The home page of the NPCC (the UK’s National Police Chiefs’ Council) says in bold letters that it is “Bringing UK police leaders together to set direction in policing and drive progress for the public”. Their About Us page explains that one of the NPCC’s roles is “National operational implementation of standards and policy as set by the College of Policing and Government”.
You would think that, as senior police officers, they would be meticulous in ensuring that everything they do conforms to the law. But it would seem they think this does not apply when it comes to equality law as it relates to women and girls. They seem to think it is perfectly acceptable to set national policy based on extremely partisan advice. It would seem they think that treating women and girls as commodities for sale is the natural order of things and not a gross violation of human rights. It would seem they think that nothing must disturb – or even mention – men’s de facto right to purchase women for sexual use and abuse, and that they are oblivious to how this, the cornerstone of the prostitution system, leads to ever more violence against women and girls generally and deepens the inequality between women and men.
This is certainly the impression we got from the NPCC’s latest national ‘sex work’ guidance. So much so, that we used the tagline: “Pandering to men and failing women” in the title of our response to it.
The NPCC introduced this new version of the guidance in response to a legal challenge brought by Not Buying It into the legality of the previous version – in particular that it did not comply with equality law and had not been consulted on. In response, the NPCC ran a consultation (you can read our submission to it here) and issued this new version of the guidance. They’ve added a considerable amount of material about the nature of what they still call “sex work” and how it affects the mainly women involved. This is of course welcome, but as the actual practical guidance remains more or less the same, it appears to be little more than window dressing.
The unspoken and unacknowledged idea that men must be allowed to pay women to use and abuse sexually continues to underly 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.
We found no evidence that the NPCC took any steps to ensure compliance with the Public Sector Equality Duty (PSED). This was introduced in the Equality Act 2010 and means that when public bodies, including the police, develop and evaluate policies, they must consider the impact of those policies on a variety of equality strands, including having “due regard” to the need: to eliminate unlawful harassment of women and girls by men; to advance equality of opportunity between women and men; and to foster good relations between women and men.
The guidance is not radically new but is an evolution on the three previous versions – those released in 2015, 2019, and 2023. We know that the NPCC took few if any steps to ensure compliance with the PSED when developing these previous versions. Freedom of Information (FOI) requests about the 2015 and 2019 versions revealed that they took no steps to conform with the PSED in 2015 and 2019, and our analysis of the 2023 version shows it’s extremely unlikely that they did in 2023 either.
We therefore submitted a new FOI request about the new 2025 version.
The first response was curious. They explained there would be a delay, which they justified as follows:
“Section 31 Law Enforcement
By virtue of Section 31 (1)(a)(b) where public authorities have to
consider the balance of the public interest in relation to a request, they
do not have to comply with the request until such times as is reasonable
in the circumstances.This is a qualified exemption and there is a requirement to conduct a
public interest test. I am obliged to consult with all stakeholders who
may be affected by me complying with your request.”
We are not convinced that this applies to national guidance rather than requests about ongoing operational enforcement operations. But they eventually responded more fully – but again curiously. This is an extract of the response:
“The NPCC does not hold a written record of all steps taken/conducted in the formation of this guidance.
However in wishing to be helpful, outside of the Freedom of Information Act I can provide the following information relevant to your questions.
In relation to questions 1 -5, a detailed Equality Impact Assessment (EIA) was completed by the NPCC Sex Work Portfolio as part of the formation of this guidance.
The purpose of an Equality Impact Assessment (EIA) is to use an evidence-based approach designed to evaluate the potential impact of policies, practices or services on different groups within society to ensure fairness and prevent discrimination.
As part of this EIA, there is evidence of Public Sector Equality Duty (PSED) compliance including assessing the impact of the guidance on protected groups, specifically including women, girls and children.
I have attached a copy of the EIA to this response letter.
Additionally I have been able to extract relevant information from minutes of NPCC Sex Work Working Group meetings where the guidance was referenced as well as a relevant VKPP Consultation on Sex Work Guidance Presentation. They are also attached to this letter.
Although provided outside of the Act, I have annotated the documents where redactions would have occurred if released under the legislation. Please note however that information released as a gesture of good will has no route for complaint under the legislation.”
Here are links to the attachments:
- Equality impact assessment: NPCC Sex Work Guidance
- Sex Work Working Group Minutes
- VKPP Consultation on Sex Work Guidance Presentation
We do not understand why this was released “outside of the [Freedom of Information] Act” – because it looks to us that what they released is a record of the action they took in relation to the PSED for the new guidance – essentially creating the EIA. However, the EIA only looks at the impact of the guidance that had already been formulated on people with the various protected characteristics who are already involved in prostitution. It does not consider the wider implications of the guidance on, for example, women and girls in the general community and the relationship between men and women in wider society generally. And there was no reconsideration of the general thrust of the guidance and its practical advice – only of minor “mitigating action”, which mostly consists of the need to work with specialist support services and for training around people with protected characteristics”. The minutes would appear to confirm this.
The Equality and Human Rights Commission (EHRC), which is tasked with enforcing the PSED, provides comprehensive technical guidance for public bodies on implementing the PSED. On page 23, it says:
“A body subject to the duty cannot satisfy the duty by justifying a decision after it has been taken. Attempts to justify a decision as being consistent with the exercise of the duty when it was not, in fact, considered before the decision are not enough to discharge the duty. […] The duty must be exercised in substance, with rigour and with an open mind in such a way that it influences the final decision. The duty has to be integrated within the discharge of the public functions of the body subject to the duty. It is not a question of ‘ticking boxes’.”
As the practical guidance in the new version is more or less unchanged from the previous version, and there is no evidence that the NPCC took steps to ensure previous versions of the guidance complied with the PSED, it would appear that what the NPCC did is exactly what the EHRC is warning against in this excerpt.
We explained in considerable detail in our submission to their consultation why to comply with the PSED, they needed to look at the impact of the guidance on wider society in addition to those directly involved in the industry for a variety of reasons. For example, we explained that:
- There is a considerable body of research that shows that men’s prostitution use is associated with sexual misconduct, domestic violence and rape – meaning that when prostitution is given free rein, there is inevitably more violence against women and girls in the general community and a deterioration in the general relationships between women and men in society.
- There is also considerable evidence that unrestricted street prostitution and a proliferation of brothels in a community leads to the environment becoming increasing hostile for all the women and girls in that community, with higher levels of male harassment of women and girls in the local streets.
- When prostitution is legitimised, it sends out a message to all men and boys that it is acceptable to treat women as commodities for their use and abuse – meaning that there is a general deterioration in the status of all women in society.
- When pimping offences are not enforced, the police effectively abandon women in what are often intolerable situations from which escape is impossible, and this contravenes binding obligations under international treaties, including those addressing trafficking and torture.
We showed that, thanks in large part to the earlier versions of the guidance, there had been a collapse in prosecutions for kerb crawling, paying for sex with someone who has been coerced, pimping, and brothel keeping. This is a clear indication that the previous versions of the guidance have led to a situation where sex buying, pimping and brothel keeping have effectively been decriminalised in England and Wales. It is no surprise therefore that rates of male violence against women and girls have gone through the roof since the 2015 version of the guidance was introduced (although there are obviously other factors involved, including the proliferation of violent and misogynistic online porn).
We also explained obligations under international law, including requirements under CEDAW Article 6 to crack down on pimping and under the Palermo Protocol Article 9 to take measures to reduce men’s demand for prostitution. It seems they totally ignore this too.
We provided evidence for everything we said, but it seems that the NPCC did not listen to us. It is as if they are a law unto themselves, with no obligation to act dispassionately and to listen carefully to all sides of a debate or to follow binding equality legislation. All the evidence suggests that they have been thoroughly captured by lobbyists for the sex industry and the prioritisation of men’s de facto right to pay to use and abuse women sexually and for the police to facilitate this as much as possible.
We are considering what steps to take next in an attempt to address this situation and hold the police to account.
10 February 2026: We are not able to report a favourable outcome to our efforts to hold the police to account over this. We wrote to the EHRC to report the lack of compliance with the PSED. While the response was helpful, it is clear that the EHRC is under-resourced and is unlikely to be able to take decisive action.