Confronting the tension as EPP advances and “permissible” fees persist
By Georgina Vazquez de los Reyes, Director, Stakeholder Engagement and Technical Assistance
The topic of ethical recruitment has reached a critical inflection point. While it is now recognized as an established global norm, implementation remains uneven, prompting urgent calls for measurable outcomes and accountability. These calls include a strong focus on zero recruitment fees paid by workers, one of the most prominent elements of ethical recruitment programs, yet far from the only one.
Verité’s work on ethical recruitment and the Employer Pays Principle spans years of field research and resource development, including open-access tools designed to enable concrete, measurable action. The Recruitment Cost Calculator (RCC), for example, has been included in the UN Migration Network Repository of Practices, a peer-reviewed collection of practical resources addressing migration governance challenges.
The Disconnect between the EPP and Regulations
As preparations accelerate for next week’s 2026 International Migration Review Forum (IMRF), one issue warrants closer scrutiny: the tension between increasing pressure to advance implementation of the EPP and regulatory frameworks that still contain provisions that allow for certain fees — prohibited by international standards — to be charged to workers.
These two competing forces create a disconnect. Even when the employer demonstrates progress and can show that it has paid legally required fees, workers may still end up bearing significant recruitment costs upfront, such as brokerage fees, legally required documents, mandatory training, and medical exams.
There are many reasons for this, but the following are relevant for upcoming conversations:
First, many destination countries adopt some elements of the ‘employer pays’ model, while allowing other fees and costs to be paid by workers. For example, in Vietnam, while the law requires employers to cover brokerage fees for overseas employment, it simultaneously permits workers to be charged other recruitment-related costs — such as a contract guarantee that ties the worker to the employer through upfront deposits into an escrow account — resulting in a substantial risk of debt bondage. This illustrates an internal inconsistency, where employer obligations coexist with high-risk fees for workers under national law.
The result is a persistent loophole: even where destination-country law appears protective, workers continue to finance recruitment through unregulated or lightly regulated charges at origin, undermining worker protections.
A second, equally important issue is conflicting regulations between migrant workers’ countries of origin and destination. In some cases, while destination countries require employers to pay placement or broker fees within their jurisdictions, workers are still left to cover “first-mile” costs to recruiters and sub-agents at origin. This disconnect shifts costs upstream onto workers.
For instance, India, Bangladesh, and Nepal permit recruitment fees to be charged to workers. These countries are part of migration corridors in which destination countries, including several in Asia and the Gulf Cooperation Council (GCC), do not legally require employers to cover those costs. To address high fees, some laws cap the amount that can be charged to workers; however, this does not necessarily reduce harm, as the total upfront costs still often force workers into debt.
The result is a persistent loophole: even where destination-country law appears protective, workers continue to finance recruitment through unregulated or lightly regulated charges at origin, undermining worker protections.
Why Accessible Migration Systems Are Key to Preventing Informal Payments and Exploitation
Legitimate recruitment fees and related costs are often tied to informal or illegitimate payments. Verité’s 2026 recruitment fees and costs research, including mapping exercises for key labor corridors, shows that even within regulated migration pathways there is space for informal payments and kickbacks.
In the Myanmar–Thailand corridor, for example, Verité found that despite a Memorandum of Understanding (MoU) between the two governments to coordinate regulation of labor migration, workers commonly paid brokers and government officials to accelerate document processing, where standard timelines for securing basic documentation stretch from three to six months.
A similar pattern was seen in the Bangladesh–Malaysia corridor, where rural workers face long travel times and limited access to passport processing facilities. These conditions create incentives for informal payments to speed up processing, pushing actual costs well beyond official fee schedules and introducing significant compliance risks.
Curbing the risk of illegitimate fees requires addressing migration channel process weaknesses, bottlenecks, corruption, and weak enforcement of EPP regulations on both ends of migration corridors. When legal processes are slow, inaccessible, or costly, workers are pushed toward informal intermediaries. Ensuring that regular migration pathways are efficient and accessible is therefore central to reducing fee-related exploitation.
A Call for IMRF Discussions Grounded in Workplace Realities
To meet this moment, discussions at the IMRF must remain grounded in implementation realities and centered on worker protection. Progress depends on coherent, aligned government action — reviewing and updating laws and regulations to put workers first. While significant pressure has been placed on companies to adopt ‘employer pays’, ‘no fee to worker’ policies, governments must embed that same standard in public regulation. Encouragingly, more governments are moving toward zero-fee frameworks, recognizing the role recruitment fees play in driving debt bondage and forced labor. As prohibitions on charging workers are integrated into forced labor laws and enforcement systems, protections will strengthen and close long-standing gaps in practice.
The key question for stakeholders at the IMRF should be how commitments are actually changing the lives of workers, and whether the strategies are robust enough to sustain that change over time. That means confronting the tension at the heart of current efforts: advancing the EPP while regulatory frameworks continue to allow for workers to continue to bear the cost of legally “permissible” recruitment fees. Until that gap is addressed, progress will remain stunted and workers will continue to pay the price.
About the author
Georgina Vazquez has over 15 years of experience working with diverse stakeholders and directing initiatives to protect migrant workers, promote ethical recruitment, and prevent labor violations in complex supply chains. As a Program Director and co-leader of the Technical Assistance to Governments Practice Group, Georgina directs various projects in the organization, including the Recruitment Cost Calculator (RCC) – Verité’s open-access ethical recruitment tool for businesses, investors, governments, and civil society organizations.
