Abstract
In August 2019, a policy change was introduced by the Dutch Secretary of State, limiting the issuance of a reflection period and residence permits to victims of trafficking in human beings (THB) who also have a Dublin status. In this research, I discuss how this is not in conformity with EU law. The provisions on the reflection period and residence permit amount to incorrect implementations of the EU Directives in the field of protection of victims of THB. I provide two important arguments in this regard: the policy rules do not fulfil the criterion of mandatory rules and the implementation is in conflict with the aim of the Directives. Subsequently, the distinction between Dublin claimants and non-Dublin claimants must be discarded. As such, changes need to be made to the current THB framework to close the gaps.