Sexual trafficking grants 2026: what changes for NGOs and social entities

Key data

Organizations working with human trafficking victims for sexual exploitation purposes face a change in the rules of the game. The Order IGD/392/2026, of April 20, modifies the regulatory bases approved through the Order IGD/183/2024, of February 28, updating the requirements, conditions and procedures applicable to these public grants.

The change directly affects any entity that wants to access these grants in the current or upcoming calls. Failing to review the new conditions before submitting the application could mean being excluded from the process due to non-compliance with the new criteria.

What does this regulation establish?

Order IGD/392/2026 updates the regulatory bases that govern the granting of public grants for projects aimed at:

• Women and girls who are victims of human trafficking for sexual exploitation purposes.
• Minor children of these victims.
• Children with disabilities of these victims.

The modification may imply variations in the following aspects compared to the 2024 regulatory bases:

The reference regulation being modified is the Order IGD/183/2024, of February 28, which approved the original regulatory bases. Any entity that has participated in previous calls under that order must assume that the conditions have changed and cannot automatically apply the same criteria.

Economic and operational impact

The main impact for affected entities is operational and regarding access to financing. These grants represent, for many NGOs and third sector organizations, an essential source of financing to sustain their care programs. An error in the application due to lack of knowledge of the new criteria may result in:

• Exclusion from the call due to non-compliance with the new eligibility requirements.
• Rejection of expense justification if criteria from the previous regulation are applied.
• Loss of access to financing in an area where public resources are limited and competition between entities is high.

Since the order entered into force on April 20, 2026, eight days before its publication in the BOE (April 28, 2026), it is possible that some entities have initiated procedures without knowing about the changes. It is advisable to verify whether ongoing processes comply with the new regulation.

Who does it affect?

This modification directly affects:

• NGOs that develop projects for care, shelter or reintegration of sexual trafficking victims.
• Non-profit entities from the social third sector with programs aimed at this group.
• Social organizations that care for minor children of trafficking victims.
• Entities working with people with disabilities who are children of trafficking victims.
• Grant managers and supervisors in these organizations who prepare or oversee applications.

It does not affect private for-profit companies or entities that do not work specifically in the field of human trafficking for sexual exploitation purposes.

Practical example

An NGO that in 2024 submitted a grant application under Order IGD/183/2024 and was a beneficiary, decides to apply again in 2026. If it uses exactly the same application model and the same expense justification criteria it used in the previous call, it runs the risk that its application will be rejected or that the subsequent justification of expenses will not be accepted, because the regulatory bases have been modified by Order IGD/392/2026.

The mandatory step before submitting any application is to review the new terms of Order IGD/392/2026 and compare them with those of Order IGD/183/2024 to identify exactly what has changed in eligibility, eligible expenses and procedure.

What should entities do now?

1. Download and read Order IGD/392/2026 in the BOE to know exactly which articles or conditions have been modified compared to Order IGD/183/2024.
2. Compare the new regulatory bases with those of 2024, paying special attention to eligibility criteria, justifiable expenses and maximum eligible amounts.
3. Update the application and justification models that the entity regularly uses to adapt them to the new requirements.
4. Inform the team responsible for grants about the changes before initiating any application procedure in the current call.
5. Verify if there are ongoing processes initiated between April 20 and April 28, 2026 that need to be adjusted to the new regulation, given that the order entered into force before its publication in the BOE.
6. Consult with a specialized advisor if there are doubts about the interpretation of the new criteria or about the impact on applications already submitted.