Coordinating multi-level responses to human trafficking: the role and limits of national referral mechanisms

The fight against human trafficking is embedded in complex multi-level regulatory and enforcement systems that combine supra-national, national and infra-national frameworks. While legal instruments, particularly at EU level, have progressively integrated victim-centred provisions, victim identification and assistance remain fragmented and challenging. This paper conceptualises National Referral Mechanisms (NRMs) as a governance tool to coordinate multi-level responses and ensure effective protection of survivors. Yet, NRMs receive diverse understandings among supranational organisations and different implementations at national levels. Drawing on the 2024 amendments to the Anti-Trafficking Directive, this paper analyses NRMs’ role in bridging gaps between national and European anti-trafficking policies, anti-trafficking legislation enforcement and daily identification, referral and assistance challenges. The study highlights three core challenges: the assistance of all survivors, the operationalisation of NRMs within diverse national contexts, and the limitations of purely national frameworks in addressing transnational survivors’ needs. By conceptualising NRMs as multi-level enforcement systems, the study argues that NRMs could complement legal norms by promoting non-conditional assistance, developing practical protocols, and fostering cooperation among state and non-state actors. Ultimately, NRMs illustrate both the promise and the limits of multi-level enforcement systems in realising a survivor-centred approach to human rights protection.