Labour exploitation action week 2026: what employers face

From 14 to 20 September 2026, authorities in 34 countries checked 137,810 entities for labour exploitation. The week produced 27 trafficking arrests, 86 arrests for related offences such as illegal employment, 182 new trafficking investigations and 248 potential victims. Most cases began as what looked like an ordinary labour law breach.

The withheld passport as the marker

In Cyprus, inspectors found a livestock worker who was unpaid, worked 10 hour days with no days off, and whose passport was held by the employer. Each element alone reads as a labour law matter. Together they marked a case of trafficking for labour exploitation.

The point for employers is the passport. A worker who hands over the passport on arrival, for safekeeping or for paperwork, creates a fact that an inspector reads as control over the person. The European Labour Authority notes that exploitation often appears as an ordinary labour law breach, which delays its detection. The reverse also holds: an ordinary breach next to a withheld document is no longer treated as ordinary.

Who inspected and on what legal basis

The week brought police, border guards, labour inspectorates, social security inspectorates and tax authorities into one operation, within an EMPACT action led by Sweden. An employer visited during such a week should expect more than one authority at the door, each with its own powers and its own file.

During the week the European Labour Authority, set up under Regulation (EU) 2019/1149, took part in 18 inspections carried out with national teams. Its contribution was logistics and analysis on top of what the national services brought. On 2 September 2026, Europol and the authority signed a Working Arrangement covering labour exploitation, trafficking and social security fraud, which links police intelligence with labour inspection findings.

Cases by country

The Dutch case was a Dutch Labour Authority investigation that crossed five EU countries. A restaurant group with branches in several member states can therefore face a single investigation built from inspections in each of them.

Victims by origin and sector

Of the 248 potential victims, 73 percent were male, and most were nationals of Vietnam, China, India and the Philippines. Male victims worked mostly in construction (28 percent), gastronomy (21 percent) and agriculture (8 percent). Minors were 5 percent of victims.

Several of these nationalities are also the main sources of legal third country recruitment into the EU. Recruitment from India in particular carries a separate risk of fraudulent offers, covered in the guide on fake job offers and illegal recruitment from India.

What follows for a worker identified as a victim

Of the 248 potential victims identified, most were nationals of Vietnam, China, India and the Philippines, and their status is then handled by the national authorities. For the employer the consequence runs the other way: the case moves from labour law into criminal law, and the sanctions for illegal employment apply in parallel, as set out in the guide on EU employer sanctions for illegal employment.

Employer checklist

1. Never hold a worker's passport or residence document, not even with consent.
2. Pay on time and to an account in the worker's own name, with a payslip.
3. Record working hours and weekly rest for every worker.
4. Keep the work permit, contract and registration for each worker on site or ready to show.
5. Check that any agency or subcontractor supplying workers applies the same rules.

Employers recruiting through a documented process can post vacancies and review candidates on the job board.