VOTs to take account of the two overarching matters under the general headings of vulnerability and information regarding the original traffickers.
225. Vulnerability. It is necessary to consider the individual’s original vulnerability and whether it has increased or decreased since they were first trafficked. This includes, in accordance with the guidance we give below, any reduction in vulnerability that could be brought about by the package of assistance and reintegration support, likely to be available to the adult male VOT upon return.
226. We consider that there is also a role in this part of the analysis for Mr Hansen’s “once bitten, twice shy” notion, albeit we would refer to it in different terms. As we have already recorded, the principal method employed for recruitment in cases such as this is one of deception, in which the victim initially believes that they are accepting an offer of employment overseas. An individual who has fallen for that lie on one occasion is unlikely to fall for it again, as held in AM & BM, at [170]. That does not mean that they are forever rendered immune to such offers; an adult male VOT who finds himself in straitened financial circumstances or in fear of threats, might succumb to an offer which is likely to result in exploitation, because he is left with no choice but to do so. In addition, the traffickers tend to use control methods which make it difficult to reject. Article 3(b) of the Palermo Protocol recognises that someone may be unwilling to become involved in criminality yet not ask to leave or flee on account of the control methods that have been used. The fact that an adult male VOT has already been taken in by false promises will necessarily be a relevant factor, amongst many, in any assessment of whether that specific individual is likely to be re-trafficked.
227. Original traffickers. It is also necessary to carefully consider what is known about the original traffickers: whether the trafficker was acting in a purely personal capacity, in collusion with an OCG, or as a part of an OCG; if an OCG was involved - the size of the operation, its level of organisation, its extent, intent and reach (bearing in mind that the nature of the power imbalance in the relationship between trafficker and VOT is such that the latter may have very little knowledge of these matters); any threats which have been made or acted upon in the past, including in relation to debt bondage; any connection to family members and acquaintances, and; any links to the community / area the individual and his family members originate from.
228. We also saw real force in the evidence which was given by Ms Trimi concerning the likely calculation which will be undertaken by an OCG in deciding whether to pursue an escaped adult male VOT. As the respondent observed, her evidence in this respect chimed with observations made in AM & BM, at [168]. It was Ms Trimi’s view that an OCG is likely to take a view about the damage which an escaped victim might be able to inflict on the organisation. She suggested that the OCG would consider the extent of the VOT’s knowledge about their operation, and would make an informed decision on whether it was necessary to silence him, whether by re-trafficking or by administering some form of threat or reprisal. It was her view that an OCG would be unlikely to pursue an individual unless they had tangible evidence which might be damaging to their operations in the event that he went to the authorities. By tangible details, she explained that she meant essentially something which might found a prosecution: the real identities of the traffickers, the specific location of their operations, or the way in which their money was stored or moved. Ms Trimi’s evidence also chimed with something said by Stephanie Schwandner-Sievers in the 2024 Asylos report:

If you have fled an exploitative situation, and the traffickers are worried that you might seek judicial redress […] you’re under a particular criminal threat to be found.
229. We do not for a moment suggest that an adult male VOT who has no tangible evidence against the OCG is unlikely to be pursued; this is merely a factor to be considered in what must necessarily be a fact sensitive analysis.
230. It is too simplistic to conclude that risk diminishes with time. This is because OCGs have been known to exact revenge long after individuals have escaped. However, we consider that the passage of time without incident might demonstrate that the original trafficker / OCG is no longer interested in pursuing the individual. It will be relevant to consider whether there have been any enquiries or threats made to the adult male VOT and his family members, bearing in mind that the fact of enquiries may not in some cases come to the attention of the VOT or their family members.
231. The risk of re-trafficking by a different trafficker also requires a nuanced assessment, focused principally on the vulnerability of the victim. This demands an assessment of both the extent to which that vulnerability has increased since the experience of trafficking either by the experience of trafficking or another and any steps which might be taken on return to reduce that vulnerability over time. Paragraph 339K will necessarily play its part in any such analysis.
Summary
232. We summarise our conclusions on issues 4 and 5 as follows:

(1) An individual who escapes from a situation of trafficking or otherwise manifests an unwillingness to be involved in drug-related or other criminality may be at risk on return to Albania. He might be at risk of re-trafficking and/or reprisal at the hands of his original traffickers or at risk of re-trafficking at the hands of another.

(2) It is not possible to quantify the risk of re-trafficking in any given case, whether at the hands of the original traffickers or at the hands of another. In considering the extent of any such risk, a decision maker who is satisfied that an individual has been the subject of past persecution or the threat thereof will consider that fact to be a serious indication of the risk of future harm unless there are good reasons to consider that it will not be repeated (paragraph 339K of the Immigration Rules refers).

(3) In considering the risk of re-trafficking or reprisal from the original traffickers, it will be necessary for decision-makers to consider:
(i) The circumstances of the individual and in particular his vulnerabilities, together with the reintegration assistance which is likely to be provided to the individual on return to Albania. In considering vulnerability to re-trafficking by deception, it will be relevant to consider that an individual who was previously duped by a trafficker will be aware of the risks associated with offers of the kind.
(ii) What is known about the original traffickers, in particular:
a) the size of the operation and its level of organisation;
b) any threats which have been made or acted upon in the past, including in relation to debt bondage;
c) any connection to family members and acquaintances;
d) any links to the community / area the individual and his family members originate from;
e) the extent to which the individual has tangible evidence against an OCG which might jeopardise its future operations;
f) the passage of time (because a significant period without interest or threat may indicate a lack of ongoing interest).

(4) In assessing the risk of re-trafficking at the hands of a different actor, decision makers should take account of the individual’s original risk profile and vulnerabilities and the extent to which this has changed or is likely to do so. In considering vulnerability to re-trafficking by deception, it will also be relevant to consider that an individual who was previously duped by a trafficker will be aware of the risks associated with offers of the kind.
Issue 6. Once an Albanian man has become a VOT, what are the aids to reintegration on return and what are the obstacles? In particular how are VOTs that have been trafficked by organised criminal gangs perceived on return?
Aids to reintegration
233. Institutional framework: It is not in dispute that Albania has a comprehensive framework of laws, strategies and policies dealing with human trafficking of males, females and children, with an associated package of measures that aid reintegration. That this framework has progressed in recent years is illustrated by comparing GRETA’s reports over time. GRETA adopts the use of three different verbs - “urge”, “consider”, and “invite” - which correspond to different levels of urgency for bringing the legislation and/or practice into compliance with the Trafficking Convention. GRETA explains that it uses the verb “urge” when it assesses that the national legislation or policies are not in compliance with the Trafficking Convention or when it finds that, despite the existence of legal provisions and other measures, the implementation of a key obligation of the Convention is lacking. In other situations, GRETA “considers” that it is necessary to make further improvements to fully comply with an obligation of the Convention. By “inviting” a country to pursue its efforts, GRETA acknowledges that the authorities are already on the right track and encourages them to continue existing action. GRETA’s third report in 2020, which (our emphasis) “urges the Albanian authorities to:… provide shelter, accommodation and access to other assistance services to male victims”, contrasts with GRETA’s fourth report in 2025, which (our emphasis) “considers that the Albanian authorities should make additional efforts to improve victim assistance and the economic and social inclusion of victims, in particular by:… providing adequate accommodation to male victims of trafficking”.
234. The National Strategy on Migration and Action Plan specifically acknowledges the need to “ensure the sustainable integration of returning Albanian nationals” and sets out a plan for doing so, recognising returnees as a particularly vulnerable group requiring targeted interventions. There is also the National Action Plan against Human Trafficking for 2024-25, the primary national policy document for combating human trafficking. This notes the overall implementation rate of the 2021-2023 plan as 89% and seeks to build on those achievements. This includes the establishment of new mobile units to identify VOTs and further extensive awareness raising initiatives. There is also a National Social Protection Strategy, 2024-2030.
235. We accept that the more specific framework of provision in place to support VOTs with reintegration has improved and can be described as comprehensive and detailed. It is only necessary to summarise that framework. Albania has a clear institutional and policy framework based around the Responsible Authority, the NRM, the SOP, as coordinated by the National Trafficking Coordinator who is the lead coordinator of all anti-trafficking efforts in the country. The NRM/SOP deal with identification and signpost the way to referral, protection and reintegration for VOTs. The new cooperation agreement on the NRM signed in June 2023 provides for consultation with VOTs through the Trafficking Victims' Advisory Board, which operates under NCATS. The OSCE provides technical assistance to Albania, especially in implementing the NRM.
236. The institutional framework is bolstered by a steady stream of reintegration initiatives undertaken by NGOs. We note Ms Trimi’s evidence:

In their written responses, MWL, Psycho-social Centre “Vatra”, D&E and NRCVT confirmed that both male and female victims of trafficking receive equal services from the moment of identification. The range of services provided include:
• fulfilment of basic needs (food, clothing, hygiene items)
• case management
• psychosocial support including individual counselling sessions
• legal assistance
• medical care and referral to health services
• employment support, assistance in accessing the labor market
• vocational training
• support to continue formal education
• financial aid for starting small businesses
• mentoring and monitoring throughout the reintegration process
• inclusion in different social activities to support social reintegration
• ongoing information about services provided in the community where they live
• mediation and empowerment of relationships with the family of origin or biological family
• possibility of safe accommodation until the victim is sufficiently empowered
• support with rent payments until the victim is granted accommodation bonus from the municipality
• Long term monitoring
• Support to victim’s family.
237. UK support: The UK also offers targeted support for Albania’s reintegration provision. The UK Ambassador to Albania’s letters dated 30 January 2023 and 20 February 2024 refer to a UK programme to reduce the prevalence of human trafficking, including funding three primary service providers to provide reintegration support. In addition, there is an £8.4m three-year project in North-East Albania aiming to improve the socio-economic conditions that often drive people to migrate illegally to the UK. Further, the Medaille Trust administers, through Vatra, an Albania Reintegration Programme supporting returning Albanian nationals. A 12-month support programme is offered focused on gaining employment, education or vocational training (including funding setting up a business) and personal development. The support available includes mental wellbeing and counselling, support on arrival including reception and transportation, and short-term accommodation.
238. Accommodation and other support: Safe accommodation is recognised as crucial to reintegration and it is necessary to consider the access to accommodation for adult male VOTs upon return. In terms of avoiding the risk of re-trafficking or being forced back into the trafficking network because there is no other choice in order to survive, and successful reintegration more generally, funded accommodation is key until such time as paid work can be secured. This is because the financial aid available to VOTs who are unemployed, is insufficient to pay their rent and other essential needs (see below).
239. We note that state funding to both government and NGO shelters has significantly increased but the system of accommodation in shelters has historically been dedicated to supporting women and girls. More recently two cohorts of men have been provided accommodation in the state shelter for defined periods. These examples do not mean that adult male VOTs who request and are deemed to require shelter accommodation are provided with it. Ms Pooley clarified that the provision of shelter to adult males were responses to specific cohorts in order to address unique challenges of non-Albanian male VOTs, at specific times. Ms Trimi accepted this when she gave her oral evidence. The picture that emerges for an individual adult male VOT who requests assistance with accommodation is that there is no shelter provision and they must rely upon accommodation in the rented sector with the assistance of NGOs or returning to their family with support, if appropriate.
240. It was submitted on behalf of the appellant that the provision of funded accommodation by the NGOs is only for a period of three to six months. This comes from Ms Trimi’s report at [6.42] in which she refers to Different & Equal’s response to her questionnaire. When asked what services were provided to male VOTs, Different & Equal explained that male and female VOTs received the same services, but adult males did not have a dedicated shelter and were assisted for a period of three to six months in rented apartments. When asked about the services they offered to male victims, their response about accommodation was “provision of safe and adequate housing until the case is resolved or strengthened, including support with rental payments until the recipient becomes eligible for a housing allowance”. Ms Trimi agreed in cross-examination that the assistance from NGOs would last from three to six months but she explained that after that time there was assistance to apply at municipalities to receive further assistance.
241. The IOM directory explains that Vatra gives housing costs assistance for up to 12 months. Vatra did not, in their response to Ms Trimi’s questionnaire, set out the length of their provision of housing or housing costs. The British Embassy’s letter dated 12 November 2025 refers to accommodation services for adult males being provided by Different & Equal and Vatra in supported rented apartments and support to access the municipalities’ housing programmes. It says that accommodation is provided “for the duration of the protection and reintegration process ranging from emergency stays of several weeks to long-term supported housing up to two years.” When Ms Pooley was cross-examined, she said that the housing offer from the NGOs was typically 6 months, but it could be extended depending on the individual circumstances. She also said that there were currently 11 male VOTs staying in apartments, she did not know if any of them had been there for more than 6 months.
242. Having considered all the evidence together, we conclude that the NGO’s normal offer of rented accommodation to adult male VOTs is limited to 6 months, but if there is the occasional need for longer term help this is likely to be able to be met. As noted in GRETA’s 2025 report and the Asylos report, NGOs are doing good work, but difficulties arise when VOTs leave the rented accommodation provided by NGOs.
243. A recognised VOT is entitled to a raft of support from the state. They are recognised as a special category of beneficiaries entitled to receive legal aid under law no 111/2017. VOTs identified by responsible stakeholders in the Ministry of Interior are included as a category of people covered by mandatory insurance of health cases (law 10383/2011 amended by law 141/2014) and Ms Trimi explains [6.36] that the responsible authority facilitates access to healthcare for potential VOTs as well. This includes assistance with obtaining health insurance cards, and access to primary healthcare services, including registration with a family doctor and medical follow-ups.
244. Both VOTs and potential VOTs are a priority group under law no 22/18 on social housing which also provides for rent subsidies which may cover up to 100% of the rent. Although VOTs are treated as a priority group for social housing and rent subsidies in legislation, there are many other priority need categories, and provision can be delayed through bureaucracy or the funding may simply not be available. Ms Pooley explained that in Tirana, the municipality can offer social housing or contribute towards rent for victims officially registered in the city, but in other municipalities, access to rented housing is often limited due to insufficient funding or the absence of social housing programmes.
245. VOTs who are unemployed and have a declaration from an appropriate organisation (such as one of the NGOs) that they are VOTs are entitled to state financial support of 9,000 Albanian Lek per month (approximately £79).
246. VOTs who wish to receive employment support are registered as job seekers at the migration counters of the National Agency for Employment and Skills (‘NAES’) with a view to facilitating their integration into the labour market. Jobseekers who have registered with the employment service may receive 100% of the minimum wage during the four months of training. VOTs can also access free vocational training in vocational schools across Albania but this is referrals based, through the NGOs supporting male VOTs.
247. GRETA’s 2025 report notes that 87 VOTs registered as job seekers at the NAES during the reporting period. In addition 24 victims or persons at risk of trafficking participated in internship programmes in private companies and 25 received support in starting their own business. However, in general terms, reintegration of VOTs remained challenging.
248. Awareness-raising: Some reports, such as the CPIN at [4.6.3], continue to refer to males appearing to have a low awareness of having been exploited/trafficked and being reluctant to seek protection. However, we note that Albania’s reply to GRETA’s third evaluation round records significant awareness-raising activity on human trafficking and that GRETA’s 2025 report acknowledges that “The National Action Plans for 2020-2023 and 2024 2025 make prevention one of their main objectives, with measures such as awareness-raising campaigns, information to vulnerable groups, such as children, Roma and Egyptians communities, asylum seekers and migrants, as well as social and economic measures for these vulnerable groups.” As already noted, the Ministry of Interior holds an awareness of human trafficking month in October each year and has reported that it organised a series of awareness-raising and sensitisation activities across all 12 of Albania’s regions. We acknowledge that Vatra reported that information on services dedicated to male VOTs remains limited.
249. In its written response to Ms Trimi, Different & Equal reported on the implementation of a range of preventative and awareness-raising measures, including campaigns in schools and through traditional and social media to promote recognition that males can also be VOTs, with information on their rights and available support services. They also reported on the establishment of four mobile units which not only facilitated the identification and referral of VOTs but also engaged in direct outreach to inform the public about the risks. Ms Trimi reached the following conclusion, which we accept:

Albania demonstrates a structured and increasingly coordinated approach to preventing and deterring the re-trafficking of male VOTs combining state-led initiatives with strong engagement from civil society. The MOI has undertaken national awareness and sensitization activities aimed at improving identification and coordination among institutions. The NRM members such as D&E, MWL, Vatra, Terre des Hommes and the NRCVT complement these efforts through targeted community outreach mobile units and reintegration programmes offering psychosocial legal and economic assistance. These initiatives have strengthened early detection and prevention capacities particularly at the local level.
250. The UK government funded a leaflet on support for Albanian nationals returning from the UK specifically to encourage take-up of services by adult males recognised in the UK as VOTs. Ms Pooley told us that if returnees had been accepted into the NRM in the UK, they should be provided with such a leaflet.
251. The KAP Survey 2025 shows some improvement in knowledge and attitudes over time. There is a good knowledge of forced criminality (82%) and forced labour (81%) involving Albanian adults abroad. Exposure to anti-trafficking campaigns is said to have significantly increased awareness and engagement, with social media and TV proving most effective. Young people exposed to awareness materials report higher knowledge of exploitation types, better understanding of reporting methods, and greater willingness to act.
252. Ms Trimi was the only expert to address awareness-raising in any detail. At [4.9] and 11.2.11 of her report, she observed:

For years now, awareness surrounding the involvement of migrants in indoor cannabis cultivation has increased significantly. This growing recognition has been driven by a combination of social media discourse, investigative journalism and audiovisual reporting. These channels have highlighted the complex realities faced by migrants, including the risks associated with unsafe migration and the potential for exploitation through criminal activities abroad. Awareness raising initiatives, led by the Ministry of Interior (MoI30) in cooperation with the NGOs, law enforcement agencies, Ministry of Education and other state and non-state agencies, focused on the links between irregular migration and vulnerability to coercion and involvement in illicit enterprises. These efforts aimed to inform both potential migrants and the general public about the dangers of unsafe migration and the importance of protective measures and legal pathways.
[…]
In my opinion, initiatives aimed at preventing human trafficking and raising public awareness about associated risks appear to have fostered a more informed and empathetic understanding of victimisation. Evidence suggests perceptions have shifted, particularly in urban areas such as the capital or other big cities. For instance, in 2014, a male victim publicly self-identified as a victim of trafficking having been exploited for labour in Africa.
Obstacles to reintegration
253. Having considered the evidence as a whole, we accept that the various awareness-raising campaigns undertaken by the Albanian authorities with the support of the international community have met with some success in addressing the problem. We note the vintage of the single example offered by Ms Trimi might suggest that the level of success is somewhat less than she suggested. On balance, we accept that initiatives described by Ms Trimi and in the reports have improved the level of knowledge and understanding of the risks of trafficking but there remains a considerable degree of stigma toward VOTs for a variety of inter-related reasons.
254. We have been taken to many reports seeking to analyse the framework of reintegration support available, together with the shortcomings and the obstacles that adult male VOTs face in accessing that support. We observed a tendency on the part of the Albanian authorities to list the support available in law or via new initiatives, without acknowledging the real difficulties some adult male VOTs have in accessing measures to support their re-integration and reduce the risk of re-trafficking.
255. We have assessed all the evidence and reach our own conclusions on the nature and extent of the obstacles to accessing such support with a particular focus on adult male VOTs. We have set out the main obstacles below under sub-headings but these are inter-related and complex. By way of example, Terre des Hommes described the multitude of obstacles frequently encountered by male VOTs: gender related stigma that hinders self-identification as a VOT, limited availability of male-specific services, mistrust toward institutions, and economic and social hardships that increase vulnerability to unsafe migration and re-trafficking. Ms Trimi described the overlapping obstacles in this way in her report:

The ability of returned male VOTs to access the protection that exists in Albania depends on a number of factors, including their effective identification and referral as VOTs rather than irregular migrants (assuming that they are genuine VOT), their willingness to avail themselves of the protection available, their willingness to report what has happened and cooperate with the authorities in any investigation, the availability and suitability of services, readmission dynamics. The gaps that sometimes adversely impact the protection for men include difficulties and issues around identification, limited or no male-specific shelters and reintegration services, police/prosecutor responsiveness (and occasional complicity), and weak follow-up and monitoring.
256. Dr Davy considered that male VOTs have access to specific reintegration policies and measures, but for each measure available there are practical challenges associated with victims’ access to the measure. In its 2025 report, GRETA concluded that it was “concerned about the numerous challenges faced by victims in their reintegration and underlines that such challenges may increase risks of re-trafficking”. According to GRETA this includes “significant gaps…in the effective investigation, prosecution and punishment of trafficking cases”. This observation has been adopted by the UNHCR in their February 2026 Guidance Note at [15b], as reproduced above, which notes that both authorities and service providers have documented VOTs being subjected to re-trafficking. UNHCR cite UNDOC 2022 which found that all dismissals of trafficking charges from the Prosecutors Office or in pre-trial hearings were due to incomplete investigations by the relevant authorities, yet no further investigations were carried out in response to those dismissals. We address the system for the detection and prosecution of trafficking in more detail when we address issues 7 and 8 below, but for the purposes of issue 6 we note that deficiencies and perceived deficiencies in the effective operation of the legal system can act as an obstacle to adult male VOTs wishing to access it.
257. We now turn to the overlapping obstacles to reintegration for adult male VOTs.
258. a) Identification. Whilst unwillingness to enter the Albanian NRM is not a bar to support, as reintegration support is available to potential VOTs, clear identification of male VOTs at an early stage assists with accessing reintegration support, which in turn reduces the risk of re-trafficking. All the experts agreed with this proposition. Ms Pooley confirmed that at the point of return, the respondent does not disclose to the Albanian authorities, details of whether a returnee is a VOT. This means that those adult males recognised as VOTs by the UK, are returned to Albania without being identified as such. Ms Trimi also indicated that the only application to VOTs returning from abroad within the SOP is to assist voluntary returnees. Ms Trimi explained that if an individual is returned without any information being disclosed about them, it would be the responsibility of the border police to interview them and if there were any indicators of trafficking, the SOP process would begin there. If a VOT recognised as such by the UK informs the Albanian border police he had been recognised in the UK, then he would be referred to a service provider. This means that the system of identification in practice depends on the VOT self-identifying or disclosing indicators of trafficking.
259. The SOP establishes a series of steps to ensure the safe assisted voluntary return of VOTs. In accordance with the NRM, the Albanian authorities must refer to the Responsible Authority all VOTs and potential VOTs that are communicated or identified through foreign authorities. Ms Trimi accepted that “there is no verifiable evidence on how Albanian male VOTs identified abroad are referred to and assisted within the NRM framework upon return” and that in her experience “effective information exchange between authorities and service providers in both the country of destination and Albania proved to be crucial for a successful reception, referral and rehabilitative process”. Ms Trimi highlighted the need for timely and detailed information-sharing to facilitate accurate risk assessments, which would inform accommodation options, tailored assistance and protection measures. As Ms Trimi put it in her report, the willingness of adult male VOTs to engage with the authorities and benefit from available protection mechanisms “constitutes a critical factor in determining the effectiveness of protection upon return.” Ms Trimi also said this: “If a returned male is not identified as a VOT at first contact, he will probably not access protection services or legal rights though this may also be by choice.”
260. Ms Trimi’s report also highlighted the increase in the number of male VOTs identified every year. By way of example, the 2025 TIP report identified 178 VOTs (17 men, 49 boys), compared to 110 in 2022 (8 men, 42 boys). Ms Trimi concluded that this increase in identification, reflects a growing recognition of male VOTs among service providers and institutions. However, it seems to us that this increase in identification of male VOTs is still at relatively low levels when compared with those accepted VOTs returned to Albania by the UK alone. Home Office statistics indicate that meaningful numbers of accepted male VOTs were returned from 2021 onwards and relatively large numbers from 2023 onwards totalling in 2023, 199 (90 enforced returns, 109 voluntary); in 2024, 312 (139 enforced returns, 173 voluntary) and in 2025, 222 (100 enforced, 122 voluntary). Ms Trimi was not asked about this, but the large number of voluntary returns of male VOTs as compared with the relatively few assisted by the NGOs, suggests that even those returning voluntarily do not wish to disclose that they are VOTs.
261. Where, as is the case for UK returned Albanian adult male VOTs, there is no identification or communication of the fact they are VOTs, accessing reintegration is made more challenging, particularly in the context of the stigma which male VOTs can experience, the shame they feel, and their mistrust of the Albanian authorities as we set out below. Nevertheless, as we have set out above, returnees are made aware of the support available on return and as we explain below, their initial point of contact for the provision of services is likely to be NGOs who do not stigmatise VOTs. We consider that it will generally be reasonable for an adult male VOT to identify himself as a VOT recognised as such in the UK and thereby access the protection available.
262. b) Vulnerability and engagement. A common theme running through the country materials and repeated in the reports of Ms Trimi and Dr Davy is the reluctance of male VOTs to engage with the services available through the NRM. The reasons for this are also complex and overlapping, ranging from stigma to mistrust for reasons relating to perceived corruption (such as the fear that an individual’s return risks being notified to an OGN who has infiltrated or bribed state officials) and / or deficiencies (such as that identified by UNDOC above in relation to the lack of investigation regarding prosecution dismissals). We address corruption in more detail under issue 7 below. At this juncture we note that corruption and Albania’s reputation for it are amongst the barriers to adult male VOTs approaching officials with trafficking concerns or being willing to identify themselves as VOTs.
263. Adult male VOTs may choose not to identify as a VOT or not to engage or to only engage partially. The possible reasons for not engaging include mental and physical health concerns. In addition, their reasoning may be inter-linked with the factors we have addressed above and below in relation to identification, stigma and fears relating to corruption. Separately, there may be no engagement, not out of individual choice but because support or the specific support required in an individual case may not be available for reasons relating to resourcing, capacity and bureaucracy issues, which we also address below.
264. c) Social mores, attitudes and stigma. Prevailing social mores in Albania seek to portray men as strong and therefore unlikely to be VOTs. These mores also act to discourage male VOTs from seeking assistance for reasons relating to shame, fear and anxiety. There are repeated references in the country background material to the lack of knowledge on the part of Albanians regarding the fact that males can be trafficked, as well as the stigma they fear if identified as such.
265. Dr Davy made it clear that male VOTs are not likely to present themselves to state services to receive reintegration assistance for reasons relating to patriarchal attitudes in Albania regarding men, and the desire to hide their status as a VOT. She also highlighted the practical difficulties in keeping their VOT experience and status confidential and the lack of privacy in state offices. In addition, some concern was expressed amongst the appellant’s experts, and by Dr Davy in particular, about the ability of VOTs to access the support to which they were entitled once they had been formally recognised as such. That includes housing and financial support. It was Dr Davy’s view, as stated at [44] of her report, that “victims who have attempted to access state services have reported experiencing discrimination, intrusive questions, and dismissal when requesting the support”. In her oral evidence, she went a stage further, describing the treatment of VOTs in government offices as “terrible”, stating that they would be “ridiculed and turned away”. She subsequently said that female VOTs were “not believed and sent packing”. In reaching those conclusions, Dr Davy drew on a report she had written for UNICEF in 2022, in which she had reported that VOTs often faced “stigma when attempting to access state services such as employment and financial support.” When pressed on the point in cross-examination, however, Dr Davy was constrained to accept that she had based her view on the experiences of a single female interviewee who had felt belittled and been turned away by staff at an NAES office, and was unable to give other examples of such discrimination, other than to say that it was also mentioned in “other reports”.
266. We have considered the evidence for ourselves. We note that the 2024 Asylos Report dealt with stigma affecting trafficked men and boys at section 1.6. Most of that section refers to what might be called “internal stigma”, of male VOTs refusing to accept that they are VOTs because of the patriarchal Albanian mindset. Different & Equal reported in October 2022 that “men feel they have to be strong and not ask for support”. In 2023, however, a representative from Terre des hommes (an NGO which is involved in anti-trafficking efforts from the transnational level to the local level in Albania) made reference to VOTs encountering “extremely strong” stigma in state offices upon declaring that they are a recognised VOT. But those comments appear to have been directed to the likelihood of men and women admitting in public that they had been the victims of sexual exploitation, whereas the source suggested that the “general attitude” towards labour trafficking might be that it was “not that big a deal”. Having considered the evidence as a whole, we have not detected a solid foundation for Dr Davy’s conclusion that an Albanian man who claimed benefits as an accepted VOT as such in a state office would necessarily be met with the derision she suggested.
267. Having considered the responses from various organisations, Ms Trimi acknowledged the interrelated obstacles impacting access to protection and rehabilitation services but described stigma as a “key obstacle” (amongst many others) preventing men from self-identification or being recognised as VOT, leading to shame, fear and reluctance to seek assistance. We also note the 2022 FFM report records being told by an employee from BIRN, a non-governmental media organisation, that male VOTs were not seen as victims, and by the General Directorate for Social Services in Tirana that: “the patriarchal mindset prevails here and men are not viewed as VOT, though maybe boys and minors could be”.
268. Awareness-raising may have increased the understanding of male trafficking for criminal exploitation but attitudes rooted in long-standing social mores can be very difficult to change. We accept that negative views and discriminatory attitudes toward VOTs generally and to males for failing to live up to patriarchal ideas on masculinity, may deter an adult male VOT from seeking support, due to fears of encountering discrimination, stigma and shame. However, it is important to note that the evidence suggests that discrimination is very unlikely in practice to emanate from one of the NGOs supporting VOTs. Indeed, the evidence overwhelmingly demonstrated that the NGOs treat male VOTs with respect and kindness. For these reasons, prevailing social mores may discourage an adult male VOT from seeking reintegration support, and this can be exacerbated where he suffers mental ill-health, is disabled or belongs to an ethnic minority, but any such subjective concerns vis a vis NGOs are not well-founded.
269. d) Fear: Reintegration can be more challenging where adult male VOTs continue to fear the risk of being targeted by an OCG to whom the VOT may be indebted or from whom the VOT may have escaped. This can cause increased anxiety, reticence to engage out of fear of being ‘discovered’ and act as an obstacle to accessing support, even where the fear is not objectively well-founded, as to which we recall what was said (in the context of deportation) at [77]-[78] of SSHD v AB [2026] EWCA Civ 230; [2026] 4 WLR 20.
270. e) Economic climate: The Albanian informal economy accounts for about 27% of GDP with one-third of employees working in the black market, which is precarious, unregulated, and often exploitative: [5.5.3] of the UNDP Development Finance Assessment refers. In these circumstances, even where employment is found, it does not necessarily achieve integration. This can be compounded by debt-related pressures. Dr Davy also pointed out that few VOTs register for the employment support service because they are aware of the lack of decent job opportunities available to VOTs through the service, as well as the length of time it takes to find a job after registration.
271. f) Capacity, resourcing and bureaucracy: The evidence suggests there may be limited capacity to assist adult male VOTs to reintegrate. For present purposes we deal with support more broadly but we acknowledge the absence of male shelters, which we turn to in more detail below.
272. The CPIN states that Different & Equal has capacity to accommodate 25 male VOTs and Vatra has capacity to accommodate 5 male VOTs. By contrast, as set out above, the annual number of male Albanians recognised as VOTs on positive conclusive grounds by the UK alone, has been significantly higher than this.
273. On the other hand, there is considerable evidence that Albania will continue to implement effectively its commitments in the framework of the Trafficking Convention and ECHR with regard to the treatment of adult male VOTs. There have been clear indications that should there be a need to increase capacity, support is scalable with the necessary funding and lead-in time to recruit and train additional staff. The CPIN notes that an official from Different & Equal said: “The capacity for shelters is good up to now” and the 2022 FFM report records an interview with Another Vision where the representative is asked: “What is the capacity of support shelters for victim of trafficking (VOT)? A… Thus far, in regard to identified potential victims of trafficking (PVOT) or VOT cases, the coalition have managed to respond to 100% of all cases, either identified or referred to us.” In its letter to the Home Office dated 12 November 2025, the FCDO stated that male VOTs are assisted with “the full package of services based on their needs: medical assistance, food packages and hygienic supplies; basic needs such as clothes, psychological counselling, legal assistance, assistance to education and attending school, professional courses/vocational training, counselling and support for employment; internship, support for opening small businesses, social activities, financial support and long term accommodation, information on available services in the community and respective contact information, monitoring and ongoing follow up.”
274. Notwithstanding these generalised, positive statements, there remain gaps in the provision of reintegration services. Ms Trimi acknowledged that “media articles and independent NGO reports highlighting that returnees frequently face economic hardship and social reintegration challenges, whilst tailored reintegration programs are typically project-based and unsustainable”. She referred to the overall impact of the steps aimed at preventing and deterring trafficking as “somewhat uneven and dependent on funding which effects continuation and geographic coverage” with gaps in tailored services for men. Whilst funding of reintegration mechanisms has increased, this remains uneven and challenging in many respects. GRETA’s fourth 2025 report acknowledged the increase in state funding to shelters but noted that it continued to be considered insufficient to meet victims’ needs. In particular, it only covers salaries of staff and food for victims, excluding other significant expenses such as operational or maintenance expenses. As an example, the annual budget of Another Vision’s shelter is about €340,000, but only about 26% is covered by state funding. GRETA therefore concluded that NGO shelters are extremely dependent on external funding, which is not necessarily sustainable.
275. Asylos and GRETA have highlighted that the package of the social services provided by the state for VOTs is insufficient to live on, such that recovery is severely impeded. Dr Davy drew attention to the duration of time it takes for paperwork to be processed and support received as a “major barrier”. Granting requests for financial assistance is ad hoc and dependent on when the local authority has the funds to provide this assistance. Dr Davy also highlighted that VOTs seeking to access the NAES must wait several months for their documents to be processed, and then often for approximately another five months until they can find a job. This brings with it financial instability, anxiety and increased vulnerability. Access to free vocational training is referrals based, so this is limited by the capacity of the NGOs. We note Professor Dalakoglou’s view that inadequate financial aid exacerbates victims’ marginalisation and deters reintegration, and this must be viewed against an economic climate in which most Albanians are excluded from pensions, sick pay, or unemployment support because these depend on insurance contributions and only 44.5% of the working-age population contribute to social insurance, particularly those in informal or seasonal work: [4.1] of the International Labour Organisation’s Review of Social Protection Systems in Albania, 2021.
276. Mental healthcare can be critical to VOTs’ recovery and reintegration but there are very few trained psychologists, and even fewer psychiatrists (approximately 1.6 psychiatrists per 100,000). Upon referral to Different & Equal or Vatra, the adult male VOT will undergo an initial health assessment and psychologists within those NGOs provide trauma informed counselling and refer them to public psychiatric services where needed (see FCDO letter of 12 November 2025). Nevertheless Another Vision noted in their response to Ms Trimi that there was an absence of targeted programmes for the psychological rehabilitation of men with complex trauma. Different & Equal reported that certain regions in Albania lack adequate services and those in rural and remote areas have significant barriers in accessing services and relevant information.
277. There are therefore clearly resourcing concerns but in general, those adult male VOTs wishing to access reintegration support have been proactively and positively assisted by NGOs to do so within the broader state-supported institutional framework. In addition, deficiencies must be viewed alongside all the other support available to adult male VOTs. Vatra told Ms Trimi that the high number of boys and men returning from the UK have been supported under a rehabilitation and economic reintegration programme by the Home Office and the Medaille Trust, running through Vatra. There is therefore a wide variety of services and provision to assist adult male VOTs, which some have accessed, and there are success stories of male VOTs achieving skilled work such as a cook or mechanic or setting themselves up in business, but for others there remain economic and bureaucratic constraints.
278. g) Specific gaps for male VOTs: The general lack of adult male VOT shelter provision denies those who require it a higher and more intense level of protection, support and security. We note Ms Trimi’s summary of the written responses she received from the NGOs, which described male and female VOTs as receiving “equal services from the moment of identification”. However, as she accepted in cross-examination, there remains a significant gap for adult male VOTs because of the absence of shelter provision for them. As Ms Trimi recognised, high security shelters offering secure accommodation for VOTs, “is particularly critical for victims involved in legal proceedings or those who have cooperated with law enforcement” and generally VOTs “who received comprehensive support were significantly prompter and more willing to cooperate with law enforcement agencies”. It follows that the absence of shelter accommodation for adult male VOTs may be a factor militating against cooperation with self-identification, law enforcement and reintegration, depending on the extent of individual needs.
279. The absence of male shelters and the need to depend upon rented or family accommodation, can also mean closer links with or reliance upon the family and / or community, which may have been involved in the original trafficking or have links to OCGs.
Summary
280. There is no shelter provision for individual adult male VOTs. A returning adult male VOT who is not able or willing to return to their family must rely upon accommodation in the rented sector with the assistance of NGOs. Such support is provided after initial identification as a VOT by an NGO and without the need for a formal declaration of that status.
281. The normal offer of rented accommodation from an NGO is limited to six months, but the occasional need for longer term help is likely to be able to be met. Whilst the NGOs current capacity for male VOTs is relatively limited, there are clear indications that should there be a need to increase capacity, support is scalable with the necessary funding and lead-in time to recruit and train additional staff. The NGOs are widely acknowledged to be supportive and to assist VOTs proactively and positively and without discrimination.
282. Once a VOT leaves the rented accommodation provided by NGOs, they are required to obtain a formal declaration of their status in order to access the support provided by the Albanian state. Such declarations must be obtained by attending an interview with a specialised police officer and a social worker. There is a comprehensive and detailed framework of provision to support recognised VOTs with reintegration including the NRM and SOP as well as some support in employment, limited financial assistance, livelihood skills, housing and access to healthcare.
283. The institutional framework is bolstered by initiatives undertaken by NGOs who will assist male VOTs to access state or municipal reintegration support but also run their own support programmes including fulfilment of basic needs, housing support, financial aid to start a small business and psychological counselling.
284. For each reintegration measure available, there are practical challenges associated with access to the measure. Whilst VOTs are a priority group for social housing and rent subsidies, and NGOs will assist the VOTs to access what is available, there are many other priority need categories and state and municipal funding may simply not be available for such programmes.
285. In addition, VOTs may encounter a range of obstacles to access these aids to integration. Prevailing social mores discourage an adult male VOT from seeking reintegration support. As a result of the support offered by the NGOs, however, it will generally be reasonable to expect an adult male VOT to identify himself as such on return, so as to access the support available from NGOs and, subsequently, the Albanian state. An adult male VOT may however be able to establish that it would be unreasonable to expect him to access that support on account of particular vulnerability, including genuinely held subjective fear, mental health problems, disability or membership of an ethnic minority group.
Issue 7. Is there a systemic sufficiency of protection in Albania for returning adult male VOTs, having regard (inter alia) to (a) s. 34 NABA 2022; (b) the willingness and ability on the part of Albanian state to provide through its legal system a reasonable level of protection from ill-treatment; (c) the systemic ability to deter and/or to prevent re-trafficking of male VOTs, as opposed to just punishment of it after the event; (d) the legislative framework affecting adult male VOTs and its implementation; (e) how corruption in Albania affects the systemic ability to deter and/or to prevent re-trafficking of adult male VOTs?
Issue 8. If there is, what are the factors that bear on whether returned Albanian adult male VOTs will be able to access sufficiency of protection from the authorities?
286. We deal with issue 7(a) to (e) (but not in that order and together given the overlapping features) before turning to the broader question of sufficiency of protection generally for male adult VOTs returned to Albania and then issue 8, the individual factors to consider when determining whether a male adult VOT will be able to access sufficiency of protection.
287. As we set out in the legal framework above, s.34 of NABA replicates essentially the same test for sufficiency of protection in reg 4 of the 2006 Regs. This requires an effective legal system for the detection, prosecution and punishment of acts constituting persecution, which reflects the approach taken in domestic jurisprudence. As outlined above, for VOTs the prospective risk of persecution is generally likely to take the form of re-trafficking and/or reprisals. The effectiveness of the system must therefore include its systemic ability to deter and/or to prevent re-trafficking and/or reprisals, not just punishment of trafficking or ill-treatment after the event. We therefore deal with issue 7(a) to (d) together. Access to any effective system is dependent on not being re-trafficked, which is in turn often dependent upon reintegration. We have already summarised the aids and obstacles to reintegration above under issue 6. We have also touched on 7(e) – corruption - but address this specifically in the context of sufficiency of protection, including the ability to prevent re-trafficking and reprisals.
Sufficiency of protection - general
288. Under issue 6 we concluded that the institutional framework of laws, strategies and policies dealing with human trafficking together with the package of measures to aid reintegration of adult male VOTs, is comprehensive. We intend no discourtesy by not repeating the detailed provisions in support of that proposition contained in the respondent’s closing written submissions. We have no difficulty in accepting that Albania: is in the process of seeking to join the EU and the European Commissioner’s 2025 report describes its legal framework as a “generally good basis for the protection of fundamental human rights”; has a comprehensive criminal code which criminalises trafficking with stringent penalties; has provided training on trafficking to its police and there are ongoing efforts to address police corruption; has shown some progress in addressing corruption through SPAK and across the justice system; has demonstrated overall increasing efforts to address trafficking according to the TIP 2025; has developed accountability mechanisms, such as the Ombudsman; has established child protection programmes, and; continues to benefit from the specialist expertise of the OSCE. Albania’s 2024-2025 National Action Plan to Combat Trafficking in Persons records that the overall implementation rate of the 2021-2023 plan was 89% for the period 2021-2023, with 43 measures fully implemented, six partially implemented and six not implemented.
289. The appellant accepts much of this and specifically accepts that Albania has laws in place to prevent and punish criminal acts such as trafficking in persons and demonstrates moderate preparedness in combating trafficking through a legislative and policy framework. However, the appellant points to deficiencies and gaps in that framework including the following: convictions have been consistently low in recent years and must be seen in the context of increased VOTs; limited resources continue to create additional obstacles; there is concerning evidence from Asylos and GRETA, that VOTs are still prosecuted for not cooperating with authorities; the Witness Protection Directorate is tasked with protecting witnesses but is ineffective - in 2023, not one VOT participated in the witness protection programme; according to GRETA only two VOTs have been granted compensation by courts, but neither received it. As we have already noted, GRETA 2025 has identified significant gaps in the effective investigation, prosecution and punishment of trafficking cases, and this observation has been noted in the UNHCR 2026 Guidance at [15b]. The UNDOC 2022 finding that all dismissals of trafficking charges from the Prosecutors Office or in pre-trial hearings were due to incomplete investigations by the relevant authorities, yet no further investigations were carried out in response to those dismissals, is of significant concern.
290. Corruption. We have already identified corruption as an obstacle to reintegration. It is also an obstacle to accessing protection. We note the European Commission’s Albania 2024 report states that, despite SPAK, “Overall, corruption remains a serious concern and preventive efforts have had a limited impact. The adoption of a broad criminal amnesty law led to 40 individuals convicted by SPAK courts and being fully pardoned and 65 others having their sentence reduced, which raises concerns”. The appellant has also pointed out that the state police, which is primarily responsible for internal security, including the protection of persons and the prevention of crime, are deemed by the European Commission to be highly vulnerable to corruption. Freedom House reported that “law enforcement agencies are still unable to function independently, and are under the influence of politicians and organized crime networks, as observed in multiple cases during 2023”.
291. In AD v Sweden (supra), the ECtHR noted at [69]:

…the reports of continuing problems relating to corruption and influence from criminal organisations. Essentially, from all the reports quoted above…it appears that corruption continues to be a widespread problem in Albania and that further efforts are needed to address this.
292. The appellant invited us to find that the Court’s general conclusion at [71] that “the Albanian authorities’ capacity to protect their people cannot be regarded as insufficient for the general public in Albania nor can it be regarded as generally insufficient for all persons who are targeted by criminal organisations” to be unhelpful when determining issues 7 and 8. By contrast, the respondent submitted that the conclusions in AD v Sweden answer the question of sufficiency of protection at the systemic level. In our judgment the Court’s conclusions are helpful but not determinative. The Court found at [70] that Albania had “made concerted efforts to address these issues” and referred to “reforms which have been introduced and measures taken to improve the capability and integrity of the law enforcement authorities”, noting that “although some problems remain, progress has been made”. As the appellant pointed out in closing submissions, the Court did not find that the reforms had rendered the problems historic. The Court’s finding at [71] does not address the particular vulnerabilities and protection needs of adult male VOTs. The Court did not consider the level and extent of evidence before us. Nevertheless, the Court’s assessment of the general protection available against OCGs is relevant and we do take it into account together with the much more detailed evidence available to us. We agree with the appellant’s submissions that Y v Switzerland (9577/21) (22 October 2024) does not materially assist.
293. The ECtHR’s findings on corruption in AD v Sweden chime with the conclusions in TD & AD that there is consistent evidence of corruption including complicity between local police/officials and traffickers, which act as a “major barrier” to combating trafficking. The analysis of corruption in these cases is broadly consistent with the observations of independent organisations. Again, we do not rehearse all of these. By way of example, the report from the Belgian Office of the Commissioner General for Refugees and Stateless Persons dated 15 December 2022 states that Albanian OCGs remain among the most powerful in all of Europe and that criminals from that ecosystem have ties to the police, judicial officials and other people in high positions. The report from the Swedish Migration Agency dated 21 July 2023 also states that the police have a history of corrupt elements facilitating or even participating in criminal activities. Legislation on the prevention of corruption is incomplete.
294. We also note that the Code of Criminal Procedure lacks provisions granting competence to Special Courts for Anti-Corruption and Organised Crime over matters related to the execution of their judgments, and Albania is not yet a signatory party to the OECD Anti-Bribery Convention. The Albanian government has declined to give up a fiscal amnesty programme, under which any Albanian or foreign citizen can deposit up to €2 million in non-declared money into the national banking system, enjoying legal immunity and a tax of only 5–10%, denounced by the EU and the IMF as providing criminals with a platform to launder the proceeds of crime. In addition, according to Asylos, Albania remains unsuccessful in its efforts to seize and confiscate OCG property and there has been a decreasing number of money laundering criminal proceedings.
295. Ms Trimi described corruption as a “real problem” but noted that “some measurable progress” had been made. Like the ECtHR, we accept that corruption remains a widespread problem in Albania.
296. Improvements. Having considered all the evidence, we have reached the conclusion that for VOTs as a general cohort, the position has strengthened and improved since TD & AD, in part for reasons relating to Albania’s attempt to join the EU. We emphasise that we have not considered the position for female VOTs in any detail and the country guidance in TD & AD remains in place for female VOTs. Our focus is on adult male VOTs. We agree with Ms Trimi that since TD & AD was decided, there has been measurable progress in tackling corruption and improvements have been made to the legal system for the detection, prosecution and punishment of offences against VOTs.
297. We have already noted the conclusion in the 2025 TIP report that Albania does not meet the minimum standards for the elimination of trafficking, but is making significant efforts to do so, such that it remains on Tier 2, alongside Norway and Switzerland. In our assessment, the institutional and legal framework together with the package of reintegration services available demonstrates a significant political will on part of the Albanian state and a clear receptiveness to international norms and standards in the field of human trafficking. We accept there are limitations and further progress is necessary, but we do not accept Professor Dalakoglou’s categorisation that “their practical effectiveness is extremely limited”.
298. The justice system has been reformed, and SPAK has jurisdiction over trafficking cases with an organised crime nexus. This is important because the preponderance of the evidence supports a close link between trafficking and organised crime. Those without such a nexus are handled by the General Prosecutor’s Office and the District Courts. Those involved have been given training on anti-trafficking issues. The judicial vetting process was noted in the European Commission’s report on Albania in October 2024 to have led to significant improvements in the functioning of the judiciary. SPAK has conducted high-profile prosecutions, albeit it remains under-resourced. Prosecutions have been brought against corrupt police officers.
299. We note the limited agreement in the evidence before us as to the effectiveness and activity of the police, particularly at District level, in combatting trafficking. We accept the evidence that some VOTs do not trust the police not to place them at risk by sharing information. That fear, whether it is well-founded in respect of an individual officer or not, can impact upon personal decisions about whether to enter the NRM and / or identify as a VOT. We accept that there may be some officers who remain susceptible to bribery. However, beyond contributing to the reluctance to access the protection available, as the respondent pointed out, there is a notable dearth of cogent evidence that corruption undermines the sufficiency of protection in place for those VOTs who enter the NRM and access the support that is available. Whilst the NGOs responding to Asylos acknowledged that there was corruption in Albania, they reported not having come across examples of corruption affecting the ability to protect VOTs. Although there are limited numbers of adult male VOTs returned from overseas who have engaged with the NGOs, Different & Equal reported in answer to Ms Trimi that they assisted four male VOTs (two of whom had been exploited in drugs trafficking) and in giving details of their experiences, did not report any reprisals or threats of reprisal. The fact that there appear to be very limited numbers of adult male VOTs returned from overseas who have engaged with the NGOs, does not mean that protection and support is unavailable. The responses of the NGOs were consistent in enthusiastically underlining their ability and willingness to assist and support every male VOT. We do not accept the appellant’s submission that corruption “cancels out” the will or ability to provide protection, otherwise apparent on the part of state organs working together with NGOs, as expressed in many of the legislative and policy instruments.
300. In a similar way to TD & AD at [81], we can say with certainty that there is a framework for the identification, referral and assistance of adult male VOTs returning to Albania. It is clear that the Albanian government has in place a functioning NRM, which was improved and updated in 2023, into which all returning VOTs will be considered for referral. Potential VOTs can be identified by state or NGO actors, either on arrival when they are interviewed by police and social workers, or when in the community, via mobile identification units. Ms Trimi reached the following conclusion, which we accept:

Albania demonstrates a structured and increasingly coordinated approach to preventing and deterring the re-trafficking of male VOTs combining state-led initiatives with strong engagement from civil society. The MOI has undertaken national awareness and sensitization activities aimed at improving identification and coordination among institutions. The NRM members such as D&E, MWL, Vatra, Terre des Hommes and the NRCVT complement these efforts through targeted community outreach mobile units and reintegration programmes offering psychosocial legal and economic assistance. These initiatives have strengthened early detection and prevention capacities particularly at the local level.
301. Adult male VOT distinguishing features. There are two key material features in the evidence before us regarding adult male VOTs, which distinguishes them from the situation for female VOTs when it comes to sufficiency of protection: (i) identification challenges appear to be more acute, which may mean that an adult male VOT is not identified at all or at a much later stage, and; (ii) the absence of an adult male shelter option. These two matters are inter-related as the absence of a shelter may contribute to self-identification reticence for those who feel they could only be fully protected by a shelter.
302. (i) Identification: Limited economic assistance and support is available to those who do not wish to declare themselves as VOTs. Adult male VOTs are unlikely to access the full protection that exists in Albania without being willing to engage in the identification process. As Ms Trimi clarified in oral evidence, the risk of being re-trafficked is low if adequate support is provided over a period of time. In these circumstances, it is important to consider whether the individual is willing to identify himself as a VOT and accept the support available, and if not, why not.
303. We have explored the possible reasons why adult male VOTs are reluctant to identify as such under issue 6, and this can mean that they do not engage with the support framework available for VOTs. The respondent submitted that in such circumstances the individual has made a choice not to engage with the surrogate protection of the state. It is necessary to recall that the identification of VOTs in Albania takes place in two phases, as it does in the UK. The process is set out at [105] of GRETA’s fourth report: “(1) initial identification, which may be carried out by a broad range of actors, including NGOs, following an initial interview; (2) formal identification, which is performed by a team comprising, in case of adult victims, a specialised police officer and a social worker…”. In relation to the first stage, there is no cogent suggestion or example in the background material that NGOs are corrupt or that they might reveal a VOT’s identity or location to traffickers. Dr Davy had no criticism of the NGOs in her oral evidence, stating that they go to “great lengths” to support. In relation to the second, formal stage of the process, an adult male VOT might claim to be reluctant to go through an interview with a specialised police officer and a social worker because of corruption but we were not referred to any evidence that the specialised officers who deal with such matters had failed to respect the confidentiality of the process.
304. Much of the support programme is delivered through NGOs who in general work effectively, subject to resourcing constraints, and are able to help adult male VOTs navigate dealings with the authorities including the police and the NAES. There are understandable concerns that ongoing corruption lowers trust in the police, which can cause a fear of disclosing trafficking. However, whatever an individual’s fear of the police may be, it is now widely known that all VOTs are entitled to and can access support from NGOs. The potential to engage with the authorities to access support and protection does not just arise at the border point of return. There are other opportunities, such as through mobile identification units.
305. We were impressed with the pivotal role played by NGOs and their willingness to proactively assist male VOTs, with dignity and without discrimination or adverse judgment. This means that an unwillingness to access the protection framework available without more, will not be a reasonable justification for not doing so. In general, given the support provided by the NGOs, it will be reasonable for an individual to engage with both phases of the identification process, which then enables them to access the protective and rehabilitative support available. The reluctance to identify as a VOT and/or engage with the support available does not render the protection framework insufficient. It might be said that the effectiveness of the system is hampered by the absence of a clear procedure or practice identifying accepted VOTs upon return to Albania. However, applying the practical standard, there remains an ability and willingness to operate an effective legal system with protective features, through the NRM. There may be specific individual factors going beyond a general reluctance to engage in an individual case. These must be considered on a case by case basis.
306. (ii) Absence of adult male shelter: The respondent urged us to find that the availability of an adult male shelter “appears to be in flux but is adaptable depending on circumstances”. In this regard we note the assertion by Another Vision that the coalition of four shelters had responded to 100% of all cases referred to them, adding that shelters had the capacity to cover all cases and that “no one was left behind”. However, Ms Pooley and Ms Trimi unambiguously confirmed in oral evidence that there continues to be no shelter that individual adult male VOTs can access as a matter of course. Ms Pooley explained in cross-examination that the government shelter had on two occasions (during 2025 and in February 2026) accommodated groups of foreign national male VOTs. She said that it was her understanding that if there was a large cohort of male VOTs who required the shelter, they could “flex” and disperse females to another shelter. We note that the director of the government shelter wrote in an email to Ms Trimi that they would, going forward “operate in accordance with the circumstances as they arise”. In order to do so, difficult arrangements would have to be made to rehouse female VOTs because the shelter would need to be exclusively male. It seems to us that there has been a longstanding problem in finding adult male shelter space in Albania. The position appears to be different for boys as there are shelter spaces for them, albeit there are concerns regarding capacity and the duration of shelter provision. We do not propose to address these concerns because as we have already explained, the focus of the country guidance is on adult male VOTs.
307. The updated oral evidence therefore makes it clear that unlike female VOTs, in the usual circumstances there is simply no reliable available option for adult male VOTs to be accommodated in a shelter. Adult male VOTs either return to their family where possible or those who request assistance with accommodation are allocated rented apartments.
308. The shelter option outlined in TD & AD, whereby in accordance with the SOP, women are met on arrival and transported directly to one of the four shelters, is therefore unavailable to adult male VOTs. We note that if it is considered that there is a risk posed to the female VOT or a family member, TD & AD concluded that it is likely that she will be placed at the guarded government shelter. A six month stay in that shelter would normally be long enough and a stay could be as short as three months, but those who were at high risk would be permitted a stay of up to two years. While living in the state shelter, female VOTs are said to be protected by special security forces, cameras and staff at all times. Shelters provide food, counselling, legal assistance, health care, educational and employment services, assistance to VOTs’ children, financial support, vocational training, and post-reintegration follow-up.
309. Against that background, the appellant submitted that there is no reliable evidence of private rented accommodation, protected to the level of the shelters, being accessible within a reasonable time, sufficient for the scale of adult male VOT returnees, or available for sufficient duration to afford the returnee to secure reintegration. On the other hand, the respondent submitted that there is no evidence of any VOT being deprived of the accommodation and support they require, particularly when Article 12 of the Trafficking Convention requires standards of living capable of ensuring the VOTs’ (our emphasis) “subsistence, through such measures as: appropriate and secure accommodation, psychological and material assistance…”.
310. We acknowledge that shelters or ‘high security centres for VOTs’ feature heavily in the SOP, reflecting their centrality in terms of security and protection. The SOP requires a risk assessment to be carried out by the case manager and where the beneficiary and/or their family appear to be at high risk of retaliation or threats from traffickers or other parties, the needs assessment states “Measures should be taken to transfer the beneficiary to a high-security centre (with their consent), and arrangements should be made with law enforcement to protect the beneficiary and their family.”
311. Ms Trimi was asked to clarify what the equivalent provision would be for an adult male VOT facing a similar risk to a female VOT, assessed to require a high security centre or shelter. She indicated that there was a “significant gap” in the protection framework given the absence of a male shelter, but that the adult male VOT would be provided with rented accommodation and police protection. We note that the use of rented apartments to accommodate adult male VOTs was referenced as far back as the 2019 Asylos report. Different & Equal’s 2017 report is quoted, including their assistance to 17 male VOTs (some boys and some young men) with a reintegration plan built for each case. This included support with psycho-social counselling, legal aid, medical assistance, support to finding a job, financial support for paying the rented apartment, training to enhance life skills, providing information and intercession for receiving services provided by different community service providers, monitoring and follow up, etc. A Different & Equal psychologist is said to have offered regular individual counselling sessions for all male beneficiaries in the program.
312. It was argued on behalf of the appellant that there are delays in securing rented accommodation and financial aid, which can be uneven. As Ms Trimi indicated, there would need to be an individualised assessment that would inevitably take time. As set out above, the Albanian authorities will have no advance notice of the impending return of any VOT and his particular circumstances. However, the British Embassy have referred to the use of emergency accommodation and there is no reason to doubt that this cannot be utilised for a vulnerable adult male VOT, whilst the practicalities of secure accommodation arrangements, police protection and commensurate support are put in place to meet the needs identified.
313. We also bear in mind that the rented accommodation with police protection option turns on the relevant local police, who continue to be regarded as vulnerable to corruption, delivering a heightened level of protection to a vulnerable adult male VOT. This was addressed at [8.3] of the 2019 Asylos report, but not in any detail in the 2024 Asylos report. When asked if there are effective safeguards to avoid detection whilst living in the apartments provided by Different & Equal, sources interviewed described risk assessment and risk management as strong components of the Different & Equal rehabilitation and reintegration program. Anonymous source 1 is quoted as explaining where there are problems, alternative accommodation is sought and for security problems there is collaboration with the police, but the source had not heard of any security problems with the males accommodated in rented apartments.
314. Whilst there is limited evidence on the practical accessibility of non-shelter rented accommodation for adult male VOTs, it is clear that some adult male VOTs have been provided with rented accommodation and NGO support, with successful outcomes. The NGOs were generally very positive about their willingness and ability to assist adult male VOTs in this regard, although we note that Terre des Hommes is quoted within the Asylos 2024 report as saying that the fact that adult male VOTs are usually accommodated in rented apartments “is not good because there might be cases that need 24-hours assistance rather than living separately.”
315. We are satisfied that in general the option of rented accommodation provided with NGO support and assistance is available for adult male VOTs. We accept Ms Trimi’s evidence that adult male VOTs can access emergency and / or private rented accommodation with the support of NGOs, whilst accessing the related reintegration services provided in order to meet need.
316. Conclusion: Drawing all the various threads together, on balance and notwithstanding the deficiencies described in many of the reports, applying the practical standard, there is a general sufficiency of protection for adult male VOTs in Albania. We acknowledge, as observed in the TIP report, that Albania is not fully meeting the requisite standards but it cannot be said that the concerns are so significant to warrant placing it on the Tier 2 watchlist. There is willingness and ability on the part of the state to provide through its legal system a reasonable level of protection to adult male VOTs. We have assessed the system in place from its systemic ability to deter and /or to prevent re-trafficking and reprisals, not just punishment after the event.
317. We have therefore reached a similar overarching conclusion to the panel in TD & AD (concerning female VOTs) on sufficiency of protection for adult male VOTs. In summary, there is in general a Horvath-standard sufficiency of protection, but it will not be effective in every case and individual circumstances must be considered. Apart from the issue of male shelters, which we have addressed above (and further below), there is no cogent evidence to cause us to question that general conclusion. Rather, the legal and practical framework of protection in place has improved since TD &AD. The lack of an adult male shelter option in Albania does not mean that there is in general insufficient protection for male VOTs. It is in the consideration of the individual factors, to which we next turn, that decision-makers should carefully assess whether nothing short of shelter accommodation will do to avoid a real risk of ill-treatment and / or re-trafficking.
Sufficiency of protection - individual factors
318. Even though there is a systemic sufficiency of protection for an adult male VOT in Albania, an individual VOT may still have a well-founded fear of persecution if he can show, to use the wording of Auld LJ in Bagdanavicius at [55(6)], that the authorities “know or ought to know of circumstances particular to his case giving rise to his fear, but are unlikely to provide the additional protection his particular circumstances reasonably require…”. Similarly, reg 4(2) of the 2006 Regulations and s.34(2)(b) of NABA clearly requires the individual male adult VOT to be able to “access protection”. This demands a careful consideration of the particular circumstances of the individual and any additional protection his “particular circumstances reasonably require”. The particular circumstances will include factors that heighten risk and the fact that a returned VOT has already been the subject of past trafficking and in some cases past persecution (although not necessarily in Albania). Past serious harm or persecution is a relevant factor when considering whether particular circumstances give rise to the need for additional protection.
319. The individual factors to be considered reflect in many ways the overlapping obstacles to reintegration for adult male VOTs outlined under issue 6, given the undisputed close relationship between accessing reintegration and the risk of re-trafficking. While we accept the general proposition that traffickers, in particular OCGs, are by their very nature violent, like the panel in AM & BM (at [168]), we consider that the issue of whether or not an adult male VOT would be able to access sufficient protection in Albania, is fact-specific and dependent on all the circumstances, including the factors we particularise below under the two main headings of (i) vulnerability and (ii) information relevant to the traffickers.
320. (i) Vulnerability. The extent to which the vulnerabilities that resulted in the initial trafficking or have been caused by the trafficking experience, continue to apply, plays an important role together with the reintegration support to address vulnerabilities. If the vulnerabilities cannot be addressed, susceptibility to trafficking is more likely to continue, subject of course to the support that can be accessed to address those vulnerabilities. We have noted that provision and demand for services can be uneven and the particular limited capacity of NGOs to accommodate adult male VOTs. This may mean capacity concerns may change with demand and funding variations.
321. The less resilient or adaptable the individual, the more likely they are to fail in their quest for financial independence with attendant increased risks of re-trafficking. Individuals who are socially isolated and suffering from the consequences of their past experiences are already vulnerable; where they are placed under the additional strain of financial hardship this can render them even more susceptible to the advances of those who would seek to exploit them. For some, the initial period upon return can be riskier, particularly where the reintegration support is delayed or incomplete. Vulnerability to re-trafficking increases with lower social status, economic standing and education; with disability or health (particularly mental health) concerns; for ethnic minority communities, particularly Roma; for those from remote / rural parts of Albania; for those who are younger; for those without a support network; and for those with a history of domestic violence in the family.
322. As we have outlined above, given the support provided by the NGOs, it will generally be reasonable for an adult male VOT to engage with both phases of the identification process, which then enables them to access the protective and rehabilitative support available. There may be specific individual factors going beyond a general reluctance to engage in an individual case. These must be considered on a case-by-case basis. In this context, if the police in the local area has not been particularly helpful in the past, this would not in itself make it reasonable for an individual not to engage with an NGO. By contrast, if an adult male is at such a high risk from a trafficker that only a shelter would suffice for protection, failure to seek the State’s protection would not be unreasonable.
323. (ii) Trafficking relationship and intent / reach of trafficker. We have already made reference to this in considering issues 4 and 5. The relationship between the trafficker and the VOT may provide important hints on the traffickers’ likely intentions. The trafficker may well consider that there is no point in pursuing the VOT or, alternatively might consider that unless the VOT is pursued and punished, others they have trafficked might flee. Traffickers might well want to ensure that their methods and the structure of their organisation are not known to the authorities. They may therefore feel that they would not want the VOT to be at large.
324. The size, intent and determination of the trafficker and its role in or relationship with the community and the adult male VOT’s family must be carefully considered. The trafficker who acts on his own or with one or two accomplices is less likely to be able to either re-traffic or hurt the VOT, than the trafficker who is part of a large OCG, albeit family members may be able to exert particular loyalty and obligation-based pressure.
325. Those assessed to be in need of the security from OCGs that only shelters can provide must be distinguished from those who can be adequately protected through the provision of rented accommodation and support by NGOs. That assessment will require a careful consideration of both the individual’s vulnerability and the intent and reach of the trafficker. We are satisfied that for those adult male VOTs with a clear need for 24-hour shelter accommodation to obviate a real risk of re-trafficking and/or reprisal at the hands of a determined trafficker and/or OCG, there will not be available sufficient protection for that individual. By contrast, where rented accommodation and NGO support are adequate to meet the level of risk and vulnerabilities, there will in general be sufficient protection.
Summary
326. The Albanian government has made significant further efforts to improve its response to trafficking and VOTs and there is a general sufficiency of protection for an adult male VOT. However, this will not be effective in every case, and his particular circumstances must be considered.
327. Whether an adult male VOT will be able to access sufficient protection from the authorities will depend upon his individual circumstances and the additional protection his particular circumstances reasonably require. In conducting this assessment, the factors under the two main headings of vulnerability and information relevant to traffickers, should be considered.
328. Vulnerability to re-trafficking increases with lower social status, economic standing and education; with disability or health (particularly mental health) concerns; for ethnic minority communities, particularly Roma; for those from remote / rural parts of Albania; for those who are younger; for those without a support network; and for those with a history of domestic violence in the family. However, given the support provided by the NGOs together with the institutional framework, it will generally be reasonable for an adult male VOT to engage with the identification process, which then enables them to access the protective and rehabilitative support available. There may be specific individual factors going beyond a general reluctance to engage in an individual case. These must be considered on a case-by-case basis. The information relevant to the traffickers as summarised above must also be considered.
329. An adult male VOT assessed to require the additional protection of shelter accommodation to avoid re-trafficking and/or reprisal, will not be able to access it but careful consideration must be given to whether on the facts of the individual case, rented accommodation with associated reintegration and security support would be sufficient.
Issue 9 – Is internal relocation a viable alternative for returned Albanian male VOTs, having regard (inter alia) to:
a. S.35 NABA 2022;
b. The effectiveness of any re-integration services offered by the Albanian State, NGOs and civil society organisations to male VOTs;
c. The relevance of the article 8 ECHR “very significant obstacles to integration” test in paragraph PL 5.1 of Appendix Private Life of the Immigration Rules.
Issue 10 – If there is, what are the factors that bear on whether internal relocation is viable and reasonable.
330. As outlined in the legal framework section above, the question for us to determine is not whether internal relocation is “viable” as set out in issues 9 and 10 above. If there is a prospective risk of persecution in the home area, consideration must be given to whether there is another part of Albania where the individual would not have a well-founded fear of being persecuted and where he can reasonably be expected to stay or remain. This requires an analysis of risk and reasonableness. We have already explained the inextricable link between reintegration and risk of re-trafficking. It follows that many of the matters that might usually be more closely aligned with the reasonableness analysis such as vulnerability factors, are also relevant to the risk analysis.
331. The risk analysis is rather different depending on whether the prospective risk in the place of relocation arises from the VOT’s original trafficker (whether for reprisals or for re-trafficking) or re-trafficking more generally (by a different person or organisation). The intent, reach and organisation of the original trafficker will be relevant for the former but not the latter. The obstacles to reintegration, particularly any vulnerabilities and the support available to address these, will be relevant to both.
332. The appellant’s contention is that internal relocation is generally unsafe as there is a real risk that an adult male VOT assessed to be at risk in his home area, may be located and re-trafficked or suffer persecution or serious harm by their traffickers wherever they live within Albania, given its size and close-knit communities. The respondent’s contention is that internal relocation would only not be safe when the trafficker has the intent, reach and motivation to find the adult male VOT, which would not be present in the vast majority of cases. Even where motivation exists, the respondent submits that a person in the locality would need to have an interest or motivation in identifying the individual and a reason to notify the trafficker/OCG, with the means of contact. The respondent submitted that the assertion that OCGs are sophisticated, skilful and tenacious in locating individuals requires critical examination.
333. Insofar as pursuit by the original trafficker is concerned, Ms Trimi agreed that Albania’s small geographical size, small communities and local networks means that relocation “rarely guarantees anonymity or safety.” Some of the reports describe the challenges of seeking to live ‘anonymously’ in Albania. Of course, the test we must apply is whether there is a real risk of prospective re-trafficking, reprisal or other ill-treatment. Ms Trimi explained that in a small community of say 5000 people everyone would know about a newly arrived person, and the local networks in a village would know the whole information about a newly arrived person. Mr Carswell persuasively explained how an individual could be located anywhere if an OCG is particularly interested in finding him, through public documents such as voter registrations, through social media postings and photographs, and through corrupt officials on the payroll of gangs. We do not suggest that every OCG, no matter how small, has access to corrupt officials who can assist in tracing a person throughout Albania, but we note Ms Trimi referred in cross-examination to coming across information that an OCG had used corruption in the police to find out information in the police system about their rivals, and an OCG who had such connections would be able to call on those connections to find an individual who is of particular interest to them. Once the local networks have the information then it only takes someone to refer in a social media post to a new person in the village for the person’s location to be easy to find for anyone looking out for it.
334. In all the circumstances, we consider that internal relocation outside of the bigger cities of Tirana, Durres, Vlore, Elbasan and Shkoder, would not be safe where a person is being actively sought by their traffickers. Whilst we appreciate that even in the bigger cities new acquaintances are likely to be questioned about their family connections, the size of the community would indicate that new arrivals are less likely to be of interest purely as such, which reduces the likelihood of relocated adult male VOTs being identified by casual postings on social media or otherwise. However, internal relocation to a large city may not be safe and all the circumstances must still be considered. By way of example, some OCGs may have such interest in the individual VOT as to be interested in finding him in one of the bigger cities; some OCGs may have corrupt connections or be powerful enough such that there is no sufficient protection from the police in the place of relocation. On the other hand, if the adult male VOT is at risk from family only or a localised OCG without corrupt connections, then a combination of internal relocation, reintegrative support and protection from the police at the place of relocation may avoid the risk of reprisals or re-trafficking, subject to vulnerability factors.
335. Those adult male VOTs who require a male shelter to be safe in their home area are unlikely to be safe anywhere else including other cities. This is because the reach and intent of their traffickers together with their vulnerabilities are such that they require a shelter, which is not available anywhere.
336. If an adult male VOT who is not at risk of reprisals from his former traffickers in his home area is so vulnerable that he is at real risk of re-trafficking in his home area regardless of the support available to reintegrate, then he is likely to be at risk everywhere unless his difficulty is the lack of relevant support services or their accessibility in his home area.
337. When determining whether it would be safe for adult male VOTs who do not require a shelter to be safe and who are not so vulnerable that they would remain at real risk of re-trafficking regardless of the support available, to relocate to a city other than their home area, the following factors must be considered: whether a person is being actively sought by their traffickers, the reach and intent of their traffickers, whether their traffickers have any connection with the authorities, the place of relocation (whether to Tirana or not), together with the factors we have identified in issue 6 which may lead a person to be unable to integrate so that he is driven back to his traffickers or is at risk from other traffickers in the area of relocation.
338. Social housing or rented housing support from the municipality is in practice limited outside Tirana. For those who will be safe from their traffickers in Tirana the length of housing support offered by NGOs and assistance with accessing housing programmes is likely to be enough in many cases, for a VOT to have the necessary time to obtain work/start a business with the help and support of the NGOs and thus be less economically vulnerable. Outside Tirana, the lack of ongoing rental support or any social housing is likely to mean that the VOT will have to be able to establish themselves in work/start a viable business within 6 months or not much more.
339. Whether the VOT will be able to establish themselves in work/start a viable business and if so whether they would be able to do so within the time that support is provided, will be a fact sensitive analysis depending on amongst other things their vulnerabilities including prior education, their skill level and health, in particular their mental health. There will be some adult men who despite the provision of accommodation, even in the medium term, will not be able to reintegrate into society and who will remain at risk of re-trafficking even in the place of relocation for the reasons explained in issue 8 above.
340. Although the specific circumstances must be considered, in general, the support available to adult male VOTs who are not at risk of reprisal or re-trafficking suggests that internal relocation will not be unduly harsh, but the reasonableness analysis must take into account all relevant vulnerabilities and mitigations in the place of relocation. When considering mitigations, it is noteworthy that two NGOs, Terre des Hommes and Another Vision, considered that relocation could reduce any stigma from the community of origin.
341. We have rejected the appellant’s submission that there is a general lack of sufficiency of protection and a lack of internal relocation option in every case. It follows that, contrary to the appellant’s submission, the “very significant obstacles to integration” test is not generally satisfied. As we were not addressed specifically on the point, we cannot say more than that. Whether there are “very significant obstacles to integration” is fact sensitive and the principles set out in case-law must be applied if that is in issue.
Summary
342. The safety and reasonableness analyses must take account of all relevant circumstances, including the vulnerabilities and mitigations in the place of relocation. In general, the support available to adult male VOTs who are not at risk of reprisal or re-trafficking suggests that internal relocation will not be unduly harsh.
343. An adult male VOT who requires a shelter to be safe in his home area, is unlikely to be safe anywhere else.
344. Where an adult male VOT is not at such risk so as to require a shelter, but is still being sought by his traffickers, internal relocation to anywhere outside the bigger cities is unlikely to be safe. Whether a person would be safe from their trafficker in Tirana or one of the other bigger cities such as Durres, Vlore, Elbasan and Shkoder will depend on how actively a man is being sought, the reach and intent of the traffickers, their connections if any with the authorities in that area and their vulnerabilities.
345. Vulnerabilities are relevant at the safety analysis stage because they play a role in the ability to access rehabilitation and support. Where rehabilitation is not possible or unlikely, the risk of re-trafficking increases.
346. Reintegration is more accessible in Tirana due to the lack of availability of social housing or rental support from the authorities in other areas.
Issue 11 – Are Albanian male VOTs a PSG, having regard (inter alia) to s.33 (2) – (5) NABA 2022? If so, are they at risk of persecution on account of such membership, and what bearing does their constituting a PSG have on questions 6 and 7 – 10 above?
347. The appellant is a member of a PSG as a male VOT because he shares a common background of being a male who was trafficked, which cannot be changed. The group, male VOTs, is not defined by the risk of persecution; it is defined by a common past experience of being trafficked.
348. The appellant claimed asylum before NABA came into force. For the reasons set out in the legal framework, we consider that the definition of a PSG in the 2006 Regs is to be read disjunctively, as explained in EMAP (see in particular [93] and [105] – [111]). The appellant is a member of a PSG applying this disjunctive approach.
349. However, even if we are wrong and the conjunctive approach is correct, male VOTs also have a distinct identity in Albania, because they are perceived as being different by the surrounding society. As already discussed, this is the required approach for post-NABA cases.
350. The respondent submitted there was no clear evidence that Albanian male VOTs have a distinct identity within society or are perceived as a distinct group by society as a whole or even by a smaller group within society. Nor, it was submitted, was there clear evidence that male VOTs are discriminated against as a group distinguished by gender. The respondent contrasted this with trafficked women. They face stigma because, being seen as trafficked for sexual exploitation they are perceived as ‘tainted’, but this is not the case for male VOTs. It was said that at the highest, there was evidence of what might be called internalised stigma based on masculinity norms in society, but this was not because they are singled out by society.
351. The respondent referred to the expert evidence. Dr Davy had accepted that male VOTs often did not seek reintegration services because they did not regard themselves as victims, not because they feared stigmatisation by seeking such services, and she had agreed that the patriarchal mindset in Albania meant that men were not perceived by society as VOTs. Professor Dalakoglou agreed that male VOTs were often socially invisible as a distinct category because their experiences tended to be absorbed into broader narratives of migration, unemployment or personal failure.
352. The appellant’s written closing submissions were to the effect that male VOTs had a distinct identity because of the discriminatory failure of state protection, but as we have explained, there is a general sufficiency of protection for adult male VOTs. They are not, as a group, discriminatorily denied state protection. It is right that not all the services provided are exactly the same as for women, in particular there are no male shelters, but that simply means that some adult male VOTs will not be adequately protected. The relevant PSG is not Albanian men; if that were the group, then one would have to consider whether men were discriminated against, but looked at overall, in a patriarchal society as Albania still is, men are plainly not discriminated against.
353. The KAP survey has examined youth knowledge and awareness of human trafficking in Albania. There have been three waves of the survey – in 2020, 2022 and 2025 respectively, surveying youth aged 15 – 29 across four regions of Albania. The FCDO explained in their letter of 12 November 2025 that “Perceptions of vulnerability remain deeply gendered: 81% of respondents consider girls under 18 as most at risk, compared to only 10% recognising men over 18. Awareness of boys at risk varies widely – highest in Shkoder (52%), and lowest in Diber and Kukes (8 – 11%) reflecting ongoing stereotypes that associate trafficking primarily with women and children” (our emphasis). Dr Davy was involved in the first and second waves of the survey. The summary of the 2020 survey records “most Albanian youths do not think that men and boys are at risk of being trafficked – 10% consider that men are at risk” and we note, that in the 2022 wave, table 4 headed “Knowledge of population groups at risk of being trafficked” records only 5% recognition of men over 18.
354. Some care must be taken not to rely too heavily on the 2022 and 2025 survey answers for evidence of the ongoing stereotypes. The FCDO letter does not reflect the wording of the 2022 and 2025 surveys, which did not ask those responding to compare risk or identify who might be at risk (or at least if that question was asked, the answer was not recorded). The question which was asked in those surveys was “to your knowledge, how much do you think each of the following groups are a “great deal” or “very much” at risk of being trafficked?”, not simply whether men were “at risk” of being trafficked. Those who responded to the 2022 and 2025 surveys may have concluded that although men were at risk they were only at some risk rather than a great deal at risk. The summary of the 2020 survey has the potential to mislead as the 10% figure reported was those who said men were a “great deal” or “a lot” at risk. In fact in the 2020 survey, 24% reported men were moderately at risk of being trafficked, whilst 66% considered men were not at all at risk, or only at little risk (as compared with 42% considering women were at moderate risk and only 19% a little or not at all at risk).
355. Furthermore, there was a good knowledge in the 2025 survey that forced criminality involving Albanian adults occurred abroad (82%) and forced labour (81%) as compared with sexual exploitation of adults (86%). It seems unlikely that the respondents to the survey thought that it was only or predominately Albanian women who were the victims of forced criminality and forced labour abroad.
356. Nevertheless, the 2025 survey does show that there is still a striking difference between the perception (by youth at least) of whether adult women or adult men are a “great deal” or “very much” at risk of being trafficked – overall 56% considered adult women at a “great deal” or “very much” at risk of being trafficked. The results of the survey chime with the reports of the NGOs discussed earlier that men are not seen as victims in the same way that women are now becoming recognised as victims. Dr Davy’s explanation, referred to above is that the patriarchal mindset means that men are not seen as victims, they are seen as strong figures who cannot be harmed or trafficked. Ms Bruci, the co-ordinator of Arise Albania, commented in the 2024 Asylos report that men experienced a different kind of stigma from girls and women. They experienced the stigma of failure, of being seen as weak and unable to provide for their families and that they were not enough of a “bad boy” to succeed.
357. Indeed, all the NGOs surveyed by Ms Trimi apart from the state shelter, reported stigma as an issue for men. Mary Ward Loreto said that the societal perception was that “men have to make it on their own”, “men are not victims” and that social stigma was a challenge to reintegration. Vatra reported that societal perceptions of men as “strong” not only discouraged them from seeking help, but led to victims feeling shame, fear or anxiety about disclosing their experiences which hindered their ability to reintegrate into society. In their list of the main challenges to the reintegration of males, “stigma and gender bias” was the first, before lack of a dedicated shelter. Different & Equal also reported stigma and the experience of prejudice from others as a barrier preventing access to services. Terre des Hommes not only referred to stigma as preventing men from self-identifying as victims but also considered that relocation could reduce any stigma from the community of origin. Another Vision also referred to relocation as reducing any local stigma.
358. We have already summarised the awareness-raising initiatives regarding the risks of trafficking upon males, females and children. Notwithstanding improvements in awareness-raising, much of the available evidence continues to suggest that Albanian society does not readily consider men to be VOTs, and when they are identified as such, they tend not to be viewed with sympathy. Rather, upon returning to their local community, they are more likely to be seen as having failed to live up to expectations of masculinity and strength, and stigmatised.
359. Having surveyed all the evidence, we have concluded that male VOTs are perceived as being different by a substantial proportion of individuals making up Albanian society. They may not be obviously visible partly because they do not or are reluctant to identify themselves as VOTs, but if their history of trafficking is discovered, they are likely to be stigmatised within Albanian society as weak and ‘having failed as men’ or ‘failures’. It is the societal attitudes towards the group, labelling male VOTs less as victims and more as failures, which differentiates them from the other male members of the surrounding society, who are generally seen as strong and with at the very least the potential to provide for their families. We note the perception that those men who have unsuccessfully sought to migrate are also viewed with disdain. This does not mean that male VOTs are not members of a PSG. Female VOTs may be viewed in precisely the same way as those who are voluntarily involved in sex work. This does not make female VOTs any less identified as a group to be stigmatised.
360. Male VOTs share a common background and are also perceived as different and stigmatised by society. That others without that common background may also be stigmatised does not mean that male VOTs are not perceived as different and as having an identity distinct from the rest of society. It is because they are perceived as different that they have a distinct identity. S.33(4) does not require that society as a whole recognise their common background, as explained above in the legal framework section. Indeed, there are some in Albanian society who sympathise with the plight of male VOTs and seek to do their best to assist. This is being increasingly acknowledged by the state and NGOs.
361. EAV v SSHD (supra) reminds us that there must be a causative link between the fear of persecution and the membership of a PSG. Where a male VOT has a well-founded fear of persecution, that fear of persecution may be for reasons relating to his membership of a PSG, either because the former traffickers will be pursuing him because of his VOT status, or the individual remains at risk because his particular vulnerabilities arising out of his experiences as a VOT have not been and cannot be adequately addressed. The specific facts of any individual case must be considered to establish the requisite causal link.
Summary
362. Albanian male VOTs share a common background and, because they are perceived as different by surrounding society, have a distinct identity in Albania. They are therefore members of a PSG both pre and post NABA. There must be a causative link between the fear of persecution and the membership of the PSG.

Country guidance
363. We now draw together our country guidance findings.

(1) Profile. There is no typical profile for Albanian male VOTs. Certain common themes are encountered amongst those who have been trafficked. Often they tend to: be teenagers or young adults; come from less affluent or marginalised backgrounds; have received a limited education; have experienced domestic violence or neglect. However, male VOTs might become vulnerable to trafficking for a variety of reasons, and come from all parts of Albania and from varied social backgrounds.

(2) Risk factors. The following non-exhaustive list of risk factors may lead an Albanian male to become a VOT:
(i) Lower socio-economic status including homelessness
(ii) Lower levels of education and difficulty in securing legitimate employment
(iii) Ill health, whether physical or mental, including addiction
(iv) Originating from Northern Albania or a rural area
(v) Age, with younger men and teenagers being more vulnerable
(vi) A lack of a family or other support network, whether by reference to blood feud, criminality or adverse childhood experiences
(vii) Belonging to a minority ethnic group or having an LGBT identity

(3) It is important to bear in mind that the presence of multiple factors may compound or increase risk but one risk factor may be sufficient to make a person a VOT.

(4) Modus operandi. Male VOTs are lured or forced into trafficking in a variety of ways including (but not limited to) the following: a young male finds himself in financially straitened circumstances, accepts an offer of claimed lucrative employment in the UK, only to discover en route or on arrival that he is to be exploited and forced to work in difficult and unlawful conditions, whether as a result of debt bondage, family pressures or because of threats to his safety or that of his family.

(5) Social media plays an increasing role in the initial recruitment process. OCNs are likely to play a role in such trafficking, although it will be for an individual decision maker to consider the nature and extent of that role in a case in which it is disputed. Trafficking by means of abduction is not commonplace.

(6) Risk on return. An individual who escapes from a situation of trafficking or otherwise manifests an unwillingness to be involved in drug-related or other criminality may be at risk on return to Albania. He might be at risk of re-trafficking and/or reprisal at the hands of his original traffickers or at risk of re-trafficking at the hands of another.

(7) It is not possible to quantify the risk of re-trafficking in any given case, whether at the hands of the original traffickers or at the hands of another. In considering the extent of any such risk, a decision maker who is satisfied that an individual has been the subject of past persecution or the threat thereof will consider that fact to be a serious indication of the risk of future harm unless there are good reasons to consider that it will not be repeated (paragraph 339K of the Immigration Rules refers).

(8) In considering the risk of re-trafficking or reprisal from the original traffickers, it will be necessary for decision-makers to consider:
(i) The circumstances of the individual and in particular his vulnerabilities, together with the reintegration assistance which is likely to be provided to the individual on return to Albania. In considering vulnerability to re-trafficking by deception, it will be relevant to consider that an individual who was previously duped by a trafficker will be aware of the risks associated with offers of the kind.
(ii) What is known about the original traffickers, in particular:
(a) the size of the operation and its level of organisation;
(b) any threats which have been made or acted upon in the past, including in relation to debt bondage;
(c) any connection to family members and acquaintances;
(d) any links to the community / area the individual and his family members originate from;
(e) the extent to which the individual has tangible evidence against an OCG which might jeopardise its future operations
(f) the passage of time (because a significant period without interest or threat may indicate a lack of ongoing interest).

(9) In assessing the risk of re-trafficking at the hands of a different actor, decision makers should take account of the individual’s original risk profile and vulnerabilities and the extent to which this has changed or is likely to do so. In considering vulnerability to re-trafficking by deception, it will also be relevant to consider that an individual who was previously duped by a trafficker will be aware of the risks associated with offers of the kind.

(10) Aids and obstacles to reintegration. There is no shelter provision for individual adult male VOTs. A returning adult male VOT who is not able or willing to return to their family must rely upon accommodation in the rented sector with the assistance of NGOs. Such support is provided after initial identification as a VOT by an NGO and without the need for a formal declaration of that status.

(11) The normal offer of rented accommodation from an NGO is limited to six months, but the occasional need for longer term help is likely to be able to met. Whilst the NGOs current capacity for male VOTs is relatively limited, there are clear indications that should there be a need to increase capacity, support is scalable with the necessary funding and lead-in time to recruit and train additional staff. The NGOs are widely acknowledged to be supportive and to assist VOTs proactively and positively and without discrimination.

(12) Once a VOT leaves the rented accommodation provided by NGOs, they are required to obtain a formal declaration of their status in order to access the support provided by the Albanian state. Such declarations must be obtained by attending an interview with a specialised police officer and a social worker. There is a comprehensive and detailed framework of provision to support recognised VOTs with reintegration including the NRM and SOP as well as some support in employment, limited financial assistance, livelihood skills, housing and access to healthcare.

(13) The institutional framework is bolstered by initiatives undertaken by NGOs who will assist male VOTs to access state or municipal reintegration support, but also run their own support programmes including fulfilment of basic needs, housing support, financial aid to start a small business and psychological counselling.

(14) For each reintegration measure available, there are practical challenges associated with access to the measure. Whilst VOTs are a priority group for social housing and rent subsidies, and NGOs will assist the VOTs to access what is available, there are many other priority need categories and state and municipal funding may simply not be available for such programmes.

(15) In addition, VOTs may encounter a range of obstacles to access these aids to integration. Prevailing social mores discourage an adult male VOT from seeking reintegration support. As a result of the support offered by the NGOs, however, it will generally be reasonable to expect an adult male VOT to identify himself as such on return, so as to access the support available from NGOs and, subsequently, the Albanian state. An adult male VOT may however be able to establish that it would be unreasonable to expect him to access that support on account of particular vulnerability, including genuinely-held subjective fear, mental health problems, disability or membership of an ethnic minority group.

(16) Sufficiency of protection. The Albanian government has made significant further efforts to improve its response to trafficking and VOTs and there is a general sufficiency of protection for an adult male VOT. However, this will not be effective in every case and his particular circumstances must be considered.

(17) Whether an adult male VOT will be able to access sufficient protection from the authorities will depend upon his individual circumstances and the additional protection his particular circumstances reasonably require. In conducting this assessment the factors under the two main headings of vulnerability and information relevant to traffickers, should be considered.

(18) Vulnerability to re-trafficking increases with lower social status, economic standing and education; with disability or health (particularly mental health) concerns; for ethnic minority communities, particularly Roma; for those from remote / rural parts of Albania; for those who are younger; for those without a support network; and for those with a history of domestic violence in the family. However, given the support provided by the NGOs together with the institutional framework, it will generally be reasonable for an adult male VOT to engage with the identification process, which then enables them to access the protective and rehabilitative support available. There may be specific individual factors going beyond a general reluctance to engage in an individual case. These must be considered on a case by case basis. The information relevant to the traffickers as summarised above must also be considered.

(19) An adult male VOT assessed to require the additional protection of shelter accommodation to avoid re-trafficking and/or reprisal, will not be able to access it but careful consideration must be given to whether on the facts of the individual case, rented accommodation with associated reintegration and security support would be sufficient.

(20) Internal relocation. The safety and reasonableness analyses must take account of all relevant circumstances, including the vulnerabilities and mitigations in the place of relocation. In general, the support available to adult male VOTs who are not at risk of reprisal or re-trafficking suggests that internal relocation will not be unduly harsh.

(21) An adult male VOT who requires a shelter to be safe in his home area, is unlikely to be safe anywhere else.

(22) Where an adult male VOT is not at such risk so as to require a shelter, but is still being sought by his traffickers, internal relocation to anywhere outside the bigger cities is unlikely to be safe. Whether a person would be safe from their trafficker in Tirana or one of the other bigger cities such as Durres, Vlore, Elbasan and Shkoder will depend on how actively a man is being sought, the reach and intent of the traffickers, their connections if any with the authorities in that area and their vulnerabilities.

(23) Vulnerabilities are relevant at the safety analysis stage because they play a role in the ability to access rehabilitation and support. Where rehabilitation is not possible or unlikely, the risk of re-trafficking increases.

(24) Reintegration is more accessible in Tirana due to the lack of availability of social housing or rental support from the authorities in other areas.

(25) PSG. Albanian male VOTs share a common background and, because they are perceived as different by surrounding society, have a distinct identity in Albania. They are therefore members of a PSG both pre and post NABA. There must be a causative link between the fear of persecution and the membership of the PSG.
The appellant’s individual circumstances
Hearing on 27 July 2026
364. The parties agreed that the issue we have to decide is whether the appellant qualifies as a refugee. The appellant’s human rights appeal has been abandoned under s.104(4A) of NABA, when he was granted leave to remain in October 2024. Mr Tabori told us that he did not require us to consider whether the appellant qualified for humanitarian protection, in the event he did not qualify as a refugee. Humanitarian protection will of course only be open to the appellant if we conclude that he is at risk of serious harm in Albania, but the requisite causal link to his being a male VOT is absent.
365. We heard evidence from the appellant through an Albanian interpreter. He confirmed his initial statement before the First-tier Tribunal dated 8 January 2024 and his supplementary witness statement dated 25 June 2026, and was cross-examined by Ms Reid on behalf of the respondent. Ms Reid supplemented written submissions on behalf of the respondent with oral submissions and we heard oral submissions from Mr Tabori. We refer to the content of that evidence and those submissions as necessary below when explaining the reasons for our factual findings and evaluation of risk on return. At the conclusion of the hearing we reserved our decision.
The appellant’s account
366. We set out a short summary of the appellant’s account at the start of this decision. It is appropriate at this stage to set out that account rather more fully, taking into account what he said before us and before the FtT, orally and in writing.
367. The appellant travelled to Belgium with his father in November 2021 and he and his father were at the bar where he asked for work because his father was meeting a friend. He had confided his situation in a waiter at the bar and asked about potential employment. Three Albanian men overheard his conversation and offered him work just saying they would give him a job and would pay him. There were no further details given of the work but he just wanted to escape from his father. He left with the men in a car, contacting his father by phone to tell him he was leaving.
368. The appellant was taken to a warehouse where another young person was working, who was taken away when the appellant entered. The operation seemed organised and professional to the appellant with people coming and going with deliveries, and one of the three men giving orders to the other two. The men were on the phone talking about packing or sending boxes and he heard them talk about distributing drugs, from the Netherlands to Belgium and then on to the UK. The men only used nicknames for each other. The appellant heard them address someone on the phone as “boss”.
369. The appellant performed manual labour at the warehouse. He was not paid and was not allowed to leave. His mobile phone was taken from him and his identity card photographed. The men unlocked his phone using his face ID, looked through his contacts and told him they had all his family’s details and his home address. They said he could not leave until he paid back what he owed them for food and accommodation. They did not tell him how much that was. When the appellant did not do the work as he was told to do it, he was beaten. He was beaten for waking up late. The appellant was told he or his family would be killed if he tried to escape or go to the police. The men threatened to kidnap or kill his younger brother. The appellant tried to escape around Christmas Day 2021 because he had become sick. He was caught, beaten and kicked and his nose badly injured. He was cursed at and threatened with death if he tried to escape again.
370. Shortly afterwards, the appellant overheard a discussion about selling him to someone in the UK. He was put in a lorry with another young Albanian. When they arrived in England, two different Albanian men met them at a petrol station and took them to McDonalds and then drove away with them in a car. The car stopped at traffic lights and the appellant was able to open the door and run away. He found some police officers and reported his situation.
371. The appellant’s mother reported receiving threats from the traffickers over an extended period of time. It is significant to note that Mr McCrossan’s evidence, accepted by the First-tier Tribunal, was that he had a conversation with the appellant’s mother in January 2022, before the appellant had access to any mobile devices to contact his parents. The appellant’s mother was genuinely hysterical and very distressed because she had not heard from the appellant in two months. She said that she had received a lot of threatening phone calls about the appellant and shared her call log, which showed calls from blocked numbers and she was afraid that those threatening the appellant would come to the house.
372. The appellant had one to one appointments with the UK police every two to three days over the course of three weeks when he applied for asylum. During those appointments he told the police everything he knew about the traffickers, their operation, their route to the UK and the warehouse where he worked (although he did not know its precise location). Mr McCrossan told the appellant that the UK police had contacted the Albanian police about his case. Mr McCrossan included in his letter before the First-tier Tribunal, an extract from a crime report from the allocated Detective Constable who had independently spoken to both the appellant and his mother and in his crime report considered that on the current level of risk based on threats made to the appellant’s mother and the information the traffickers had, the appellant’s home address was at risk and returning the appellant to Albania would increase the likelihood that the appellant would come to further harm.
373. The appellant’s mother told him that the traffickers became aware that he had reported them to the police, because his father informed them. The traffickers went to the house, and his father told them that he did not have any issue with them, it was the appellant who had reported them to the police. He was asked why he thought that his father would do that and he said that he must have thought that the traffickers would thereby think that he, his father was not to blame.
374. The appellant said that his mother received threatening calls every couple of days for around two years. The traffickers told his mother that the appellant owed them a large amount of money and threatened to kill her and the appellant’s younger brother. Not only did they visit the family home, but they also visited the appellant’s brother’s school, his father’s workplace and the coffee shop his grandfather frequented in another area of Tirana to make threats.
375. The appellant’s parents and his younger brother left Albania in about 2024 (after the First-tier Tribunal’s decision) and claimed asylum in the USA, because of their fears of the appellant’s traffickers. They changed their details so that the appellant only found out his family had claimed asylum in November 2025 when his mother called him.
The preserved findings
376. As set out above, the respondent accepted in her letter dated 14 February 2023 refusing the appellant’s asylum and human rights claims, that he was a victim of domestic violence (from his father) and was trafficked to the UK from Belgium. Before the First-tier Tribunal, the respondent did not challenge or dispute the details of the appellant’s account of his trafficking (see [45] of the First-Tier Tribunal decision). Indeed, the judge recorded that there was no real attack on the appellant’s credibility (see [49]).
377. The judge’s preserved findings can be summarised as follows:
(i) The appellant and his mother were victims of domestic abuse from his father;
(ii) The appellant was taken to Belgium by his father, who said he was taking him for medical treatment for his vitiligo;
(iii) The appellant ran away from his father in Belgium and asked for work in a bar where he was offered work by Albanian males;
(iv) As a result he was trafficked to the UK;
(v) He was able to escape in the UK and claimed asylum straight away;
(vi) The appellant’s traffickers took his identity card or a copy;
(vii) The appellant’s traffickers had access to his phone;
(viii) The appellant’s father failed to report him missing to the police in Belgium;
(ix) The appellant contacted his parents with the help of Mr McCrossan, his social worker at the time;
(x) Mr McCrossan was a most impressive witness and his evidence was reliable – this included the detailed letter dated 7 February 2024;
(xi) The appellant’s mother had been receiving threatening phone calls from blocked numbers;
(xii) The threats were made by the appellant’s traffickers;
(xiii) The appellant’s traffickers might well seek to pursue him if he were to be returned to Albania;
(xiv) The appellant would not be supported by his family if he were to return to Albania;
(xv) The appellant could not manage without support in the UK;
(xvi) The appellant would be unlikely to be able to access such help as might be available in Albania.
Our findings of fact
378. This is a pre-NABA asylum claim and it follows that we must apply the lower standard of proof throughout. We must therefore consider whether the appellant’s evidence as to what has taken place since the preserved findings are reasonably likely to be true. We are satisfied that the appellant’s evidence is entirely credible. We bear in mind that the respondent did not dispute the appellant’s credibility before the First-tier Tribunal and he benefits from wide-ranging and significant preserved factual findings. We have nonetheless carefully considered the updated evidence in the light of the questions posed in cross-examination and the submissions made on behalf of the respondent.
379. The appellant provided straightforward and direct answers to all questions asked. He readily made concessions in cross-examination which might be seen as undermining his case. By way of example, he agreed that he had good job prospects in Albania because of his skills and education, and that his mental health was better than it had been in Albania.
380. We do not accept that the appellant’s credibility has been undermined in the manner suggested on behalf of the respondent. We do not regard his claim that his mother disclosed to him that his father had told his traffickers that the appellant had reported them to the police to be improbable. That claim must be considered against the background of abuse by the father and the mother reporting to Mr McCrossan in stark terms and in a very distressed manner that the appellant’s father would kill him if he returned. Before the First-tier Tribunal, Mr McCrossan explained very persuasively why he was sure that due to the appellant’s lack of access to, and fear of using mobile phones when he was initially placed in local authority care, the appellant and his mother had not been able to contact each other before they spoke. His mother therefore provided spontaneous and unrehearsed important information to Mr McCrossan. It is clear from this that the appellant’s father had no motivation to save the appellant from the traffickers. He refused to speak to Mr McCrossan when his son was located and made his views very clear to the mother. In the circumstances, it is plausible that the father would seek to distance the rest of the family from the appellant’s actions and make it clear that they were not responsible for any difficulty the traffickers might experience.
381. We do not find it undermines the appellant’s credibility that he has not produced any evidence that his mother reported the traffickers’ threats to the local police as he said. He explained that he did not know how he could prove it and the ways he might have done that were not put to him.
382. In his supplementary statement the appellant explained that his parents and his younger brother left Albania in about 2024 and claimed asylum in the USA, because of their fears of the appellant’s traffickers. They changed their details so that the appellant only found out his family had claimed asylum in November 2025 when his mother called him through WhatsApp on an American number. Ms Reid put to the appellant in cross-examination that he had not asked his mother to prepare a witness statement or other letter for the tribunal. He agreed he had not. Ms Reid did not take that any further. Ms Reid submitted that although there were preserved findings from the First-tier Tribunal, a significant amount of what had happened in the last 2 ½ years was communicated to the appellant through his mother and as there had been no attempt to take evidence from his mother, she asked us to place little weight on the second-hand account of what his mother had told him. We do not accept that the mother’s failure to provide corroborative written evidence undermines the appellant’s credibility. It is plain that the mother has been living in fear of the father, who does not want her to be in contact with the appellant or provide him with details of their circumstances. As noted in MAH (Egypt) v SSHD [2023] EWCA Civ 216; [2023] Imm AR 713, at [86], the absence of corroborative evidence can, depending on the circumstances, be of some evidential value: if, for example, it could reasonably have been obtained and there is no good reason for not obtaining it, that may be a matter to which appropriate weight can be given. For the reasons we have given, in this case there are cogent reasons why the appellant could not be reasonably expected to press his mother for more details on the claim for asylum in the USA.
383. Ms Reid submitted that the position the appellant presented of lacking in independence and requiring the support of support staff was not credible. The absence of any evidence from social services to support his lack of independence was because he was far more independent than he would have the tribunal believe. The appellant was asked why he had not obtained a statement from his current social worker or from his mentor and he pointed out that his social worker was present in court and that no one had asked him for a statement from his social worker or his mentor.
384. The appellant has clearly moved on from being a child under the violent control of his father and then the traffickers. He is 21 and has been sufficiently educated in the UK that he has been accepted on a university course. He candidly explained that he would still find it very difficult to cope with living alone in Albania. We accept his evidence that he would have no family to rely upon. His immediate family are in the USA. He has no contact with any other members of his extended family. We note his paternal grandparents live in Tirana but the very poor relationship between the appellant and his father explains the absence of any relationship with his paternal grandparents. The appellant will have the potential re-integration support in Albania including from NGOs, and we consider this further below. Nevertheless, we accept his reasoning that he would feel genuine difficulty about living alone. He has never lived alone and had to cope by himself. He continues to be accommodated as ‘a looked after child’ in specialist accommodation with the benefit of support from a social worker and a mentor. To his credit the appellant recently completed six months in work experience, but he was not living away from his supported accommodation and would have been acting under the direction of others. The appellant was the victim of serious abuse from his father, whom he described as controlling and not allowing him to have friends and he suffered depression from the age of 14. The First-tier Tribunal accepted he was not able to manage on his own at the age of 18. He suffers from vitiligo which makes him self-conscious. He is a VOT and genuinely timid and fearful that his original traffickers remain adversely interested in him. We find below that these fears continue to be well-founded notwithstanding the passage of time. Accordingly we consider that the evidence he gave about his feelings was credible and we do not consider it undermines his evidence that there is no supporting evidence from his social worker or mentor.
385. We therefore accept the appellant’s account in its entirety. To summarise, we are therefore satisfied that:
(i) The appellant’s family were regularly pursued and threatened up until their departure from Albania;
(ii) The traffickers visited the appellant’s home, his father’s workplace, his brother’s school, and the coffee shop his grandfather used, making threats;
(iii) The threats were not just to the appellant but also to the appellant’s mother and younger brother;
(iv) The traffickers said the appellant owed them money;
(v) The appellant’s father has told the traffickers the appellant reported them to the police in the UK;
(vi) The appellant was interviewed by the UK police regarding his trafficking experiences and information was passed to the Albanian police;
(vii) The appellant’s mother reported the threats to the local police who told her that they could not do anything;
(viii) The appellant’s family travelled to the USA and claimed asylum because of the threats from the traffickers.
Evaluation of prospective risk
386. We acknowledge that the fact of past persecution is a serious indication of the risk of future harm unless there are good reasons to consider that the future harm will not be repeated (CG finding (7)), applying paragraph 339K of the Immigration Rules). The appellant has been trafficked and suffered serious harm relating to this. However, this appellant’s overriding and clearly articulated fear upon return is that he is at risk of reprisal from the original traffickers, particularly in the light of the extended period of threats to his family members and it is upon this claim that we pay particular focus.
387. When assessing the risk from the original traffickers we need to consider (i) the appellant’s circumstances and vulnerabilities, together with the assistance that would be provided to him on return to Albania, and (ii) what is known about the original traffickers (CG finding (8)). In the circumstances of this case it is more convenient to begin with what is known about the original traffickers, and we do so by reference to the factors at CG finding (8)(ii).

a) The size of the operation and its level of organisation. We are satisfied that the traffickers do have a significant presence in Albania. The men in Belgium were Albanians and they were able to threaten the appellant’s family not only by phone but face to face in Albania. We therefore do not accept the respondent’s written submissions to the effect that the evidence did not support a finding that the traffickers were a sufficiently large or organised group to place the appellant at risk. The group clearly had a sufficiently significant presence in Albania, even though the appellant first encountered them in Belgium. In addition, the credible description given by the appellant of the traffickers and their activities indicates that they had links to international drug trafficking, to the Netherlands and the UK as well as a presence in Belgium and Albania.

b) Threats made or acted upon in the past. We have accepted the appellant’s family were subjected to threats which ultimately led to his parents and brother claiming asylum in the USA. The appellant’s mother may, we agree, have protected him from knowing the full extent of the threats or indeed any action the traffickers may have taken, but clearly they did not carry out their threats to the extent of killing the appellant’s mother or kidnapping and killing the appellant’s brother. Nevertheless there were both repeated and regular threats over a two year period, face to face in Albania as well as over the telephone. The traffickers have maintained that the appellant owes them money. That the appellant has not been threatened in the UK is not, we consider, an indication of lack of interest. The appellant has never been threatened in the UK even when his family were being regularly threatened. The appellant does not use social media under his real name. This makes it far more difficult to locate the appellant. He is in the care of the local authority. In these circumstances threatening or attacking him or attempting to re-traffic him in the UK would be a ‘high stakes’ operation. We do not accept the respondent’s submission that because the threats to the family were not acted upon, the appellant would not be at continuing risk.

c) Connection to family members or acquaintances. There is no obvious connection between the traffickers and family members, save that the traffickers have demonstrated that they have been able to successfully track down family members and probably have access to relevant information from the appellant’s phone.

d) Links to the community/area the appellant and his family originate from. The traffickers made threats in the appellant’s local area near to Tirana and in Tirana more generally. Whilst the traffickers would have had the appellant’s address and the contact numbers in his phone, that would not automatically have led them to his father’s workplace, his brother’s school (although they might simply have looked round local schools) or the coffee shop in another part of Tirana which his grandfather frequented. The traffickers must have had information from local people about the family or had resources to follow family members. The local police were either not willing or not able to act to protect the family as they did not act on the appellant’s mother’s complaint.

e) The extent to which the appellant has tangible evidence which might jeopardise future operations. The appellant has already provided information to the police in the UK. They regarded it as sufficiently pertinent to ask him further questions over a period of three weeks. He has nothing left to tell them. The appellant said in his witness statement that he believed that the traffickers would have had to abandon the warehouse in Belgium and the operation in the UK might have been disrupted. The appellant was cross-examined on this point and he said that his traffickers would think he had reported the location of the warehouse and he had cost them money and they had lost profit; maybe that was a safe route to the UK before and the traffickers could not do that anymore. Ms Reid submitted that this was speculative and there would be no reason for the traffickers to shut down the entire operation. Of course the appellant cannot know what the traffickers believed or did, but the appellant was not blindfolded when he was taken to the warehouse so it could reasonably be thought that he revealed the location and could identify their faces. Whilst they took precautions against identification (such as the use of nicknames), it is reasonably likely that they believe that the appellant has tangible evidence which he has already reported to the UK police and might yet report to Albanian law enforcement. The traffickers knowing that the appellant had spoken to the UK police must at least have led to some disruption whilst they evaluated whether the appellant’s actions had caused them damage.

f) The passage of time. We entirely recognise that there has been a lengthy period since the appellant was trafficked and a further period since the family left Albania. However, threats continued up until the family’s departure. There have been no further threats because the traffickers have no obvious means of contacting the family or the appellant. That two years or so have passed without threats does not mean that the traffickers have lost interest in the appellant, given the particular circumstances we have already described.
388. Pulling everything together, we consider that there remains at least a reasonable degree of likelihood that notwithstanding the passage of time, the appellant’s original traffickers continue to hold an adverse interest in him, and he is at real risk of reprisal if returned to Albania. The traffickers are reasonably likely to be part of a large, organised group who operate internationally. They have had the resources to make repeated and regular threats to the appellant’s family in different parts of Tirana, over an extended period of time. The traffickers know that the appellant reported them to the UK police. The length of time they pursued the family after the appellant’s escape indicates they are serious about extracting revenge and ensuring his silence. Their influence is such that the local police were either unable or unwilling to take steps against them, notwithstanding the mother’s complaints.
389. Ms Reid made the point that the traffickers will not know the appellant has returned. As we set out above, the traffickers were able to find the coffee shop the appellant’s grandfather used and appear to have the reach, resources and motivation to locate the appellant. They must have local sources around Tirana and word is reasonably likely to reach them shortly after the appellant has returned. As Mr Tabori pointed out, locals from the appellant’s area commute into Tirana for work. More importantly, the original traffickers are reasonably likely to learn of the appellant’s return to Albania within a short space of time, whether he returns to his home area in or around Tirana or to another part of the country. This is reasonably likely to be so for a combination of reasons. The original traffickers have demonstrated their determination over an extended period of time. They are reasonably likely to make use of their connections and contacts within the authorities to help them to do so. We bear in mind the observations in AD v Sweden (supra) and our conclusion that there has been measurable progress in tackling corruption at [295], but the country background reports are clear that corruption remains a concern. Ms Trimi readily accepted that corruption remains a problem in Albania (see [178]) and at [333] we summarise Ms Trimi’s evidence that an OCG with connections would be able to use these to find an individual of particular interest to them. In addition, we recall the evidence regarding Albania’s small size at [333] above, including Mr Carswell’s persuasive explanation that an individual could be located anywhere if an OCG is particularly interested in finding him, including through corrupt officials. Those observations are consistent with the conclusion in previous country guidance decisions that Albania is a small country in which communities are alive to newcomers. We therefore conclude that the particular circumstances of this case are such that it is reasonably likely that this appellant will be located by the original traffickers within a relatively short time after his arrival in Albania.
390. This means that we do not necessarily need to assess the impact of the appellant’s vulnerability when assessing the risk of reprisal without more. For completeness, we have accepted that the appellant is genuinely fearful of coping on his own and has never lived on his own or had to organise his own life. Ms Reid submitted that if the appellant returned voluntarily he would also have access to up to £3000 from the voluntary return scheme but as we pointed out at the hearing, the appellant currently has permission to stay in the UK and the website link she gave us indicated that he would not be eligible for the scheme in these circumstances.
391. There is no shelter provision for adult male VOTs and the appellant has no family to return to. The appellant would therefore have to rely on accommodation in the rented sector with the assistance of NGOs. Such support is provided without the need for formal declaration of VOT status by the authorities (CG finding (10)). We note the appellant’s reluctance to identify as a VOT in Albania. There are four main reasons for this: (i) he would be stigmatised as a male VOT; (ii) he does not trust the police, (iii) in any event, he would not be provided with the level of security he needs, and; (iv) his fears. These reasons are consistent with the obstacles to reintegration we discuss at [257]-[285] above. There are a number of factors which when taken together provide justification for this appellant not wishing to engage with the state authorities. His fears of the traffickers are based upon his belief that they are well-organised and with connections in Albania, and their determined attempts to threaten and silence his family over an extended period of time. We have found these fears to be well-founded. On the other hand, it would be reasonable for this appellant to obtain help from the NGOs. His mental health has improved and he has demonstrated that with support in place he can access education and work experience. The appellant will no doubt encounter obstacles but it would in principle be reasonable for him to access the support the NGOs can provide to him as a VOT – see CG finding (15) and [268] above. Whether that support together with other protection available, would be sufficient to obviate the real risk of reprisal from the original traffickers, we turn to below.
392. Before addressing sufficiency of protection, we wish to address the submissions made on behalf of the appellant to the effect that he would not be able to access accommodation given the capacity concerns we identify at [271] above. We reject that submission. Whilst we found the current capacity for accommodation for male VOTs to be relatively limited, we noted that there was the desire and ability to increase capacity if necessary, albeit funding was uncertain. We also noted there to be no evidence that NGOs were turning away those male VOTs who came to them for help (see [273]). The position is rather that there have been limited numbers approaching the NGOs ([223]). In addition, there is emergency accommodation that could be accessed ([312]). Hence the conclusions at CG findings (11)-(15).
393. Having concluded that the appellant is at real risk of reprisal from the original traffickers within a relatively short period of his arrival in Albania, we turn to consider whether the state will be able and willing to offer him sufficient protection. As made clear at CG finding (16), the Albanian government has made significant further efforts to improve its response to trafficking and VOTs and there is a general sufficiency of protection for an adult male VOT. However this will not be effective in every case. We must therefore address whether this appellant will be able to access sufficient protection from the authorities, having considered his individual circumstances and the additional protection his particular circumstances reasonably require. The two main headings to consider are again information relevant to the traffickers and vulnerability (CG finding (17)).
394. We note the dearth of cogent evidence that corruption undermines the sufficiency of protection in place for VOTs generally at [299] above. However, the appellant’s individual circumstances demand a level of additional protection at the higher end of the spectrum in the light of our findings regarding what is known about the original traffickers, especially their level of organisation, intent and determination, notwithstanding the passage of time. As set out at CG finding (19) we must consider whether rented accommodation with associated reintegration and available security support would obviate the real risk of serious harm from the original traffickers. As we note at [311], Ms Trimi was asked to clarify what the equivalent provision would be for an adult male VOT, assessed to require a high security centre (to use the language in the SOP) or shelter. She indicated there was a significant gap in the absence of a male shelter but that there would be police protection. There was very little in the way of detail as to what that police protection would involve but we were not taken to any cogent evidence that the police would be able to provide the 24-hour equivalent protection available in the state-run shelter, as described at [44(b)] of TD & AD. Indeed, we noted at [314] that Terre des Hommes is quoted within the Asylos 2024 report as pointing out that the fact that adult male VOTs are usually accommodated in rented apartments “is not good because there might be cases that need 24 hours assistance rather than living separately”.
395. As we have noted, there is no shelter provision for male VOTs, and there is certainly no shelter which provides for male VOTs the level of protection provided by the state-run NRCVT. In these circumstances, and given the nature and level of threat faced by the appellant from the original traffickers, we consider that he would require something akin to a witness protection programme in order to ensure his safety. The appellant would only be eligible for formal witness protection if he was cooperating with a criminal investigation or prosecution. As we have already explained, we think it unlikely that he would engage with the authorities in that way, and his reluctance to do so is reasonable in his particular circumstances. It is nevertheless instructive to consider what is said in the background material about the witness protection programme, so as to assess the efficacy of steps taken by the Albanian state to protect individuals who are known to be at heightened risk but are not housed within a protective institution such as the NRCVT.
396. At a general level, the CPIN makes reference to the European Commission reporting in 2022 that the witness protection programme had worked satisfactorily, with 24 witness protection operations performed in 2021, compared to 19 in 2020. However it is clear that this refers to the general witness protection programme, which appears not to have been extended effectively to VOTs.
397. We note only one instance of a (female) VOT being admitted to a witness protection programme in the GRETA reports, leading that body to recommend in 2020 that additional steps should be taken to provide victims with effective and appropriate protection. The 2023 TIP report noted that victims who testified against traffickers had access to the programme but that none had participated in 2021 or 2022. The 2024 report reported that none had participated in 2023. Mr Carswell was entitled in our judgement to describe, in answer to the respondent’s written questions, the number of VOTs placed in witness protection as “incredibly low”. Different and Equal reported to Asylos that it was “seldom used”. We also note that the Director of the NRCTV’s response to Ms Trimi’s questions in 2025 highlighted “obtaining witness protection status” as one of the ongoing challenges faced in the reintegration of male VOTs. The EC’s Albania 2024 Report noted that Albania is not aligned with the acquis on victim’s rights. Whereas female VOTs at imminent risk of harm are safeguarded within the state-run shelter, we consider there to be a lack of evidence to demonstrate any form of comparable provision for those male VOTs who require it, such as this appellant.
398. The appellant therefore requires a level of security from the original traffickers that cannot be provided in rented accommodation, even with NGO and police support. Upon identification to an NGO, the initial offer to the appellant will be of emergency accommodation whilst he is assessed. Wherever that accommodation is, the appellant’s well-founded fears are such that without the protection a witness protection programme or a shelter would provide, he faces a real risk of serious harm in relation to which the state are unable to provide sufficient protection.
399. In addition, the appellant’s fears are such that he will understandably feel highly anxious and insecure, and unable to access work. This means that his vulnerability is an additional reason why he requires a shelter, albeit his vulnerability is predominantly rooted in his fears. The appellant is now more mature, much better educated and with greater prospects of finding work. His updated circumstances must be viewed in the context of living in Albania, even assuming NGO support. He would be returning with significant anxiety, uncertainty and fears for his life. Whilst it might well be the case that he would be in a good position after practical support from an NGO to help him integrate, he would nevertheless be returning in an understandable and objectively justified state of fear of the traffickers. For the reasons we have outlined we regard those fears to be well-founded and the associated anxiety accompanying those fears as justified.
400. The appellant remains at risk from his traffickers in his home area on the outskirts of Tirana. Given its proximity to Tirana he is also at risk there. The local police have proved unwilling or unable to protect his family. Provision of accommodation with the oversight of police who have not protected his family in the past and in relation to traffickers who have demonstrated a level of sustained determination in making threats against the family, would not be sufficient to protect him. We are therefore satisfied that the appellant would require a shelter to be safe in his home area. Having found that this appellant’s circumstances are such that he requires the additional protection of a shelter to avoid the real risk of reprisal from the original traffickers and having noted that the requisite level of police protection he requires would be unavailable outside of a shelter or witness protection programme, we conclude that he would not be able to access the additional protection his particular circumstances reasonably require.
401. An adult male VOT who requires a shelter to be safe in his home area is unlikely to be safe anywhere else (CG finding (21)). We are satisfied that in the particular circumstances of this case, what is known about the original traffickers is such that they have the ability and inclination to locate the appellant away from his home area. In the circumstances, internal relocation is not viable because it would not be safe.
402. It remains for us to consider the nexus question posed by Article 1A(2) of the Refugee Convention i.e. whether the appellant’s well-founded fear is for reasons of his membership of a PSG. We recall, in the light of [17] of K & Fornah v SSHD, that the ground on which the appellant relies need not be the only or even the primary reason for the apprehended persecution; it is enough that the ground relied upon is an effective reason. In our judgement, the position is clear. There is a real risk that the appellant’s original traffickers seek to target him for reasons relating to his VOT status. This is because he has disrupted their operation; they fear that he might provide tangible evidence to the Albanian police; and they claim he owes them money. Each of those essentially criminal motives is inextricably linked to the appellant’s status as a VOT. We therefore consider there to be a clear causal link between the persecution feared i.e. reprisal from the original traffickers and the appellant’s membership of a PSG, male VOTs (CG finding (25)).
Conclusion
403. We are satisfied that the appellant remains at real risk from those who trafficked him and would not receive sufficient protection from the authorities and cannot safely relocate. He therefore qualifies for asylum.

Decision
We allow the appellant’s appeal on Refugee Convention grounds.

DCP Plimmer
Deputy Chamber President Plimmer

12 August 2026

ANNEX: List of Sources

Date
Title Author/Source
26 February 2026 Number of male Albanian VOTs who have received a positive CG decision from the SCA and either forcibly returned or returned voluntarily to Albania. The period of data relates to 2015-2025. Home Office
February 2026 Guidance Note on Albania UNHCR
12 December 2025 SPAK – Annual Report 2024 Spak.gov.al
28 November 2025 Request for information – Asylum and Refugees – Male Victims of Trafficking from Albania Intergovernmental consultations on migration, asylum and refugees (IGC)
19 November 2025 Albanian PM accuses Mahmood of
'ethnic stereotyping' BBC News Article
14 November 2025 Expert Report
Anila Trimi
13 November 2025 Respondent’s Country Information Report in respect of Albanian trafficked males GOV.UK
4 November 2025 The European Economic and Social Committee and The Committee Of The Regions, 2025 Communication on EU enlargement policy European Commission, Communication From The Commission To The European Parliament, The Council
November 2025 Global Organised Crime Index – November 2025 – Albania Global Initiative
November 2025 Global Organised Crime Index – November 2025 – United
Kingdom Global Initiative
22 October 2025 UK sanctions gangs and illicit
finance network propping up people smuggling trade GOV.UK – Press release
22 October 2025 Albanian asylum seekers in
the UK and the EU The Migration Observatory
20 October 2025 Chair's conclusions of the
Western Balkans economic ministerial conference GOV.UK – Policy Paper
20 October 2025 Western Balkans Summit
Economy Ministers’ meeting GOV.UK – Policy Paper
16 October 2025 Albanian victims of trafficking in the UK: A breakdown (previously tab 418 of the Composite Trial bundle) Miclu.org
16 October 2025 Border security officers sent to Balkans to disrupt people-smuggling networks Guardian Article
15 October 2025 WBF Success story westernbalkansfund.org
15 October 2025 Foreign Ministers’ meeting of the Western Balkans Summit on the Berlin Process: Chair’s Conclusions GOV.UK – Policy Paper
15 October 2025 Rising housing prices and
tourism, how rents are "flying" Revista Monitor
15 October 2025 Expert Report
Professor Dimitrios Dalakoglou

14 October 2025 Press release – Western Balkans Summit on the Berlin Process, 22 October 2025: Chair’s Conclusions GOV.UK
9 October 2025 Press Release -Foreign Secretary to put boosting security and tackling illegal migration at the heart of foreign policy during meeting of European partners GOV.UK
8 October 2025 Implementing Decision on approving the second release of funds to Albania, Montenegro and North Macedonia under the Reform and Growth Facility for the Western Balkans EU Commission
7 October 2025 40% of Household Budgets Spent on Food – Albanian Families Struggle Under Rising Prices Euronews Albania
3 October 2025 Summary of latest statistics Home Office
3 October 2025 17 suspected human traffickers arrested in Albania and Colombia Europol.com
3 October 2025 International human trafficking ring
rolled up in Albania and Colombia Eurojust Press Release
October 2025 1+1 Apartment for Rent in Unaza – Opposite Harry Fultz School Duashpi.al
October 2025 Apartments for Rent in Tirana Albania Property Group
October 2025 OSCE Presence in Albania, “Combating Human Trafficking – Activities and Projects”
Organisation for Security and Cooperation in Europe (OSCE)
October 2025 Apartment Listings in Tirana
RealEstate.al
10 September 2025 Albania Among the Countries with the Highest Informal Economy in Europe Politiko
8 September 2025 Expert Report Mr Colin Carswell
1 September 2025 Overtourism and Higher Living Costs
Worry Albania Tourism Review
September 2025 Investment Climate Statement
2025: Albania US Department of State
September 2025 Statistical analysis Directorate of Free Legal Aid
September 2025 Examining the exploitation of vulnerable migrant populations and interventions to combat human trafficking and modern-day slavery within the illegal UK cannabis cultivation industry. Necchi, H., and Bradford, T. Journal of Economic Criminology
26 August 2025 Country Expert Report Dr Deanna Davy
19 August 2025 Albania UNICEF
11 August 2025 Modern Slavery: Statutory Guidance for England and Wales (under s49 of the Modern Slavery Act 2015) and Non-Statutory Guidance for Scotland and Northern Ireland GOV.UK
August 2025 Albania: Position and Rights of Victims in Criminal Proceedings – Analysis of judicial practice in human trafficking cases for 2024 VATRA
22 July 2025 Modern Slavery and human trafficking in Persons 2024 CPS
21 July 2025 Corruption Trial Against Former Prime Minister Sali Berisha Begins Associated Press (AP News)
15 July 2025 Prosecution Accuses Former Ruling Party MP of Organised Crime Ties Balkan Insight
15 July 2025 “Government Decision: Self-
declaration of address becomes mandatory on e-Albania” Euronews Albania
8 July 2025 Albanian State Police Bring Down Multi-National Trafficking Network Ourrescue.org
8 July 2025 2025 Rule of Law Report – Country
Chapter: Albania European Commission
1 July 2025 Albania - Enlargement and Eastern Neighbourhood European Commission
18 June 2025 Fourth Evaluation Report on
Albania (2025) Council of Europe / GRETA
18 June 2025 Fourth evaluation round: Measures to prevent and detect vulnerabilities to human trafficking Group of Experts on Action against Trafficking in Human Beings (GRETA)
16 June 2025 Border corruption across the Western Balkans Transparency International Knowledge Hub
12 June 2025 Wages in Construction and Tourism Remain Below Average CNA
June 2025 Asylum claim and initial decisions detailed datasets (male only) - for the period 2009-2025 GOV.UK
22 May 2025 Stigma Prevents Albanians from Seeking Mental Health Treatment Euronews Albania
20 May 2025 Albania country security report Overseas Security Advisory Council (OSAC) (2025)
20 May 2025 Albania country security report Overseas Security Advisory Council (OSAC) (2021)
12 May 2025 A Disastrously Successful Judicial Reform New Lines Institute
May 2025 Annual Report -2024-2025 Independent Anti-Slavery Commissioner
May 2025 Albania: Trafficked boys and young men Asylos
30 April 2025 Concluding observations on
the third periodic report of Albania UN Human Rights Committee
24 April 2025 Consequences of Informality VoxDev (VoxDevLit Issue 2). Centre for Economic Policy Research (VoxEU Network)
2 April 2025 Key Figures from SPAK's 2024 Annual Report
Euronews Albania
April 2025 Shpresa Programme and MiCLU,
Trafficking and organised crime in Albania Garden Court Chambers
April 2025 Dismissing Risk: The impact
on trafficking survivors of labelling countries of origin as ‘safe’ Helen Bamber Foundation
April 2025 Albanian Nationals Gender Split for the period 2014-2025 UK Data Service
April 2025 Annual Report 2024 ARSIS
April 2025 Position and Rights of Victims in
Criminal Proceedings, Analysis of judicial practice in human trafficking cases for 2021-2023 VATRA - Albania
29 March 2025 Albanian crime lords are using TikTok to advertise £100,000-a-year jobs as drug dealers Sun.com
25 March 2025 Barriers and opportunities to reduce corruption and organised crime in Albania –Research Study 2024 IDRA Research & Consulting (Albania)
24 March 2025 World News story – UN Human Rights Council 58: UK Statement for Albania’s UPR GOV.UK
21 March 2025 Exploitation of Colombian women Voxnews.al
21 March 2025 Second Compliance Report on Albania Group of States against Corruption (GRECO)
15 March 2025 Modern Slavery National Referral Mechanism and Duty to Notify Statistics, Quarter 1 2025 - January to March Home Office
12 March 2025 Labour Force Survey Q2 2025 INSTAT
11 March 2025 Wage Statistics – Quarter 4 2024 INSTAT
6 March 2025 National Referral Mechanism statistics: brief analysis and comment Modern Slavery and Human Rights Policy & Evidence Centre (PEC)
6 March 2025 Annex: An analysis of NRM referrals and DtN reports for potential victims of modern slavery, 2023 to 2024
GOV.UK
6 March 2025 Modern slavery: National Referral Mechanism and Duty to Notify statistics UK, end of year summary 2024 Home Office Official Statistics
March 2025 Home Sweet Home: Housing
Challenges in the Municipality of Tirana Transform Network
March 2025 Directory of services for survivors of trafficking returning to Albania International Organization for Migration (IOM)
10 February 2025 Albanian Court Orders Mayor into Custody on Corruption Charges Associated Press (AP News)
7 February 2025 Press Release - UK to drive international cooperation on irregular migration as host of Western Balkans Summit GOV.UK
February 2025 CPIN Albania: Actors of Protection GOV.UK
January 2025 CPIN Albania: Mental healthcare GOV.UK
January 2025 Albanians seeking protection and mental health Helen Bamber Foundation
January 2025 Albania: 2024 Article IV
Consultation—Staff Report International Monetary Fund
January 2025 Shpresa Programme and MiCLU,
Analysis of the Home Office CIN on Mental Health v.3.0, January 2025 Garden Court Chambers
2025 Albania Youth Unemployment Rate (Ages 15–29) pp3-4 Trading Economics
2025 National Action Plan to combat trafficking in persons (2024-2025) in Albanian Albanian Ministry of the Interior
2025 Understanding Albanian Culture of Migration: The Role of the Family in Precarious Journeys and Human Trafficking Brachou et al., Anti-Trafficking Review (Issue 24, 2025)
2025 Dumani: 33 Former Officials
Investigated RTSH English, 2024 Report
2025 Albania: Trafficking –
Annex 1 (London: Asylos, 2025) Asylos & Asylum Research Centre
2025 Albania: National Action Plan for the Fight Against Human Beings Trafficking, 2021-2023 Albanian Ministry of the Interior
2025 2025 Trafficking in Persons
Report: United Kingdom (2025) US Department of State
2025 2025 Trafficking in Persons
Report: Albania (2025) US Department of State
2025 Small boat arrivals by Nationality - 2018 to end December 2024 (2025) The House of Commons Library
2025 National Action Plan to combat trafficking in persons (2024-2025) translated Albanian Ministry of the Interior
2025 Medaille Trust launches new project to support returning Albanian nationals Medaille Trust
2025 Mapping of Social Services in Albanian 2025 Arlinda Ymeraj
6 December 2024 Presence in Albania, School of Magistrates deliver specialised training on human trafficking OSCE
December 2024 Mock Trial on Trafficking in Persons in Albania United Nations Office on Drugs and Crime (UNODC)
December 2024 2024 report for monitoring of the National Action Plan against Trafficking in human beings (in Albanian) U.S Department of State
December 2024 2024 report for monitoring of the National Action Plan against Trafficking in human beings – translated U.S Department of State
26 November 2024 Presence organises second simulation based training on human trafficking in Albania OSCE
9 November 2024 Long-term rents in Tirana up ~20% year-over-year Revista Monitor
2 November 2024 The bad experience of returning to Albania Politiko
1 November 2024 Presence in Albania enhances collaboration with Albanian Prosecutors and State Police OSCE
November 2024 Mixed Migration in the Western Balkans: Shifting policies, smuggling dynamics and risks Danish Refugee Council
November 2024 Integrity and Independence of Criminal Justice Institutions in the Western Balkans, Police and Prosecution Global Initiative Against Transnational Organized Crime
31 October 2024 European Western Balkans, Key findings of the 2024 European Commission Report on Albania
31 October 2024 Fighting Corruption Remains One of the Most Challenging Issues European Western Balkans
30 October 2024 EC Enlargement Report, 2025 Albania Directorate-General for Neighbourhood & Enlargement Negotiations (DG NEAR)
30 October 2024 Albania Report 2024 European Commission (EC)
23 October 2024 Assistance from the OSCE Presence in Albania OSCE
17 October 2024 Concluding Observations on Albania Committee on Economic, Social and Cultural Rights (CESCR)
October 2024 Fighting human trafficking in Southeastern Europe Permanent Representation of France to the UN and OSCE
October 2024 Albania Country Climate and Development Report: Western Balkans World Bank
17 September 2024 Albania: Is It Really a “Safe Country” for the Purposes of Certification? Garden Court Chambers
14 September 2024 Former Albanian PM Indicted for Corruption Organised Crime and Corruption Reporting Project (OCCRP)
7 September 2024 Albanian drug gangs recruiting cannabis farmers on TikTok Hymas C
6 September 2024 Country Info Brief: Trafficking in Human Beings – Albania ASTRA (Anti-trafficking action)
4 September 2024 Duraku, Z. et al (2024). Mental health awareness, stigma, and help-seeking attitudes among Albanian university students in the Western Balkans: a qualitative study Frontiers in Public Health, 4(2)
2 September 2024 Ethnic Greek Politician Fredi Beleri
Released from Albanian Prison Balkan Insight
1 August 2024 15 arrested in crackdown on high-profile Albanian criminal network Europol
August 2024 Barriers and opportunities to reduce corruption and organised crime in Albania UKGCSI
August 2024 Labour exploitation in the Western Balkans Global Initiative Against Transnational Organised Crime
23 July 2024 General Guideline No. 06 “For the investigation and effective criminal proceeding of the offences against trafficking in persons” (in Albanian) Unknown
23 July 2024 General Guideline No. 06 “For the investigation and effective criminal proceeding of the offences against trafficking in persons” – translated Unknown
4 July 2024 Report on Tirana Prosecution uncovering an alleged hospital corruption scheme BIRN/Balkan Insight
2 July 2024 Social Protection for Children and Families in Albania UNICEF
July 2024 CPIN Albania: Human trafficking GOV.UK
June 2024 Home Office outcome analysis for asylum claims (2006- 2023) Home Office
June 2024 Trafficking in Persons ("TiP") Report US Department of State
June 2024 NRM Implementation Guide and Simulation- Based Trainings (2023–2024) (translated) Organisation for Security and Co-operation in Europe (OSCE)
June 2024 NRM Implementation Guide and Simulation-Based Trainings (2023–2024) Organisation for Security and Co-operation in Europe (OSCE)
31 May 2024 Unsafe in a Safe Country: Evaluating the Support and Reintegration Challenges for Albanian Trafficking Victims within the Context of the UK’s “Safe Country” Designation Guri, K., and Rees, S. (2024) Open Journal of Social Sciences
21 May 2024 On the approval of the National Strategy on Migration 2024-2030
and its Action Plan 2024-2026 Council of Ministers’ Decision No. 21.05.2024
22 April 2024 The tortuous journey of the UK
government's Rwanda plan Guardian.com
18 April 2024 Informality and Decent Work in Southeastern Europe International Labour Organization (ILO)
12 April 2024 Albanian police arrest police officers and businessmen involved in migrant trafficking Reporteri
4 April 2024 Criminal Amnesty is approved in Assembly with 116 votes in favor, 4 Apr 2024 & Amnesty
implementation begins Euronews Albania
April 2024 Albania: Trafficking Asylos
April 2024 Country Profile – Albania UNECE & Housing Europe
7 March 2024 National Referral Mechanism and Duty to Notify statistics UK, end
of year summary 2023 (including Annex) Home Office Official Statistics - Modern slavery
20 February 2024 Fourth evaluation round: Reply from Albania to the Questionnaire for the evaluation of the implementation of the Council of Europe Convention on Action against Trafficking in Human Beings by the Parties Group of Experts on Action against Trafficking in Human Beings (GRETA)
14 February 2024 Repatriated Albanians find new routes back to Britain Bashkin Shala
7 February 2024 Deported Albanians find new ways to return to the UK Reporter.al
February 2024 Small Boats, Big Business - The Industrialisation of Cross-
channel migrant smuggling Global Initiative against Transnational Organised Crime
February 2024 Analysis in the field of migrant smuggling in Albania Balkan and Refugee Migration Council and Danish Refugee Council
12 January 2024 Prevention of Torture
report on Albania Council of Europe Committee
2024 Labour Market Statistics 2023–2024 (translated) INSTAT
2024 Western Balkans Competitiveness Outlook 2024 – Albania Chapter OECD
2024 Information regarding the drafting of the report on Trafficking of Women and Girls (1 August 2022 – 30 April 2024) Unwomen.org
2024 Trafficking Statistics - 2010-2024 Ministry of Justice of Albania
2024 Human Trafficking in the Western Balkans: A review of legal and security perspectives Karaj Stela and Xharo Kristaq
2024 CPI 2024 for Eastern Europe & Central Asia: Vicious cycle of weak democracy and flourishing corruption Transparency.org
2024 Between anti-corruption reform and decline: Examining key actors, strengths and weaknesses in the Western Balkans and Türkiye’s national integrity systems Transparency International
2024 2024 Trafficking in persons report: Albania US Department of State
2024 Global Corruption Barometer: Albania Transparency International
2024 Breaking the Vicious Circles of Informal Employment and Low-Paying Work Organisation for Economic Co-operation and Development (OECD)
2024 Labour Market Statistics 2023–2024 INSTAT
2024 BTI 2024 Country Report Albania Btiproject.org
2024 Global Report on Trafficking in Persons United Nations Office on Drugs and Crime (UNODC)
2024 Albania's Migration Profile (2024) (in Albanian) Instat.gov.al
2024 Albania's Migration Profile (2024) translated Instat.gov.al
2024 Development Finance Assessment: Albania (2024) United Nations Development Programme (UNDP)
2024 Annual Report Mary Ward Loreto Foundation
2024 Corruption Perceptions Index 2024 – Albania Transparency International
2024 Alternative Report to the UN CRPD on the Rights of Persons with Disabilities in Albania. Albanian Disability Rights Foundation (ADRF)
2024 Nations in Transit 2024 country report Freedom House
2024 OSCE Guidance on establishing and maintaining National Referral Mechanisms & OSCE National Referral Mechanisms Handbook OSCE
2024 Albanian housing prices soar, especially along the coast RTSH Albania (2024)
2024 Albania, strengthening national and local systems to support effective socio-economic integration of returnees United Nations Development Programme (UNDP)
2024 Special Bulletin (in Albanian) Unknown
2024 Special Bulletin - translation Unknown
2024 Adaptive Social Protection in Albania. Washington DC. World Bank
2024 Economic Empowerment and Reintegration Programmes for Trafficking Survivors Qendra Vatra (Vlora)
2024 People’s Advocate Avokati i Popullit, 2024 Annual Report
2024 Informal Economy Country Profile: Albania International Labour Organization (ILO)
2024 Annual Report 2024 (in Albanian) Police Oversight Agency
2024 Annual Report 2024 – translated Police Oversight Agency
2024 Annual Report 2024 Different & Equal
2024 Albania Country Diagnostic European Bank for Reconstruction and Development (EBRD)
2024 Freedom in the World 2024 Report Albania Freedom House
2024 Albania National Strategy on Migration 2024 IOM
8 December 2023 Human Trafficking: First Report of Session 2023-2024 House of Commons - Home Affairs Committee
6 December 2023 Stigma toward people with mental disorders among Albanian psychiatrists. Dashi, E., et al. Frontiers in Psychiatry
15 November 2023 Rwanda asylum plan: Timeline of government's policy to deport migrants Independent.co.uk
8 November 2023 Albania Report 2023 European Commission (EC)
October 2023 Inspection report on Home Office country of origin information, Albania and Pakistan Independent Chief Inspector of Borders and Immigration
28 September 2023 OSCE Presence in Albania Introduces Mock-Trial Training for Human Trafficking Cases OSCE Presence in Albania
8 September 2023 Asylum and migration: Albania: Government Response to the Committee's Second Report House of Commons - Home Affairs Committee
8 September 2023 Joint instruction No. 132: For the establishment of the Responsible Authority for the Identification, referral, protection and reintegration of the victims and potential victims of trafficking (in Albanian) www.sherbimisocial.gov.al
8 September 2023 Joint instruction No. 132: For the establishment of the Responsible Authority for the Identification, referral, protection and reintegration of the victims and potential victims of trafficking - translation www.sherbimisocial.gov.al
September 2023 Mental Health Action Plan Albania 2023–2026 Ministry of Health & Social Protection
September 2023 Train the Trainer Manual - Translated OSCE Albania
September 2023 Train the Trainer Manual OSCE Albania
28 July 2023 Albanian Police Crime Sweep includes top law enforcement officials Balkan Insights
30 June 2023 Fourth evaluation round: Questionnaire for the evaluation of the implementation of the Council of Europe Convention on Action against Trafficking in Human Beings by the Parties Group of Experts on Action against Trafficking in Human Beings (GRETA)
29 June 2023 Albania endorses a new National Referral Mechanism OSCE News release
29 June 2023 Albania endorses a new NRM for Potential and Victims of Trafficking OSCE
27 June 2023 Presence in Albania supports the Albanian Law Enforcement Agencies OSCE
12 June 2023 Albania: Second Report of Session 2022-2023 House of Commons - Home Affairs Committee – Asylum and migration
May 2023 CPIN Albania: Medical and healthcare provision GOV.UK
25 April 2023 Albania agreement on illegal migration Home Office News Story - Milestone reached in UK
1 April 2023 Minimum Wage in Albania Wage Indicator Foundation
23 March 2023 In conversation with Edi Rama, Prime Minister of Albania Event transcript
5 March 2023 Young Albanian men ‘viciously exploited’ after arriving in UK. Gentleman, Amelia - The Guardian
2 March 2023 National Referral Mechanism and Duty to Notify statistics UK, end of year summary 2022 Home Office Official Statistics - Modern slavery
March 2023 Written evidence submitted by Hestia Hestia
20 February 2023 Albania Country Partnership Framework for FY23–FY27 World Bank
16 February 2023 “Albanian Gangs Have Set Up Their Own CCTV Networks to Spy on Cops” Prothero, M., VICE News
10 January 2023 Third periodic report submitted by Albania under article 40 of the Covenant pursuant to the optional reporting procedure, due in 2022 UN International Covenant on Civil and Political Rights
2023 Young People Not in Employment, Education or Training in the Western Balkans UNICEF & EU4Youth
2023 Albania Health System Program-for-Results: Performance Review (2023) World Bank
2023 Review of Employment Promotion Programmes – Policy Brief UNDP Albania & NAES
2023 The role of public and internalized stigma on seeking psychological help: A study targeting Albanian youth. Dushaj, A. (Impact Psychology Conference)
2023 NRM Agreement – translated GOV.UK
2023 NRM Agreement (in Albanian) GOV.UK
2023 Progress Report on the National Social Protection Strategy (2024) Ministry of Health and Social Protection (MHSP)
2023 Albania – Informal Employment Estimates The Global Economy
2023 Global Organized Crime Index: Albania Global Initiative Against Transnational Organized Crime
2023 Underground lives: Albanian survivors of modern slavery Hestia
2023 Socio-economic Reintegration and Social Protection Programmes, internal assessment summary United Nations Development Programme - Albania
2023 2023 country reports on human rights practices: Albania US Department of State
2023 2023 Trafficking in persons report: Albania US Department of State
2023 2023 Findings on the Worst Forms of Child Labour US Department of Labor
2023 IDM National Integrity System Assessment Idmalbania.org
19 December 2022 Report submitted by the authorities of Albania on measures taken to comply with Committee of the Parties Recommendation CP/Rec (2020)06 on the implementation of the Council of Europe Convention on Action against
Trafficking in Human Beings, December 2022 Committee of the Parties to the Council of Europe Convention on Action against Trafficking in Human Beings

13 December 2022 Enhancing bilateral Cooperation in areas of common interest Prime Minister's Office - Policy Paper - UK-Albania Joint Communique
8 December 2022 Lucrative Business:
Albanian Criminal Exploitation of the UK Asylum System Royal United Services Institute
December 2022 Supplementary written evidence to the Home Affairs Select Committee Written Evidence submitted by Dr Andi Hoxhaj (Lecturer in Law, University College London)
December 2022 Report of a fact-finding mission Albania: Human trafficking GOV.UK
8 November 2022 Albanian Exodus - Transcript BBC Broadcast
5 November 2022 Albania's Young Migrants Programme - Transcript BBC Broadcast
4 November 2022 Channel crossings: Albanian migrants
recruited to the UK by gangs BBC News Article
4 November 2022 All aboard the UK Express: Guy Adams goes to Albania to find out who’s coming to Britain and how they get here after the Home Office admitted up to 2% of the Balkan state’s young male population has landed in the UK in small boats this year Daily Mail
2 November 2022 Albanian migrants: Why are they coming to the UK and how many have arrived? BBC News Article
November 2022 Albania: Extent of State Protection in Cases of Blood Feuds Asylos
November 2022 Evaluation of the Programme on
Transforming the National Response to Human Trafficking in and from Albania, 2019–2022 UNICEF
26 October 2022 Oral evidence: Channel crossings, HC 822 House of Commons - Home Affairs Committee
26 October 2022 Channel crossings, migration and asylum: Government Response to the Committee's First Report - Fourth Special Report of Session 2022-23 House of Commons - Home Affairs Committee
26 October 2022 Investigative interviewing 2013, updated 2022 APP
12 October 2022 Presence launches project to advance Albania's training capacities in fight against human trafficking OSCE
28 September 2022 Who Grows Cannabis in
Albania? JIED - The Big Unknown
September 2022 Survey regarding human trafficking in four regions of Albania - Second wave UNICEF
September 2022 Little Black Book of Organized Crime
Groups in Western Balkans Dusan Stankovic
12 July 2022 Chanel crossings, migration and asylum - First Report of Session 2022-23 House of Commons - Home Affairs Committee
July 2022 Economic reintegration of trafficking survivors in Albania: A qualitative study of the experiences of survivors in accessing and frontline professionals in providing economic reintegration support. Davy, D. UNICEF Albania and IDRA
7 June 2022 Human trafficking migrant health guide 2017, updated 2022 GOV.UK
May 2022 ‘Trafficked by someone I know’ Davy, D. UNICEF
20 April 2022 Commission Staff Working Document: Albania 2022 Report (SWD (2022) 332 final) European Commission
April 2022 Analysis of Cases of Trafficking in Persons in Albania. United Nations Office on Drugs and Crime (UNODC). Vienna: UNODC
April 2022 Unlocking impunity of traffickers and supporting justice for victims of trafficking in persons in Southeastern Europe: Analysis of cases of trafficking in persons in the Republic of Albania UNODC
3 March 2022 Modern slavery: National Referral Mechanism and Duty to Notify statistics UK, end of year summary 2021 Home Office Official Statistics
26 February 2022 The impact of adverse childhood experiences on health problems Dube S. et al.
15 February 2022 Albania’s Ex Interior Minister Jailed for Helping Drug Traffickers OCCRP

January 2022 Trauma Informed Code of Conduct 2nd Edition Helen Bamber Foundation
2022 Albania: Social Protections Situational Analysis World Bank Group
2022 Stages of Recovery and
Reintegration: A Guide for Practitioners Different & Equal
2022 Memorandum of Understanding - Amendment Letter Foreign, Commonwealth and Development Office
2022 Informal employment, precariousness, and decent work: from research to preventive action International Journal of Sociology and Social Policy
2022 Corruptions Perception Index Transparency International
2022 Albania Freedom House
18 November 2021 Decision No. 700 on The Approval of the National Action Plan for LGBTI+ persons, 2021-2027 (in Albanian) Albanian Council of Ministers
18 November 2021 Decision No. 700 on The Approval of the National Action Plan for LGBTI+ persons, 2021-2027 – Translation Albanian Council of Ministers
November 2021 Handbook for Albanian Police OSCE
November 2021 Handbook for Albanian Police - Translated OSCE
November 2021 Re-thinking trafficking - the Current State of Play Rights Lab
20 October 2021 Third Evaluation Report - United Kingdom: Access to Justice and Effective Remedies for VoT GRETA
1 September 2021 Report - Albanian arrests in Spain Europol
September 2021 A detailed analysis: Registered long-term unemployed job seekers in Albania.
Miluka, J., and Tori, A. United Nations Development Programme (UNDP)
27 July 2021 Albanian traffickers advertising on Tik Tok Insider.com
2 July 2021 Albanian Police Arrested in
International Anti-Drug Trafficking Raids Balkan Insights
30 June 2021 National Strategy for Gender Equality 2021-2030 Albanian Ministry of Health and Social Protection
June 2021 Health and Safety in Cannabis Cultivation WorkSafeBC
June2021 Situation analysis of children and adolescents in Albania UNICEF
7 May 2021 The aftermath of human trafficking:
Exploring the Albanian victims’ return, rehabilitation, and reintegration challenges. Ramaj, K. Journal of Human Trafficking
18 March 2021 Modern slavery: National Referral Mechanism and Duty to Notify statistics UK, end of year summary 2020 Home Office Official Statistics
2021 Return and regret, labor market
reintegration challenges of Albanian returnees Xhaho and Fetahu (2021)
2021 Review of Social Protection System in Albania: Coverage, Expenditure, Adequacy and Financing ILO
2021 Albania Child Notice UNICEF
2021 EU Serious and Organised Crime Threat Assessment 2021 Europol
2021 Case Management Manual Different & Equal
2021 Mental Health Atlas 2020: Country Profile – Albania. Geneva World Health Organization
2021 Promoting Inclusive Labour Market Solutions in the Western Balkans II UNDP
2021 Social Protection
Monitor: Albania Country Brief. Geneva. International Labour Organization
2021 Rehabilitation and Reintegration Services within the
Social Welfare System in Albania for Women Survivors of Violence ADC
2021 Blood feuds in Albania exploited by criminal groups Global Initiative Against Transnational Organized Crime
2021 Psycho-Social Centre - Compliance of the Albanian legal framework with the Acquis Communautaire of the European Union in the area of the fight against Trafficking in Human Beings VATRA
2021 Psycho-Social Centre - Services to the Survivors or to the system? Access to and quality of services for victims/potential victims of trafficking in Albania VATRA
15 December 2020 Evaluation report: Albania. Third evaluation round: Access to justice and effective remedies for victims
of trafficking in human beings Group of Experts on Action against Trafficking in Human Beings (GRETA)
4 December 2020 Recommendation CP/Rec (2020)06 on the implementation of the Council of Europe Convention on Action against Trafficking in Human Beings by Albania, adopted December 2020 Committee of the Parties to the Council of Europe Convention on Action against Trafficking in Human Beings
December 2020 First wave survey study on youth knowledge, attitudes and practices with regard to human trafficking, in four regions in Albania: Report on
findings. Davy, D., and Metanji, B. (2020) UK Government / IDRA / UNICEF Albania
18 November 2020 The EU Rule of Law Initiative Towards the Western Balkans Hague Journal on the Rule of Law
2 September 2020 Memorandum of Understanding Foreign, Commonwealth and Development Office
August 2020 National Referral Mechanism UK
- End of Year Summary 2019 Home Office Statistics
July 2020 A typology of child trafficking cases in
Albania Organization for Security and Cooperation in Europe (OSCE)
July 2020 Underground Lives: Criminal Exploitation of Adult Victims Hestia
19 May 2020 Albania arrests 24 in alleged human trafficking ring
AP News
15 January 2020 ‘On procedures, criteria and regulations for the implementation of the employment promotion through employment, on-the-job training, and professional Practices’ Decision of the Council of Ministers no. 17
15 January 2020 DCM no. 17, 2020, ‘On procedures, criteria and regulations for the implementation of the employment promotion through employment, on-the-job training, and professional practices - Translated Council of Ministers of the Republic of Albania
2020 Can people afford to pay for health care? New evidence on financial protection in Albania World Health Organisation
2020 Mental health, men and culture: how do sociocultural constructions of masculinities relate to men's mental health help-seeking behaviour in the WHO European Region? World Health Organization Regional Office for Europe
2020 Majority of returning migrants in Albania are unemployed Tirana Times
2020 IOM Special Programme for the Reintegration of Returnees
to Albania, Kosovo and Macedonia International Organisation for Migration
2020 Trust in Governance Survey Report UNDP Opinion Poll 2019
October 2019 Human Trafficking and Exploitation, What health workers need to know NHS Scotland
20 June 2019 Third evaluation round: Reply from Albania to Questionnaire for the evaluation of the implementation of the Council of Europe Convention on Action against Trafficking in Human Beings by the Parties Group of Experts on Action against Trafficking in Human Beings (GRETA)
8 March 2019 National Coalition of Anti-Trafficking Shelters in Albania GOV.UK
22 February 2019 National report submitted in
accordance with paragraph 5 of the annex to the Human Rights Council resolution 16/21 Albania UN General Assembly
2019 Beyond Borders - Analytical Research Report on Migration in Albania MWL Foundation
2019 Tackling Vulnerability in the Informal Economy International Labour Organization & Organisation for Economic Co-operation and Development
2019 Balkans Act Now – Report (in Albanian) Office for Democratic Institutions and Human Rights (OSCE)
2019 Balkans Act Now – Report - translation Office for Democratic Institutions and Human Rights (OSCE)
2019 Systematic Country Diagnostics 2019 World Bank Albania
2019 The National Strategy on Migration 2019-22 (Albania) Ministria e Brendshme
2019 ‘Between Two Fires’: Understanding vulnerabilities and the support needs of people from Albania, Viet Nam and Nigeria who have experienced human trafficking into the UK University of Bedfordshire and International Organisation for Migration (IOM)
2019 Study Report on the Need of Drafting a Special Law for the Protection of
Victims of Trafficking in Albania Different and Equal/Save the Children
20 November 2018 Third evaluation round: Questionnaire for the evaluation of the implementation of the Council of Europe Convention on Action against Trafficking in Human Beings by the Parties Group of Experts on Action against Trafficking in Human Beings (GRETA)
November 2018 Research on local job market
skills and opportunities to support the economic empowerment of survivors of trafficking and domestic violence in Tirana, Kukës, Dibra and Saranda Different and Equal
October 2018 Doctors leaving Albania Friedrich-Ebert-Stiftung - Office Tirana
October 2018 2018 UK Annual Report on Modern
Slavery HM Government
30 September 2018 Police arrest two Rinas border police officers, part of human
trafficking ring Tirana Times
29 August 2018 No.499 “On the approval of the Standard Action Procedures for the protection of victims and potential victims of trafficking”
(SOP) in Albanian Decision of the Council of Ministers (DoCM)
29 August 2018 No.499 “On the approval of the Standard Action Procedures for the protection of victims and potential victims of trafficking”
(SOP) – translated Decision of the Council of Ministers (DoCM)
July 2018 ‘Vulnerability’ to human trafficking:
A study of Viet Nam, Albania, Nigeria and the UK Hynes, P. et al
July 2018 Vulnerability to Human Trafficking in Albania: Institutional Gaps and Socio-Economic Drivers. University of
Bedfordshire, Institute of Applied Social Research Hynes, P., Burland, P., Dewar, L. & Gilson, R.
October 2017 2017 UK Annual Report on Modern
Slavery HM Government
3 July 2017 Informal Patient Payments and Bought and Brought Goods in the Western Balkans – A Scoping Review Mejsner, S. L. Karlsson
February 2017 Human Trafficking of Minors and Childhood Adversity in Florida Joan A. Reid, PhD, Michael T. Baglivio, PhD, Alex R. Piquero, PhD, Mark A. Greenwald, MPA, and Nathan Epps MS
2017 The Road: An Ethnography of
(Im)mobility, Space and Cross-Border Infrastructures in the Balkans Dalakoglou, D., Manchester University Press
2017 Understanding Trafficking of Girls and Women from Albania. Tahiraj, E. Shpresa Programme
October 2016 2016 Report of the Inter-Departmental
Ministerial Group on Modern Slavery HM Government
3 June 2016 Report concerning the implementation of the Council of Europe Convention on Action against Trafficking in Human Beings by Albania - Second Evaluation Round GRETA
January 2015 Falling through the cracks;
Trafficking of boys and men in Albania – translated Different & Equal
January 2015 Falling through the cracks;
Trafficking of boys and men in Albania (in Albanian) Different & Equal
2015 Overlapping Threats to Freedom Insight Briefing 2015 Independent Anti-Slavery Commissioner
31 January 2014 The employment network from Vlora to Equatorial Guinea is revealed Shqiptarja.com
2014 Legacy and Change: Albanian
Transformation from Multidisciplinary Perspectives Pichler, R. (ed.)
October 2013 Informal Economy in Albania
Çeliku, E. & Leka, S. University of Tirana.
2013 Informal Payments in the Public Health
Service of Elbasan, Albania Lika B.
2012 Guidance Note on ‘abuse of a position of vulnerability’ as a means of trafficking in persons in Article 3 of the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime UNODC
12 July 2011 Overview of corruption and anti-corruption U4 Albania
21 June 2011 Paying informally in the Albanian health care sector Tomini S., W. Groot, M. Pavlova
2010 The causes and consequences of re-trafficking evidence from the IOM HT database International Organisation for Migration (IOM)
2010 The Causes and Consequences of Re-Trafficking 2010 International Organization for Migration
June 2009 Study on the Social-Economic Reintegration of Victims of Trafficking in Albania (Tirana:
Different & Equal, 2009) Different & Equal
September 2006 Beliefs about informal payments in Albania Free in Health Policy and Planning, Volume 21, Issue 5, September 2006, Pages 392–401 Vian, T., L. Burak

3 June 2005 What Do the Tiers of the Trafficking in Persons Report Mean? Office to Monitor and Combat Trafficking in Persons (US)
16 May 2005 Explanatory report to the Council of Europe Convention on Action against Trafficking in Human Beings Council of Europe
2004 United Nations Convention Against Transnational
Organized Crime and the Protocols Thereto 2004 UNODC
2003 The Kanun in the City: Albanian Customary Law as a Habitus and Its Persistence in the Suburb of Tirana Voell, S.
April 2001 Albania study on third-country national victims notes border-control failures IOM
15 November 2000 Protocol to Prevent, Suppress and Punish Trafficking Office of High Commissioner Human Rights (OHCHR)

Undated Cannabis Cultivation CrimeStoppers
Undated Foreign travel advice Albania UK Government (n.d)
Undated Balkan Studies, Google Scholar Link
Undated Google Scholar Link East European Studies
Undated Questionnaire sent by Anila Trimi (Respondent Expert) to various NGOs
(translated) Anila Trimi
Undated Constitution of Albania Constitutionnet
Undated Protection - Regional Strategic Roadmap Unknown
Undated Tjetër Vizion services (in Albanian) Tjetërvizion.org
Undated Tjetër Vizion services – translated Tjetërvizion.org
Undated Handbook on Protection and Assistance to Migrants Vulnerable to Violence, Exploitation, and Abuse: The Determinants of Migrant Vulnerability IOM
Undated Albania information LGBTI-era.org
Undated Information on Rights and Support Services in Albania for Trafficked Persons - Leaflet (in both Albanian and English)
Undated UK-Albania Strategic Partnership - Joint Declaration GOV.UK
Undated Country evidence - Albania Office for the High Commissioner for Human Rights (OHCHR)
Undated Cultural Influences and cultural competency in the prevention and protection of survivors of modern slavery and human trafficking: insights from the UK and Albania St Mary's University
Undated Framework Document - Developing standard operating procedures to facilitate the identification and protection of victims of trafficking UNHCR
Undated Minimum Standards for the Elimination of Trafficking in Persons TVPA
Undated Voluntary Returns Service Home Office
Undated Global Organized Crime Index - Albania Global Initiative
Undated Reintegration Programme Information,
Leaflet and Enquiry Form Medaille Trust
Undated Helpline Request Help in
Albania Mary Ward Loreto Foundation