Full legalisation

In this model, sex work is made legal and regulated. Workers must register, obtain a permit, and pay taxes, similarly to other professions. It aims to reduce exploitation, improve working conditions, and weaken organised crime.

Examples: Germany, Austria, the Netherlands

Supporters say:

• Sex work should be formally recognised as work.
• Potential for regulation to improve safety and labour rights.

Critics say:

• It often benefits brothel owners and third parties more than workers.
• Some sex workers avoid registration due to privacy concerns.
• A hidden “second tier” may emerge, where unregistered workers face increased risks.

The Nordic Model (Sex Buyer Law)

Under this approach, selling sex is legal, but buying it is a criminal offence. The goal is to reduce demand and eventually eliminate sex work.

Examples: Sweden, Norway, Iceland, France, Ireland, Northern Ireland

Supporters argue:

• It discourages exploitation by reducing demand.
• It frames sex work as a form of violence or coercion against women.

Critics argue:

• It drives sex work underground, making it more dangerous.
• Clients fear arrest, so meetings become more rushed and hidden, reducing negotiation time and increasing risk.
• It doesn’t address poverty, trauma, or lack of options that often lead people to sell sex.

Decriminalisation

This is the model supported by many sex worker-led organisations, as well as Amnesty International, the World Health Organisation, and the Royal College of Nursing.

Example: New Zealand (the only country with nationwide decriminalisation)

Supporters argue:

• All laws that criminalise sex work are removed – sex workers can avoid going through the criminal justice system which deepens marginalisation.
• Sex workers have the same legal protections as other workers.
• Police focus on serious crimes like trafficking, violence, or coercion.

Critics argue:

• It doesn’t eliminate stigma or fix broader issues like gender inequality or poverty.
• Exploitation and abuse can still occur, as in any industry.

Reported outcomes in New Zealand since adopting the decriminalisation model are:

• A significant drop in trafficking.
• Around 70% of sex workers feel more confident reporting violence.
• Greater control and autonomy for those selling sex.

Safety is key

At One25, we believe that any discussion about laws must begin and end with safety. In 2022, we consulted our staff, volunteers, and the women we work with to better understand what legal model would serve them best. The result was that decriminalisation would offer the greatest protection.

Criminalising sex workers, directly and indirectly, only deepens stigma and increases risk. Decriminalisation allows the police and services to focus on real harms: exploitation, violence, and trafficking. It gives women more power to make informed choices, seek support, and report abuse without fear of punishment.

Ultimately, the law should serve to protect, not punish.