Opponents of the Nordic Model often claim that it pushes prostitution underground. They say that because buying sex is illegal under the Nordic Model, punters (sex buyers) are more anxious and so women have less time to assess and negotiate with them and there are fewer options for screening punters. As a result, they say, prostitution moves to more marginal and isolated locations and puts the women at increased risk.

These claims can be persuasive – after all, no one wants the women involved to face more danger. But are they true? To examine this, we’ll look at the issues from various angles and show that once again these claims don’t stand up to scrutiny.

Punter anonymity is already sacrosanct in the sex industry

On 19 November 2025, Siobhian Brown, Scottish Minister for Victims and Community Safety, spoke on behalf of the Scottish Government to the Criminal Justice Committee in the Scottish Parliament about the Prostitution, Offences and Support (Scotland) Bill. This Bill was introduced by Ash Regan MSP as a private members bill and is colloquially known as the ‘Unbuyable’ Bill. If passed, it would introduce the Nordic Model in Scotland.

The Minister expressed concern that it would make women involved in prostitution less safe. When pressed for detail, she said:

“One reason is that women who currently choose to be involved in prostitution and have clients come to their house can have security in place, so that they can get the client’s identification, passport, credit cards and so on.”

The implication left hanging in the air is that none of this “security” could exist once purchasing sex became a criminal offence. But in reality in the UK, such security checks rarely, if ever, happen. What the Minister actually revealed was how ill-informed she is about how the prostitution system actually works in practice.

I asked the women in our network who have survived prostitution if they or “security” had ever checked punters’ passports or credit cards before they went ahead with the arrangement. They were unanimous. Even in a brothel, they said, the payments were always made in cash and ID checks were never conducted. For example, Venessa said:

“My experience was in Edinburgh, Scotland. I always dealt in cash, never card. 99% wouldn’t even use their real names, never mind show us their passports. Besides how is seeing someone’s passport or credit card going to stop an assault? If anything, it would just escalate the situation.

All the Minister needs to do is actually listen to the experience of survivors before conjuring up excuses for condoning prostitution.”

As for the presence of “security”, they suggested that what the Minister really meant was pimps. Pimps whose driving concern is to keep their gravy train rolling, not the wellbeing of “their” woman or women.

In the sex industry, punter anonymity is sacrosanct. Research into men who buy sex is clear that the vast majority would stop doing it if there was any threat to their anonymity. Most of them are married or in long-term relationships and have jobs and do not want their wives, partners, children or bosses to know what they do in their spare time. Some are politicians, lawyers, or successful businessmen with a public profile. They know that this would be in jeopardy if it came out that they pay to use marginalised individuals sexually – just as it was for Keith Vaz. The sex industry as a whole recognises this and goes to great lengths to protect punters’ anonymity.

The survivors I talked to pointed out that most punters seldom use their real names when arranging prostitution encounters and typically use burner phones and email addresses when making contact. When card payments are necessary, punters tend to use anonymous prepaid cards that are not linked to their bank accounts. This is in the UK, where men buying sex have more or less total legal impunity. It is absurd to suggest they are suddenly going to be anonymous if the law was changed, when in the vast majority of cases they already are anonymous.

There are also several reasons why many women involved in prostitution might not take card payments. For example, women who do not have legal immigration status are prevented from opening a bank account, making the use of card payments impossible. Many women in the UK are in prostitution because they are unable to make ends meet on Universal Credit and the threat of the Department for Work and Pensions (DWP) or HMRC accessing their bank account and seeing such payments would be a strong disincentive to taking card payments.

Prostitution advertising websites

A similar myth persists about prostitution advertising websites, like AdultWork and Vivastreet. People claim that they provide features that enable women to screen punters and that this would end under the Nordic Model and put women in more danger. But this is another example of ignorance of how the sex industry works in practice.

Many people assume that these websites work like Airbnb, where both parties have to provide photo ID when registering, that initial contact is restricted to registered users, and payments are made through the site – motivating both parties to behave well to avoid bad reviews or being banned from the service or reported to the police when things go wrong.

However, this is not how prostitution advertising websites work – because punter anonymity is sacrosanct. When advertisers register on these sites, they are required to provide photo ID of the women being advertised (although pimps often sell women behind someone else’s photo ID), but no photo ID is required to register as a punter. So, if a punter gets a bad review, he can just set up a new account using a fake name and email address, but the women being advertised cannot. This means that punters have no incentive to behave well and there is no audit trail enabling the site or the police to contact them easily when things go badly wrong.

Pimps and punters use this unequal system to their advantage. Punter reviews determine how much women can charge and how many punters they will attract. Punters use this to coerce women to engage in more painful and risky behaviour and to give discounted rates. Pimps use the reviews to control women, including serious reprisals for bad reviews. Independent punter forums (such as UK Punting) provide further opportunities for men to retaliate against women who do not please them. Sometimes they do this in groups, like a pack of hyenas.

Furthermore, many adverts on these sites are visible to anyone anywhere on the internet with no requirement that they register and log in. As adverts often carry a phone number, men make contact without any form of screening whatsoever.

These sites do not provide payment services for meeting in person for prostitution. Payment is made during the encounter, usually in cash or anonymous prepaid cards.

So far from providing measures that increase women’s safety, these sites already provide features that advantage pimps and punters and disadvantage the women involved. Suggesting that these sites provide robust screening services and protection for the women is nothing more than wishful thinking. Anyone who suggests they do provide safety is demonstrating their utter ignorance of how the prostitution system works in practice.

What the European Court of Human Rights said about prostitution in France

France introduced the Nordic Model in April 2016. A group of self-identified ‘sex workers’ subsequently took the French Government to court on the basis that it forced them to work in more dangerous situations (i.e. ‘underground’), putting their physical and mental health in danger and that it infringed their human rights to respect for their private life, personal autonomy and sexual freedom. They worked their way through the French courts, who each ruled against them, and eventually took their case to the European Court of Human Rights (ECHR).

In June 2023, after a lengthy and thorough examination of all the relevant facts, the ECHR unanimously ruled that there had been no violation of the applicants’ rights and they subsequently declined leave to appeal.

In the final judgement, the ECHR recognised the undeniable risks to which prostituted people are exposed but observed that the negative effects that the applicants claimed to have been caused by the Nordic Model had in fact existed before the law was introduced and were therefore likely to have other causes, including that these risks are inherent to prostitution itself.

The judgement also explained that the Nordic Model law “contributed to reversing the power balance between prostitutes and their clients, by positioning the former as victims and enabling them to report clients in the event of violence, since henceforth it was the client who would face prosecution”.

The court recognised that as well as measures to support persons moving away from prostitution, the Nordic Model law strengthened public policies to reduce health risks for the benefit of all prostituted people, through the introduction of special measures to improve access to support and general healthcare for persons who continued to engage in this activity, and by ensuring that they were not left to fend for themselves.

Sweden

We are in touch with a Swedish organisation called Intedinhora, which is made up of women who have experience of prostitution in Sweden and who strongly support the Swedish Nordic Model law. When we put the claim that the Nordic Model pushes prostitution underground to Lea, their representative, she responded by asking whether there is anywhere in the world where punters want to have sex in the open.

She said, “The law makes little difference in this regard because they don’t want their wife, girlfriend or employer to find out and anyway most people want to have sex in private. The fact that the meeting in some countries takes place in public areas doesn’t mean that the selling part is safer. Women get killed every year in those small cubicles in the red-light district in Amsterdam. And in Sweden we haven’t yet had one reported murder of a person in prostitution by a john since the sex buyer law was established in 1999.”

She said that the price of prostitution in Sweden is much higher than in European countries where the sex trade is condoned. “This makes the johns furious,” she said. “You can often see them talking in online forums about how the ‘hookers’ here in Sweden are ‘spoiled’ and how they wish it were more like Germany where prices are less than half what they are in Sweden. This means that we don’t have to see as many johns to survive and can say no when we’re uncomfortable.”

Cajsa, another Swedish prostitution survivor, echoed this when she was speaking at a UK conference. She talked about how upset it makes her that people claim that the Nordic Model hurts women, when she is absolutely clear that she owes her life to it. She debunked the myth that it is illegal to carry condoms in Sweden and talked more about the Nordic Model’s benefits:

“Under the Nordic Model, the men are more careful when buying sex. But for me, a key benefit was psychological – knowing that buying sex is wrong. If you want to, then OK, but the men shouldn’t see you as one. You should be offered help – and if you don’t need help, that’s fine.”

Sweden is now seen as a hostile destination by international sex traffickers.

Prices

As Lea explained, women in Sweden are able to charge considerably more than women in other European countries where prostitution is tolerated.

As a rule of thumb, any liberalisation of prostitution law and policy, expands the size of the industry and lowers prices. Lower prices mean that women have to engage with more punters and are under more pressure to engage in more unpleasant, risky, and dangerous behaviour. Prostitution is not unique in this – it is a well-known economic principle that expanding supply tends to reduce prices. Even research that argues for decriminalisation confirms this.

The Nordic Model, when well implemented, has the opposite effect because it tends to reduce the numbers of women involved (the ‘supply’). As punters are the source of most of the risks, needing to see fewer punters for the same financial benefit would reduce the statistical risk to which each woman is exposed – in direct contradiction of the claim that the Nordic Model makes it more dangerous.

More isolated and dangerous?

From October 2014 until June 2021, an area of Holbeck in Leeds was designated a decriminalised prostitution zone. The same people who argue that the Nordic Model drives prostitution underground claimed that this decriminalised zone would make women safer. I visited the zone one Friday night in August 2019 and found that far from being the safe and friendly environment that supporters claimed, it was a dark, isolated and lonely light industrial area with almost all the buildings closed for the night or derelict and there were no public toilets or washing facilities.

I took the above photo. If you look carefully, you can see a woman standing under a street light on the left side of the road in the distance. She was soliciting to sell sex. Her pimp was waiting in the shadows on the opposite side of the road (not visible in the photo) – not to provide her with ‘security’ but to ensure that she did not abscond with her earnings.

Most punters were in cars and when they drew up, the women would hop in almost immediately. There didn’t seem to be much assessment or negotiation going on. The car would then take off to some lonely carpark or turning where the act would take place.

One woman was murdered by a punter in the first few months of the zone’s operation. There were numerous rapes and several attempted murders over the years, and local women reported relentless harassment from the kerb crawlers, day and night. Yet the zone was trumpeted a success and many other local councils and police forces showed interest in following suit.

However, the local residents, who were mostly on low and modest incomes, saw the truth and the hypocrisy of the local officials. They could see that the women selling sex were either addicted to Class A drugs and were desperately trying to get money for their next fix or they were under the control of brutal pimps, including some Romanian men who brought groups of women to the scheme in a van. It was as clear as day that the women were being driven by forces outside their control and were not making a positive and informed choice to be there. What they needed was drug rehabilitation and their pimps locking up.

The local residents campaigned tirelessly against the zone for years and for it to be replaced with something similar to the Nordic Model-inspired scheme introduced in Ipswich after a punter murdered five women there. They wanted the police to crack down on the punters and pimps and the authorities to provide the women with genuine assistance to leave the industry, including drug rehabilitation and means to safely escape their pimps. Their hard work and persistence were rewarded when the scheme was eventually closed down, although this did not end street prostitution in the area. But at least it dampened the official cognitive dissonance that prostitution can be safe and men must be enabled to pay to use and abuse desperate women.

The cheerleaders of the scheme were undeterred and announced that they were “very disappointed” at the scheme’s closure and were “firmly of the view” that it was “the best way of providing as much safety as possible to sex workers who work on street”. They also claim that the Nordic Model drives prostitution underground and is more dangerous than full decriminalisation, which they campaign for. These are people who are willing to publicly defend a scheme that very clearly puts desperate women at enormous risk rather than challenge men’s de facto right to pay to use and abuse women sexually.

Some local campaigners found this hypocrisy particularly hard to forgive and for the rest of us, it should be a cautionary tale about the motives of those who claim that the Nordic Model forces prostitution underground. It certainly makes me wonder why the cheerleaders of the scheme would be so against the Nordic Model, which attempts to reduce the size of the industry by cracking down on punters and pimps and giving women trapped in it genuine routes out, that they would suggest that it drives prostitution underground when the scheme they backed led to a large increase in the numbers of punters frequenting prostitution, enormous and unforgivable dangers to the women involved in circumstances that it’s hard to imagine could get much worse.

The truth is that prostitution is always dangerous for the women involved and nothing can reduce those dangers to a level that would be acceptable in a regular workplace.

Ipswich

A Nordic Model-style approach to tackling prostitution was implemented in Ipswich after a series of brutal murders of prostituted women in the town.

The police had video evidence from before the scheme when street prostitution was widely tolerated and after the scheme was introduced, when the police used number plate recognition software to operate a zero-tolerance policy towards kerb crawling. The videos show there was no apparent change in behaviour. When a car drew up before the scheme, just as I witnessed in Holbeck, the woman would get in more or less immediately. She did not spend any significant lengths of time assessing the punter and negotiating with him. And this did not change after the scheme was introduced.

This suggests that the idea that women involved in street prostitution routinely spend significant amounts of time assessing and negotiating with punters before committing to the transaction is yet another misconception.

The University of East Anglia (UEA) was commissioned to conduct an independent evaluation of the scheme and they assessed it as successful and cost effective. In fact, they said that every pound spent on the strategy saved the public purse two pounds – because of lower criminal justice and social support costs.

Switzerland

Switzerland provides further evidence that counters the myth that the Nordic Model drives prostitution underground. During the Covid lockdown period, buying sex was prohibited. Government-backed data demonstrates that there was no decrease in trafficking referrals, victim identification or assistance during this period – which would not be true if the ban had pushed prostitution underground. Furthermore a 2022 study, which alleged increased vulnerability of prostituted women during the lockdown period, in fact proved the opposite. They found no increase in violence, although the usual pressure for unprotected sex persisted – a problem that has existed for decades.

Does the corollary hold true – that legalising prostitution brings the underground industry to an end?

Germany’s legalised prostitution system now requires women to register with public officials. The German government, whose efficiency is world renowned, keeps records of the numbers of workers in all its various industries – with one exception. The prostitution industry. As a result, there is no reliable data on the numbers of women involved in it. Estimates range from about 90,000 to 400,000, but in 2024 only about 32,300 of these women were registered as they are now required to do by law. In other words, the vast majority of women involved in prostitution in Germany are operating “underground” of the official system.

Clearly a majority of these women prefer not to be registered. There are many reasons for this, some of which we will look at in a moment.

The fact that legalised prostitution models tend to lead to a two-tier system with one tier being legal and the other “underground” is one of the reasons that some people lobby for full decriminalisation, which they say doesn’t have this problem. Before we go on to look at full decriminalisation, first let’s consider the legal, “above ground” brothels in Germany.

Germany’s prostitution industry thrives under its legalised model. Megabrothels cater for up to 1,000 men simultaneously and more than a million men are estimated to pay for sex every single day.

Ellen Templin, a dominatrix, explains how the liberalisation of the law changed things:

“Since the [2002] reform, adverts are more uninhibited, buyers more brutal. Now, if you say, ‘I don’t do that,’ they say, ‘Come on; don’t be so difficult, it’s your job.’

“Before, it was forbidden to demand unprotected sex. Now, they want to piss on your face, do it without protection, do it anally or orally. Before, buyers still had a guilty conscience. That doesn’t exist anymore.”

Two journalists who undertook an in-depth study of the German prostitution system, concluded that the intention to improve the position of the women through legalisation has in fact achieved the opposite.

“Women have become a resource, to be used as efficiently as possible for profit.”

A police inspector says the law has made Germany an Eldorado for traffickers, pimps and brothel owners. The huge scale of the industry has made it more or less impossible for the police to hold more than a tiny minority of exploiters to account. The European Union’s law enforcement agency Europol is clear that legalised prostitution incentivises human trafficking for the purpose of sexual exploitation and notes that, where prostitution is legal, trafficking in human beings and violence perpetrated against its victims and other people in prostitution increases tenfold, as perpetrators can hide behind legal structures.

Changes to the law introduced in 2017 with the aim of ameliorating some of the worst excesses has led to few if any tangible benefits for the women because most of the measures are aimed at them and not the pimps and punters. The main impact has been that the industry is increasingly concentrated in large brothels and chains of brothels, making profits for the brothel operators even easier and larger, while the conditions remain, as Dr Ingeborg Kraus reports, “hell on earth”.

This reality of legal prostitution again calls into question the sincerity of the lobbyists who claim that the Nordic Model pushes prostitution underground. Both the “overground” and the “underground” parts of the prostitution system in Germany are grim beyond comprehension. The real lesson is surely that prostitution is simply incompatible with modern democratic social norms and the solution must be focused on a pathway to closing the industry, providing genuine transitions out for those caught up in it, educating the male population that this behaviour is unacceptable, and when all else fails, penalising both punters and pimps of all kinds. This is exactly what the Nordic Model aims to do.

Why women might not want to be registered

Many, perhaps most, women who are involved in prostitution see it as a temporary solution to a crisis situation and not as a long-term career. It should be no surprise therefore that so few of them want to register with state authorities in Germany, especially given the negative consequences that women often face once their involvement is known. Consequences such as difficulty in securing alternative paid work, harassment and worse from men who consider them to be ‘fair game’, being blacklisted by landlords when seeking accommodation, and being blamed for their own difficulties by health and social workers, and officials of all kinds. These are all factors that work together to make it difficult for women to exit prostitution and are present in most countries, including the UK.

There are specific groups of women whose particular circumstances lead to additional issues. For example, women with insecure immigration status might be at risk of deportation if state agencies become aware of them – meaning they will have even more motivation to not register or alert the authorities in other ways to their involvement in prostitution. This risk is not connected with the Nordic Model.

Similarly, women who are in receipt of means-tested benefits are likely to be subject to penalties including loss of benefits or even prosecution for benefit fraud if the authorities become aware of their prostitution related income. Others may be keen to slip under the radar of the tax authorities.

Full decriminalisation or legalisation of prostitution has not been accompanied by liberalisation of immigration laws or changes to tax and benefit rules. States within the European Union (EU) are bound to uphold measures relating to migration from countries outside the EU.

What about full decriminalisation?

Sex industry lobbyists like to suggest that full decriminalisation is very different from legalisation and that it therefore does not have the problems that are seen in Germany, the Netherlands and Switzerland, for example.

Frankie Miren, a campaigner for full decriminalisation describes the difference between legalisation and decriminalisation like this:

“Under legalisation, sex work is controlled by the government and is legal only under certain state-specified conditions. Decriminalisation involves the removal of all prostitution-specific laws, although sex workers and sex work businesses must still operate within the laws of the land, as must any businesses.”

However, in practice there are many similarities. As we have touched on above, this is not surprising because of the logic of the sex industry and the interactions with immigration law, social security, tax legislation, and so on.

New Zealand introduced full decriminalisation in 2003 and it is one of the very few places that have had full decriminalisation for any length of time. Lobbyists claim that it has made women safer, however, the evidence in the New Zealand government’s own reviews says otherwise.

Testimony from survivors backs this up. For example, Michelle Mara who was in prostitution in New Zealand both before and after the transition, explains that after decriminalisation:

“I felt less safe. I didn’t know what it was at the time. But looking back it was a shift in the structure. More responsibility was on us. We were responsible for money related transactions now which messed with the illusion. It also meant a power struggle in the room. Before it was more ‘our’ domain. Walk in, walk out. Now that the money touched hands it felt like an anchor. They saw themselves buy our silence as well as our bodies. […]

They expected more. I worked at the most expensive place in Wellington by then – always by appointment. These men saw us as objects and we knew it. And they knew we knew. […]

Now we were shameful commodities that they legally bought. We both knew it.”

Chelsea Geddes, who started in prostitution shortly before decriminalisation was introduced and remained trapped in the industry for about two decades, backs up everything Michelle says. Chelsea has spoken extensively about how decriminalisation works in practice: about how it hasn’t improved their safety, about the myth that they have employee rights, about the police disinterest in following up assaults by punters and pimps, and the corruption of the entire system. We particularly recommend the following:

What might full decriminalisation look like in the UK?

Poverty is a major factor in the backgrounds of most women involved in prostitution. In the UK women, particularly single mothers, have been disproportionately affected by cuts in benefits and public spending since 2010 and more recently, the “cost of living” crisis. There has been a significant increase in the number of women becoming involved in prostitution as “survival sex” to supplement low wages or income from benefits.

If full decriminalisation of prostitution were implemented in the UK so that brothels were treated in the same way as other legitimate businesses, brothel-owners’ accounts of payments by identifiable women for the use of their rooms might be accessible by HMRC.

If women have become involved in prostitution to supplement inadequate benefit payments, which is very common, they won’t want this information shared with HMRC, as the DWP may then become aware of their additional income and they would risk benefit sanctions or prosecution for fraud.

They would therefore likely be involved in street prostitution or outside the “fully decriminalised” system because otherwise they would risk being criminalised for benefit fraud.  As such, they would be part of an “underground”. This risk will not change under full decriminalisation because the risks are not related to prostitution per se.

It is not the Nordic Model that creates the “underground” sex industry. Full decriminalisation would increase the size of the “underground” in the UK because the consequent massive increase in demand would be followed by a huge increase in the number of women being drawn into prostitution and most of these women will be in precarious situations which necessitate being “off the books”.

Conclusion

As the ECHR found, prostitution is inherently dangerous and fraught with risk. The idea that legalising or decriminalising it would make the women safer might sound appealing, but it is just an idea. Ideas alone do not change the reality.

Evidence from Germany, Belgium, the Netherlands, Australia, and New Zealand shows that legalising or decriminalising prostitution does not change the brutal reality for the women involved. The main practical impact is that it enshrines men’s right to use and abuse (mainly) women as sexual commodities and third parties’ right to profit from this obscene trade – and this always leads to an increase in the size of the industry. The impact on society is incalculable and comes with a very high economic and social cost.

This begs the question of why there is such hostility to the Nordic Model, the only legislative approach that recognises prostitution’s intrinsic harms and that aims to change men’s behaviour and reduce the size of the industry while giving those caught up in it a viable transition out.

This enduring hostility and the multitude of unsubstantiated claims about the Nordic Model’s supposed harms suggest that prostitution has a profound role in maintaining social and economic inequality and preserving the unfair advantages of those who already hold power at the expense of those with less power. This is why such financially and politically powerful vested interests are stacked against any measures that would weaken prostitution’s inherently harmful function.

We like to believe that we live in a modern democratic society that upholds the inherent dignity and inalienable rights of everyone equally. Prostitution’s persistence and the reluctance of those with power to seriously challenge it is evidence that we are in fact a long way from realising the human rights and potential of women and girls and other marginalised populations. Implementing the Nordic Model would be a bold and courageous first step to addressing this.

But what about the studies that show the Nordic Model is more dangerous?

Further reading

This page was first published on 31 December 2025.

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