The situation in other countries


In 1999, Sweden introduced legislation that criminalises the purchase of casual sexual services and decriminalises the sellers. The rationale was that prostitution constitutes violence against women and is incompatible with gender equality. Surveys have revealed that more than 80 per cent of the Swedish population supports the legislation.

The Swedish government recently evaluated the legislation and found that the number of men paying for sex in that country had reduced. It also found a reduction in the number of women involved in prostitution and that the number of women and girls being trafficked into the Swedish sex industry had fallen significantly. The National Rapporteur stated that human trafficking was a problem of diminishing proportions in Sweden. The shrinking commercial sex industry in Sweden has had a subsequent impact on the level of sex trafficking in neighbouring countries.

Download an evaluation of the Swedish situation: Swedish Evaluation Summary.


Norway introduced legislation similar to that of Sweden in late 2008. Their motivation was to combat sex trafficking, as opposed to gender equality, but they recognised the success of the Swedish model and hence decided to criminalise the purchase of sex.


In April 2009, Iceland also followed the Swedish example, criminalising the purchase of sex. Those convicted under the Icelandic legislation can face a fine or up to one year in prison. If the person from whom sexual services is bought is under the age of 18, the maximum penalty is two years in prison. Before the introduction of this legislation, the buying and selling of sexual services was legal in Iceland. The selling of sex was decriminalised in 2007, when the government also criminalised the making of profits from the prostitution of others.


The UK recently passed the Policing and Crime Act, 2009, which outlaws the purchase of sex from controlled individuals. In focusing on the demand for sexual services, the Act shifts criminal liability away from people exploited through prostitution and places responsibility on those who contribute to commercial sexual exploitation by choosing to purchase sexual services.

Legislators proposed the law after examining the various approaches taken in Europe towards addressing demand for paid sex and following visits to countries that support the legalisation model, as well as Sweden. It is estimated an average of 80% of the women involved in prostitution in UK meet the criteria for being “controlled”. Not knowing that a person is being controlled is not a defence under the legislation.


On 1 March 2012, Albania’s government adopted a new law criminalising the purchase of sex as a way of combating the rising problem of prostitution and sex trafficking in their country. The purchase of sex is now punishable with a maximum penalty of three years in prison. However, while Albania has realised the need to combat pimping (punishable with five to fifteen years in prison) and those who exploit prostituted women, the decriminalization of the women in prostitution, who are the focus of concern of the authorities, remains to be developed further.


On the first of October 2000, the Netherlands lifted the ban on brothels and prostitution organising, thus becoming the first country in the world to legalise prostitution, to accept sex as work and to decriminalize pimps. The country attempted to adopt a pragmatic approach to prostitution as towards an inevitable situation, which needs to be made “as pleasant as” possible; improve the employment status and working conditions of women and empower them. They put in place a brothel licensing system and educate women about their ‘employment rights’; to impose taxes and police checks while the executive role and administrative responsibility stayed with the municipalities.

However, these measures have done little to prevent the involvement of organised criminals and sex traffickers in the trade. In 2008, a report was produced saying that of Amsterdam’s 8,000 to 11,000 prostitutes, 75 per cent were foreigners, mainly from Eastern Europe, Africa and Asia. The national police force (KLPD) estimates that 50% to 90% of the women in licensed prostitution ‘work involuntary’. This would mean that in Amsterdam, there are at least 4,000 victims of trafficking on yearly basis.

Former mayor of Amsterdam Job Cohen has stated: “We realise that this is no longer about small-scale entrepreneurs, but that big crime organisations are involved,” he said “It’s about trafficking women, it’s about drugs and it’s about killings.” Source

New Zealand

Please click here to see our summary of the report on New Zealand compliance with the Committee on the Elimination of Discrimination against Women (CEDAW) produced by Coalition Against Trafficking in Women New Zealand.

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