Submission of evidence to inform the new EU Strategy on Combatting Trafficking in Human Beings January 2026 (Screening Regulation, Art. 12(3)), and to record where an asylum applicant claims to be stateless pending determination (Asylum Procedures Regulation, Art. 27(2)),vi as well as within the amended Anti-Trafficking Directive, which explicitly highlights the need to give particular attention to stateless persons in its application (Recital 22). Statelessness as a root cause of trafficking Statelessness is increasingly recognised as a factor that increases vulnerability to trafficking and exploitation. The impact of being stateless, including being excluded from basic rights and services, facing barriers to education and formal employment, limited freedom of movement, and lacking identity documentation, can lead to circumstances where individuals face heightened insecurity and are exposed to exploitative actors and situations. This can lead to stateless people being forced into precarity and unsafe options to meet their needs, including in a migratory context. For example, the UN Special Rapporteur on Trafficking in Persons has observed that stateless people “often resort to smugglers for assistance and are at heightened risk of trafficking” due to a lack of documentation.vii Stateless people are often unable or unwilling to access protection or assistance when exploitation occurs, either because no national authorities are willing to assist them (as they are not recognised as a national by any State) or because they are reluctant to seek help due to fear of discrimination or previous negative experiences with the authorities. Moreover, the absence of pathways to regularisation for stateless people in many EU Member States can contribute to long‑term exclusion, heightening risks of exploitation. viii Although there is limited data on the proportion of trafficking victims who are stateless (or vice versa), available evidence indicates a clear overlap in populations in Europe known to be at higher risk of trafficking and those affected by statelessness.ix This includes people belonging to Romani communities, people with migrant and refugee backgrounds, including unaccompanied minors, and those affected by conflict-induced displacement. For example, UNODC and others have highlighted the heightened risk of trafficking among stateless and undocumented people fleeing Russia’s full-scale invasion of Ukraine.x UN treaty bodies, including the Human Rights Committee xi and the Committee on the Elimination of Discrimination against Women,xii have underscored the importance of addressing statelessness as part of efforts to prevent trafficking. The UN Special Rapporteur on trafficking in persons has further emphasised this connection, stating that “[t]he obligation of due diligence to prevent trafficking in persons requires States to take measures to prevent and eliminate statelessness, especially given the credible evidence of heightened risks of trafficking, in particular for children who are stateless”.xiii This recognition is also now reflected in EU law in the Anti-Trafficking Directive, which explicitly states in Recital 22 that “[s]tateless persons are at greater risk of becoming victims of trafficking in human beings”. Despite this, the role of statelessness in increasing vulnerability to trafficking remains insufficiently addressed in European policy and practice. Addressing this gap in the new strategy will be essential to give effect to the Directive. ENS recommends that the new EU strategy on combatting trafficking in human beings explicitly recognises the role of statelessness as a root cause of trafficking, ensuring that indicators of statelessness are identified in risk and vulnerability assessments across antitrafficking systems. Coordinated multi-stakeholder responses should be promoted, including