Published: 16 October 2026. The English Chronicle Desk. The English Chronicle Online
Survivors of sexual violence could be denied recognition and support as victims of human trafficking under proposed changes to UK immigration law, the country’s independent anti-slavery commissioner has warned. Eleanor Lyons has raised concerns that new credibility requirements contained in the immigration and asylum bill could make it significantly harder for survivors to have their experiences formally recognised, particularly when trauma, fear or the passage of time has affected their ability to provide consistent accounts.
The warning has particular relevance for women who have accused the late businessman Mohamed Al Fayed of sexual abuse and trafficking. Several alleged survivors say the proposed rules could undermine investigations into what they describe as an international network of exploitation connected to Fayed. They fear that requirements designed to prevent misuse of the modern slavery system could instead make it more difficult for genuine victims to obtain protection and cooperate with authorities.
Under the proposed legislation, Home Office officials would be required to treat delays in making a claim of modern slavery or human trafficking as a factor that damages an individual’s credibility. In addition, inconsistencies, inaccuracies or omissions in a person’s account could be considered reasons to question whether their claims are genuine.
The legislation would also require decision-makers to take similarities between different accounts into consideration when assessing credibility. Critics argue that this could be particularly damaging in cases involving multiple victims of the same alleged perpetrator, because similar experiences may actually provide important evidence of a repeated pattern of exploitation rather than evidence that individual accounts are unreliable.
Lyons said the proposed approach was fundamentally unfair to survivors of sexual violence. She warned that trauma can affect memory and make it difficult for victims to remember precise dates, locations or sequences of events. Survivors may also delay reporting because they fear retaliation, financial consequences, social pressure or further abuse from people who hold significant power over them.
For women who have made allegations against Fayed, these concerns are particularly significant because many years have passed since the alleged abuse. The women have described circumstances in which they were allegedly exploited by a powerful and wealthy employer or businessman, making the decision to report their experiences especially difficult.
Lyons argued that the proposed credibility requirements could effectively place survivors in a situation where the circumstances surrounding trauma are interpreted against them. A delayed disclosure could be viewed as evidence of unreliability, while inconsistencies caused by trauma could further weaken a claim. At the same time, similarities between accounts could be treated with suspicion even when they potentially indicate a common pattern of abuse.
Holly Johnson, who says she was trafficked and sexually abused while working at Harrods and at Fayed’s offices in London, said the measures risked re-victimising survivors. She argued that similarities between accounts should not undermine credibility when multiple women are describing alleged conduct by the same person.
Johnson said Fayed had allegedly used a specific strategy to target and assault women and argued that it would be unreasonable to dismiss accounts because they resembled those of other alleged victims. Her comments reflect a central concern among campaigners that the proposed rules could misunderstand the nature of organised or repeated exploitation.
A survivor collective known as No One Above has also raised concerns about the impact of the proposed legislation. The group says many women who allege abuse by Fayed did not feel able to report their experiences until after his death in 2023 and after Harrods announced in 2024 that it would not enforce non-disclosure agreements signed by alleged victims.
For some survivors, those developments were critical in creating a sense that they could speak publicly without facing devastating personal or financial consequences. One member of the group, who has already been recognised by the Home Office as a trafficking victim, said she had needed reassurance that speaking out would not result in losing her home.
Another alleged survivor, Pelham Spong, has described being trafficked from Paris to London in 2008 and allegedly being sexually assaulted by Fayed. She said she did not approach the Metropolitan police until 2017 because she feared the consequences of challenging someone with enormous wealth and influence.
Spong has described the prospect of speaking out as a young woman without money or resources as almost impossible. Her account illustrates the difficulties faced by survivors who believe their alleged abuser possesses the financial, professional or social power to damage their lives if they come forward.
Her case is also reportedly being examined by French authorities, highlighting the international dimension of the allegations surrounding Fayed. Survivors and campaigners say the alleged pattern of exploitation crossed national boundaries, making effective cooperation between law enforcement agencies particularly important.
The government has defended the credibility provisions, saying they are intended to prevent abuse of the National Referral Mechanism, the system used to identify potential victims of modern slavery and human trafficking and connect them with support.
Ministers have argued that the wider immigration and asylum legislation is designed to strengthen protections while also preventing improper use of the system and facilitating the removal of people who do not have a legal right to remain in the UK.
The Home Office has rejected the suggestion that the credibility requirements would undermine protections for genuine victims. A government spokesperson said modern slavery was a serious crime and that ministers remained committed to identifying victims and ensuring they received appropriate assistance.
The government also said the proposed credibility considerations were balanced and contained safeguards intended to ensure that decision-making remained robust. Ministers argue that stronger rules are necessary to protect the integrity of the system and prevent opportunities for exploitation of the referral process.
Anti-slavery organisations remain unconvinced. Eleanora Fais of Anti-Slavery International said that prioritising immigration enforcement could result in safeguarding becoming secondary. She stressed that the National Referral Mechanism was designed to help survivors disclose exploitation, receive support and, where they choose, cooperate with police investigations.
Campaigners fear that if victims believe their accounts will be judged against strict credibility standards, some may decide not to come forward at all. That could have consequences not only for individual survivors but also for investigations into alleged perpetrators, because police rely heavily on victims being willing and able to provide information.
Hilary Agg, head of policy and research at the anti-slavery organisation Unseen, similarly warned that the measures could make it easier for trafficking to continue because fewer victims might be identified. She also highlighted the fact that the majority of people affected by trafficking and modern slavery are British nationals, meaning that the consequences of the legislation would not be confined to migrants.
The debate has therefore exposed a difficult tension between two government objectives: controlling immigration and maintaining an effective system for identifying and supporting victims of modern slavery. Critics argue that rules designed primarily around immigration enforcement could unintentionally weaken protections for people who have suffered serious exploitation.
The issue is particularly sensitive in cases involving sexual violence, where delayed disclosure and fragmented memories can be common features of trauma. Survivors may spend years trying to process what happened before deciding to tell authorities, while fear of retaliation can discourage them from reporting at the time.
For women alleging abuse by Fayed, the controversy has added another layer of uncertainty to an already lengthy effort to obtain recognition and accountability. Their supporters argue that the passage of time should not automatically weaken their claims, particularly where there are multiple accounts describing similar alleged conduct.
Businesses connected with the allegations have also responded. Harrods said it supported survivors seeking justice and continued to cooperate with the Metropolitan police investigation. The Ritz Paris said it was deeply concerned by the allegations that had been reported and expressed sympathy for the women who had come forward.
The controversy is now likely to remain closely watched as the immigration and asylum bill progresses. At its centre is a fundamental question about how the UK should assess credibility when people disclose traumatic experiences years after alleged exploitation.
For survivors and anti-slavery organisations, the concern is that rigid credibility requirements could punish precisely the behaviours that trauma and fear can produce: delayed reporting, imperfect memories and similarities between accounts of the same alleged abuser. For the government, the challenge is to demonstrate that stronger immigration controls can coexist with a system capable of identifying genuine victims and supporting them effectively.
The outcome could have consequences far beyond the cases involving Fayed. If enacted without sufficient safeguards, campaigners fear the provisions could affect victims of trafficking and modern slavery across the UK, including people whose experiences have nothing to do with immigration status.
The debate ultimately centres on whether credibility should be assessed through a rigid set of assumptions or through a fuller understanding of trauma, coercion and the realities of exploitation. As Parliament considers the proposed legislation, survivors and their advocates are urging lawmakers to ensure that efforts to prevent abuse of the system do not inadvertently create another barrier for people who have already endured serious harm.


























































































