Labour exploitation is taking place across the United Kingdom in sectors such as private security, agriculture, construction, cleaning, hospitality, warehousing, care and logistics. It can affect directly employed workers, agency workers, migrant workers, people classified as self-employed, and individuals supplied through subcontractors, umbrella companies, gangmasters or other labour intermediaries.

The problem is not limited to one type of abuse. Labour exploitation can involve:

• workers being paid below the National Minimum Wage
• wages being withheld or unlawfully deducted
• unpaid training, travel time, briefings or overtime
• false self-employment used to avoid employment rights
• excessive working hours and denial of rest breaks or holiday entitlement
• unlawful recruitment, accommodation, transport or administration charges
• unsafe, degrading or unsuitable working conditions
• threats, intimidation, blacklisting or dismissal for raising concerns
• employers or intermediaries controlling identity documents
• workers being trapped by debt, immigration dependency or accommodation arrangements
• deliberate use of complex subcontracting chains to conceal who is responsible
• forcing workers to accept unlawful conditions because they believe they cannot leave, refuse work or obtain help.

These practices can cause severe financial, physical and psychological harm. They can also distort competition by allowing businesses that exploit workers to undercut responsible employers.

A fragmented legal framework

The United Kingdom has laws that address many individual aspects of exploitation. Wage violations may fall under the National Minimum Wage Act 1998. Unlawful deductions and employment rights are addressed through the Employment Rights Act 1996. Working hours and rest periods are covered by the Working Time Regulations 1998. Labour providers and employment agencies are subject to separate licensing and conduct rules. Health and safety matters are regulated under the Health and Safety at Work etc. Act 1974. The most extreme conduct may fall under the Modern Slavery Act 2015.

However, these legal protections were developed at different times and for different purposes. They are enforced through separate regulatory and criminal-justice systems, each with its own powers, thresholds and priorities.

This means that the same situation may be viewed differently depending on which organisation discovers it. One regulator may see a wage violation. Another may identify unlicensed labour supply. A third may identify an unsafe workplace. A law-enforcement agency may later discover threats, debt bondage or forced labour.

There is no sufficiently clear and consistent statutory definition that brings these connected harms together as labour exploitation.

The supplied whitepaper describes this as a fragmented regulatory landscape and proposes a shared four-level framework: regulatory non-compliance, labour abuse, serious exploitation and Modern Slavery Act offences. It also identifies the creation of the Fair Work Agency under the Employment Rights Act 2025 as an opportunity to improve coordination across employment-rights enforcement.

Why a definition is necessary

A clear legal definition would help distinguish between:

• an isolated administrative mistake that can be corrected quickly deliberate or repeated labour abuse serious exploitation involving control, dependency or abuse of vulnerability and conduct that meets the criminal threshold for slavery, servitude, forced labour or human trafficking.

 

• Without this distinction, serious patterns of abuse may be dealt with as minor technical breaches.

 

• Workers may be required to prove the most extreme form of exploitation before receiving meaningful protection. Employers and supply-chain managers may also lack a consistent standard for identifying and escalating risk.

A statutory definition would not replace existing offences. Instead, it would connect the different areas of law and make clear when a series of employment, wage, safety or licensing breaches may indicate a wider pattern of exploitation.

The opportunity created by the Fair Work Agency

The Employment Rights Act 2025 established the Fair Work Agency and brought together important labour-market enforcement functions. Government materials describe the Agency as bringing together enforcement relating to employment agencies, the National Minimum Wage and other employment rights.

This creates an opportunity to establish a common national approach. The Fair Work Agency should be given a clear statutory duty to identify and coordinate action against labour exploitation across the employment market, while continuing to work with:

• HM Revenue & Customs
• Health and Safety Executive
• Security Industry Authority
• local authorities
• Police
• National Crime Agency
• Immigration Authorities
• Trade Unions
• Worker-Support Organisations
• Victim-Support Services

The Fair Work Agency should not be expected to replace the police or criminal courts. Its role should be to ensure that labour-market abuse is recognised early, investigated properly and escalated when evidence suggests serious exploitation or modern slavery.

Proposed definition: We are calling for the following definition to be adopted in UK legislation:

“Labour exploitation” means the recruitment, engagement, management or use of a person’s labour or services in circumstances where, through coercion, deception, financial abuse, abuse of vulnerability, unlawful control, dependency or a serious or systematic breach of employment, wage, working-time, health and safety or recruitment law, the person’s freedom to refuse work, leave the arrangement or exercise their legal rights is materially restricted or undermined.

Labour exploitation may occur through direct employment, self-employment, agency work, labour providers, umbrella companies, subcontractors, intermediaries, informal arrangements or any other labour-supply chain.

In assessing whether labour exploitation has occurred, regard should be given to all the circumstances, including the worker’s vulnerability, financial dependency, recruitment or accommodation debt, threats or penalties, deception, restriction of movement, withholding of wages or documents, unsafe conditions, excessive working hours, abuse of immigration status, the duration and repetition of the conduct, and the number of workers affected.

This definition must not narrow or replace the offences of slavery, servitude, forced or compulsory labour or human trafficking under the Modern Slavery Act 2015 or equivalent legislation in Scotland and Northern Ireland.

Labour exploitation as a continuum

The law should recognise that exploitation can develop over time and that conduct may escalate.

Level 1: Regulatory non-compliance - This would cover an isolated or inadvertent breach where there is no evidence of intent, coercion or control. Examples could include an administrative payroll error, incomplete records or a minor procedural breach.

The response should focus on correction, repayment, compliance notices and monitoring. However, repeated or unresolved breaches should be reassessed rather than permanently treated as administrative mistakes.

Level 2: Labour abuse - This would cover deliberate, reckless, repeated or systemic conduct that materially disadvantages workers but does not yet show structural coercive control.

Examples could include:

• deliberate underpayment
• unlawful deductions
• false self-employment
• repeated denial of holiday pay
• unlawful recruitment fees
• excessive or unlawful working hours
• repeated safety breaches
• unlicensed labour supply
• falsifying employment or payroll records.

Possible consequences should include repayment, civil penalties, public naming, licensing action, director liability and criminal prosecution where the existing law permits it.

Level 3: Serious exploitation - This would cover structural or organised exploitation involving financial, contractual or situational control, abuse of vulnerability or dependency.

Indicators could include:

• debt bondage
• excessive charges for transport, accommodation or recruitment
• threats or intimidation
• control of identity or immigration documents
• wage manipulation combined with threats
• organised false self-employment
• opaque subcontracting designed to hide responsibility
• exploitation connected to immigration status
• conditions that make a worker reasonably believe they cannot leave, refuse work or exercise their rights.

At this level, a joint investigation and immediate worker-safeguarding response should be required. Where modern-slavery indicators are present, the matter should be referred for consideration under the National Referral Mechanism and to the police or National Crime Agency.

Level 4: Modern slavery offences - This would cover conduct that meets the criminal threshold under the Modern Slavery Act 2015, including slavery, servitude, forced or compulsory labour and human trafficking.

Modern-slavery guidance describes forced labour as a severe violation of human freedom and identifies coercion, threats, penalties, deception, restriction and vulnerability as important considerations.assets.

The existence of a continuum must not weaken the modern-slavery framework. Instead, it should allow harmful conduct to be identified and stopped before it reaches the most serious criminal level.

What we are calling for: We call on the UK Government and Parliament to:

• Create a statutory definition of labour exploitation in a new Labour Exploitation Act or through amendments to existing employment and modern-slavery legislation.

 

• Introduce a national four-level framework covering regulatory non-compliance, labour abuse, serious exploitation and modern-slavery offences.

 

• Give the Fair Work Agency a formal coordinating role in identifying and responding to labour exploitation across the UK labour market.

 

• Require regulators to investigate patterns, not just individual breaches, where multiple workers, sites, agencies or subcontractors are involved.

 

• Make principal contractors and lead businesses accountable for serious exploitation within their labour supply chains.

 

• Require transparent supply-chain records, including the identity of every labour provider, subcontractor, umbrella company and intermediary involved in supplying workers.

 

• Protect whistleblowers and workers who report exploitation from dismissal, retaliation, blacklisting, victimisation and other detriment.

 

• Ensure safe reporting regardless of immigration status, so that workers are not discouraged from seeking help because they fear immigration consequences.

 

• Provide accessible remedies, including recovery of unpaid wages, unlawful deductions, recruitment fees, accommodation charges and compensation for financial or personal harm.

 

• Strengthen penalties for serious and repeated exploitation, including director disqualification, licensing bans, asset recovery and exclusion from public procurement.

 

• Require businesses to conduct meaningful labour-rights due diligence, including confidential worker interviews and monitoring beyond the first-tier supplier.

 

• Publish an annual report to Parliament on cases, referrals, enforcement action, unpaid wages recovered, worker outcomes and repeat offenders.

The change we want: 

No person should have to endure threats, intimidation, wage theft, unsafe conditions, debt, deception or coercive control before the law recognises that they are being exploited.

No business should be able to avoid responsibility simply by placing an agency, umbrella company or subcontractor between itself and the worker.

No worker should be treated as disposable because they are a migrant, an agency worker, classified as self-employed, financially vulnerable or dependent on their employer for accommodation or immigration sponsorship.

Labour exploitation should be defined by the reality of the worker’s circumstances, not by the wording of a contract, the corporate structure of an employer or the number of intermediaries placed between the worker and the organisation benefiting from their labour.

We are calling for a clear, modern and enforceable legal framework that identifies exploitation early, protects workers, holds responsible businesses accountable and ensures that the most serious cases are escalated into the modern slavery and criminal justice systems.

Please sign this petition and support a clear legal definition of labour exploitation in the United Kingdom.