The Nordic Model

What is the Nordic Model?

The so-called “Nordic Model” is a legal framework aimed at combating human trafficking and forced prostitution, which is increasingly being demanded as a political solution in the context of prostitution. The Nordic Model is based on the assumption that prostitution is a violation of human rights and makes gender equality impossible.

The underlying ideas are as follows: Prostitution and human trafficking for the purpose of sexual exploitation are harmful practices that can hardly be separated from one another. Prostitution is seen as a highly gendered issue, as sexual services are almost exclusively consumed by men and are predominantly provided by women.

Prostitution is not viewed as a form of sexual freedom and self-determination, but rather as an opportunity for men to buy women’s bodies. Therefore, the Nordic Model questions whether it is acceptable for sexual acts or the bodies of people to be purchasable, advocating for a ban on the purchase of sex.

Facts at a Glance

The Nordic Model was first introduced in Sweden in 1999 (hence the name) and was part of changes to various laws aimed at achieving gender equality in Sweden. It is also known as the “Equality Model.”

The Nordic Model is implemented in several countries, each with individual adjustments. The following countries have already amended their laws:

  • Sweden (since 1999)
  • Norway (since 2009)
  • Iceland (since 2009)
  • Canada (since 2014)
  • Northern Ireland (since 2015)
  • France (since 2016)
  • Ireland (since 2017)
  • Israel (since 2018)

One of the core elements, however, is always the criminalization of the purchase of sex while decriminalizing the sale of sex. This means that clients are criminalized for purchasing sex (= ban on buying sex), while people involved in prostitution can still offer sex without legal consequences.

Foundations of the Nordic Model

Nordisches Modell
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Components of the Nordic Model are:

  • Criminalization of sex purchase (the buying of sexual services), pimping, operating brothels, and human trafficking. In the Nordic Model, the client is made criminally liable.
  • Decriminalization of prostitution (the offering of sexual services). The Nordic Model no longer holds the person who has to engage in prostitution criminally liable but recognizes the various circumstances and pressures that lead women into (coerced) prostitution.
  • Counseling and various exit assistance for affected women.
  • Prevention and education of society (starting in schools).
  • Gender equality and thus an end to the purchasability of a gender.

The Nordic Model brings about a paradigm shift: The purchase of sex is prohibited, not the offering.
The focus is thus placed on the behavior of the clients.

The goal of the Nordic Model is a societal change in thinking regarding prostitution and gender equality.

The Nordic Model in Numbers and Studies

Numerous studies and research show the positive changes brought about by the Nordic Model and the ban on purchasing sex. In all countries that have adopted the Nordic Model, the following results can be observed:

  • The number of clients decreases
  • The number of women in prostitution is reduced
  • A shift in societal attitudes takes place
  • A decline in coerced prostitution and human trafficking

Sweden, which has had the Nordic Model in place for over 20 years, shows the following positive outcomes:

In France, according to a 2018 study, the number of clients already dropped by 50-75%.

The evaluation following the introduction of the Nordic Model in Norway in 2009 shows a weakening of the prostitution market by 20-25% (with street prostitution decreasing by 45-60%), a reduction in demand, a decrease in human trafficking, and fewer recruitment efforts.

In Northern Ireland, street prostitution decreased by 50%, and 11% of clients reported adhering to the sex purchase ban and not visiting prostitutes since its implementation.

So far, it appears that the law works where it is effectively implemented.

Criticism of the Nordic Model

Critics of the Nordic Model typically raise concerns in the following areas:

Critics of the model view prostitution more as sex work and an opportunity for individuals to engage in work autonomously. Therefore, they disagree with the core idea of the Nordic Model, which states that prostitution is incompatible with human dignity. They instead advocate for strengthening the rights of people in prostitution, rather than imposing prohibitions.

They acknowledge the problem of coerced prostitution but believe that combating it is more about strengthening the rights of those in prostitution. They distinguish sex work clearly from coerced prostitution. Since they want to strengthen and de-stigmatize prostitution as a normal occupation, they reject a stigmatizing ban on purchasing sex. Instead, they advocate for strengthening rights and taking measures against stigmatization.

It is also criticized that by criminalizing the purchase of sex, prostitution is pushed further into illegal and/or less protected areas, which are less accessible for outreach workers. (For example, less prostitution on the streets, but more offers in apartments.) As a result, they see an increased risk of violence against people in prostitution.

Advocates of the Nordic Model

Many survivors of (coerced) prostitution, as well as various organizations and politicians, support the Nordic Model and critically address the arguments listed above.

They find the argument that prostitution moves underground and becomes less detectable and controllable unconvincing. For them, prostitution already takes place in secret. In 2021, only 23,700 prostitutes were legally registered in all of Germany. Many experts estimate the actual number to be much higher, and authorities and police see that prostitution and the organized crime associated with it are currently uncontrollable.
(Forced) prostitution and human trafficking take place in a parallel society in Germany. Even though the red-light district or street prostitution in a city is well-known to citizens, many areas and locations of the sex trade, such as hotel rooms or apartments, are not visible from the outside.
Advertisements on billboards might disappear, but clients are already active on many online platforms where women are advertised.

Swedish police officer Simon Häggström writes:

“I was in the prostitution unit for over 10 years, and prostitution is not hidden at all; we can find it. Just give me a phone, and I’ll show you where it is.”

In response to the argument that the rate of rape would increase if the purchase of sex were banned, proponents argue that this statement itself is sexist and discriminatory, as it implies that women in prostitution are more acceptable targets for rape. In reality, it is observed that where prostitution is legal, more women are raped. Clients rape eight times more often than men who do not buy sex. In countries where the Nordic Model is applied, the societal changes in mindset and attitudes lead to altered behavior from men, raising the threshold for sexual violence against women.

By decriminalizing prostitution, more women in prostitution gain trust in the police and the justice system, as they can now report clients as perpetrators and receive help and protection.

The Nordic Model - A Solution for Germany?

Based on the criticisms of the Nordic Model, it becomes clear that support and opposition to the model depend on one’s personal stance on prostitution. For those who are pro-prostitution and prefer to talk about sex work, the Nordic Model would represent a setback.

For those who view prostitution critically for various reasons, the Nordic Model could offer a way out of the current dire prostitution situation in Germany. However, the model itself is not a panacea. Its success can only be demonstrated if it is truly implemented, and if resources and means are made available to advance education, prevention, and awareness programs, as well as law enforcement. Police, the judiciary, and (social) offices and authorities must be trained. Financial support for actual exit programs for affected individuals must be included in new legislation so that the state invests resources and takes responsibility. If this does not happen, the current situation is unlikely to change, even if a new law is officially introduced.

That is why some advocate for an abolitionist model, which builds on the foundations of the Nordic Model but implements the above-mentioned demands.

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