Why Not the Nordic Model?

The Swedish Model, otherwise known as the Nordic Model, is a legal approach to sex work that criminalises the purchase of sexual services and the clients of sex workers. First introduced in Sweden in 1999, this policy is currently in effect in Sweden, Norway, Iceland, France, Ireland, Northern Ireland, Canada and Israel. Since its inception, the Nordic Model has been controversial among those working in the sex industry, and has been met with huge resistance and protest from sex workers who are impacted by these laws.

Scottish sex workers overwhelmingly oppose plans to introduce the Nordic Model. Many spoke of the impact of the constant threat of this policy being introduced, saying it harmed their mental health due to the instability of the legal status of their work (Armstrong, Phillips, Ryan, Fraser & Kelly, 2024). 

Amnesty International argues that, despite sex workers not being directly criminalised by the Nordic Model, it still has an impact on certain aspects of selling sex, such as the purchase of sex and the use of premises to do this work in. In Scotland, under partial criminalisation, we are already criminalised if we work together under the same roof for reasons of safety, forcing us to go underground and compromise our ability to protect ourselves from exploitation. This leaves us more vulnerable to abuse, and to police harassment. 

The Nordic Model means that we have to take more risks to shield those who purchase sex from police detection. We have to give more reassurance, and compromise our own plans for safety in order to continue being able to work. Instead of working with other sex workers, we are isolated and have to meet buyers in private settings – often leading to more abuse.

Sex work is still highly stigmatised under the Nordic model and contributes to the discrimination and marginalisation of sex workers (Amnesty International, 2017) 

The Negative Impact

How the Nordic Model has impacted sex workers in NM countries

Sex workers in Ireland are subject to the Nordic Model. Unfortunately, sex workers can still be criminalised as the crime of “loitering” remains on the books – targeting street based workers. The law also criminalises those who live from the proceeds of sex work, which can target those who live with sex workers. It also criminalises those who provide accommodation for sex workers to work from, which can lead to sex workers being evicted as the law encompasses landlords. Once a landlord becomes aware of a sex worker using their property for work, they become criminally liable. This isolates sex workers further if they cannot use their own living space to work, or if their family and partners become criminalised as a result of living with them. 

Similar to laws in Scotland, two or more sex workers cannot work together as this is defined as a brothel. Sex workers may offer services from the same location in order to provide protection for one another, but again the Nordic Model isolates and drives us underground. 

Sex workers in Ireland were interviewed about their thoughts
on the Nordic Model:

“I think it’s a fucking travesty. It does so much harm and it’s insulting because they have brought in laws that the evidence shows are harmful and they say they are doing it in the name of protecting us… Of course if you put more pressure on clients, that pressure is transferred to the worker, you know, and so then you have to go further out of your way to meet their demands and, you know, now they are more likely to insist that they see you on your own if you are working indoors, that you are not in a place with someone else. Out on the streets I’ve had to go further away so we don’t get picked up by the guards.”

(Caroline, Ireland)

“…you end up having to protect abusive spaces or people since you’re left without any alternative. The law boasts that it has the effect of preventing those sorts of players from access to us, but that’s not really the case – it’s just eliminated any means of fighting bad practice.”

(Sarah, Ireland)

“Brothels are not a negative thing. They are actually a positive experience for a vast number of reasons, one being safety in numbers, two being that you can have cameras and things like that… It can be set up in a way that this space is being used for sex work, so it can have the essential things that we need to be safe… It’s frustrating, you know, like if I was paying a driver, so that driver is not only my transport but they are also my fucking security – that’s illegal… so I can’t do that. So, I can’t have security, I can’t work in a safe place and I can’t also like, enjoy the camaraderie of my sex worker pals. You know, that’s something I miss from the brothel – like going to work. When I was in Australia, it was fun – I had friends there… And all that craic is completely fucking gone. And I don’t know why that [working together] is such a bad thing. Like where is it negative? Why can’t we enjoy our jobs? Why can’t we enjoy working with our colleagues in the same way that other people do?”

(Sarah, Ireland)

“…not all of them want to exit the industry completely but they want to work for themselves and like, nobody is interested…If you are worried about people being coerced or not being able to leave the industry, make it easier to get into treatment, make housing easier to get… If they are afraid of someone, make refuges easier to get into… Do something about the state of addiction services… Just trying to cut off people’s income – it’s ridiculous. Like you are just trying to narrow people’s options until they have nothing, in which case they will probably just die without you ever having to notice them – which is ultimately the goal.”

(Suzanne, Ireland)

Workers from other countries with the Nordic Model have also been interviewed about their thoughts on the legislation:

“The Nordic model doesn’t protect me in any way. Quite the opposite because clients are afraid to go through safety screening and be honest about their identities. They also fear reporting exploitation when they see it, because they don’t want to go to jail or be outed. The Nordic Model makes sex work more dangerous and pushes trafficking victims underground. These laws fail in every way and I feel it’s easy to see how ridiculous they really are.”

(Annie, Canada)

“I have never been able to fully relax in my home, knowing that someone could with very little effort ruin my life by exposing me as a former or current sex worker to my landlord, whereupon I would be forced to move and hope my current landlord doesn’t spread my name to every other landlord in the city.”

(Anonymous, Norway)

Criminalising sex workers online presence is dangerous

Evidence shows the internet platforms have made working in the sex industry safer, empowering sex workers to screen potential clients, share safety information and access lists of dangerous individuals. Despite claims by proponents of the Nordic model that advertising websites online benefit third parties, online platforms have allowed more sex workers to work independently, seizing control over their rates, services, and ultimately their profession. Banning online advertisement also removes peer support and prevents labour organisation, leading to an increase in the isolation of sex workers.

Upon the introduction of FOSTA (Allow States and Victims to Fight Online Sex Trafficking Act) and SESTA (Stop Enabling Sex Traffickers Act) in the United States in 2018, online advertising platforms were shut down. Those affected abruptly faced financial hardship, with many being pushed into unsafe or exploitative working conditions. Sex workers reported that the loss of their online presence had made them more susceptible to labour exploitation and trafficking, with many being forced to work outdoors. Research shows that the introduction of SESTA/FOSTA led to an increase in poverty, insecure housing, suicide, murder, isolation, and the deterioration of physical and mental health. 

Northern Ireland

In a 2019 review commissioned by the Northern Irish Ministry of Justice, the policy of criminalising the purchasing of sexual services in Northern Ireland was shown to be an abject failure.

Reported assaults against sex workers increased by 225% from 2016 – 2018

Sex workers experienced higher levels of intermediate level crimes, with a 667% increase in abusive phone calls, and a 200% increase in threatening behaviour from 2016 – 2018.

Sex workers were receiving more requests for unsafe sexual practices or for those sexual practices that they are not willing to perform

Evidence suggested that, while some 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 an impact on their day to day life.

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