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No Nordic Model – Criminalising Clients Undermines Sex Workers’ Safety

The “No Nordic Model” briefing brings together statistical evidence and narrative to show how criminalising clients undermines sex workers’ safety. It also answers the ideological argument put forward by proponents of the Nordic Model that prostitution is inherently and distinctly more harmful than other work and therefore must be banned, and provides evidence of the success of decriminalisation as introduced in 2003 in New Zealand. Prostitution has always been connected to women’s poverty, which is why most sex workers (88%) are women and most clients are men. This briefing argues that to support women and reduce levels of prostitution, politicians should reverse austerity cuts and ensure that women, particularly mothers, have viable economic alternatives.

Who sex workers are.

Of the approximately 72,800 sex workers in the UK, 88% are women.[1] Most sex workers are mothers working to support families.[2]

Prostitution has always been connected to women’s poverty – that’s why most clients are men, and most sex workers are women. Politicians who want to reduce prostitution should address government policies which promote prostitution. 86% of austerity cuts since 2010 have fallen on women, particularly single mothers.[3] [4]Benefit sanctions and the introduction of Universal Credit are directly linked to rises in prostitution.[5] [6]Measures that would help women exit prostitution include repealing benefit sanctions, the benefit cap, the two-child limit and reinstating Income Support for single mothers.

Criminalisation, of sex workers or clients, undermines safety.

Criminalisation exacerbates the harms sex workers suffer.[7] Research from the UK shows that where arrests of sex workers and clients were high, less women report violence.[8]

Sweden – Criminalised the buying of sex (Sexköpslagen law) in 1999. This law known as the “Nordic Model” is touted as feminist because it criminalises men (i.e., the clients) rather than women (i.e., the victims). But its effect on women has been disastrous. Sex workers face increased stigma, are more at risk of violence,[9] and are less able to call on the protection of the police and the authorities as this can lead to police harassment, the loss of custody over children, or deportation.[10] [11]

Comprehensive field work and research[12] found that there is “no convincing empirical evidence that the law has resulted in a decline in sex work in Sweden” — which was the law’s principal ambition. It also countered the claim that sex workers have been decriminalised: sex workers can be prosecuted under procuring laws when they band together for safety.  

Norway – Criminalised clients in 2009. Amnesty International’s 2016 research[13] found that sex workers are still criminalised, including for working together for safety. Forced evictions, investigations, surveillance, prosecutions, and increased stigma are prevalent with migrant workers particularly targeted.

Research in Sweden, Finland, and Norway in 2022 found that Nordic Model legislation was a smokescreen for punitive and racialised policing where sex workers were targeted for deportations and evictions.[14]

France – Criminalised clients in 2016. Medecins du Monde’s 2018 report[15] found that since the law was introduced: 63% of sex workers have experienced deterioration of their living conditions, more isolation and greater stress; 42% are more exposed to violence (sexual violence, theft, and armed robbery); 38% have found it increasingly hard to demand use of condoms.

Ireland – Criminalised clients (Criminal Law (Sexual Offences) Bill) in 2017. Reported incidences of violent crime against sex workers, from threats to assaults with weapons, have risen by 92%.[16] Migrant and trans women sex workers in particular have been targets of violence. Sex workers are now less likely to report dangerous clients to Gardaí.[17] Amnesty International’s 2022 report[18] found the law “purportedly designed to protect human trafficking victims and sex workers from exploitation is instead facilitating the targeting and abuse of sex workers. . . ” 

Criminalising clients does not reduce trafficking.

A 2014 Vancouver study found that “criminalisation and policing strategies that target clients…profoundly impacted the safety strategies sex workers employed.”[19] Sex workers continued to mistrust police, had to rush screening clients and were displaced to outlying areas with increased risks of violence, including being forced to engage in unprotected sex.

Research found that less than 6% of migrant sex workers in the UK had been trafficked with many saying they prefer working in the sex industry than the “unrewarding and sometimes exploitative conditions they meet in non-sexual jobs”.[20]

The Home Affairs Committee (HAC) recommended decriminalisation.

In July 2016 HAC recommended[21] that: “… the Home Office change existing legislation so that soliciting is no longer an offence and so that brothel-keeping provisions allow sex workers to share premises.” It called for “previous convictions and cautions for prostitution [to be deleted] from the record of sex workers”. Government research commissioned as a result of the HAC report found that financial need and criminalisation create the “perfect cocktail of conditions” for undermining sex workers’ safety.[22]

New Zealand – Decriminalisation promotes rights and safety.

The New Zealand Prostitution Reform Act (2003) removed prostitution from the criminal law, allowed people to work together collectively and organise to assert their rights to better working conditions. Since decriminalisation, over 90% of sex workers said they had additional employment, legal, health and safety rights. The percentage of sex workers who felt able to refuse clients – a key marker of exploitation — went up from 47% (a year before decriminalisation) to 68% after decriminalisation. 70% said they were more likely to report incidents of violence to the police.[23]

A comprehensive government review[24] found: no increase in prostitution; no increase in trafficking; sex workers more able to report violence and leave prostitution if they choose.

New Zealand did not decriminalise exploitation, rape, extortion, threats, trafficking, and other violence. Offences of compelling anyone into prostitution were reinforced.

In New Zealand, the State discriminates in favour of sex workers who want to leave sex work and need to claim benefits. This could also be implemented here.

Do we not count?

The Nordic model has a detrimental impact on women working in the sex industry – how can it be considered feminist? Sex worker organisations the world over are campaigning for decriminalisation – why are we being ignored or dismissed? Do we not count as women and as workers?

DOWNLOAD: No Nordic Model


[1] Brooks-Gordon, B., Mai, N., Perry, G., Sanders, T. (2015). Calculating the Number of Sex Workers and Contribution to Non-Observed Economy in the UK for the Office for National Statistics.

[2] Home Office. (2004). Paying the Price: A Consultation Paper on Prostitution

[3] The Guardian, 9 March 2017. Women bearing 86% of austerity burden, Commons figures reveal | Gender | The Guardian

[4] The Guardian, 5 July 2022.

[5] 60% increase in street prostitution in Doncaster “because of benefit sanctions” (The Star, 19 March 2014), 166% increase in Sheffield (The Star, 1 June 2014)

[6] The Guardian, 22 May 2019.

[7] A systematic review of all sex work research conducted in 33 countries from 1990 to 2018, found that criminalisation of sex work is linked to ‘extensive harms’ among sex workers. Sex workers are three times more likely to experience sexual or physical violence where the trade is criminalised. Platt L, Grenfell P, Meiksin R, Elmes J, Sherman SG, Sanders T, Mwangi P, Crago AL. (2018). Associations between sex work laws and sex workers’ health: a systematic review and meta-analysis of quantitative and qualitative studies.

[8] A 2014 survey found that w only 5% of sex workers who were victims of a crime reported it. This compared to 46% of victims in areas where police adopted a harm reduction approach. Data provided by National Ugly Mugs (UKNSWP). (2012-2015).

[9] Jakobsson, P. & Edlund, C. (2014). Another Horizon; Sex Work and HIV Prevention in Sweden.

[10] Levy, J. and Jakobsson, P. (2014). Sweden’s abolitionist discourse and law: Effects on the dynamics of Swedish sex work on the lives of Sweden’s sex workers, Criminology and Criminal Justice.

[11] English Collective of Prostitutes. (2016). Decriminalisation of Prostitution: the Evidence. 

[12] Levy, J. (2015). Criminalising the Purchase of Sex: Lessons from Sweden.

[13] Amnesty International. (2016). The Human Cost of ‘Crushing’ the Market: Criminalization of Sex Work in Norway.  

[14] Vuolajärvi, N. (2022) Criminalising the buying of sex? Experiences from the Nordic Countries.

[15] Medecins du Monde. (2018). What do sex workers think about the French Prostitution Act?  web_en_rapport-prostitution-finale.pdf (

[16] The Belfast Telegraph, 27 March 2019.

[17] “Not collateral damage: Trends in violence and hate crimes experienced by sex workers in the Republic of Ireland” p.294

[18] Amnesty International (2022). “We live within a violent system” – Structural violence against sex workers in Ireland.

[19] Krüsi A, Pacey K, Bird L, et al. (2015). Criminalisation of clients: reproducing vulnerabilities for violence and poor health among street-based sex workers in Canada—a qualitative study. BMJ Open 2014.

[20] Mai, N. (2011). Migrant Workers in the UK Sex Industry: ESRC Full Research Report.

[21] Third Report from The Home Affairs Select Committee Session. -17 HC 26: Prostitution. (2016). House of Commons.

[22] Hester, M, Mulvihill, N, et al. Centre for Gender and Violence Research, University of Bristol. (2019). The nature and prevalence of prostitution and sex work in England and Wales today.

[23] Abel, G., Fitzgerald, L. & Brunton, C. (2007). The Impact of the. Prostitution Reform Act on the Health and Safety Practices of Sex Workers.

[24] Ministry of Justice. (2008). Report of the Prostitution Law Review Committee on the Operation of the Prostitution Reform Act 2003.