Equally Safe - challenging men's demand for prostitution: consultation

3. International Approaches to Prostitution

Background

Different countries have adopted different policy approaches to prostitution. New Zealand decriminalised sex work with their Prostitution Reform Act (PRA) 2003,^[30] whilst Sweden adopted Sexköpslag (Sex Purchase Law),^[31] more commonly known as the Nordic Model whereby those who purchase sex are criminalised with those selling decriminalised, in 1999.

Countries have continued to adopt new approaches in recent years, with France and Northern Ireland adopting new laws to criminalise the purchase of sex in 2016^[32] and 2015^[33] respectively.

Policies in Other Countries

A 2005 paper, "Study on National Legislation on Prostitution and the Trafficking in Women and Children" for the European Parliament noted that, though the policies on prostitution adopted by the then 25 member states were different, it was possible to group them into 4 models, seen below in Table 3.1.

Table 3.1 - Policy Approaches by EU Member States to Prostitution^[34]

Policy Approach: Abolitionism

Definition: A country falls under this model if outdoor and indoor prostitution are not prohibited. The State decides to tolerate prostitution and not to intervene in it. Prostitution by adults is not subject to punishment, but profiting from another person's prostitution is, however, criminalised.

Policy Approach: New abolitionism

Definition: This model is a development on the "abolitionism" model. A country falls under this model if outdoor and indoor prostitution are not prohibited, but with reference to the latter the State intervenes to explicitly prohibit the existence of brothels.

Policy Approach: Prohibitionism

Definition: A country falls under this model if outdoor and indoor prostitution are prohibited. Parties involved in prostitution can be liable to penalties, including in some cases, the clients.

Includes the approach adopted by Sweden in 1999, where the purchase of sexual services was criminalised whilst the provision of sexual services was decriminalised. This model is more commonly known as the "Nordic Model".

Policy Approach: Regulationism

Definition: A country falls under this model if outdoor and indoor prostitution are regulated by the State and are therefore not prohibited when exercised according to this regulation. Prostitutes are often registered by local authorities and are in some cases obliged to undergo medical controls.

Question

Question 3. Which of the policy approaches (or aspects of these) outlined in Table 3.1 do you believe is most effective in preventing violence against women and girls?