The unprecedented restrictions on human movement imposed around the world to curb the spread of COVID-19 in the spring of 2020 posed new challenges and protection risks for migrants and refugees. Exploring how pandemic response measures have shaped the human smuggling industry, and consequent migrant protection risks, offers an unparalleled opportunity to scrutinise the unintended consequences of responses to irregular migration and human smuggling which are principally based on border control and interdiction of smugglers. This chapter explores these consequences, questions the impacts of current response frameworks, and suggests that a pivot in response frameworks is required to address elements of the human smuggling market.