
Scotland for Decrim responded to the Criminal Justice Committee’s call for views on the Prostitution (Offences and Support) (Scotland) Bill. We are publishing our full response below, so you are able to see our evidenced reasons for opposing this dangerous proposed legislation.
1. The Bill proposes to create a new offence of paying for the performance of a sexual act by a person. The Bill (at section 1) includes details of the circumstances in which an offence would be committed. The Bill (at section 9) includes a definition of “a sexual act”. The Bill states that activities such as striptease, pole dancing, lap dancing, or other erotic performances are not included in the definition of a “sexual act”. What are your views on this proposal?
Scotland for Decrim is a sex worker-led grassroots organisation dedicated to fighting for the full decriminalisation of sex work. We strongly oppose the criminalisation of paying for the performance of a sexual act, a legislative model which is often known as the Nordic Model. This model is also opposed by NUMbrella Lane, a sex worker support organisation based in Glasgow, and every sex worker-led organisation around the UK.
As a sex worker-led organisation, we speak for the people who will actually be affected by the implementation of this law. We strongly urge the Committee to recommend that this Bill does not become law. No one currently selling sex was involved in the development of this bill. It is unthinkable in our current day and age to exclude the people who will be most affected by legislation from the creation of it. This does not fit the Scottish Parliament’s ethos as the people’s parliament.
Criminalising clients puts sex workers in danger
The criminalisation of clients would have an extremely negative impact on sex workers’ ability to keep ourselves safe. We would be less able to screen potential clients by asking for their identification details in order to check them against a list of dangerous clients, or by asking for a deposit before confirming a booking to enable us to see a client’s full name and have a record of the booking, as clients would be unwilling to give these personal details for fear of being criminalised. Apps which enable sex workers to screen clients against a bad client list may no longer be hosted by app stores or made available online, as they could be seen as ‘facilitating prostitution’.
At the same time, this proposed bill does not seek to decriminalise ‘brothel-keeping’. The legal definition of brothel-keeping includes any premises where two or more sex workers are working, even at different times. Not permitting sex workers to legally work together indoors has the effect of making sex workers more isolated, and more vulnerable to potential violence. We are aware of cases where clients have been abusive, but the sex workers involved were unable to call the police for help, as the clients stated that they knew that if the police were called the sex workers would be at risk of arrest for brothel-keeping. Dangerous clients should not be emboldened by current laws, but this would continue under Regan’s bill.
Brothel-keeping laws are used overwhelmingly to target migrant women: research from the Republic of Ireland found that 85% of those convicted in Ireland for ‘brothel- keeping’ in recent years were migrant women. One of our members was charged with brothel-keeping, despite only seeking to create a safer environment for herself and her colleagues. Police arrived in large numbers with a battering ram, arrested her, and then proceeded to make stigmatising comments associated with her being a sex worker. This law clearly does not protect sex workers’ safety.
Street-based sex workers would also be negatively impacted by this bill. Street-based sex workers often work in the same area together for reasons of safety. This means they can take note of clients who workers are leaving with, such as identifying features and license plate numbers, as a safety measure. We understand that current Scottish Government policy intends to move the focus of police enforcement away from sex workers and on to clients, as does this proposed bill. While soliciting in a public place is already a criminal offence, including for both clients and sex workers, we believe that this bill would likely increase police enforcement action against soliciting by clients, known as kerb-crawling. Increased police action in search of clients will drive street- based sex workers out of their usual work areas and into working alone, in order to avoid police attention or their clients being arrested. This will inevitably have negative consequences for sex workers’ safety.
It is also important to note that this bill does nothing to tackle the fundamental reasons why many of us enter sex work – out of economic need. Poverty and the cost of living crisis are some of the main issues which lead people to enter sex work. A 2019 report from the House of Commons Work and Pensions Committee found that many women were engaging in survival sex work in order to support themselves after having their benefits sanctioned.
The inadequacy of the social security system (including benefits levels being too low or people having their benefits sanctioned) particularly impacts women and mothers, who are also overrepresented in sex work. In addition, vulnerable groups that are widely discriminated against in society (trans people, especially trans women, disabled people, and people of colour) also often enter sex work due to challenges in securing other employment. This bill seeks to criminalise a key survival strategy for all of these groups.
International evidence shows that the Nordic Model harms sex workers
The implementation of the Nordic Model in other countries has led to increased levels of violence against sex workers, as well as failing on its own terms in its aim to reduce demand.
According to Ugly Mugs Ireland, crimes against sex workers almost doubled in the two years following the introduction of the law in the Republic of Ireland in 2017, with experiences of crime up 90% and violent crime up 92%. A 2020 study commissioned by HIV Ireland found that sex workers who experienced violence at work were increasingly reluctant to report to the police under the Nordic Model, and that both their physical and mental health were impacted by the introduction of this legislation. Sex workers also reported that both stigma and violence against them had increased.
In a 2019 review commissioned by the Northern Irish Ministry of Justice, the policy of criminalising the purchase of sexual services in Northern Ireland was shown to be an abject failure. Reported assaults against sex workers increased by 225% from 2016 to 2018. Evidence suggested that, while a small number of clients were deterred by the law, dangerous, violent and abusive clients remained unaffected by the legislation. Nearly all workers interviewed felt that the law had increased the stigmatisation of sex workers in ways that made them more anxious and which had a negative impact on their day to day life. When surveyed, 98% of sex workers in Northern Ireland did not want the Nordic Model.
One of the most important findings from the review is that this legislation had no impact on demand for sexual services. In a letter to the committee, the Minister for Victims and Community Safety also points to a review from the Department of Justice in the Republic of Ireland, which found that there was also no decrease in demand from similar legislation.
In France, the Nordic Model has been in place since 2016. A Medicins du Monde report found that the law has led to 42% of workers being exposed to more violence, 38% finding it increasingly hard to demand condom use, 70% observing no improvement or a deterioration of their relations with the police, 78% losing income, and 63% experiencing a deterioration of living conditions.
A 2018 systematic review of 28 years of global research found that any criminalisation of sex work (including criminalisation of the purchase of sex) triples the likelihood of sex workers experiencing violence, and doubles their likelihood of contracting HIV.
We have prepared a briefing paper setting out, in more detail, the international evidence that exists on the effects of criminalising the purchase of sex, which we will forward to the committee separately.
Scotland does not want the Nordic Model
The Scottish public has already been consulted on the laws on sex work, through a 2024 YouGov poll which found that:
· In a rejection of SNP plans to outlaw the purchase of sex, 47% think it should be legal for a person to pay someone to have sex with them, versus 32% who think it should not be legal.
· 69% of Scots say the Scottish Government should focus on protecting the health and safety of sex workers, and providing support to people who want to leave the industry, compared to 14% who support the government passing new laws to prevent people exchanging sexual services for money.
· 62% oppose the Scottish Government’s declaration that sex work always equals violence against women, with only 13% supporting this idea. The SNP refuses to allow groups who will not sign up to this extreme proposition – including National Ugly Mugs – to join Government-backed working groups on sex work policy and exiting.
· Instead, 79% think the Scottish Government should consult sex workers and sex worker-led groups when considering new laws to keep sex workers safe (7% opposed).
· Despite Nordic Model campaigners’ calls to outlaw adult services websites, used by sex workers to advertise their services and access support from charities, 63% say they would prefer sex workers to look for business online, versus 2% who would prefer them to look for business on the street.
· 45% think that two sex workers should be allowed to work together in the same premises, a practice often adopted for safety reasons, instead of the current legal position in which both can be charged for exploiting each other under brothel- keeping legislation – versus 24% who disagree.
· Only 1% of Scottish adults think issues around sex work should be a priority for the Scottish Government at the present time.
Rather than addressing sex work through the criminal justice system, we believe sex workers should be given the social, financial, and emotional support they require. While we understand that the Scottish Government is concerned about tackling potential exploitation or trafficking within the sex industry, more effective measures to tackle exploitation would include an overhaul of the immigration system, better access to disability benefits, rent controls and more truly affordable and social housing, and a universal basic income. Academics from Dundee and Edinburgh Napier University have also stated that criminalisation of sex work, whether of sex workers or clients, drives people into more vulnerable positions and increases the risk of exploitation.
Finally, we have significant concerns about Regan’s views of sex workers and how those views may influence her bill. In the bill consultation, Regan used the following quote approvingly: “In prostitution, no woman stays whole. It is impossible to use a human body in the way women’s bodies are used in prostitution and to have a whole human being at the end of it, or in the middle of it, or close to the beginning of it. It’s impossible. And no woman gets whole again later, after.” This damaging, divisive, and stigmatising rhetoric further feeds the idea that sex workers are not human beings capable of advocating on our own behalf. We are speaking up, and we completely reject the Nordic Model, as well as Regan’s stigmatising rhetoric.
2. The Bill proposes to repeal section 46 of the Civic Government (Scotland) Act 1982. Under this section of the 1982 Act, a person who is found guilty of loitering, soliciting or importuning in a public place for the purposes of prostitution commits an offence. What are your views on this proposal?
We strongly support the proposal to repeal this section of the 1982 Act.
This law targets the most vulnerable sex workers, those who are street-based workers, and is part of an outdated mode of thinking: out of sight, out of mind. Sex workers working on the street are likely to be those with the most urgent financial need or who are facing other difficult circumstances: these people need support, not criminalisation.
Current criminal offences for loitering and soliciting put sex workers in a vulnerable position with the police. Sex workers often report harassment and abuse from the police. A recent report confirms that misogyny is a problem in Police Scotland, noting that “some units and divisions actively stalled investigations of gendered crime or did not act in accordance to what was expected because of the pervasiveness of sexist and misogynist attitudes they collectively held.” In East London, an article in the British Journal of Medicine found that 42% of street based sex workers had faced violence from police.
While Regan’s bill proposes to decriminalise these offences, the police would still hold power over sex workers due to their ability to refer sex working mothers to social services, to refer migrant sex workers for potential immigration enforcement, and more generally the risk of sex workers being outed to their friends and family. Sex workers are also sometimes criminalised under offences which don’t specifically relate to prostitution, such as anti-social behaviour offences.
We know from the experiences of members of our group that some police officers are also clients of sex workers. We need only mention the Emma Caldwell case to highlight the issues with giving Police Scotland more power over women, specifically sex workers. A senior officer who worked on the case was accused of offering to not charge a sex worker with an offence if she had sex with him. Regan’s bill said only two hours of training would be needed for officers to be able to enforce this legislation – when in actuality, it is an overhaul of the entire system itself which is required.
When Emma’s colleagues complained about Packer to the police, this was not taken seriously, and in fact many of the women themselves were arrested instead. Also, because of the criminality associated with sex work, Emma had to go to extreme lengths to not be found, and so worked in isolated areas with no one else around. This severely affected her ability to call for help when needed. She had no other workers around her who could have intervened or called for help. If sex workers did not have to work in isolation, driving us further underground, then she may still be with us today.
The criminalisation of clients soliciting also has a serious detrimental impact on sex workers’ ability to protect their own health by limiting the time they have to negotiate condom usage and what acts will be performed, as they have to enter the client’s car or go to a private place as quickly as possible in order to avoid police detection. When discussions about condoms and what acts will be performed take place when the worker is already in a vulnerable position, this affects their ability to say no and increases the likelihood of violence from clients. Furthermore, we know that Police Scotland have used condoms as evidence of solicitation taking place, which creates a disincentive for sex workers to carry condoms on their person to protect themselves while working.
If this proposed legislation should become law, we believe it is likely that Police Scotland would put more of its resources into enforcement against clients, and may even have to meet certain targets for arresting clients. Therefore, police interaction would likely increase if this bill, which is in line with the Scottish Government’s policies on so-called Commercial Sexual Exploitation, becomes law – in fact, we are seeing this increase already with Operation Begonia.
If some clients are discouraged from paying for sex by this law, then street workers would end up competing for a smaller group of clients and may find themselves having to charge less money or offer services they would usually prefer not to, such as oral without a condom, or penetrative sex without a condom. Often once the Nordic Model is introduced, the clients that continue to purchase sex are those who are less concerned about breaking the law, and thus potentially more likely to be violent.
The Médecins du Monde report on the impact in France includes quotes from sex workers, including street sex workers, who said that the criminalisation of clients while removing criminal penalties for sex workers has not improved their lives, and has in actuality, worsened it in some ways. The police still harass sex workers, and sex workers now work in even more isolated areas such as the woods in order to avoid detection.
It is also the case that sex workers are still stigmatised when one aspect of sex work is criminalised, even if clients are criminalised rather than sex workers. Stigma links directly to violence against sex workers, as well as sex workers feeling less able to access support or health services.
The issues associated with criminalisation are compounded for those who are members of other vulnerable groups; such as migrants, LGBT people, people of colour, disabled people, and people who are working class. These groups are over-represented in sex work due to discrimination from more traditional forms of employment, and/or because of severe underfunding for support services aimed at these groups. To criminalise these already severely marginalised groups is to further entrench their poverty and oppression.
We agree that sex workers should not be criminalised for working to support themselves to survive. It is instead the duty of the Scottish Government to ensure that people, mostly women, do not have to enter sex work in order to feed themselves and their families by ensuring the social security system is fit for purpose.
3. The Bill proposes to quash historic convictions under section 46 of the Civic Government (Scotland) Act 1982, which relates to the offence of loitering, soliciting or importuning in a public place for the purposes of prostitution. What are your views on this proposal?
We are strongly in favour of historic convictions being quashed.
One of the main points that all sides of this debate agree on, is that people should be able to leave sex work should they wish to do so. No one should feel that they have no other option than to sell sexual services to survive. However, having a criminal record with prostitution-related convictions and/or a police warning makes it much more difficult for people to leave sex work. Employers are likely to rescind offers of employment, or the worker can be barred from certain forms of employment if they have to undergo a Disclosure Scotland check. There is no reason why a sex worker who has been convicted of an offence for soliciting should be barred from any form of employment.
By keeping these convictions in place, sex workers are actually made more vulnerable to exploitation and abuse, as we will be unable to gain further and/or better employment. It keeps us trapped in a cycle of poverty, and a cycle of having to dip in and out of sex work in order to keep our heads above water.
If the Scottish Government’s aim is to help people leave sex work and enter other forms of employment, they must quash historic convictions and repeal any section of this Act which criminalises sex workers.
4. The Bill proposes (at section 6) to place a duty on the Scottish Ministers to ensure that a person who is or has been in prostitution is provided with assistance and support. The Bill sets out a non-exhaustive list of the types of assistance and support that may be provided. What are your views on this proposal?
In theory, we support the proposal for a duty to ensure that current or former sex workers receive assistance and support. However, in reality, there is no money available to fund this support. Regan points to the Delivering Equally Safe fund as well as the Victim Centred Approach fund – these funds are already highly competitive, with the Scottish women’s sector already struggling to maintain financial viability. The Minister for Victims and Community Safety has also agreed that these funds would be entirely insufficient to cover the range of support services that Regan discusses. These funds are, to quote a letter from the Minister to the committee “fully committed”.
Nordic Model advocates lean on the provision of ‘exit services’ as justification for increasing criminalisation. But in reality, these exit services are incredibly underfunded. In Sweden and France, where similar Nordic Model legislation with support provisions was introduced, support services have not been fully realised. Instead, the money set aside for this has been spent on policing. In Ireland, Nordic Model supporters acknowledge that “there is no evidence that these things are in place in Ireland”. There is also a risk that such services would align with common practice in support services for sex workers, i.e. requiring that sex workers must no longer engage in sex work in order to receive help. Anyone, whether they must continue engaging in sex work or not, deserves a right to support.
The Scottish Government’s own research highlights that current support services for sex workers are not adequate, and often these services rely on the worker leaving the industry in order to access support. This leaves people in an extremely vulnerable position, either leaving sex work with insufficient financial support to replace their earnings, or many sex workers continuing in sex work but not telling the support services about this, meaning they are not able to discuss issues concerning safety.
More widely, there is a severe lack of financial support available for mental health and addiction services in Scotland, as well as a lack of affordable and social housing, and restricted access to legal aid. If the Scottish Government wishes to reduce the number of people entering sex work, it must address these issues.
5. Do you have any other comments on the Bill which you have not already covered elsewhere?
Rather than seeking to place a vulnerable population in further danger by enforcing Nordic Model legislation which has been proven to be ineffective in its aims, as well as increasing violence against sex workers, this committee should listen to those who will be most affected by this legislation – sex workers. All sex worker-led organisations in Scotland and the rest of the UK oppose the Nordic Model.
Instead, the Scottish Government should seek to improve people’s access to affordable housing, and to build more social housing. It should ensure that the social security system works to prevent poverty. It should also be a priority to ensure that sex workers have equal access to healthcare and other important forms of support in which we will not have to encounter stigmatising attitudes that drive us away. A good place to begin would be implementing training for medical professionals and others who work in support services we frequent, provided by sex worker-led organisations.
The Scottish Government should take action to reduce stigma, discrimination and violence towards sex workers by creating a national campaign to achieve this, with current sex workers having a large input in how this campaign should be run.
Finally, we would highlight that there are no other groups in society that would typically be excluded in this way from the creation of policy and law on their own lives and work. Many groups have historically been excluded from this process, but great efforts have been made to rectify this, particularly in the Scottish Parliament. It is depressing to see that sex workers are still not given the respect and consideration that others are, including the ability to be involved in creating policy which will better our lives. We echo the motto of the disability rights movement: nothing about us, without us.
International Evidence on the Effects of Criminalising the Purchase of Sex
A response to claims made by Ash Regan MSP during Stage 1 consideration of the Prostitution (Support and Offences) (Scotland) Bill
September 2025
During the Stage 1 evidence session on 25 June 2025 for the Prostitution (Support and Offences) (Scotland) Bill, the Criminal Justice Committee expressed interest in reviewing the international evidence that exists on the effects of criminalising the purchase of sex. This followed claims made by the Bill’s sponsor, Ash Regan MSP.
This briefing examines the available international evidence and demonstrates that:
- No reliable evidence exists that criminalising clients reduces demand for sexual services
- Sex workers consistently oppose client criminalisation due to the harms it causes them
- The evidence on trafficking impacts is methodologically flawed and cannot reliably be used to draw any causal connection between legal models and trafficking rates
Client criminalisation does not reduce demand
Ash Regan claimed:“… the international evidence presents an extremely compelling and consistent case that, if you bring in laws in the style of the Nordic model, you will reduce the market for prostitution…”Official government reviews across countries that criminalise the purchase of sex consistently show that client criminalisation does not reduce demand.A report prepared by the Swedish National Board of Health and Welfare in 2008 concluded that “it is difficult to discern any clear trend of development: has the extent of prostitution increased or decreased? We cannot give any unambiguous answer to that question.”1 A subsequent report by the Swedish government in 2010 found that while street sex work declined since the introduction of the law, internet-based sex work increased. While overall prostitution levels had not increased, there was no evidence of any reduction.2
A review commissioned by the Northern Ireland Department of Justice found the law had no effect on demand. Sex work advertisements increased after the law took effect, and only 11% of clients surveyed indicated they would stop purchasing sex as a result of the legislation.3
A French government evaluation was unable to conclude that client criminalisation had any impact on demand due to a lack of reliable statistical data both before and after the law’s adoption. The report noted that sex work had shifted from outdoor to indoor venues, further complicating quantitative assessment.4
A comprehensive review commissioned by the Israeli Ministry of Welfare and Social Affairs and the Ministry of National Security found that rates of purchasing sexual services increased in Israel after criminalisation and the majority of clients surveyed either were unaware of the law or remained uninfluenced by it.5
Based on a recent review of its sex purchase law by the Republic of Ireland’s Department of Justice6, its Minister for Justice, Jim O’Callaghan, noted that “despite the criminalisation of the purchase of sexual services, demand has not decreased”.7
In a Scottish Government commissioned assessment of the international evidence on the impacts of client criminalisation it is acknowledged that “the deterrent effect of the law may be anticipated, but is difficult to evidence empirically.”8
The international evidence reveals a consistent pattern: criminalising clients has no verifiable impact on the levels of sex work.
Sex workers consistently oppose client criminalisation due to the harms it causes them and there is no improvement in relations with the police
Ash Regan claimed:
“When the women are decriminalised, they develop a better relationship with people in law enforcement… We have seen in other countries, particularly in Sweden, that there is an improved relationship between the sellers and law enforcement.”
Proponents claim that criminalising the purchase of sex while decriminalising the sale improves conditions for sex workers and makes it easier for them to report experiences of violence to the police. In fact, the Preamble to Canada’s Protection of Communities and Exploited Persons Act 2014, which introduced client criminalisation, states that it explicitly aimed to “encourage those who engage in prostitution to report incidents of violence.”
Research demonstrates that this objective has failed completely.
A survey of 200 sex workers across five Canadian cities found that the law completely failed to meet this stated aim. Among sex workers who had worked before the law change, 80.24% reported workplace violence had increased or remained constant, while 87.43% found it harder or no easier to access emergency help.9
A longitudinal study (2010-2017) in Canada examining the period before and after legal change found “no immediate change in the prevalence of reporting violence… and no significant difference in the trend of reporting violence“.10
Further qualitative Canadian research documented how client criminalisation increased risks for sex workers by reducing their ability to negotiate terms, increasing cash-based transactions (heightening robbery risk), and increasing client aggression.11
Research in France by the international NGO, Medecins du Monde, involving interviews with 70 sex workers and surveys of 583 others revealed that sex workers were “almost unanimously opposed to client criminalisation,” finding it more detrimental than previous laws directly targeting them.12 Contrary to expectations, the law did not decrease the number of sex workers, only worsened their conditions while increasing marginalization and stigma with 62.9% reporting that that their overall quality of life worsened.
A study conducted across Sweden, Norway, and Finland with 210 sex worker participants demonstrated that client criminalisation leads to a breakdown in police- sex worker relations and increases reluctance to report crimes.13 Crucially, 96% of sex workers interviewed opposed the client criminalisation law due to the harms they experienced. Amnesty International has also documented extensive human rights abuses that sex workers face under Norway’s sex purchase law.14
The evidence consistently shows that sex workers universally oppose client criminalisation, experience deteriorating relationships with law enforcement, increased violence, difficulty accessing services, and growing mistrust of authorities.
There is no evidence that client criminalisation reduces rates of trafficking for sexual exploitation
Ash Regan claimed:
“The international evidence shows that, if you pass the bill and enforce it appropriately, you will see a reduction in the influx of trafficked people.”
Claims that criminalising the purchase of sex reduces trafficking rates rely primarily on two studies – one global study covering 150 countries15 (“the Global study”) and one focused on Europe16 (“the European study”). Crucially, neither produced direct empirical evidence that client criminalisation reduced trafficking rates. Both are seriously methodologically flawed and cannot establish causal effects between legal regimes and trafficking rates.17 Indeed, the European study acknowledged that it was “not able to conclude that changes in laws cause changes in trafficking flows”.18
Data Quality Issues: Both studies used trafficking data issued by the United Nations Office on Drugs and Crime (UNODC), which the UNODC itself cautioned against using for cross-national comparisons due to unreliability. The European study acknowledged that their data, and data on trafficking generally, “may be of bad quality“19 and is “limited and unsatisfactory in many ways.”13
Inability to Establish Causation: The European study explicitly stated that the “data do not allow us to infer robust causal inference.”20 The Global study admitted their conclusions were “somewhat tentative” and it is “difficult, perhaps impossible, to find hard evidence establishing” the relationship between prostitution laws and trafficking.21
Aggregated Data Problems: Both studies relied on data combining all forms of trafficking rather than data focusing on sex trafficking specifically. The International Labour Organisation, in 2017, noted that of the estimated 24.9 million victims of forced labour, 4.8 million were in forced sexual exploitation, which equates to just under 20%.22 Using aggregated trafficking data, therefore, means that rates of trafficking for sexual exploitation are likely exaggerated and over-estimated.
Snapshot Rather than Longitudinal: Neither study relied on longitudinal data, representing only temporal snapshots rather than tracking changes over time.
Conclusion
Parliament should base its consideration of the Prostitution (Offences and Support) (Scotland) Bill on this substantial body of empirical evidence rather than unsupported assertions. The research demonstrates that end-demand legislation fails to protect those it purports to help while actively harming them and achieving no measurable reduction in sex work or trafficking.
1 Swedish National Board of Health and Welfare (2008) Prostitution in Sweden 2007, p.63, as referenced in Levy, J., & Jakobsson, P. (2014). Sweden’s abolitionist discourse and law: Effects on the dynamics of Swedish sex work and on the lives of Sweden’s sex workers. Criminology & Criminal Justice, 14(5), 593- 607. https://doi.org/10.1177/1748895814528926, see p.5
2 Swedish Government Public Investigations (2010) Prohibition of the purchase of sexual services:
An evaluation 1999–2008, https://www.regeringen.se/contentassets/2ff955c847ed4278918f111ccca880dd/forbud-mot-kop-av- sexuell-tjanst-en-utvardering-1999-2008-sou-201049/, see pp.34 to 36 (summary in English)
3 Northern Ireland Department of Justice (2019) Assessment of review of operation of Article 64A of the Sexual Offences Order (Northern Ireland) 2008: Offence of purchasing sexual services, https://www.justice-ni.gov.uk/publications/assessment-impact-criminalisation-purchasing-sexual- services, see paras 6 – 7, 11 – 12
4 General Inspectorate of the Administration (Inspection générale de l’administration), the Inspectorate- General of the Judicial Services (Inspection générale de la justice), and the General Inspectorate of Social Affairs (Inspection générale des affaires sociales) (2019) Evaluation of the law of April 13, 2016 aimed at strengthening the fight against the prostitution system and supporting prostitutes,https://www.interieur.gouv.fr/Publications/Rapports-de-l-IGA/Rapports-recents/Evaluation-de-la-loi-du- 13-avril-2016-visant-a-renforcer-la-lutte-contre-le-systeme-prostitutionnel-et-a-accompagner-les- personnes-prostituees?__cf_chl_tk=yC_yDRLGWVWH8VohAo4rxHhtoInSYJRUyLhr3GpW8sU- 1756583488-1.0.1.1-.I5rwTvrke_nkA4vkR5P_B6gzjD_UIPYnNe3vDXjztM, see pp. 5 – 6 for summary (in French)
5 Myers JDC Brookvale (2024) Implementing the Prohibition of Prostitution Consumption Law: Evaluation Study Report (Summary), https://brookdale.jdc.org.il/en/publication/implementation-of-the-prohibition- of-prostitution-consumption-law/, see p. iv
6 Department of Justice (2025), Review on the Operation of section 7A of the Criminal Law (Sexual Offences) Act 1993, https://www.gov.ie/en/department-of-justice-home-affairs-and- migration/publications/review-on-the-operation-of-section-7a-of-the-criminal-law-sexual-offences-act- 1993/
7 Department of Justice (2025), Press Release, Review of legislation that criminalised the purchase of sex completed, https://www.gov.ie/en/department-of-justice-home-affairs-and-migration/press- releases/review-of-legislation-that-criminalised-the-purchase-of-sex-completed/
8 Scottish Centre for Crime and Justice Research (2017) Evidence Assessment of the impacts of the criminalisation of the purchase of sex: a review, https://www.gov.scot/publications/evidence- assessment-impacts-criminalisation-purchase-sex-review/, see p.28
9 Anna-Louise Crago, C. Bruckert, M. Braschel & Kate Shannon (2022) Violence against sex workers: Correlates and Changes under ‘End-Demand’ legislation in Canada: A five city study, Global Public Health, 17:12, 3557-3567, https://www.tandfonline.com/doi/10.1080/17441692.2022.2092181?url_ver=Z39.88- 2003&rfr_id=ori:rid:crossref.org&rfr_dat=cr_pub%20%200pubmed, see 3563 – 3564
10 McBride, B., Shannon, K., Bingham, B., Braschel, M., Strathdee, S., & Goldenberg, S. M. (2020). Underreporting of violence to police among women sex workers in Canada: amplified inequities for im/migrant and in-call workers prior to and following end-demand legislation. Health and human rights, 22(2), https://pmc.ncbi.nlm.nih.gov/articles/PMC7762889/pdf/hhr-22-02-257.pdf, see p.261
11 McDermid, J., Murphy, A., McBride, B., Wu, S., Goldenberg, S. M., Shannon, K., & Krüsi, A. (2022). How client criminalisation under end-demand sex work laws shapes the occupational health and safety of sex workers in Metro Vancouver, Canada: A qualitative study. BMJ open, 12(11),https://bmjopen.bmj.com/content/bmjopen/12/11/e061729.full.pdf
12 Hélène Le Bail, Calogero Giametta, Noémie Rassouw (2019) What do sex workers think about the French Prostitution Act?. [Research Report] Médecins du Monde, https://sciencespo.hal.science/hal- 02115877/file/2019-04-le-bail-mdm-report-prostitution.pdf, see p.6
13 Niina Vuolajärvi (2022) Criminalising the Sex Buyer: Experiences from the Nordic Region, Centre for Women, Peace and Security at the London School of Economics, https://www.lse.ac.uk/women-peace- security/assets/documents/2022/W922-0152-WPS-Policy-Paper-6-singles.pdf
14 Amnesty International. (2016). The Human cost of ‘crushing’ the market: Criminalization of sex work in Norway, https://www.amnesty.org/en/documents/eur36/4034/2016/en/
15 Cho, S. Y., Dreher, A., & Neumayer, E. (2013). Does legalized prostitution increase human trafficking?. World development, 41, 67-82,https://www.sciencedirect.com/science/article/pii/S0305750X12001453?ref=cra_js_challenge&fr=RR-1
16 Jakobsson, N., & Kotsadam, A. (2013). The law and economics of international sex slavery: prostitution laws and trafficking for sexual exploitation. European journal of law and economics, 35(1), 87-107, https://link.springer.com/article/10.1007/s10657-011-9232-0
17 Weitzer, R. (2025). Flawed research on the impact of law reform: The case of legal prostitution and sex trafficking, a research note. Criminology, 63(2), 557 – 569, https://onlinelibrary.wiley.com/doi/abs/10.1111/1745-9125.12407
18 See footnote 16, p. 94
19 See footnote 16, p.93
20 See footnote 16, abstract 21 See footnote 15, p.76
21 See footnote 15, p.76
22 International Labor Organization (2017). Global estimates of modern slavery, https://www.ilo.org/publications/global-estimates-modern-slavery-forced-labour-and-forced-marriage, see p.10