2004/68/JHA of 22 December 2003 on combating the sexual exploitation of children and child pornography; Council Directive 2004/81/EC of 29 April 2004 on the residence permit issued to third-country nationals who are victims of trafficking in human beings or who have been the subject of an action to facilitate illegal immigration, who cooperate with the competent authorities. While the existing instruments oblige EU Member States to criminalise all possible acts that constitute Trafficking in Human Beings and to provide an adequate framework to protect victims of Trafficking in Human Beings as victims of crime, their transposition into domestic legislation lies with the Member States. Thus, besides the still-existing legislative gaps in compliance of national legislation with European standards, the elements determining Trafficking in Human Beings vary considerably across EU Member States. For the purpose of this study all elements that are in compliance with Council Framework Decisions and Directives determining trafficking in human beings on the respective national level constitute the basis for the assessment of the extent of the phenomenon.In addition, elements that go beyond the definition of the European instruments were taken into consideration.