Fourth evaluation round of the Council of Europe Convention on Action against Trafficking in Human Beings 

Ministry for Foreign Affairs of Finland 

Reference: VN/24998/2026 

14 October 2026 

The National Council of Women of Finland welcomes the opportunity to contribute to Finland’s response to GRETA’s fourth evaluation round. 

The Council wishes to draw attention to the gendered nature of human trafficking, structural factors that increase vulnerability to exploitation, and the importance of accessible support services and adequate funding for civil society organisations. 

The Council provides observations on questions 3, 11, 21, 24 and 41.  

Question 3 – Gender-related vulnerabilities to human trafficking 

According to the Finnish Assistance System for Victims of Human Trafficking, 271 new victims were admitted to the system in 2025, of whom 61% were women and girls. The statistics recorded 314 forms of exploitation among these victims, as some had experienced more than one form of trafficking. 

The gender differences between forms of exploitation are significant. Women and girls accounted for 89 of the 90 recorded instances of forced marriage and 48 of the 59 instances of sexual exploitation. The statistics also demonstrate that women can experience several forms of exploitation. 

This underlines the need for gender-sensitive identification procedures and support services. Human trafficking should be addressed in connection with wider efforts to prevent violence against women and gender-based discrimination. 

The National Council of Women of Finland emphasises that the prevention of human trafficking must address gender inequality and structural factors that increase vulnerability. Gender impacts should be systematically assessed in legislation, policies and support services related to human trafficking. 

Sources: 

1. Finnish Assistance System for Victims of Human Trafficking (2026). Ihmiskaupan uhrien auttamisjärjestelmän tilastot 2025. 

2. Council of Europe Convention on Action against Trafficking in Human Beings, Article 5(3), concerning gender mainstreaming and a child-sensitive approach. 
   https://rm.coe.int/168008371d 

Question 11 – Migration legislation and policies 

The National Council of Women of Finland is concerned that recent changes to immigration legislation may increase vulnerability to human trafficking. 

Amendments to the Aliens Act that entered into force in May 2025 have made the reflection period particularly important for trafficking victims without a legal right of residence. Without a valid reflection period or another legal basis for residence, submitting a residence permit application does not make their stay legal during its processing. 

Further amendments introduced in June 2025 allow workers who lose their employment generally three or six months to find a new job before their residence permit may be withdrawn. 

Insecure residence status and dependence on employers may make it more difficult to leave exploitative situations. According to the Finnish Assistance System for Victims of Human Trafficking, 68% of victims exploited in Finland in 2025 had a valid residence permit. This demonstrates that exploitation also affects people residing legally in the country. 

The Council is also concerned about the potential impact of stricter family reunification requirements and asylum procedures on vulnerability to human trafficking. Restrictions on family reunification may increase insecurity and dependence on others, particularly among migrant women and children. Stricter asylum procedures may hinder the identification of trafficking victims and their access to protection and assistance. 

 Finland’s legislation on temporary measures to combat instrumentalised migration raises further concerns about access to international protection and compliance with the principle of non-refoulement. Restrictions on asylum procedures may also hinder the identification of trafficking victims at Finland’s borders. The Council emphasises that the right to seek asylum, effective victim identification and access to protection must be safeguarded. 

Sources: 

1. Finnish Assistance System for Victims of Human Trafficking (2025). The Aliens Act was amended – impacts on the status of trafficking victims, 11 July 2025. 
   https://ihmiskauppa.fi/en/the-aliens-act-was-amended-impacts-on-the-status-of-trafficking-victims/ 

2. Finnish Immigration Service (2025). Changes to work-based residence permits – protection period for unemployment and new notification obligation for employers, 11 June 2025. 
   https://migri.fi/en/-/changes-to-work-based-residence-permits-protection-period-for-unemployment-and-new-notification-obligation-for-employers 

3. Finnish Assistance System for Victims of Human Trafficking (2026). https://ihmiskauppa.fi/wp-content/uploads/2026/01/Tilastot_2025.pdf 

4. Finnish Immigration Service (2025). Legislative amendments and new requirements for family reunification. 
   https://migri.fi/en/-/legislative-amendments-and-new-requirements-for-family-reunification 

5. Ministry of the Interior. Government reforms to migration policy. https://intermin.fi/maahanmuutto/ho-uudistukset-maahanmuuttopolitiikka 

6. National Council of Women of Finland. Statement on the proposed extension of the Act on Temporary Measures to Combat Instrumentalised Migration (2026). https://naisjarjestot.fi/njkln-lausunto-rajalaista/  

7. Council of Europe. Convention on Action against Trafficking in Human Beings, Article 10(2), concerning victim identification and protection against removal. 
   https://rm.coe.int/168008371d 

Question 21 – Encouraging victims to report exploitation and seek assistance 

The National Council of Women of Finland emphasises that victims must be able to seek assistance safely and without fear. Under Article 12(6) of the Council of Europe Convention on Action against Trafficking in Human Beings, assistance must not be conditional on victims’ willingness to act as witnesses. In Finland, victim identification and assistance have been independent of criminal proceedings since 2023. 

Civil society organisations play an important role in identifying victims and reaching people who may be reluctant to contact the authorities. In 2025, 467 applications were submitted to the Finnish Assistance System for Victims of Human Trafficking, and 271 new victims were admitted. Half of the applications came from the Finnish Immigration Service and reception centres, while 19% were submitted by victims themselves. 

The Assistance System does not conduct outreach work itself, highlighting the importance of cooperation with authorities and civil society organisations. In its 2024 evaluation report, GRETA recommended strengthening proactive victim identification and establishing a National Referral Mechanism involving relevant authorities and NGOs. 

The Council calls for accessible, low-threshold services, adequate resources for specialised NGOs and effective referral procedures. Victims must be able to seek help without fear of further harm or negative consequences. 

Sources: 

1. Finnish Assistance System for Victims of Human Trafficking (2026). Annual Statistics 2025, p. 2. https://ihmiskauppa.fi/wp-content/uploads/2026/01/AnnualStatistics_2025.pdf 

2. Finnish Assistance System for Victims of Human Trafficking (2025). Ihmiskaupan puolivuotiskatsaus 1–6/2025. 

3. Council of Europe (2024). Evaluation Report Finland: Third Evaluation Round, GRETA(2024)06. https://rm.coe.int/greta-evaluation-report-on-finland-third-evaluation-round-focus-access/1680b0577c 

4. Council of Europe Convention on Action against Trafficking in Human Beings, Article 12(6). https://rm.coe.int/168008371d 

Question 24 – Assistance to particularly vulnerable victims 

The National Council of Women of Finland emphasises that assistance to victims of human trafficking must be accessible, gender-sensitive and tailored to individual needs. Attention should be paid to children, victims with children, persons with disabilities, LGBTIQ+ persons and victims experiencing severe trauma. 

In Finland, assistance may include safe accommodation, social and healthcare services, financial support, counselling and legal assistance. However, responsibility for providing services is divided between the National Assistance System for Victims of Human Trafficking, wellbeing services counties and reception centres, depending on the victim’s circumstances and residence status. 

In its 2024 evaluation report, GRETA identified shortcomings in the availability and continuity of assistance. It recommended adequate resources for the Assistance System, stronger cooperation with wellbeing services counties, training for professionals and sufficient funding for NGOs providing specialised assistance. GRETA also called for safe accommodation suited to victims’ needs. 

The Council is particularly concerned about the financial pressures facing wellbeing services counties and the significant cuts to public funding for civil society organisations. These developments risk further weakening the availability and continuity of specialised support for victims of human trafficking, particularly those in vulnerable situations. 

The Council urges Finland to implement GRETA’s recommendations and secure sufficient and sustainable funding for both public services and specialised NGOs. Equal access to trauma-informed support must be ensured throughout the country, regardless of victims’ residence status or individual circumstances. 

Sources: 

1. Council of Europe (2024). Evaluation Report Finland: Third Evaluation Round, GRETA(2024)06, paragraphs 191, 194, 196 and 200–201, pp. 44–46. 
   https://rm.coe.int/greta-evaluation-report-on-finland-third-evaluation-round-focus-access/1680b0577c 

2. Finnish Assistance System for Victims of Human Trafficking (2025). Ihmiskaupan puolivuotiskatsaus 1–6/2025, p. 13 

3. Council of Europe Convention on Action against Trafficking in Human Beings, Article 12. 
   https://rm.coe.int/168008371d 

4. Funding Centre for Social Welfare and Health Organisations (STEA) (2026). Tutustu avustuksiin. https://www.stea.fi/tutustu-avustuksiin/  

5. Ministry of Finance (2025). Government Budget Proposal for 2026, Section 9: Wellbeing Services Counties’ Finances 2026. https://budjetti.vm.fi/sisalto.jsp?lang=fi&maindoc=%2F2026%2Ftae%2FhallituksenEsitys%2FhallituksenEsitys.xml&opennode=0%3A1%3A3%3A81%3A&year=2026 

Question 41 – Developments since GRETA’s third evaluation report 

The National Council of Women of Finland welcomes the adoption of Finland’s Action Plan against Trafficking in Human Beings for 2026–2027. The Action Plan includes four strategic objectives and 43 measures, addressing issues such as sexual exploitation, forced marriage and trafficking involving children and young people. 

The need for effective measures remains evident. In 2025, the Finnish Assistance System for Victims of Human Trafficking admitted 271 new victims, compared with 207 in 2024. 

The Council is concerned that cuts to civil society funding may undermine the implementation of the Action Plan. STEA funding for social welfare and health organisations has been substantially reduced, from approximately EUR 384 million in 2024 to EUR 274 million in 2026. According to the Government’s spending framework decisions, funding is set to decrease further to approximately EUR 190 million in 2027, representing a reduction of around 50% compared with 2024. These reductions risk weakening organisations’ capacity to identify victims, prevent exploitation and provide specialised assistance. 

GRETA has recommended adequate funding for NGOs providing specialised assistance to trafficking victims. The Council therefore emphasises that successful implementation of the Action Plan requires sufficient and sustainable resources, effective monitoring and close cooperation with civil society organisations. 

Sources: 

1. Ministry of Justice (2026). Suomi torjuu ihmiskauppaa: Ihmiskaupan vastainen toimintaohjelma 2026–2027. Publications of the Ministry of Justice, Reports and Guidelines 2026:24. 
   https://julkaisut.valtioneuvosto.fi/items/3fb5b436-58ba-4c5d-993c-917909a55a3e 

2. Finnish Assistance System for Victims of Human Trafficking (2026). Ihmiskaupan uhrien auttamisjärjestelmän tilastot 2025, pp. 2 and 6. 

3. Funding Centre for Social Welfare and Health Organisations (STEA) (2026). Tutustu avustuksiin, funding statistics for 2025 and 2026. 
   https://www.stea.fi/tutustu-avustuksiin/ 

4. Council of Europe (2024). Evaluation Report Finland: Third Evaluation Round, GRETA(2024)06, paragraph 201. 
   https://rm.coe.int/greta-evaluation-report-on-finland-third-evaluation-round-focus-access/1680b0577c