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  • Writer's pictureAntonia Boorman

[Sex Work Series] The Nordic Model in Sweden & Norway

Updated: Dec 20, 2020

[Sex Work Series] Paper 4c: Sex Work Legislation Case Studies - The Nordic Model in Sweden & Norway: An evaluative analysis of the legal approaches to sex work in Western Europe to distinguish which system best protects the human rights of sex workers.


The Nordic Model

The Nordic Model is an approach whereby sex work is illegal and a criminal offence, yet instead of the sex worker (the seller of sex) being prosecuted and criminalised, it is the purchaser of sex who is prosecuted rather than the seller (Chapter 6, Section 11, Swedish Penal Code). This system was created in the Scandinavian region, in Sweden, which is why the name “Nordic/Swedish model” was coined. It is a popular approach and is continuously being adopted by different liberal countries today such as Ireland, France, Iceland, Norway, and Canada. For this chapter, I will be focusing on case studies of Sweden and Norway respectively.

Amnesty International specifies the Nordic Model as the system where; buyers of sex are criminalised; the selling of sex is decriminalised, as is street advertising and solicitation; and associated activities such as brothel-keeping and involvement of third parties are criminalised (Amnesty International, 2016). The Nordic model was enacted to be more aligned with the feminist views of the nation in an attempt to be more protective of sex workers. The Nordic model aims to reduce the overall amount of sex work occurring in the country without harming sex workers through criminalisation, which was recognised by Nordic lawmakers to be harmful to sex workers. Nordic lawmakers view that passing a progressive law will “shift the weight of stigma and prosecution from sex workers to pimps and clients” (Nielsen, 2018, para. 2).

In Sweden, the penalty for purchasing sex, or attempting to, is a fine of between or up to six months imprisonment (Chapter 6, Section 11, Swedish Penal Code, 1999). By limiting demand, policymakers aim to reduce the amount of sex work supplied. This is aligned with the ‘neo-abolitionist-feminist’ ideology¹ where sex work is seen as synonymous with violence against women (Amnesty International, 2016) made upon the assumption that sex work can never be consensual or autonomously chosen (Amnesty International, 2016). Sex workers are seen as victims, which is why Nordic lawmakers aim to protect them, and the buyers of sex are deemed, oppressors. The Nordic model victimises the sex workers and criminalises the buyers.

A parliamentary evaluation of the Nordic model in Sweden claimed that the model has been successful as it had resulted in a halving of street prostitution within the 10 years since its introduction (Regeringskansliet, 2011)². Yet, this didn’t take into account the increase in internet advertisements for sex work, meaning that sex work may not have been reduced but instead just developed into an “indoor market” (Amnesty International, 2016, p. 22). In a similar evaluation of the Nordic Model in Norway, Amnesty International investigated between November 2014 and February 2015, conducting 54 interviews of sex workers, government and social service agencies³, civil society organisations, to examine the impacts of the Nordic Model legislation on sex workers in Norway (Amnesty International, 2016). From their report, many problems were resulting from the Nordic Model that caused harm to sex workers, despite the aim of the Nordic Model to do the opposite.

This aim of the Nordic Model, to protect sex workers from violence, is admirable, yet unfortunately, the Nordic model doesn’t work in the progressive way that it was intended. In Sweden, sex workers have “reported greater competition, declining prices and harsher conditions” (NSWP, 2011, p.2). By limiting demand, it only makes the work more dangerous for sex workers to conduct as the reduced demand doesn’t fix the underlying economic reasons that influence sex workers' decisions to pursue sex. Instead, criminalising the buyer limits the amounts of clients available to sex workers, meaning that they are less able to reject clients who perhaps are violent or otherwise problematic, as they still need to make money (BBC, 2019).

As reported by the Global Network of Sex Work Projects, “sex workers with fewer potential clients are less likely to turn away those who are intoxicated or about whom they simply feel unease” (NSWP, 2017, p. 7). Since the clients are now subject to the risk, this weakens sex workers' bargaining power in interactions, where “sex workers have lost negotiating power and are more subject to customer demands” (Grant, 2016, para. 10). Coupling this with fewer clients to choose from, sex workers will have to compensate by taking more risks (Nielsen, 2020). For example, a recent study by the Norwegian National Police Board found that sex workers are more likely to overcompensate from the income lost by having fewer clients by offering more services such as condom-less sex (NSWP, 2017), which increases the risk and spread of HIV/AIDS. For sex workers in Sweden, access to health and social services is often reliant upon their guarantee that the leave the trade (NSWP, 2017), meaning that many sex workers who perform sex work for economic reasons and are unable to give up sex work due to these financial constraints are ineligible to access treatment (NSWP, 2017). This is harmful both for the health and safety of sex workers but also in the effort to reduce the transmission of HIV/AIDS. Furthermore, from the Amnesty International (2016) report, it was found that sex workers “felt apprehensive about carrying condoms in case it led to police action against them” (Amnesty International, 2016, p. 9) and that condoms in indoor premises, such as apartments or massage parlours, could be used as evidence for brothel charges incentivising sex workers not to use condoms to avoid arrest.

Reducing demand by scaring off safe clients, therefore, leaves sex workers only with clients who aren’t scared off by the criminalisation, who may be drunk, aggressive or dangerous to meet with (NSWP, 2017), while simultaneously reducing their ability to say no to clients due to reducing the supply of clients available to them. Police surveillance of sex workers to locate and arrest clients make clients wary of approaching sex workers publicly (Amnesty International, 2016). Sex workers will attempt to make the clients feel more at ease by working secretively and in remote locations, such as the client's apartments or in secluded areas (Amnesty International, 2016). These unequal power dynamics make sex workers more vulnerable to attack (BBC, 2019). The report from Amnesty International shows an increase in violence towards sex workers, as well as a rise in STD rates among sex workers and social isolation after the adoption of the Nordic Model (Amnesty International, 2016). This is further backed up from a recent Irish study showing that since the adoption of the Nordic Model system violence against sex workers, specifically, has risen by 92% (Ugly Mugs, 2017).

Similar to the partial criminalisation model, the restrictions on brothel-keeping and third-party involvement can have negative consequences that reduce a sex worker’s safety, such as relying on using the client's house or being unable to work with other sex workers. Within the Nordic Model, pimping and third-party involvement are illegal. The definition of pimping is similar to partial criminalisation legislation, being defined as ‘profiting from somebody else’s sex work’ (Swedish Penal Code, Chapter 12, Section 12, 1999) and acts as an ‘accessory to the promotion of sex work’ (Section 206, Norwegian Penal Code, 1902). Criminalising third-party involvement can criminalise landlords making legal sex workers subject to discrimination regarding housing, at extreme risk for immediate eviction, and possible homelessness, which these exit services do not combat or aid. In Norway, this clause was specifically used to discriminate against sex workers in “Operation Homeless” (Amnesty International, 2016, p. 31). Operation Homeless was a direct policy strategy aiming to enforce Section 315 of the Norwegian Penal Code banning premises from being used for sex work operating between 2007-2011 that resulted in over 400 evictions of sex workers (Amnesty International, 2016). Police would pressure landlords to evict sex workers, despite selling sex being legal, as under Section 315 of the Norwegian Penal Code landlords would be considered brothel owners and could be prosecuted (Amnesty International, 2016). Refusal to do so would lead to charges of ‘promotion’ of sex work, which could result in pimping charges under Section 206 of the Norwegian Penal Code (Amnesty International, 2016). Amnesty International (2016) states these immediate evictions constitute “human rights violation under international law” (Amnesty International, 2016, p. 7). This also directly contradicts the aim of the Nordic Model to protect sex workers. Criminalisation of third-parties fails as it cannot formally distinguish between third parties who are taking advantage of sex workers and third parties who are either helping or not associated with the transaction of sex work ie. landlord, friends, drivers, etc.

An important part of the Nordic Model is the “exit services” that are provided (Mac & Smith, 2018). The Nordic Model claims that they are designed to aim sex workers move into different work industries, however, in practice the high levels of associated negative stigma make these exit services difficult to access without judgment (Grant, 2016). In Sweden, social workers deny sex workers condoms as they don’t want to be seen as endorsing sex work due to the ‘zero tolerance towards prostitution’ stance (Amnesty International, 2016). Swedish sex workers critique these services as being “overly conditional and ultimately inadequate” (Nielsen, 2018). The inaccessibility of access to these exit services and failure for these laws to protect sex workers, in reality, means that the Nordic Model is more of a philosophical solution than a practical legislative one.

The Nordic Model doesn’t aid the fight against trafficking, as intended, as the clients could not report sex workers who seem uncomfortable, abused, and/or scared, as the clients would be prosecuted themselves, therefore, they have less incentive to report a potential victim of trafficking, who will also most likely not report themselves due to the various constraints to come forward; psychological manipulation, visa/citizenship requirements, fear of the trafficker, lack of safety net, etc. Furthermore, a recent Norwegian police report has detailed how the Nordic Model has “made it harder to gather evidence – from sex workers and clients – against people who have coerced or exploited sex workers” (NSWP, 2011, p. 2). Therefore the Nordic Model, out of all the legislative models analysed in this series, maybe the most protective of traffickers, not trafficking victims, as it shelters them as clients, the only outside party, is incentivised to report any abuse.

In conclusion, the Nordic Model, criminalisation of buyers rather than sellers aims to stop the demand for sex work, which it does do, however, the reality is that it just lowers the supply of customers for workers without, again, fixing the economic problems that led them to this work in the first place, meaning that they are forced again to work more, lower prices or accept riskier clients, to earn what they need to survive meaning that sex workers are more vulnerable and have a higher risk to violence from clients. In comparison to the penalties faced by clients for purchasing sex, a penalty of between 15,000 to 25,000 kroner (approx. US$1,700-2,850) (Amnesty International, 2016), the prospects of homelessness, loss of income and ineligibility to access health and social services faced by sex workers as a consequence seem to be more severe and dire, which is directly contradicting the goal of the Nordic Model to protect sex workers over clients. By victimising sex workers this takes away the respect for their agency and autonomy. The Nordic Model prioritises operating ‘rescues’ over enabling sex workers’ rights, which is not a model to strive for in terms of achieving gender equality.



¹ Views similar to Catherine MacKinnon (2001), as discussed in Paper 3: Should sex work be criminalised?

² The details of their methodology of this evaluation were not available.

³ Including “the Ministry of Justice and Public Security, the Oslo police district, the Regional Public Prosecution Office for Oslo and the Ombud for Equality and AntiDiscrimination” (Amnesty International, 2016, p. 8).



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