
Legal reforms
Real change means fixing the laws that let abuse thrive — stronger prevention, real accountability, and a justice system survivors can actually reach. NOA is building relationships with academics, advocates and allies to accelerate reforms centered on safeguarding and the needs of survivors.
Why legal reform matters
Lasting change requires legal reform that prevents abuse, stops its continuation, and ensures survivors can access justice on equal terms. Prevention means stronger safeguarding, early identification of risk, and genuine deterrence through penalties — including civil fines, expanded damages, and a review of limitation laws.
Abuse must be harder to hide: NDAs, SLAPPs, and retaliation against whistleblowers must be curtailed, and mandatory reporting enforced. Stopping abuse demands effective policing, trauma-informed prosecution decisions, and pattern-based case reviews. Finally, survivors need real access to justice, through affordable representation, fairer cost rules, and statutory redress that holds perpetrators and institutions truly accountable.
NOA's focus on legal reforms
SLAPPs
SLAPPs are legal threats or actions used by powerful figures to silence survivors, journalists, and whistleblowers through intimidation and financial pressure. Mohamed Fayed notoriously used defamation and harassment claims to deter scrutiny and suppress accounts of abuse. While the Economic Crime and Corporate Transparency Act 2023 introduced limited anti-SLAPP provisions, they apply only to cases linked to economic crime, leaving survivors of sexual abuse, corruption, or exploitation unprotected. This narrow reform fails to prevent misuse of the courts for coercion. A universal anti-SLAPP law is needed to safeguard all public-interest speech and survivor testimony. The author contends that this omission matters: it narrows the public’s understanding of systemic exploitation, minimises the institutional mechanisms that enabled abuse and reflects a broader reluctance to confront trafficking when it involves the wealthy and powerful. The piece calls for greater honesty and legal precision when describing such organised patterns of coercion and control.
Mandatory Reporting
Mandatory reporting could have been transformative for the Harrods survivors, forcing professionals who saw or suspected abuse to act rather than remain silent under institutional pressure. Recent reforms under the Crime and Policing Bill 2025 introduce a legal duty to report child sexual abuse. While this is a long-overdue step toward accountability, the law’s scope is far too narrow: it applies only to children and carries no criminal sanction for failure to report. Adult survivors remain unprotected, and institutions can still suppress evidence. True reform demands universal, enforceable reporting duties across all forms of abuse. The use of pictures is helpful in several ways: crossing any language barriers, providing quick reference points and also through supporting communication when trauma may hinder clarity. Importantly, the tool simplifies the language, process and layers which can complicate the ways in which trafficking is identified. The aim of the tool is for survivors to feel safer by enabling clearer communication and therefore understanding, so leading to greater trust. The tool can be used in First Responder interviews by pointing to pictures that apply to your experience so that images can convey information when words may be hard to find.
Limitation Periods
Strict time limits on bringing civil claims still block many survivors from seeking justice. At present, adults generally have only three years after turning 18 to start a claim, even though research shows it often takes decades for survivors to feel safe enough to disclose abuse. Courts can extend this deadline in some cases, but the rule still gives powerful defendants a legal tool to shut cases down early. Recent government reforms will remove this three-year limit for child sexual abuse, which is welcome progress, but the change doesn’t cover adult survivors or other forms of exploitation, leaving major gaps in access to justice.
Judicial College Guidelines (JCG)
The Judicial College Guidelines (used by courts to value personal injury damages) are poorly suited to complex sexual abuse and trafficking cases. They treat lifelong trauma as if it were a short-term psychological injury, with awards often far below the real impact of abuse on a survivor’s life, health, and earning capacity. This undervaluation not only minimises the seriousness of the harm but also makes many cases financially unviable for claimant lawyers, limiting access to representation. The JCG were never designed for the cumulative trauma of abuse or exploitation. Without reform, they continue to reinforce inequality and injustice.
New Torts for Trafficking and Exploitation
Current civil law does not adequately capture the realities of trafficking and exploitation. Survivors must rely on outdated or ill-fitting causes of action (such as assault, false imprisonment, or negligence), which fail to reflect the organised, coercive nature of these crimes and increase cost risk for survivors. This leaves major gaps in accountability, particularly where abuse involves multiple perpetrators or institutional complicity. Creating specific torts for trafficking, coercive control and exploitation would recognise the distinct harms involved and provide clearer legal routes to redress. Without these reforms, survivors remain forced to fit their experiences into laws that were never written for them.
Cost Risk Against Wealthy Defendants
For survivors bringing claims against wealthy or powerful abusers, the risk of crippling legal costs is one of the biggest barriers to justice. Under current rules, if a survivor loses, or even wins but fails to beat a defendant’s settlement offer, they can be ordered to pay the other side’s costs, often running into hundreds of thousands of pounds. Wealthy defendants exploit this imbalance to pressure survivors into silence or low settlements. Existing cost protections are narrow and inconsistent, leaving claimants exposed. Reform is essential to level the playing field, ensuring that access to justice doesn’t depend on who has deeper pockets.
Public Interest Exemptions to Part 36 Offers
Part 36 rules, designed to encourage settlement, can unfairly penalise survivors in public interest cases. If a survivor rejects a settlement offer but later wins less at trial, they may face severe financial sanctions, even when their case exposes serious wrongdoing or serves the wider public good. Powerful defendants use these rules tactically to force early, low-value settlements and avoid scrutiny. Introducing public interest exemptions to Part 36 would protect survivors and whistleblowers pursuing cases that reveal systemic abuse or institutional failure. Justice should reward truth and accountability, not punish those who seek them.
Statutory Redress
A statutory redress framework is essential to deliver justice where litigation is too slow, risky, or unequal to succeed. Survivors of systemic abuse (including those linked to Harrods) face enormous barriers when suing powerful individuals or institutions. Voluntary or private schemes have repeatedly failed, offering token payments, demanding confidentiality, and avoiding accountability. A statutory scheme, created and overseen by law, would guarantee fair compensation, transparency, and independence from those responsible. It would also reduce court pressure and public cost by providing a consistent, trauma-informed alternative to litigation. Without statutory redress, survivors remain trapped in a system built to protect the powerful.
Pattern Recognition Across Cases (Police and CPS)
Failures to identify and act on patterns of abuse have allowed serial offenders to continue harming victims for years. Police and CPS processes often treat reports in isolation, missing links that reveal organised or repeat offending. In cases like those connected to Harrods, this failure to join the dots meant survivors were disbelieved and predators remained protected. Mandatory pattern recognition (requiring forces and prosecutors to review connected reports and reopen cases when new patterns emerge) is vital. Abuse is rarely a one-off event. The justice system must be equipped to recognise that and respond accordingly.
CPS Duty to Reopen Cases Where Patterns Are Identified
When new evidence or consistent patterns of abuse emerge, the CPS must have a clear duty to revisit past decisions not to prosecute. Too often, survivors are dismissed as isolated cases, only for later reports to reveal repeat offending or systemic cover-ups (as seen in the failures surrounding powerful men linked to institutions like Harrods). A statutory requirement to reopen such cases would correct historic injustices, restore public trust, and deter institutional complacency. Survivors should not bear the burden of repeatedly proving credibility when the pattern itself confirms the truth that was ignored.
CPS Decision Processes
CPS charging decisions in abuse and exploitation cases often lack transparency, consistency and a trauma-informed approach. Survivors are frequently told there is “insufficient evidence,” even where multiple credible reports exist. In cases involving powerful or well-connected suspects (such as those linked to Harrods) the threshold for prosecution has historically been applied unevenly, reinforcing a perception of impunity. CPS decision-making must be reformed to prioritise evidence patterns, survivor credibility, and public interest, not reputational risk. Clearer guidance, external oversight, and mandatory explanations for non-prosecution decisions would help ensure that justice is applied fairly, regardless of power or status.
