Following a guest commentary by doctoral psychologist and internationally renowned psychotraumatologist Ingeborg Kraus, we once again turn to the subject of the Nordic Model. In France, ten years after the introduction of the Nordic Model, activists and civil society groups are taking stock and sending a clear public message. Around 500 people took to the streets. Their message: what has been achieved so far is only the beginning. Protesters are calling for the complete abolition of prostitution and for long-term political commitment to consistently continue along this path.
The Nordic Model – An Abolitionist Law
On April 13, 2016, France adopted an abolitionist law introducing penalties for buyers of sex. Yet a broader look across Europe shows that the Nordic Model has so far remained the exception. Only a small number of countries have adopted this approach. Sweden was the first to do so in 1999, when for the first time a fundamental shift in perspective was anchored in law: not the prostituted person but the buyer is criminalized. Purchasing sex is punishable; selling sex is not. The aim is to treat prostitution not as ordinary labor but as an expression of exploitation and structural inequality while deliberately reducing demand.
The abolitionist law is based on the assumption that prostitution constitutes a form of violence against women and therefore cannot be regarded as a regular service industry. Its objective is to change the structural conditions that enable and sustain this form of exploitation. Here you can find our blog post.
A Direct Comparison
In contrast, there is the model used in countries such as Austria. There, prostitution is legal and state-regulated. The focus lies on control, health-related prevention and public order. Brothels are permitted, there are registration requirements exist, and regular investigations. The state accepts prostitution as an existing reality and attempts to manage it administratively. The Nordic Model, by contrast, follows a different logic: it seeks a long-term reduction of prostitution by criminalizing demand while simultaneously providing exit assistance for those affected.
The political turning point in France was largely driven by testimonies from formerly prostituted women. They publicly spoke about violence, sexism, and racism – experiences they systematically endured inside prostitution. These voices broke a longstanding social silence and forced political institutions to act. Since then, in France prostitution has officially been classified as a form of sexual violence against women.
In other countries such as Germany and Austria, however, a regulatory approach still dominates. Although discussions surrounding violence against women have intensified there as well, the role of prostitution itself often remains excluded from the debate. Critics regard this as a central blind spot. They argue that a system based on structural inequality cannot simultaneously promote equality. This criticism becomes especially clear in international comparison: because of its liberal legal framework, Germany is widely considered one of the largest prostitution markets in Europe.
In France on the other hand, also major social actors have taken a clear position. Labor unions, for example, reject the classification of prostitution as “work,” arguing that it fundamentally contradicts the goals of gender equality. Dignity, they contend, is not negotiable. This position increasingly shapes both political and public debates.
At the same time, it is criticized that important discussions in other countries continue to be avoided or postponed. Instead of structural reform, prolonged evaluations often dominate. Also cultural representations that trivialize prostitution or normalize sexualized violence are facing growing criticism. Such portrayals, critics argue, may shape social norms and reinforce harmful ideas regarding role models.
A Shift in Perspective Seems Impossible …
The French debate condenses one central accusation into a single phrase: “mental laziness.” The assumption of prostitution being an unchangeable part of society prevents new political approaches from emerging. Yet the example of France demonstrates that a shift in perspective is possible – if the political will exists.
A closer comparison between Austria and the Nordic Model highlights their fundamentally different political logics. While Austria attempts to create order and control within an existing market through regulation, the Nordic Model deliberately targets what it identifies as the root cause: demand. By criminalizing buyers, the market itself is intended to shrink over time. At the same time, support services for affected individuals are expanded in order to make exit realistically possible. This is therefore not merely a matter of different laws but of two fundamentally different social objectives.
This distinction is also reflected in the underlying ideas embedded within each approach. The Austrian model primarily treats prostitution as an economic activity that should be made safer under certain conditions. The Nordic Model, by contrast, views prostitution as an expression of structural inequality, particularly regarding gender and power. From this follows a broader political consequence: the priority is not the management of a market but its long-term abolition. It is precisely at this point that it is determined which path a society chooses to follow.
International comparison makes it clear: this is not only about differing legal frameworks but about fundamental social values. The key question, therefore, is not whether change is possible – but whether it is desired.
Translated by Julia Matzinger
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