The debate about the law to abolish prostitution in Spain has raised the question of what model is best for supporting sex workers, the vast majority of whom are women. Spain follows the so-called “Nordic” model [the economic and social models of the Nordic countries (Denmark, Finland, Iceland, Norway and Sweden)], in which the client of the sex worker is punished if the prostitute complains. This model, based on which “requests to purchase sexual services can be prosecuted”, is applied to reduce demand.
But unlike the countries of Northern Europe and the desire of the left-wing government of Spain, not all countries follow this path.
In Germany, prostitution is legal and considered a profession, however, they are reviewing their latest regulations this month to assess their effects. This assessment will result in a report to the German Bundestag [Federal Parliament] by July 1, 2025. The German example and the Spanish programs are only two of the diverse approaches in the European Union; Where countries take different legal paths when it comes to prostitution.
There is agreement on human trafficking and forced prostitution, and all governments have criminalized such behaviors. However, there is virtually no consensus about sex work [prostitution] and its voluntary nature.
The position of the European Union
According to the European Commission’s latest report on human trafficking, 60% of victims in EU member states are trafficked for sexual exploitation, and more than 90% of them are women. Faced with this reality, the commission describes the problem as “a form of violence against women” that originates “in gender inequalities”.
In 2014, the European Parliament passed a resolution in which it said: “Prostitution, forced prostitution and sexual exploitation are issues that are highly gendered and a violation of human dignity and are contrary to the principles of human rights, including gender equality, and therefore contrary to “The principles of the charter are the fundamental rights of the European Union.”
European Union institutions are advocating prosecution of soliciting prostitution by punishing clients. But the reality is that in 27 member states there is a wide disparity in national regulations ranging from legal loopholes to banning or legalizing prostitution.
Nordic model
Sweden was the first country to criminalize prostitution and thus focused on clients. The term “Nordic model” is the first legislation on this subject that dates back to 1999 and has inspired other EU countries such as France and Ireland. Swedish criminal law also punishes pimps and aims to eradicate prostitution.
In 2016, France followed Sweden’s example by imposing fines on those who solicit sex from prostitutes. A year later, Ireland became the third EU country to adopt this approach, imposing fines of up to €500. If the crime is repeated, the fine will increase up to one thousand euros.
A key aspect of this model is what assistance is provided to sex workers who may be forced into the profession or driven into the profession by poverty. The Swedish Gender Equality Agency explains: “In Sweden, if a prostitute lives legally in the country, social service organizations assess their needs, which may include housing, financial support, etc. “If a person comes from another country, whether he is a victim of trafficking or not, he can benefit from the program of voluntary return and reintegration in his country of origin, which is provided by social service organizations in agreement with the International Organization for Migration.”
In France, financial support for the social and work integration of sex workers amounts to 330 euros per month for single people, and if these people have dependent children, the amount is added to 102 euros per child. According to the law of social and family action, people who are victims of prostitution, panhandling and human trafficking for the purpose of sexual exploitation are helped. In each department of France, a government agency is responsible for evaluating each case.
In Ireland, the 2017 reforms do not include specific financial support. However, in June last year Ireland’s Executive Council presented a new national strategy against gender-based violence, which aims to address the issue of prostitution. Ireland’s Justice Minister tells Euronews: “The strategy sets out a number of measures related to prostitution and exit strategies, including income maintenance support through the Department of Social Protection.”
