Submission of evidence to inform the new EU Strategy on Combatting Trafficking in Human Beings January 2026 Introduction European Network on Statelessness (ENS) welcomes the opportunity to contribute evidence to inform the forthcoming update to the EU Strategy on Combating Trafficking in Human Beings. ENS is a civil society alliance with over 180 members in 41 countries (including NGOs, lawyers, academics, activists, and other independent experts) committed to breaking the cycle of statelessness in Europe. ENS regularly provides expert advice, information, and training to diverse stakeholders, including governments and regional institutions. This submission responds to the call for evidence on the challenges and possible measures needed to prevent trafficking in human beings, protect victims, improve investigations, and strengthen cooperation at EU and international level. It focuses on the critical but often overlooked role of statelessness, on the one hand as a root cause of trafficking and, on the other, as a key protection concern increasing vulnerability among some victims of trafficking and therefore requiring a response. Although the amended EU Anti-Trafficking Directive recognises statelessness as a root cause of trafficking (Recitals 2, 18, & 22),i the existing EU Strategy (2021–2025) makes no reference to statelessness nor stateless people. This submission therefore further explains the relevance of statelessness as a root cause of trafficking and identifies concrete opportunities to adequately respond to statelessness in the future strategy. We strongly recommend that statelessness is addressed both from a prevention perspective and a protection perspective in the new strategy, to ensure the specific rights and needs of victims who may be affected by statelessness are addressed, and to prevent future cases of statelessness arising from situations of trafficking. Statelessness in Europe A stateless person is a person “not considered as a national by any State under the operation of its law”.ii For the more than 10 million stateless people worldwide and over half a million in Europe, this can mean the denial of basic rights most people take for granted. In Europe, statelessness affects in situ populations who have long‑standing ties to a country but lack a recognised nationality due to factors such as State succession, administrative barriers, or discrimination (including some members of Romani communities and people affected by the dissolution of the former Soviet Union and former Yugoslavia, for example).iii Statelessness also affects migrants and refugees, including people arriving in Europe who were already stateless or who became stateless during or after displacement. iv Stateless migrants and refugees are often not officially recognised as stateless, and may be recorded as having ‘undetermined nationality’ or under an imputed nationality. Many individuals, including children, may be unaware that they are stateless. EU Member States have clear legal obligations towards stateless people as well as to prevent and reduce statelessness, arising from international and regional law, including the 1954 UN Convention Relating to the Status of Stateless Persons, the 1961 UN Convention on the Reduction of Statelessness, and other instruments such as the UN Convention on the Rights of the Child. v Statelessness is also addressed in EU law, including in new provisions in the EU Asylum & Migration Pact establishing obligations on Member States to identify and record indications of statelessness