U.S. Dep't of State, 2025 Trafficking in Persons Report: Hong Kong

DOS

Section: Hong Kong (2025)

Bluebook Citation: U.S. Dep't of State, 2025 Trafficking in Persons Report: Hong Kong

HONG KONG (Tier 2 Watch List) The Government of Hong Kong does not fully meet the minimum standards for the elimination of trafficking. Despite making significant efforts to do so, it did not demonstrate overall increasing efforts compared with the previous reporting period. Therefore, Hong Kong remained on Tier 2 Watch List for the second consecutive year. Efforts included identifying more trafficking victims, increasing the number of trafficking investigations and convicting more traffickers, including the first labor traffickers convicted since 2017.

The government identified more victims and implemented new policies to address employers withholding wages and worker benefits. However, it did not prosecute or convict any sex traffickers. Victim identification efforts and services remained inadequate; despite the government screening thousands of vulnerable persons for trafficking indicators, it identified eight victims during 2024. Foreign domestic workers remained at high risk of trafficking, and authorities did not take adequate measures to protect them and prevent trafficking; the government did not identify any victims among foreign domestic workers.

Authorities penalized unidentified trafficking victims through arrest and deportation for immigration, narcotics, and commercial sex offenses committed as a direct result of being trafficked. The government did not make efforts to amend its laws to fully criminalize all forms of trafficking. PRIORITIZED RECOMMENDATIONS: Improve the quality of screenings conducted to identify trafficking victims, increase screening of individuals in commercial sex and foreign domestic workers for trafficking, and ensure children exploited in commercial sex are identified as trafficking victims and referred to services. Enact legislation that criminalizes all forms of trafficking consistent with the definition set forth in the 2000 UN TIP Protocol.

Ensure authorities offer and refer trafficking victims to services. Vigorously investigate and prosecute suspected sex and labor traffickers and seek adequate penalties for convicted traffickers, which should involve significant prison terms. Adopt a comprehensive national action plan and dedicate resources to its implementation. Engage in continuous and regular collaboration with NGOs and social welfare experts to update anti-trafficking policies; review victim-centered interview processes and investigations.

Cease penalization of victims for unlawful acts committed as a direct result of being trafficked. Create in-depth training programs for the judiciary, labor tribunal, and other interagency officials involved in anti-trafficking work. Develop formal SOPs for referring victims to care and train stakeholders on their use. Increase the availability and quality of protection services – including short-term shelter, long-term housing, counseling, and medical care – for all trafficking victims, including by collaborating with civil society service providers.

Consistently enforce existing rules to allow foreign victims – including foreign domestic workers – to work and study in Hong Kong while participating in investigations and judicial proceedings against traffickers. Increase protections for foreign domestic workers, including by prohibiting worker-charged recruitment fees, permanently eliminating the “two-week rule,” affording workers an option to live outside their place of employment, and creating legal maximum working hours.

PROSECUTION

The government increased anti-trafficking law enforcement efforts; the absence of laws that fully criminalize trafficking made it difficult to accurately assess the government’s prosecution efforts compared with the previous year and to determine which law enforcement actions involved human trafficking as defined by international law. Hong Kong law did not criminalize all forms of human trafficking, and the government relied on various provisions of laws relating to “prostitution,” immigration, employment, and physical abuse to prosecute trafficking crimes. Inconsistent with the international law definition, Section 129 of the Crimes Ordinance, which criminalized “trafficking in persons to or from Hong Kong,” required transnational movement and did not require the use of force, fraud, or coercion. Section 129 prescribed penalties of up to 10 years’ imprisonment, which were sufficiently stringent and, with respect to sex trafficking, commensurate with punishments prescribed for other grave crimes, such as rape.

Section 130 criminalized the harboring, controlling, or directing of a person for the purpose of “prostitution” and prescribed penalties of up to 14 years’ imprisonment. Section 131 criminalized procuring a person to engage in commercial sex acts and prescribed penalties of up to 10 years’ imprisonment. Section 137 criminalized living on the earnings of commercial sex acts of others and prescribed penalties of up to 10 years’ imprisonment. The government reported initiating seven trafficking investigations in 2024 (one for sex trafficking and six for forced labor), compared with no investigations in 2023.

The government reported initiating two prosecutions, both for labor trafficking, compared with prosecuting six alleged sex traffickers in 2023. The government reported six ongoing prosecutions involving five alleged sex traffickers and one alleged labor trafficker. In addition, the government reported arresting 71 suspects (compared with 26 in 2023) during investigations potentially related to sex trafficking, including for violations of Sections 130 and 137 of the Crimes Ordinance; however, the government reported it ultimately did not identify cases of sex trafficking in relation to these arrests. The government convicted two traffickers, both for labor trafficking, which represented the first labor trafficking convictions since 2017, compared to no sex or labor traffickers convicted in 2023.

Both traffickers were convicted under conspiracy to defraud charges and sentenced to terms of imprisonment ranging from three years to four years and eight months’ imprisonment. The government did not report any investigations, prosecutions, or convictions of government employees complicit in human trafficking crimes. Law enforcement officials often did not adequately investigate trafficking cases and sometimes closed cases with clear indicators of trafficking. For example, in July 2024, the Department of Justice’s Court of First Instance partially granted a potential trafficking victim leave to apply for judicial review of allegations that the government failed to adhere to its published policy and procedures for screening trafficking victims.

The court found that the government’s determination that the applicant was not a victim of trafficking was unreasonable where the government had found three indicators of trafficking and did not conduct further assessment, as required by policy and procedure. However, the court also decided the government did not fail its investigative duty which was not tied to the identification of trafficking victims, denying that the lack of specific legislation criminalizing forced labor lead to a breach of Article 4 of the Hong Kong Bill of Rights. The government reported using a “joint investigative process” in trafficking cases to coordinate interviews of victims among law enforcement agencies to prevent victims who experienced trauma from repeated interviews. Law enforcement did not adequately prosecute operators of unscrupulous employment agencies or money lenders for their roles in facilitating labor trafficking through debt-based coercion.

The absence of laws criminalizing all forms of trafficking impeded officials’ ability to investigate or charge suspected traffickers. This also sometimes resulted in the prosecution of trafficking crimes under laws with weak penalties, although both traffickers convicted in 2024 were sentenced to penalties that included significant terms of imprisonment. Fears of penalization and the absence of adequate services resulted in victims choosing not to report their exploitation or declining to cooperate with authorities in investigations. In prior years, inadequate victim identification led to victims identified by NGOs pursuing justice in civil tribunal courts, and the government did not pursue criminal cases against the traffickers.

Observers reported prosecutors and judicial officials lacked an awareness of trafficking and recommended those officials attend anti-trafficking trainings. The police had dedicated teams for investigating trafficking and the exploitation of foreign domestic workers, and the government maintained designated points of contact for trafficking issues in relevant agencies. However, civil society organizations reported being unable to reach these designated police contacts and teams, including when attempting to refer victims to police; and some reported government officials could not direct them to a person responsible for trafficking in their agency. The government cooperated with foreign governments and law enforcement on anti-trafficking investigations involving Hong Kong victims in Southeast Asia countries.

The government trained officials from various agencies and prosecutors on anti-trafficking policies, including the trafficking law and investigations.

PROTECTION

The government maintained inadequate efforts to protect victims. Police, immigration, labor, and customs officials used a two-tiered identification mechanism to screen vulnerable populations for trafficking indicators. Through this mechanism, officials referred potential victims for a full identification “debriefing” after determining whether an individual met at least one of seven indicators listed on the standard screening form of the first tier of the identification mechanism. Officials screened approximately 11,294 individuals in 2024, compared with 10,989 screened in 2023, and identified eight victims in 2024 (one sex trafficking victim and seven labor trafficking victims) – compared to identifying three victims in 2023 and 32 victims in 2022.

The seven labor trafficking victims were all Hong Kong residents exploited in scam operations in Southeast Asia; the government also continued to repatriate additional victims exploited in scam operations in early 2025. Authorities’ implementation of the screening mechanism and victim identification was ineffective and inconsistent, and officials did not identify foreign domestic workers as trafficking victims, despite ongoing concerns many of these workers faced conditions indicative of forced labor. Authorities did not routinely screen individuals in commercial sex for trafficking indicators. Hong Kong’s low age of consent, 16 years, further hindered efforts to identify children exploited in sex trafficking.

Despite media reports indicating officials identified children in commercial sex during law enforcement actions on brothels, government authorities did not identify them as trafficking victims or refer them to services. NGOs reported law enforcement provided breaks, meals, and basic amenities to potential victims, but officials lacked understanding of psychological trauma associated with trafficking and law enforcement often did not use a trauma-informed approach while interviewing potential victims during the identification process, which exacerbated victims’ emotional distress. Authorities used a standard screening form; although the government reported the screening form applied to all persons, the form itself only included vulnerable populations of foreign nationals, not Hong Kong citizens. The government did not consistently provide potential victims with immediate stabilizing care upon their initial contact with authorities or provide legal assistance for victims.

The government continued to maintain an interagency task force comprised of the Security Bureau, the Immigration Department, and Public Security to identify and support victims exploited in overseas employment fraud and online scam operations. The task force coordinated with foreign governments and the Chinese embassies in foreign countries to repatriate 25 victims of scam centers in Southeast Asia to Hong Kong from January 2024 to March 2025. Of these, the government screened and formally identified seven as labor trafficking victims in 2024 and an additional 11 as labor trafficking victims from January to March 2025. The remaining seven individuals declined screening.

While the government reported agencies could refer potential victims to anti-trafficking teams and provide them services, the government did not consistently apply the formal referral process or offer clear guidance for officials to inform victims of available services. The Hong Kong government reported offering services to all eight trafficking victims formally identified in 2024; the sex trafficking victim and two labor trafficking victims accepted care in the form of mental health and psycho-social support, basic and immediate medical care, and translation/interpretation services. The government also funded the repatriation of the sex trafficking victim to mainland China. This was compared with offering services to three identified victims but referring no victims to services in the previous reporting period.

Victims commonly refused referral to services offered by the government, preferring to receive services provided by foreign consulates or NGOs. The Social Welfare Department funded an NGO-run Multi-Purpose Crisis Intervention and Support Centre, five refuge centers and a family crisis support center that served victims of violence, abuse, and exploitation, including trafficking victims. These shelters could provide temporary accommodation, counseling, and medical and psychological services to local and foreign victims, regardless of sex or age. Some services were not available to foreign victims, including welfare and social services provided by the Social Welfare Department.

The government could assist foreign victims, including domestic workers, with returning to Hong Kong to serve as witnesses in trials by providing financial assistance; it did not report providing financial assistance to victims. To enable foreign victims to temporarily remain in Hong Kong, the government could provide visa extensions with fee waivers and could provide victims who were foreign domestic workers with permission to change their employer. Authorities generally did not permit foreign victims, including those given visa extensions, to work or study while they remained in Hong Kong, unless an exception was granted; this deterred some victims from remaining in Hong Kong to participate as witnesses in investigations against traffickers. Hong Kong law allowed victims to seek compensation from traffickers through civil suits and labor tribunals.

Nonetheless, a shortage of interpretation services, a lack of trained attorneys, a prohibition for foreign victims from working while awaiting a decision, and judges’ inexperience with forced labor cases impaired victims’ attempts to claim back wages or compensation through labor tribunals and deterred some from bringing claims forward. Due to a lack of effective identification procedures, the government did not take effective measures to prevent the inappropriate penalization of potential trafficking victims solely for unlawful acts – including immigration, narcotics, or commercial sex offences – committed as a direct result of being trafficked. In previous years, during police actions on brothels, authorities arrested individuals in commercial sex, did not screen them for indicators of trafficking, and deported foreign individuals without screening. The government intercepted non-local child victims of sex trafficking during anti-vice operations – seven in 2024 – and only identified one as a victim of sex trafficking, despite this being a form of sex trafficking according to definitional standards under international law.

In previous years, the government typically initiated immigration proceedings against foreign victims, rather than referring them to services and investigating or prosecuting the traffickers. The government did not report granting immunity from prosecution to any victims or exploited foreign domestic workers, compared with three victims in 2022.

PREVENTION

The government maintained efforts to prevent trafficking. However, the government continued to publicly deny trafficking was a prevalent crime in Hong Kong, despite ongoing anti-trafficking efforts by government officials and NGOs that contradicted this claim. The Hong Kong authorities reported a governmental anti-trafficking steering committee led by the Chief Secretary for Administration and the inter-departmental working group led by the Security Bureau met regularly. A liaison group between the Hong Kong government and Philippines and Indonesian consulates representing Filipino and Indonesian foreign domestic workers held meetings every six months and met twice during the reporting period to address immigration and labor concerns related to the Special Administrative Region’s foreign domestic worker community.

The government allocated 80 million Hong Kong dollars ($10.3 million) for its 2024-2025 fiscal year budget to continue implementation of the 2018 anti-trafficking action plan, compared with 77 million Hong Kong dollars ($9.9 million) allocated in the previous year. The 2020 imposition of the National Security Law by the Chinese National People’s Congress on Hong Kong, under which any speech critical of the government or its policies could be construed as pro-secession, subversive, or inciting hate against the government, along with increased restrictions to freedom of expression, and March 2024 enactment of the Safeguarding National Security Ordinance under Article 23 of the Hong Kong Basic Law, produced an operating environment where NGOs and other civil society organizations were not freely able to engagement with the government, including on human trafficking. Governmental policies also prevented or discouraged civil society organizations from conducting some anti-trafficking efforts in cooperation with foreign organizations and governments. The government did not conduct city-wide campaigns to raise awareness of sex trafficking; however, it continued to display alerts in airports and distribute flyers at departure counters to warn passengers traveling to Southeast Asian countries of the increased risks of overseas employment scams, including forced labor in online scam operations.

The government organized trafficking awareness training for front-line staff at the Hong Kong International Airport. To improve awareness of the rights of foreign domestic workers, the Hong Kong government worked with the Philippines and Indonesian consulates to provide orientation sessions for newly arrived domestic workers and first-time employers, however, smaller consulates with fewer citizens employed as domestic workers did not offer these orientations. According to observers, NGO recommendations to the Labor Department to host orientation sessions to reach all incoming foreign domestic workers were disregarded. The Immigration Department produced a briefing video in English, Tagalog, and Bahasa for foreign domestic workers, which included signs of exploitation and encouraged workers facing exploitation to contact authorities, and collaborated with the Philippines and Indonesian consulates to include the video in their orientation sessions.

The Hong Kong Immigration, Labor, Police, and Justice Departments held regular meetings with the Philippines and Indonesian consulates to engage on and discuss topics relevant to their citizens, most recently focusing on scam prevention. In March 2025, the Labor Department and the police hosted a webinar for foreign domestic workers from the Philippines and Indonesia on money laundering and how to avoid becoming a scam victim. The Hong Kong government provided information on labor rights and employer responsibilities through information kiosks at various public parks, and through the Labor Department, which had a dedicated website for foreign domestic workers. The website provided common Q&A information, translated versions of standard employment contracts, and contact information for emergency services and foreign consulates; it published materials in writing, audio, video, and other visual formats in 13 languages.

While the Hong Kong government provided information on rights, responsibilities, and resources for domestic workers, these materials rarely included information on human trafficking, and it was unclear if they were widely publicized where workers would come across them, including in Filipino or Indonesian language news platforms such as social media, newsletters or newspapers. Compared with recent years, the government significantly increased collaboration and information sharing with foreign governments about its anti-trafficking efforts. The government’s process for evaluating non-refoulement claims, which did not allow claimants to legally work in Hong Kong while their claims were under review, increased some refugees’ vulnerability to trafficking; however, the government commonly granted work permissions for those with approved claims and those awaiting UNHCR resettlement. The government required foreign domestic workers to live with their employer and to return to their home countries within two weeks after their contracts’ termination (“two-week rule”), increasing workers’ vulnerability to exploitation by abusive employers and unscrupulous employment agencies.

The requirement that domestic workers live with their employers enabled exploitative employers to limit workers’ freedom of movement and communications, and some employers housed workers in inadequate conditions. The lack of regulations setting a maximum number of legal working hours for foreign domestic workers also contributed to their vulnerability. The government required employment agencies to comply with a code of practice covering statutory requirements and standards for Hong Kong-based employment agencies. Despite being a violation of the code of practice, observers reported money lenders and employment agencies often operated at the same address without consequence; this enabled employment agencies complicit in labor trafficking to indebt workers through loans for recruitment fees that were often beyond the legal limits.

In May 2024, the Labor Department passed and promulgated an amendment to the code of practice requiring employment agencies to clearly brief foreign job seekers on the relevant immigration regulations, and prohibiting business practices such as providing monetary incentives to employed foreign domestic workers to induce them to prematurely terminate their employment contract. NGOs said the new rules would make it harder for exploited or abused workers to leave dangerous work environments and could exacerbate vulnerability to forced labor. The revised code of practice also imposed stricter regulations on employment agencies, prohibiting them from providing foreign domestic workers with information on personal loans and from withholding workers’ employment contracts to force them to pay fees or repay loans. Foreign domestic workers who brought cases against their employers were almost always terminated from their positions and remained in Hong Kong, unemployed, until their case was resolved.

The Immigration Department’s criteria for disqualifying employers from hiring foreign domestic workers required employers be found guilty of either a criminal offense or in breach of the Employment Ordinance, and given the low number of convictions of employers for exploiting workers, this resulted in abusive employers being able to continue to hire and employ foreign domestic workers. Previously, observers reported the government allowed employers convicted of exploiting foreign domestic workers to continue to hire workers. The Immigration Department determined the duration of employers’ disqualifications arbitrarily on a case-by-case basis. During the reporting period, the government introduced new requirements for construction contractors responsible for recruiting and employing mainland Chinese and foreign construction workers, and for Hong Kong companies seeking workers, to pledge to name a manager to oversee personnel, accommodation, and other living needs of their workers, and restricted hiring companies from imposing “unreasonable” fees on workers.

In 2024, the police arrested 41 employers of foreign domestic workers for physically or sexually abusing employees but did not report investigating such cases for potential trafficking crimes or identifying those involved as potential victims. The government prosecuted 12 employers for charges including assault, voyeurism, criminal intimidation, and rape; it convicted five, with sentences ranging from a suspended sentence of 12 months’ probation and 24 months’ imprisonment to four months and two weeks’ imprisonment. Hong Kong law permitted employment agencies to charge job seekers, including foreign domestic workers, up to 10 percent of their first months’ salary in recruitment fees; however, because authorities did not enforce this rule, agencies often charged much higher fees and sometimes confiscated workers’ passports and/or contracts as collateral, practices that perpetuated debt-based coercion. Additionally, Hong Kong lacked MOUs with countries sending foreign workers – particularly Indonesia and the Philippines, and employment agencies in workers home countries also often charged excessive fees.

In February 2025, the government introduced revisions in the Construction Labor Import Scheme, which prohibited employment agencies from imposing fees on foreign construction workers. The Labor Department reported conducting more than 2,000 inspections annually of employment agencies, including announced and unannounced inspections; unannounced inspections occurred when the Employment Agencies Administration (EAA) received complaints or concerns of possible employment irregularities. However, observers reported the inspections were ineffective, often only consisted of cursory reviews of documentation, and did not scrutinize the fees employers charged foreign domestic workers. The EAA was not regularly open on Sundays, the only non-work day for most foreign domestic workers, preventing some workers from filing complaints in person; however, the EAA opened on some weekends.

To facilitate the ability of foreign domestic workers to make inquiries and complaints, the Labor Department operated an online portal as well as a 24-hour hotline with interpretation available in 14 languages. In 2024, the Labor Department prosecuted six agencies for operating without a license, or other violations (four agencies prosecuted in 2023) but did not report the number convicted or referral of any for criminal investigations for potential trafficking crimes. The Labor Department revoked the licenses of three employment agencies in 2024, citing non-compliance of the code of practice, including overcharging or attempting to overcharge commissions from foreign domestic workers, and engaging in unlicensed operations (five in 2023). Previous reports indicated some employment agencies continued to operate, and unlawfully retain workers’ passports with impunity, after losing their licenses, sometimes operating while their conviction was under appeal or reopening under different names.

Despite having the legal discretion to revoke agency licenses administratively, observers reported the EAA over-relied on criminal convictions of agencies to do so. Furthermore, fines and other penalties given to employment agencies for exploiting foreign domestic workers were not significant enough to act as a deterrent. The government did not report efforts to reduce demand for commercial sex acts, nor did it provide anti-trafficking training to its personnel posted overseas. The Labor Department operated a hotline for potential trafficking victims from Hong Kong and their families to report fraudulent employment scams and receive help; the Immigration Department operated an online messaging channel to replace the hotline approach, in order to enhance the convenience for Hong Kong residents in need of assistance outside Hong Kong to contact the Immigration Department.

While China included Macau in its accession to the 2000 UN TIP Protocol in 2010, it stated the Protocol “shall not apply” to Hong Kong. TRAFFICKING PROFILE: Trafficking affects all communities. This section summarizes government and civil society reporting on the nature and scope of trafficking over the past five years. Human traffickers exploit domestic and foreign victims in Hong Kong, and traffickers exploit victims from Hong Kong abroad.

Victims include citizens from mainland China, Indonesia, Japan, Kenya, the Philippines, Thailand, Uganda, and other Southeast Asian countries, as well as countries in South Asia, Africa, and South America. Traffickers exploit foreign women, including from Eastern Europe, Africa, and Asia, in sex trafficking. Traffickers exploit migrant workers in shipping and construction, electronic recycling facilities, nursing homes, and private homes. Drug trafficking syndicates coerce foreign women, including through physical violence, to carry drugs into Hong Kong.

Increasingly, traffickers use fraudulent promises of high-paying jobs to lure Hong Kong citizens to primarily Cambodia, Laos, and Burma and exploit them in forced labor in online scam operations. Traffickers recruit victims from the Philippines, mainland China, and countries in South America using false promises of lucrative employment and force them into commercial sex. Some foreign victims enter Hong Kong on two-week tourist visas, as part of a circuit of major cities in the region used by traffickers, including Bangkok and Taipei, and are coerced into commercial sex through debt-based coercion. NGOs reported occurrences of online solicitation of commercial sex acts, which reduced their access to individuals in commercial sex and potentially increased individuals’ vulnerability to coercive tactics.

Traffickers use coercive methods, such as threats of reporting victims to police or immigration authorities, withholding of identification documents, and blackmailing victims with threats of online distribution of photographs, to coerce them to engage in online commercial sex acts. Brothel operators and others exploit Hong Kong children in sex trafficking. “Compensated dating” also continues to facilitate commercial sexual exploitation of Hong Kong children and adults, making them vulnerable to trafficking. Traffickers exploit victims from Hong Kong in North America in commercial sex.

Approximately 370,000 foreign domestic workers, primarily from the Philippines and Indonesia, work in Hong Kong. Some foreign domestic workers become victims of debt bondage and domestic servitude in the private homes in which they are employed. Some operators of employment agencies subject victims to labor trafficking through debt-based coercion by charging workers job placement fees above legal limits and by sometimes withholding their identification documents. The accumulated debts sometimes amount to a significant portion of a worker’s first-year salary, and unscrupulous agencies sometimes compel workers to take loans from money lenders to pay excessive fees.

Some employers, money lenders, and employment agencies illegally withhold passports, employment contracts, or other possessions until the debt is paid. Some workers are required to work up to 17 hours per day; experience verbal, sexual, or physical abuse in the home; live in inadequate conditions; and/or are denied a legally required weekly day off. Observers also reported brothels, bars, and clubs recruit foreign domestic workers to engage in commercial sex acts, sometimes through fraudulent recruitment methods. Some foreign domestic workers sign contracts to work in Hong Kong, but, upon arrival, traffickers coerce or lure them to work in mainland China, the Middle East, or Russia.

As demand for foreign domestic workers in Hong Kong increased, NGOs reported workers from countries other than Indonesia and the Philippines are increasingly vulnerable to exploitation. Some employment agencies reportedly hire foreign domestic workers under false pretenses and force them into commercial sex. On This Page search > < HONG KONG (Tier 2 Watch List) PRIORITIZED RECOMMENDATIONS: PROSECUTION PROTECTION PREVENTION TRAFFICKING PROFILE: Tags Bureau of East Asian and Pacific Affairs Hong Kong Human Trafficking Office to Monitor and Combat Trafficking in Persons Reports

Chat with this agency guidance using AI

Ask CiteLaw's AI Navigator anything about this agency guidance, verify citations, and research related authorities. Sign up for CiteLaw free today to get started.