Safeguarding Gap In the UK, modern slavery is tackled, among other approaches, through training frontline professionals to recognise and report signs of exploitation among vulnerable people. If carers were to wait to be identified as victims of modern slavery, they would wait forever. It could be argued that the authority with responsibility for protecting these workers is the local authority (LA), given its role as a commercial purchaser of care services. While local authorities may not consider themselves “commercial” organisations, they enter into contracts and make payments for services, effectively operating as buyers in a supply chain. By procuring home care and live-in care through commissioned contracts, the LA becomes part of a supply chain in which care workers constitute the labour component of the services it acquires. Under Section 54 of the Modern Slavery Act 2015, this positions local authorities, like any other organisation procuring goods or services, as entities expected to ensure that their supply chains are free from slavery, servitude, forced or compulsory labour and human trafficking. Several local authorities have taken the proactive step of publishing modern slavery statements and acknowledging the workforce within their procured services as part of their supply chains. By adopting such measures, local authorities demonstrate how commissioning bodies can extend accountability beyond statutory thresholds. Since most care providers fall below the £36 million turnover required for Modern Slavery Act reporting, local authorities have a critical role in closing this oversight gap by embedding workforce protections into contracts, requiring supplier declarations on fair labour standards and actively monitoring compliance to safeguard carers from exploitation within publicly funded care services.However, with the above arrangement, there are several structural conflicts which should not be ignored. On one side, the Care Act 2014 directs local authorities to safeguard adults with care and support needs, typically the older or disabled person receiving care. Within this framework, the carer is often viewed as a potential risk or suspect of abuse not as someone in need of protection.On the other side, the Modern Slavery Act 2015 would then place a legal and moral duty on the same local authorities to ensure that all workers delivering publicly commissioned services, including home care and live-in care, are protected from exploitation. In this case, the potential abuser or exploiter could just as easily be the care recipient, their family or even the agency itself.This contradiction becomes even more troubling when we look at how care is commissioned. Many local authorities purchase home care on ‘time and task’ contracts paying agencies only for short visits, sometimes as little as 15-minute slots, despite carers working 14–16-hour days. These long hours, coupled with low pay, lack of rest and constant availability, are all clear indicators of forced labour under both ILO Convention No. 29 and the UK Government’s Modern Slavery Assessment Tool (MSAT).So, when the same authority that commissions exhausting, underpaid work is also the one tasked with identifying modern slavery, a clear conflict of interest emerges. It is unrealistic to expect the commissioner to acknowledge exploitation that their own procurement model may be sustaining. Under the Modern Slavery Act 2015, local authorities are designated First Responder Organisations, with statutory duties to identify potential victims, recognise indicators of exploitation and refer cases to the National Referral Mechanism (NRM). This responsibility exists in direct conflict with their parallel role as commissioners of care services. For carers, this dual function presents a unique dilemma. Seeking help from a local authority that simultaneously commissions the very service under which exploitation occurs can be complex and discouraging. How can a local authority fulfil its statutory duty to refer victims of modern slavery when those victims are produced by its own commissioning practices? In contrast, for other residents within the locality, such as general members of the public or service users, approaching the local authority for support does not carry this inherent conflict of interest. As highlighted by the Homecare Association (2025), when local authorities procure care at rates that do not allow providers to pay even the legal minimum wage, they risk enabling what has been described as “state-sponsored labour exploitation.”“Ministers tell everyone they are introducing a Fair Pay Agreement to attract British workers and avoid the need for international recruitment but this is a fantasy. Our research shows there isn’t enough money in the system even to pay all homecare workers the minimum wage of £12.21 per hour. It’s a scandal of epic proportions on this government’s watch. And it must stop” (Homecare Association, 2025).One might then understand why there appears to be no public body willing or able to stand up for the protection of domiciliary carers because without adequate funding, there is no viable solution. The result is a cycle in which underfunding perpetuates inaction. Those who could intervene are aware of the deep financial pressures shaping care, yet domiciliary carers are often treated as outside the remit of local authorities’ safeguarding responsibilities. This allows the system to justify its failure to address exploitation, even when the causes are well understood. In practice, commissioning bodies often avoid taking responsibility for the exploitation of carers by pointing to legal technicalities, because carers are employed by healthcare agencies or private families, authorities claim the law does not require them to intervene. This allows the system to appear compliant while leaving the very workers it funds unprotected.This is why the Independent Anti-Slavery Commissioner’s current emphasis on training frontline professionals to spot victims is not fit for purpose in the care sector. The model assumes that victims are visible but live-in and domiciliary carers are not. Their workplaces are private homes, hidden from public view, often in towns or villages far from where they live.A police officer might be trained to notice warning signs in a random encounter, for example, someone who doesn’t know where the local supermarket is might be flagged as confined or trafficked. But for a live-in carer who has just arrived from Slough to work two weeks in Axminster not knowing the local area is entirely normal, it’s part of the job.Neighbours rarely see them. Even visiting relatives of the person receiving care, carers have reported them as contributors of the exploitation, expecting the carer to cook for them, do laundry or care for their pets or children. In these circumstances, no one will “spot” the carer as a victim.When official systems fail to act, people often turn to the public for moral support and collective pressure. Yet for carers, this route is far more complicated. The “public” they would appeal to is often the very group receiving their services, older people, disabled people and their families, many of whom depend on affordable or publicly funded care. In such circumstances, public sympathy can be muted by self-interest: the same citizens who might ordinarily demand fair pay and decent work may, consciously or not, support policies that keep care costs low. This leaves carers with few natural allies, isolated between an unresponsive system and a public that benefits from their underpayment. It is another reason why empowerment and collective organisation among carers themselves are so crucial, without their own voice, no one will speak for them. Free Course - Understanding Modern Slavery in the UK Social Care Sector The only realistic form of protection comes from self-recognition and self-referral, carers being able to identify the signs of exploitation in their own situation, understand their rights and know how to report it safely. That is exactly why the free course, Understanding Modern Slavery in the UK Social Care Sector was developed by Social Care Research. The course is grounded in research and takes an empowerment approach, to bridge the safeguarding gap the system itself created. Click here to start your free course
