The Upper Tribunal (Immigration and Asylum Chamber) issued country guidance on 13 August 2026 on Albanian male victims of trafficking, covering profile, risk factors, protection, relocation and refugee status.
Key facts
- Who: Albanian men who say they were trafficked and are claiming international protection, and those advising or representing them
- From: 13 August 2026 (date issued)
- Source: LR (Male VOTs) Albania CG [2026] UKUT 315 (IAC)
The Upper Tribunal (Immigration and Asylum Chamber) issued its country guidance decision in LR (Male VOTs) Albania CG [2026] UKUT 315 (IAC) on 13 August 2026. Deputy Chamber President Plimmer and Upper Tribunal Judges Blundell and Landes heard the case at Field House over several days in March and on 27 July 2026. The appellant, referred to as LR, has an anonymity order.
Background
LR is an Albanian national who was trafficked as a teenager and later claimed international protection in the UK. The Secretary of State accepted that he was a victim of domestic violence and of trafficking. The claim was refused on 14 February 2023 on the basis that he could obtain a sufficiency of protection in Albania and that the Refugee Convention was not engaged.
The First-tier Tribunal dismissed his appeal on international protection grounds on 25 March 2024. It allowed the appeal on Article 8 ECHR grounds because of his specific vulnerabilities. At the Upper Tribunal in December 2024 it was agreed that the dismissal on protection grounds involved a legal error and should be set aside. It was also agreed that the appeal was a suitable vehicle for country guidance.
The Secretary of State said there was a "significant number" of similar appeals. Official statistics showed 4,107 Albanian males referred to the UK authorities as potential victims of trafficking in 2022 and 3,463 in 2023.
The questions
The parties and the Tribunal agreed a list of issues in May 2025. They included whether there is a typical profile of an Albanian trafficked man, what risk factors exist, what the risk on return is, whether there is a systemic sufficiency of protection, whether internal relocation is viable, and whether Albanian male victims of trafficking are a "particular social group" under the Nationality, Immigration and Asylum Act 2022.
The guidance
The Tribunal's headnote says there is no typical profile of an Albanian male victim of trafficking. Common themes are that people often tend to be teenagers or young adults, come from less affluent or marginalised backgrounds, have received a limited education and have experienced domestic violence or neglect. However, men might become vulnerable to trafficking for a variety of reasons and come from all parts of Albania and from varied social backgrounds.
The headnote also sets out a non-exhaustive list of risk factors, beginning with lower socio-economic status, including homelessness.
What this means for people claiming asylum and their advisers
The decision addresses how profile, risk, protection and relocation are assessed for Albanian male victims of trafficking. People whose claims involve these issues may wish to read it with an adviser. Every case depends on its own facts, so get advice on your own circumstances before any appeal deadline passes, and keep documents about your history and any referral as a potential victim of trafficking.
Sources
- LR (Male VOTs) Albania CG [2026] UKUT 315 (IAC), Upper Tribunal (Immigration and Asylum Chamber), issued 13 August 2026: https://caselaw.nationalarchives.gov.uk/ukut/iac/2026/315