by NMN
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The updated NPCC ‘Sex Work National Police Guidance’: Pandering to men and failing women

The UK National Police Chiefs’ Council (NPCC) has issued a new version of its “Sex Work National Police Guidance”, dated April 2025.

The previous version was issued in June 2023. We responded, welcoming the news that police officers and staff are now banned from paying for sex, but criticizing the NPCC’s choice of terminology and focus on unrealistic notions of “sex worker” safety and building an “intelligence picture” rather than on preventing and enforcing the law against pimping, brothel-keeping, kerb crawling, and paying for sex with someone who has been coerced.

Later in 2023, Not Buying It initiated a challenge to the legality of the guidance and in response, the NPCC ran a consultation. This was not widely publicised, but we were issued with a private invitation to respond. Our response ran to 30 pages and covered numerous angles, including obligations under the Public Sector Equality Duty (PSED) and international law.

We are dismayed to find that apart from some fairly superficial changes, the guidance is largely unchanged.

Window dressing

The Foreword no longer claims that “sex working is not a violence against women and girls (VAWG) issue”. Instead it says: “Whether or not sex working should be considered a form of violence against VAWG per se is contested and nuanced.” So at least it acknowledges that there is a difference of opinion, although the way it is discussed clearly suggests on which side the NPCC’s views fall.

Many of the other changes are similar. For example, there’s a new introduction to the Guiding Principles section, recognising the polarised views and “complexities” involved. It then goes on to say the guidance: “seeks to simplify these issues to provide practical, frontline guidance for police officers and staff. The primary aim for policing should be to safeguard vulnerable individuals who need protection while also effectively tackling those who cause harm.” (Emphasis added.)

This might sound great in theory, but how exactly does a police officer “safeguard” a woman involved in the most dangerous occupation in the Western world? Just like previous versions, the new guidance is extremely slim on what exactly a police officer can do to make such a woman safe. If the officer suspects sex trafficking, it says she should be referred to the National Referral Mechanism (NRM). But the guidance considers only a minority of “sex workers” to be trafficked. So what is the poor police officer supposed to do for all the others to keep them safe? And is it even possible? We don’t think so. That is why we advocate for the Nordic Model, which seeks to reduce the size of the industry, deter men from paying for sex, and give those involved genuine routes out and alternatives.

The Terminology section has been expanded with a new introduction that explains that they use the “sex work” term “for clarity” and that this “choice does not imply alignment with any ideological stance”. This assertion might be more convincing if it didn’t go on to explain that the term “respects the autonomy of individuals who engage in selling sexual services” and that it “aligns with the terminology used by many organisations.” The “sex work” terminology is emblematic of the ideological divide and aligning itself with organisations who use it and not with those who repudiate it, makes the NPCC’s ideological position unambiguous.

We are absolutely clear that no one should be criminalised for their own prostitution, and we appreciate the guidance to treat the women involved with respect and not to prosecute them for loitering and soliciting or brothel keeping. But this doesn’t mean we have to use the “sex work” terminology.

The “sex work” terminology is loathed by many survivors of prostitution. It suggests that prostitution is a normal job, not much different from being a barista for example; a neutral activity that is of no concern of anyone else. This grooms young women as fodder for the industry and young men into thinking that buying sex is no different from paying for a haircut. The fact that the NPCC needs to put out a 76-page guidance document about policing prostitution when it doesn’t even need one-page of guidance on policing coffee and barber shops gives the lie to this. Prostitution is not a normal job.

The list of recommended terminology is unchanged. It decries describing prostitution advertising websites as “pimping websites” because: “Likening websites to ‘pimps’ or directly linking them to sexual exploitation implies deliberate involvement in trafficking and suggests that they are solely engaged in advertising linked to trafficking, which has not been evidenced”.

But this is not true. According to the Cambridge English Dictionary, pimping involves “getting customers for prostitutes” – which pretty much sums up what these websites do. To demand that this should not be articulated implies that the NPCC wants the basic realities of the prostitution industry to be covered up, including that third parties (pimps) can make vast amounts of money off the backs of the suffering of the women directly involved. This again, reveals the NPCC’s biased ideological position.

There are some welcome additions to the “Nature of Sex Work” section, but like most of the other changes, we can but see them as window dressing, when there are no substantive changes to the practical guidance. A new “Pathways and influences leading to sex work” subsection explains some of the factors that lead people into prostitution, including financial pressures, “survival sex”, alcohol and substance abuse, trauma and adverse childhood experiences, domestic abuse, and the normalisation of the sex industry.

A new “Experiences of those selling sex” subsection sets out: how mental health problems are common among those who sell sex and how this is closely linked to experiences of violence and stigma; how many kinds of violence and abuse are prevalent; that interaction with the police is often negative; and stigma can make it difficult to exit.

And yet this does not appear to give the NPCC pause to wonder why men should be enabled to pay for sex with desperate women trapped in what they themselves describe as a dangerous situation from which it is hard to escape. Nor whether their description of it as a form of “work” is appropriate. Nor what “autonomy” and “consent” mean in this context.

Total silence on deterring sex buyers

The unspoken and unacknowledged idea that men must be allowed to pay women for sex underlies the entire guidance. Even though their description of how women get into prostitution, the violence that is common in it, and the difficulty in exiting all give the lie to the idea that paying for sex is just normal sex between consenting adults.

Men who want truly consensual sex with a willing partner do not pay for it and do not inflict the forms of violence the guidance describes as common in prostitution. Men pay for sex because they want it with someone they can control and sometimes also inflict violence on.

Nowhere does the guidance recommend making full use of the two offences under the law in England and Wales that can be used to deter men from buying sex – the kerb crawling law and the law against paying for sex from someone who has been coerced. These offences are mentioned, but there is no guidance on how to use them. The implicit message is therefore that they should not be used.

Brothels

Similarly there is no mention of how to take action against brothels. Instead the guidance suggests that brothels should be allowed to operate freely.

Like the previous version, the guidance incorrectly lists Section 33A (Keeping a brothel used for prostitution) under an introduction to summary-only offences for which the police have full discretion on how to respond. In fact it is an indictable offence for which the police do not in fact have such discretion. But rather than providing guidance for enforcing it, the guidance says:

“Community concerns and complaints may focus neighbourhood teams on a brothel. If a location is being used as a brothel and is the cause of anti-social behaviour, there may be less intrusive ways to tackle this type of complaint. Interacting sensitively with the occupants may immediately address community concerns.”

This not only ignores the plight of the women trapped in the brothel, but also totally ignores the very real problems that brothels can cause to people, particularly women and children, in the local area, and that in residential areas, brothels violate planning laws. It also ignores how brothels increase men’s demand for prostitution. Of course seeing brothels operating in plain sight makes it more likely that men will use them than if there were no brothels. The NPCC would do well to remember that the UK has a binding obligation under international law to reduce men’s demand for prostitution.

That the guidance does not even mention legislation in the Sexual Offences Act 2003 that makes provision for closing brothels, let alone how to use it, is further evidence that enabling men to buy sex is the unspoken priority.

There is, however, considerable focus on the police conducting “welfare visits” in brothels, with the “primary aim of safeguarding and fostering trust within the sex-working community”. This is pure hubris.

As we explained in our response to the consultation, women who are actively involved in prostitution typically defend it vigorously. Just as women trapped in domestic abuse situations are unlikely to admit, especially to a stranger, the reality of what is happening to them, women in brothels are unlikely to open up about the reality of their situation to a visiting police officer. To survive intolerable situations, you often have to deny the reality. It is only after escaping and reaching a place of safety and having time to reflect, that most women are in a position to articulate the reality of the abuse they suffered, and even then, they are unlikely to tell a total stranger.

So quite what the NPCC think police officers are going to achieve in these recommended “welfare visits” is anyone’s guess. And how do they expect officers to “safeguard” the women? There is absolutely no information about how to do this other than working with specialist services. This begs the question of why not leave the specialist services to get on with helping the women, while the police focus on enforcing the law against third parties and sex buyers?

There is a real risk that by conducting “welfare visits” in brothels while not taking any form of enforcement action against the brothel keepers or the brothel itself, the police are intrinsically giving a message of tolerance, which could undermine future prosecutions and closure orders.

Pimping websites

The previous guidance described ASWs (i.e. pimping websites) as “partners”. For example, it said “UK policing and its law enforcement partners are committed to working with ASWs as a key partner to make the industry safer, spot exploitation and increase good practice”. (Emphasis added.)

This has now been replaced with the following: “Police will actively engage and work alongside Adult Services Websites (ASWs) as part of their strategy to combat and prevent exploitation and trafficking. This engagement is seen as essential for safeguarding vulnerable individuals”.

There is no subsequent mention of these websites being “partners”. But working alongside each other for a common purpose sounds like a partnership to me. Regardless how the NPCC describe this relationship, we question whether it is ethical, given that these websites are key enablers of pimping and sex trafficking of women and children, and thus arguably in breach of the law.

The guidance goes on to repeat claims made in the previous version that some of these websites “have very robust measures to ensure the person advertised is an adult and not exploited”.

We have written quite extensively about how this is nonsense – pimps frequently sell women and even children behind a profile based on someone else’s ID – as is the idea that these websites provide robust mechanisms for screening clients. But the guidance persists in these misconceptions, along with the flawed idea that you can easily distinguish the profile of a woman who is being coerced from one who is fully “autonomous”.

Equality and international law

There is no evidence that the NPCC took any steps to ensure that the guidance complies with the Public Sector Equality Duty. In our submission to their consultation, we wrote at some length about this and why they need to consider the impact of, for example, brothels and kerb crawling on women and children in the wider community, and the general impact of the guidance on relationships between men and women.

Similarly, there is no evidence that the NPCC considered the UK’s binding obligations under international law. For example, Article 6 of CEDAW requires states to “suppress” third parties profiting from women’s prostitution. It’s hard to see how their laissez-faire approach to both brothels and pimping websites complies with this.

Article 9 of the Palermo Protocol requires states to “discourage the demand that fosters all forms of exploitation of persons, especially women and children, that leads to trafficking”. It is hard to see how the guidance’s prioritising of not challenging men paying for sex acts complies with this.

We have submitted a freedom of information (FOI) request about the steps they took to comply with the PSED, CEDAW and the Palermo Protocol. We have now written about the response we got.

Conclusion

It appears that Not Buying It’s legal challenge to the last version of the guidance made the NPCC realise that they need to make some changes to avoid challenges to its bias. But instead of going back to the drawing board and rethinking the guidance from scratch, they seem to have simply made some superficial changes in the hope that this would deflect any criticism, while almost all the substantive advice remains fundamentally unchanged. As a result, most of the problems that we addressed in our reviews of the previous two versions (see here and here) remain.

Our concerns are focused on the shallow understanding of how the sex industry works and its impact on the wider community, the idea that the police can successfully “safeguard” women who are involved in prostitution, the partnering with pimping websites, and the emphasis on lack of enforcement of the legislation against brothels, pimps, and sex buyers. As we said before, we would go as far as to suggest that this guidance goes both beyond the law that has been democratically passed by Parliament and the legitimate role of the police.

The Foreword states that resources are finite and demand exceeds the police’s capacity to respond. As such, it goes on, “there is a need to prioritise and focus efforts on tackling the highest harm offences”. But this underestimates the amount of harm that prostitution causes to both individuals and communities.

The contrast with the official strategy against drug crime set out in the Serious and Organised Crime Strategy is stark. While overall this prioritises the top of the criminal chain, it recognises the need to attack the drug supply chain at every level and to tackle the middle market of the drug supply, in recognition of the immense harm that drug crime causes to communities. Given that prostitution also causes immense harm to individuals and communities, we do not believe there is any justification for not taking a similar approach to the prostitution industry.

The idea that resourcing issues is the reason for the NPCC decision not to enforce the law on brothels, pimping websites and kerb crawlers for example, is far fetched given that eye watering amounts of police resources are spent on arresting people who post “offensive” messages on social media – more than 30 a day according to a recent report. That’s more than twice as many as the number of pimps prosecuted in a year on average over the five years to 2022. (And yes, we are aware that arrests are not the same as prosecutions. But even so…)

Evidence is now compelling that men who pay for sex are more prone to commit rape and other sexual misconduct against women and girls in the wider community. The Government has no hope of achieving its commitment to halve male violence against women and girls if the police continue along these same lines.

We fear that the real problem is the capture of the NPCC and most other key UK institutions by lobbyists for the expansion of the sex industry. The capture is so complete that policy makers are simply unable to even hear other viewpoints, let alone consider whether they might have value.

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