The European Court of Human Rights (First Section) delivered a chamber judgment on 3 September 2026 in A.S. v. Latvia (no. 9327/23), holding that there was no violation of Article 4 (prohibition of slavery, servitude and forced or compulsory labour). The applicant alleged she had been subjected to conditions amounting to servitude and that Latvian authorities had failed in both their substantive and procedural obligations to investigate and protect her. The Court found the facts supported an arguable claim but concluded Latvia provided an adequate legal framework, treated the allegations as potentially engaging Article 4, and conducted effective ex officio investigative steps. It therefore held that the State met its positive and procedural obligations under the Convention. ([echr.coe.int](https://www.echr.coe.int/w/a.s.-v.-latvia?utm_source=openai))
Why it matters: the judgment clarifies how the ECHR will assess State responsibilities where labour‑exploitation complaints fall at the borderline between employment law and the criminal offence of trafficking or servitude. The Court emphasised two linked points: (1) States must have laws capable of criminally characterising exploitation that reaches the threshold of Article 4, and (2) authorities must take credible, timely investigative action when an arguable claim is raised — even where domestic courts later conclude the facts do not meet the trafficking threshold. Practically, the ruling reinforces that administrative or labour remedies alone may be insufficient when coercive elements are plausibly alleged, and it underlines the continuing role of the ECHR in policing procedural protection in trafficking/forced‑labour cases. The decision will be relevant to national prosecutors, police and courts across Council of Europe states when deciding whether to open and pursue criminal investigations into suspected exploitation. This report does not reproduce extended passages of the judgment and does not provide legal advice.