more about France and Sweden

In my last post I looked at MSP Ash Regan's attempt to introduce the Nordic Model to Scotland. She seems to accept that the Nordic Model hasn't worked in the Republic of Ireland or Northern Ireland. She puts this down to lack of enforcement and said that the Nordic Model has worked in France and Sweden.

I've just been reading a 2018 anti-trafficking report from ICI (Immigrant Council of Ireland). There hasn't been a more recent report, as far as I can tell. It has something to say about the Nordic Model in France and Sweden. It doesn't say that that the Nordic Model is working just fine in France but it is very complementary about Sweden. Although it gives false statistics about Sweden. It was written by Dr Monica O'Connor.

This is what it says about France. I have highlighted what I think is important.

"The recent French law has clearly had an immediate impact on policing in terms of the focus of law enforcement being on the buyer not the person selling sex on the streets. But the French expert highlights a number of challenges ahead, including: the inconsistency in the implementation of the criminalisation of buyers from region to region; the continued use of other public order offences against women in some areas; weak implementation of the law in relation to minors in prostitution, particularly in relation to the defence by buyers of not knowing her age; trafficked and procured women being regarded as undocumented migrants rather than victims of exploitation; delays in the resourcing and establishment of exit route programmes, services and accommodation for women seeking to exit prostitution. It is also worth noting all the arrests of buyers have been on the streets and that a further challenge will be the policing and arrest of buyers in indoor locations."

I have summarised the main points below. 

• the law has only been enforced in some regions in France
• women are still being arrested
• weak enforcement of the law with minors
• women are getting deported and not helped
• women are not being helped to exit
• enforcement only applies to the minority of women who work on the street
• they have barely begun to enforce this law with the majority of prostitutes and clients, those who work indoors, and it's uncertain if that is even possible

It doesn't seem that Ash Regan has read this. Dr Monica O'Connor isn't being as critical as she could have been, she didn't state that prostitution of minors is on the increase - up 285% since 2015. Although Dr O'Connor might not have known this in 2018. It doesn't seem that anything has changed for the better in France since 2018 judging from the 2025 report.

This is what it says about Sweden. I have copied-and-pasted the whole paragraph and highlighted the false statistics.

"Since the legislation came into force on 1 January 1999, 7,059 men have been apprehended for attempting to purchase or for having purchased a sexual service resulting in 3,006 convictions. In addition, 1,593 men have been arrested for the purchase of a sexual act from a child under 18 years of age resulting in 233 convictions. There have been 1,328 reported crimes for procuring and 481 for trafficking for sexual exploitation. Through the direct or indirect intervention by the police, many more have been dissuaded from purchasing someone for the purpose of exploitation in prostitution. These arrest figures indicate the successful enforcement of the law but a government-appointed Commission of Inquiry in 2010 indicates the wider positive outcomes of the law. The Inquiry found the law has acted as an effective anti-trafficking measure; reduced the number of people in prostitution compared to neighbouring states such as Denmark, which, at the time, had three times the number of people in prostitution; and has had the desired normative effect with strong public support for the law. The law has proven to be an effective deterrent to sex purchasers with a decrease in reported users down from 13.6 per cent in 1996, 7.9 per cent in 2008 and 7.5 per cent in 2015, with a normative effect on prospective buyers. Despite claims by critics of the Swedish approach that criminalising the purchase of sexual services and sexual acts increases the risk to women in prostitution, the Walby et al. (2016) research once again confirms there is no evidence to substantiate this claim."

So there were 3,006 convictions in 19 years. As far as I know all or nearly all of these 'convictions' were fines. That works out at about 158 a year. Do you think this would be enough of a deterrent to change behaviour?

I have read the 2010 Inquiry (by Anna Skarhed) and it doesn't claim a reduction in the amount of prostitution. It claims that prostitution would probably have increased in Sweden as it has done in Denmark were it not for the Nordic Model. However, it does seem that her information about an increase in Denmark is incorrect.

The bit about the 'desired normative effect' is disturbing. In a democracy a government should reflect the attitudes of the populace: it shouldn't seek to change them. There is strong public support for criminalising men, there isn't strong public support for decriminalising women. So whether they support the Nordic Model or a different model like what is found in America is impossible to say.

The most important thing though is that the Swedish government has lied to its people about the effectiveness of its policies. In any country you might have a third of people who want prostitution and drugs to be criminalised, a third who want the opposite (usually because they think it doesn't work), and a third who are undecided. That undecided third will be swayed by what they are told. If they are told that it works then they will think "Well if it works at substantially decreasing the problem then I will go along with it".

The ICI report says that "reported users down from 13.6 per cent in 1996, 7.9 per cent in 2008 and 7.5 per cent in 2015". The more up-to-date figure for 1996 is 12.7% and for 2008 it is 7.6%. They give the 2014 survey figure of 7.5% (saying that it is from 2015). They omit the figure from the 2011 survey which shows that it was 10.2%. So there was a drop followed by a rise followed by a drop. It's obvious why they don't want to tell you about the 2011 survey result: they want you to believe that there was a continuous drop.

The ICI report is from 2018, so they should have been aware of the 2017 survey results. This puts the figure at 10%. So there was a drop (12.7% to 7.6%) then a rise (7.6% to 10.2%) then a drop (10.2% to 7.5%) then a rise (7.5% to 10%). None of which would surprise a statistician who expects statistics to rise and fall. It would surprise anyone else who has been told there was a continuous drop. This is cherry-picking, one of the worst examples.

These figures aren't even for 'reported users'. They are for the proportion of men who had paid for sex at some time in their life. We have the figures for men who are users, as well as for women who had been paid for sex at some time in their life. In 1996 1.3% of Swedish men were active sex buyers and in 2008 1.8% were. In 1996 0.3% of Swedish women had been paid for sex and in 2008 1.1% were. So even more cherry-picking. I have gone into the detail here.

There is evidence for an increased risk to women in prostitution in Sweden, but not proof. The evidence from France and Ireland is stronger. The Walby et al study of 2016 is very cherry-picky. Sylvia Walby doesn't tell her readers the statistics from Sweden that I have outlined above, only the ones that support her view that Sweden has been a success and reduced demand. She knows about the 2014 report from two Swedish women Mujaj and Netscher that has all of the relevant statistics. She makes a reference in her 2016 study of their 2014 study. However, her claim that the results from the 2014 Swedish survey are the lowest in Europe is not found in the Mujaj and Netscher study. So as well as being a cherry-picker she has made a false statement.

When you think that ICI was started by Sr Stanislaus Kennedy of the Religious Sisters of Charity who used to run Magdalene Laundries it's not really surprising that they are dishonest. Ruhama was founded by members of two orders of nuns both of whom had run Magdalene Laundries. Ruhama stated that 38% of Irish prostitutes have attempted suicide, which is another lie. Do they want to help women or do they want to stop sin? At least Dr Monica O'Connor was willing to say that the Nordic Model in France is harming women. She believes in the Nordic Model but is willing to say when it harms women. That makes her different from Ash Regan who is more determined to support this ideology no matter what.

Ash Regan's bill and evidence from France

Ash Regan's bill has been rejected by Scottish MSPs. So now there is no chance of having the Nordic Model in Scotland for the foreseeable future, not that there was much chance to begin with. I have been finding out what she has been telling people, and this document shows it more than any other that I have found. It is a transcript of a committee meeting from late last year.

"We can look at Sweden. After the buyers were criminalised, the share of men paying for sex fell by almost half, and Sweden now has one of the smallest prostitution markets in Europe."

This is not true. She may be referring to the surveys in Sweden that showed a drop from 12.7% to 7.6% between 1996 and 2008 in the proportion of Swedish men who had paid for sex at some time in their life (not 'men paying for sex'). Or she may be referring to the drop in the number of street-based sex workers. I have dealt with this extensively on other parts of this blog so I won't go over it again.

There is something new that I wish to talk about. Many people are saying that the reason why the Nordic Model failed in Ireland, both North and South, is because of lack of enforcement. Ash Regan has been telling people that France is different, France has enforced the law and it is working there.

"Other countries are not having trouble with enforcement. The latest statistics that I saw from France, which has not had the law in place for nearly as long as Sweden has, show that it has convicted 5,000 men. I know that France is a large country in comparison with Ireland and Scotland, so the context is different, but it shows us that enforcement of these offences is possible."

This is misleading. Paying for sex is a 5th class contravention and results in a fine. Thousands of men have been fined, few of them the maximum amount and it isn't such a large number for a country of this size over this many years. If a man doesn't pay the fine he often gets away with it. Many buyers simply ignore the notice. Enforcement agencies often lack the resources to chase non‑payment. A fine is a conviction but it doesn't carry the same consequences as in the UK: the conviction does not usually show up on the records used by employers.

It seems that the police in France have been going after men in Paris who pay for sex with street-based sex workers, leaving the men who pay for sex with indoor sex workers untouched. In any country, street based sex workers are only between 10% and 20% of sex workers.

"Most of the arrests take place in the public space (and not online) within the scope of street prostitution."

It looks like women are being forced off the streets and into flats. This is what happened in Ireland in 1993. I don't like street prostitution, I don't have anything to do with that, so I would not get arrested in France especially outside of Paris. The one advantage of street-based sex work and the reason why some women chose it is independence.

Before 1993 in Ireland there were many street-based sex workers. They were nearly always independent. When they were forced to work indoors many of them needed pimps. If they couldn't afford to rent a flat or to advertise they had to go to work for a pimp who could. So the 1993 law increased the number of pimps in Ireland. You can read about this in Rachel Moran's book Paid For and in the research done in the 1990s by Ann Marie O'Connor and her colleagues.

I believe that this happened in Sweden in 1999, was made worse in Ireland in 2017, and would happen in Scotland too if Ash Regan managed to get her way. The pimps are benefitting from the Nordic Model. Pimps like it when women can't be independent.

I don't want to see more pimping. I want to see more women working without pimps, working together for safety, making the rules for themselves and keeping the profits for themselves. That can't happen with the Nordic Model, the only way it can happen is with decriminalisation. Or just stop arresting young women for 'brothel-keeping': you'd think that we could all agree on that.

"These fines "are very unevenly distributed across the territory," notes the Observatory led by the Interministerial Mission for the Protection of Women against Violence and the Fight against Human Trafficking (Miprof). A majority of them (58%) were issued in Paris, while over the same period no fines were recorded in 36 departments, he said.

For the secretary general of Miprof, Roxana Maracineanu, "it is clear that the victims of "prostitutional violence" are "still largely invisible, going under the radar of the security forces and the public authorities in general"."

Pimping is spreading over the Internet, as it says below. Prostitution of minors is on the increase.

"However, in some parts of France, the law continues to be only partially implemented: the criminalisation of 'clients' remains largely inadequate and too heterogeneous across the country, and pimping is spreading over the Internet."

"The digitalisation of the prostitution system goes hand in hand with the increasing digitalisation of society. As a result, the victims of prostitution are increasingly invisible, as are the "clients" and the pimps. All stages of prostitution are now dematerialised: recruitment of victims on social networks, advertisements published on specialised platforms, appointments arranged by SMS and encrypted messages, etc. This new reality is forcing associations working in the field to adapt by developing digital outreach services. At the same time, while France ranks as the 2nd country in the world in terms of pornography consumption, FACT-S observes that pornography has become the most commonplace and violent form of online prostitution."

The above two paragraphs come from a report called The impact of the abolitionist law in France: Report by FACT-S 2025. It came out less than a year ago. It is not an official government report but put together by different NGOs. You would expect it to be biased in favour of the 2016 law change but it points out many of the problems.

It starts by saying that many women have been helped out of prostitution, although migrant women are not getting the same help. Sex workers are less visible now because of the increasing use of the Internet. Prostitution of minors has increased.

This is the core tension: the law targets demand, but enforcement targets visibility. Those two don’t line up well in a digital, indoor market. A relatively small, visible slice of prostitution absorbs most of the policing pressure. The larger, online-based part of the market is hard to touch without major surveillance powers that France (like most democracies) is reluctant to use. Much of prostitution is effectively untouched by fines, even though it is formally illegal to buy sex anywhere.

The majority of French sex workers who work indoors are unaffected. The minority of French sex workers who work outdoors have been harmed. Either they continue to work outdoors but in more difficult and dangerous conditions - earning less money. Or they begin to work indoors, often for a pimp. Or they can try to use the exit programme which has its problems.

"According to the official circular implementing the exit programme in January 2017 (DGCS/B2/2017/18), the organisation that applies on behalf of the person must provide the following documents: a request form to begin or renew the given exit route, evidence of the administrative, family and social situation of the individual, and a ‘sworn statement to cease the activity of prostitution’. Considering the fact that sex workers will lose their earnings, the law proposes quite modest financial assistance (see above). This support is allocated when the individual cannot benefit of any other form of social assistance. This means that French nationals and regular residents are not beneficiaries since they can obtain better financial assistance through other programmes. Financial support is supposed to be complemented by a priority access to social housing, yet this is almost never the case due to the dearth of supply of social emergency housing in France. Furthermore, applicants are requested to cease sex work as soon as their request for the exit programme starts, but the procedures usually take several months. This implies that during this waiting period the person remains without an income."

Why is Ash Regan telling people that France is not having trouble with enforcement? Why is she so keen to say that prostitution cannot be forced underground? She doesn't seem to have read the report. Nobody would want what has happened in France to happen in Scotland. The MSPs were wise to vote against it just a few days ago, although they have enraged many.

There is another report from 2020 that is very damning of the French prostitution laws. It says that in 2015 4% of students had been paid for sex. In 2019 7% had. This is similar to what happened in Sweden, according to the Mujaj and Netscher 2015 study. The issues of violence, STIs and sex worker independence are all discussed. One section is "Divergent explanations for the Act’s relative failure".

Ash Regan accepts that the Nordic Model hasn't worked in Northern Ireland or the Republic of Ireland. She says this is because the law has not been enforced there. She has been telling people that we have two examples of countries where the law has been enforced, France and Sweden. One thing that these two countries have in common is that there is strong evidence that teenage girls and young women especially are being paid for sex more than before the Nordic Model came in.

"[An] analysis carried out in 2019 by the University of Grenoble-Alpes, in conjunction with the Amicale du Nid and the [departmental directorate of social cohesion], updating the 2015 analysis, highlights a 3% increase in the percentage of students who had engaged in sexual relations in exchange for goods, services or money over this period (from 4% to 7%). […] Students who engage in sexual relations in exchange for goods, services, or money are in diverse situations as regards the practice of prostitution. Some of them do not necessarily identify as being involved in prostitution. The contact with clients mostly takes place via the internet. Advertising, escort, or sugar dating sites put sugar daddies, or older benefactors, in touch with ‘sugar babies’ in exchange for sexual favors [...]." Government report, p. 85

Below is Table 4 from page 26 of Prostitution in Sweden 2014 The extent and development of prostitution in Sweden by Endrit Mujaj and Amanda Netscher (Länsstyrelsen 2015). It shows that there has been an increase in girls/women who have received payment.

In columns 3 and 4 the Swedish word "år" did not get translated into "year" or "years". So column 3 regards 17 to 25 year olds and column 4 regards 15 to 29 year olds.

This is what would have happened in Scotland if MSPs had been stupid enough to vote for Ash Regan's bill.

I have created a page where I have countered other things that Ash Regan has been telling people.

Below are the documents that I have talked about in this post.

1. Official Report Criminal Justice Committee Wednesday 26 November 2025
2. FACT-S THE SITUATION OF PROSTITUTION IN FRANCE 9 YEARS AFTER THE ADOPTION OF THE ABOLITIONIST MODEL
3. Prostitution: the number of clients fined is stagnating, according to a study
4. The impact of the abolitionist law in France: Report by FACT-S 2025
5. The National and Moral Borders of the 2016 French Law on Sex Work: An Analysis of the ‘Prostitution Exit Programme’
6. Comparative Summary of Evaluation Reports on France’s 2016 Prostitution Act December 2020

This is a good one too. Long read: How the Nordic model in France changed everything for sex workers