Thursday, 18 December 2025
Today the government announced its long-awaited strategy to tackle violence against women and girls (VAWG). While we welcome this historic strategy, we are disappointed that it does not fully address the needs of Black, minoritised and migrant women. For Black, minoritised and migrant women, experiences of violence are inseparable from structural inequalities rooted in racism, immigration control, including the actions of statutory agencies themselves. Any VAWG strategy that fails to address these intersecting systems risks reinforcing harm rather than preventing it.
Safe Reporting/the Firewall
We welcome the inclusion of limited measures within the VAWG Strategy that recognise the importance of safe reporting for migrant victim-survivors, including steps to limit data-sharing between statutory agencies and Immigration Enforcement. This recognition reflects what SBS has long highlighted: that fear of immigration enforcement prevents many women from disclosing abuse or accessing protection.
These developments follow sustained negotiations between Southall Black Sisters, Latin American Women’s Rights Service (LAWRS) and the Home Office, which have resulted in the introduction of a requirement to seek victim-survivors’ consent before their data can be shared with Immigration Enforcement. This represents an important shift away from the routine sharing of victim-survivors’ data without their knowledge or consent.
While these measures are long overdue and introduce a degree of protection for migrant victim-survivors who report abuse, they do not amount to a full, unconditional firewall. The proposed approach remains conditional and continues to allow data sharing with Immigration Enforcement, undermining victim-survivors’ ability to seek help without fear of detention or deportation.
The introduction of consent-based safeguards is a significant development. However, consent cannot be treated as meaningful where power imbalances, trauma and fear of immigration enforcement remain. To mitigate these risks, consent must be sought through independent specialist ‘by and for’ services, rather than statutory agencies, so that victim-survivors are supported to make informed decisions in a safe and trusted context.
No Recourse to Public Funds
These shortcomings are mostly starkly exposed in the Strategy’s continued failure to fully address the needs of migrant victim-survivors with insecure immigration status who are subject to the No Recourse to Public Funds (NRPF) condition. NRPF is a draconian, state-imposed barrier that makes women three times more likely to experience VAWG.
SBS service-users routinely report being turned away from statutory and voluntary services, experiencing homelessness, destitution and exploitation as a direct result of NRPF.
We therefore welcome the continued investment in the Support for Migrant Victims Scheme (SMV), however, (1) this support is not sufficient to meet the number of migrant victim-survivors in need, and (2) the Action Plan does not introduce legal reforms so that all women regardless of their immigration status are able to escape abuse.
The combined model of Migrant Victims of Domestic Abuse Concession (MVDAC), which provides time-limited access (12 weeks) to benefits, and Domestic Violence Indefinite Leave to Remain (DVILR), which offers a route to regularise immigration status independently of the perpetrator, is a vital safety net that urgently needs to be extended to all victim-survivors regardless of immigration status.
Funding for ‘By and For’ Services
Whilst the Action Plan which accompanies the VAWG Strategy mentions provision for specialist advocacy across England and Wales, including ‘by and for’ it is not clear whether there will be sufficient ring-fenced funding for specialist ‘by and for’ services that provide life-saving support to Black, minoritised and migrant women. Research from the Domestic Abuse Commissioner shows that 67% of the most marginalised victim-survivors prefer ‘by and for’ services[1]. The Commissioner has also called for £158.3 million per year in ring-fenced funding for specialist services supporting Black and minoritised, deaf and disabled women, and other marginalised groups, alongside £63.5 million per year in dedicated funding for victim-survivors with No Recourse to Public Funds[2]. Without ring-fenced funding, the government continues to leave some of the most vital and chronically under-funded specialist services across the country in a state of ongoing and unsustainable precarity. We therefore call on the government to urgently ring-fenced long-term funding for specialist ‘by and for’ services.
Selma Taha, Executive Director, Southall Black Sisters said:
“This VAWG Strategy acknowledges, at least in part, what Black, minoritised and migrant women have long known-that fear of immigration enforcement prevents many survivors from reporting abuse or accessing protection. We welcome the limited steps taken to restrict data-sharing between statutory agencies and Immigration Enforcement, secured through sustained negotiations with the Home Office, but these measures fall short of a full, unconditional firewall.
Consent-based safeguards are an important development, but consent cannot be meaningful where trauma, power imbalances and the threat of detention or deportation remain. Victim-survivors must be supported to make informed decisions through trusted specialist ‘by and for’ services, not left to navigate these risks alone.
We also welcome the continued investment in the Support for Migrant Victims Scheme, which has provided a critical lifeline for some women. However, the scheme remains limited in scope and duration and does not remove the structural barriers created by No Recourse to Public Funds. NRPF continues to push thousands of migrant women into destitution, homelessness and further abuse.
Extending the MVDAC–DVILR model to all victim-survivors, regardless of immigration status, is essential if women are to escape violence and rebuild their lives. But legal reform alone is not enough. Without ring-fenced, long-term funding for specialist ‘by and for’ services, the government risks undermining the very organisations best placed to support the most marginalised women. In 2025, it is unacceptable that a flagship VAWG strategy still denies migrant women the safety, support and dignity every survivor deserves.”