The University of Chicago Press

Is There a Nordic Prostitution Regime?
Author(s): May-Len Skilbrei and Charlotta Holmström

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Source: Crime and Justice, Vol. 40, No. 1, Crime and Justice in Scandanavia (2011), pp. 479-
517
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May-Len Skilbrei and Charlotta Holmström
Is There a Nordic
Prostitution Regime?
ABSTRACT
Prostitution policies in the Nordic countries have undergone major
changes in the past 15 years. One that has drawn attention, within the
Nordic region and internationally, is the criminalization of purchase of
sexual acts or services in Sweden, Norway, and Iceland. Finland has crimi-
nalized buying sex from victims of trafficking or persons involved in pimp-
organized prostitution. Laws concerning prostitution have to be under-
stood in the light of how prostitution is defined and dealt with as a social
problem. The recent changes can be explained by reference to ideological
developments and developments in the prostitution market. That several
countries have implemented similar regimes does not mean that the Nor-
dic countries take a consistent approach. National policies have emerged
from different ideological and empirical contexts and have been combined
in diverse ways with different models for social work and other
interventions.
When the Icelandic Parliament criminalized the purchase of sex1 in the

midst of an economic recession in the spring of 2009, it became evident
that the question whether the Nordic countries’ prostitution policies
are beginning to form a common regime is a valid one. Sweden made
it illegal to purchase sex 10 years earlier, even though selling sex con-
May-Len Skilbrei is senior researcher at the Fafo Institute for Applied International
Studies, Oslo. Charlotta Holmström is senior lecturer at the Fakulten för Hälsa och
Samhälle, Malmö Högskola, Malmö, Sweden. This essay is based on a research project
comparing Nordic prostitution and trafficking policies funded by the Nordic Gender
Institute and the Nordic Council of Ministers.
1
We use several terms for the client in prostitution interchangeably. There are
variations from country to country and over time in which terms are used and which
are generally considered appropriate.
䉷 2011 by The University of Chicago. All rights reserved.
0192-3234/2011/0040-0007$10.00
479
480 May-Len Skilbrei and Charlotta Holmström
tinued to be legal. Finland introduced a partial ban on purchasing sex

in 2006. Norway introduced full criminalization of buying sex in 2009.
These legal reforms occurred at different times and were influenced
by different national and international discourses on prostitution, gen-
der, sexuality, social work, criminal justice, human trafficking, immi-
gration, and the role of the welfare state, but they are also connected
to one other. The Nordic countries are social democratic welfare states
with a strong emphasis on equality (Kautto and Kvist 2002) and there
is also a strong tradition of regional cooperation, particularly on the
issue of prostitution (Holmström and Skilbrei 2008). To understand
policy development in one country it is necessary to contextualize that
development within a Nordic context.
In this essay we explore development of prostitution policies in the
Nordic countries. We focus on Sweden as it has for the longest time
had—by traditional standards—the radical model of criminalizing only
buyers of sexual services, not sellers. The Swedish case has drawn con-
siderable international attention and been heralded by radical feminists
internationally (Raymond 2004). Politicians, journalists, and activists in
the other Nordic countries relate their arguments to the Swedish case,
discussing whether the “Swedish model” constitutes a “best practice”
for dealing with prostitution or not.
Criminalization of purchase but not sale of sexual services differs
from approaches to prostitution elsewhere. Several other European
countries have moved toward the introduction of regulation of the sex
industry. Many countries around the world prohibit both the buying
and selling of sexual services.
Different models for state intervention in prostitution have been
developed by scholars, distinguishing among prohibition/abolition, tol-
eration, legalization, and decriminalization (Westmarland and Gangoli
2006). It is common to dichotomize into abolitionist and liberalist pol-
icies (see, e.g., Thorbek 2002).
One-sided criminalization has posed a challenge to previous classi-
fications of prostitution policies. Criminalizing the clients while keep-
ing sale of sex legal does not fit any of these categories. Since the
abolitionist approach is to work toward banishing prostitution alto-
gether, such an approach implies criminalizing both selling and buying.
Economists Niklas Jacobsson and Andreas Kotsadam (2010) intro-
duced the term neo-abolitionism in order to characterize the Nordic
approach to prostitution.
Is There a Nordic Prostitution Regime? 481
There remain some notable differences between and within the Nor-
dic countries in how prostitution is dealt with. We describe and discuss
differences and similarities in the current regulation of prostitution,
social policies directed at prostitution, and also the intellectual history
of the subject in the Nordic countries. If we are to get a fuller under-
standing of the development of prostitution policies, they must be
placed within a wider framework and compared more explicitly to
other policy areas.
We trace how different arguments gained momentum, what issues
seemed to be at stake in the debates, and how the shift toward a focus
on clients, often referred to as “the demand side” in prostitution, came
about (Svanström 2006b; Siring 2008). To understand this shift, both
previous laws and regulations on prostitution and current constructions
of “the problem with prostitution” are relevant, as are developments
within social work and research.
Even though the prostitution policies in the Nordic countries look
very similar to those of the outside world, they differ substantially in
how they were argued for and how they function. At the core of these
differences are diverging explanations for and understandings of pros-
titution, and differences in what the laws were introduced to achieve.
Criminalization of clients in Sweden was introduced in a society that
had only a small prostitution market in order to change attitudes to-
ward gender, sexuality, and prostitution—building on a feminist anal-
ysis. Debates in the other countries related more directly to current
developments in the prostitution market and to class inequalities and
globalization.
In the Nordic countries, as elsewhere in Western countries, prosti-
tution policies are changing, quickly and in a variety of ways (Lehti
and Aromaa 2006). The patterns of these changes offer insights into
how policy processes work concerning controversial subjects such as
prostitution.
This essay consists of six sections. Section I briefly describes current
laws in the five Nordic countries. Section II, to provide a context for
recent changes, discusses approaches to prostitution in the five coun-
tries as they have evolved since the 1960s and 1970s. Section III dis-
cusses social work approaches to addressing the needs and problems
of prostitutes. Section IV discusses research on prostitution problems
and Section V discusses changing prostitution markets (human traf-
ficking, increasing numbers of foreign prostitutes, the influence of new
technologies, shifts in where prostitution occurs), estimates of the size

of the prostitution markets, and evidence concerning the efforts of the
1999 Swedish law. Section VI discusses the limits of current knowledge
and the need to view prostitution in all its increasing complexity and
diversity.
I. The Current Legal Approaches

The criminalization of the purchase of sexual services in Sweden, Nor-
way, and Iceland, and the partial criminalization in Finland, may signal
the formation of a joint Nordic approach to prostitution, with a focus
on the client as the marker of “a Nordic prostitution regime.”
Purchase of sexual services in Sweden was criminalized January 1,
1999, after two decades of debate about whether to criminalize one or
both parties involved in prostitution. Swedish authorities issued two
white papers on the subject, and it was considered in several other law
reform processes as a secondary issue. The 1995 white paper on pros-
titution (Socialdepartementet 1995, p. 15) proposed criminalizing both
buyers and sellers, an approach disapproved by most participants in the
public review of the act. The final push toward criminalization came
when the issue was linked to a broader initiative on sexualized violence
in the Act on Violence against Women. The Swedish parliament en-
acted the proposed law. It was aimed at changing societal norms and
influencing the size of the prostitution market. It was also designed to
influence policy developments elsewhere, as a model for use by poli-
ticians and activists in other countries in their fight to criminalize the
purchase of sex.2
The question whether to criminalize clients was debated in other
Nordic countries, particularly Finland and Norway. In Finland it was
debated for several years. A working group established to explore the
question reported in July 2003, recommending that purchasing sexual
services should be criminalized. The white paper was the focus of a
public hearing, and 72 statements were given; some favored criminal-
ization. The decision was postponed. The ultimate decision in 2006
2
In 2005, the definition of prostitution in the Swedish penal code was changed,
from “sexual relations” to “sexual act.” The goal was to attain more neutral language,
as “sexual relations” was thought to connote “something voluntary and mutual” (Re-
geringskansliet 2005). The law was also changed to include temporary sexual relations
that someone else paid for.
was to criminalize buying of sex from victims of trafficking or from

persons involved in pimp-organized prostitution (Marttila 2008).
Norway has experienced debates on criminalization on and off since
the early 1980s. These debates led to a parliamentary vote in favor of
a law against buying sex in 2008; it was implemented in 2009. The act
prohibits Norwegian residents from buying sex abroad ( Jahnsen
2008).3
In 2009 Iceland criminalized the purchase of sex. The law was in-
troduced without much preparatory work, but activists and lobbyists
had worked toward it for many years and the issue had been debated
in the Parliament for several years (Atlason and Gudmundsdóttir 2008;
Halldórsdóttir 2009).
Criminalization of the purchase of sexual services has also been the
subject of heated debates in Denmark, but only in the last few years.
The outcome of the latest efforts to introduce such a law remains an
open question (Bjønness 2008). At the time of writing, buying sexual
services is thus fully criminalized in Sweden, Norway, and Iceland and
partially criminalized in Finland. Buying sexual services from persons
below the age of 18 is illegal in all the Nordic countries.
In the last two decades other important legal changes concerning
prostitution have been made, particularly the decriminalization of the
sale of sex, which involve decriminalization of soliciting and vagrancy,
but also of living on the earnings of indecency. The last country to
decriminalize the sale of sexual services completely was Iceland, which
removed its ban against living on the earnings of prostitution in 2007.
The acts of selling sex or of selling sex in particular ways were for long
periods the only behaviors addressed by prostitution laws in the Nordic
countries. This fact makes the recent criminalization of purchase a
radical one. Decriminalizing the sale was the first step toward a redis-
tribution of responsibility from the seller to the buyer. Criminalization
of the purchase was the second step. This shift took place over a short
historical period, particularly in Iceland, where selling sex was fully
decriminalized in 2007. Buying sex was criminalized in 2009.
Another central issue concerns involvement in another person’s
prostitution, the so called third party in prostitution (Davidson 1998).
This legislation is of particular importance, as very exploitative rela-
3
Even though the Swedish law has not been used in this way, it has been argued
that it can be applied when Swedes buy sex abroad (Ekberg 2004; Justitiedepartementet
2010).
tionships and situations are often involved that make crimes more se-
rious, in a legal sense. The third party can be someone organizing
prostitution or someone mediating contact between the seller and the
buyer. The relationship can range from assistance to extreme forms of
exploitation. Pimping and procuring are illegal in all the Nordic coun-
tries. The existence of these laws has not been challenged, even in
periods in which much attention is devoted to law reform. Most par-
ticipants in policy debates have agreed that pimping should remain
illegal.
The Nordic countries have, however, seen great changes in how
third-party involvement is dealt with, especially what acts constitute
pimping or procuring and to what extent exploitation is a prerequisite.
Some of these changes are linked to the introduction of prohibitions
against human trafficking and how these are implemented.4 There are
some differences between the Nordic countries in the relationship be-
tween the policies on pimping/procuring and trafficking; there are dif-
ferences in how the boundaries between different forms of organization
and exploitation of prostitution are drawn. While overlapping laws on
pimping/procuring and trafficking were not regarded as troubling in
Denmark, the Norwegian authorities removed exploitation as a pre-
requisite for pimping/procuring when introducing a new law on traf-
ficking in 2003. Thus the definition of pimping/procuring was dra-
matically changed, as all forms of organizing another person’s
prostitution now constitute pimping/procuring, even when there is no
monetary gain (Skilbrei 2008).
The national penal codes provide an overarching framework for how
prostitution is dealt with, but there are many other national policies
and regulations that need to be considered. Laws in action may be
something entirely different from laws in books. Nowhere is that more
evident than if we look closer at how the laws on pimping/procuring
have been implemented. Even though there is seemingly great consen-
sus on keeping the laws against pimping and procuring, reviews of
4
Combating trafficking in human beings has been high on the political agenda in
all the Nordic countries. All have signed and ratified international conventions on
human trafficking such as the 2003 UN protocol on human trafficking; the so-called
Palermo Protocol, and the Council of Europe Convention on Action against Trafficking
in Human Beings, which came into effect in 2008. Most Nordic countries have de-
veloped and implemented action plans on trafficking, with actions also relating to the
regulation of prostitution or to social measures directed toward the parties involved
in prostitution as a way of preventing trafficking.
court cases show few prosecutions during the 1980s and 1990s (Giert-
sen 1985; Prieur 1985; Moustgaard 2008; Skilbrei 2008).5 A lack of
prosecutions could of course signify that very little pimping/procuring
is taking place, but empirical evidence shows that not to be the case
(see, e.g., Månsson 1981; Skilbrei 1998).
A variety of other laws and regulations are also relevant. Even
though the responsibility and therefore the culpability for prostitution
are placed on the buyers of sex in most of the Nordic countries, other
policies build on different premises.
One example is the use of immigration law. Persons travelling to
Denmark,6 Finland,7 and Sweden8 from outside the European area can
be stopped and returned at the border if the border patrollers have
reason to believe they have come to sell sex (Holmström and Skilbrei
2008). This policy targets sellers, which is inconsistent with the general
shift of attention to buyers.
Finland provides another example of other laws being used to influ-
ence the prostitution market. Helsinki approved new regulations pro-
hibiting both selling and buying sex in public places in 1999, a pro-
5
The number of cases has risen dramatically, e.g., in Denmark from 15 cases during
1990–2001 to 271 in 2000–2007 (Moustgaard 2008, pp. 287–88). In Norway, there
has also been a great change, which the police describe as due to their being more
aware of third-party involvement in prostitution today and having more resources to
follow up with because trafficking for prostitution is high on the political agenda
(Skilbrei 2008).
6
Third-country nationals selling sex in Denmark are in breach of the Danish im-
migration act, which makes their stay in Denmark illegal. It is difficult to obtain figures
on how often the act is enforced. When figures are available, they show substantial
use, e.g., in 2002 when 51 women were expelled from Denmark for this reason (Social-
og ligestillingsdepartementet 2002).
7
In Finland the Foreigner Act was amended in 1999 to ban foreigners’ selling sex
in Finland; it was introduced as a way to combat organized crime (Penttinen 2008).
8
In Sweden this policy is regulated in 4 chap. 2 §2 (suspected of coming to the
country to earn money through dishonest means) and 4 chap. 2 §, first part of 1 (lack
of means for subsidence) of the Immigration Act. It is difficult to learn how often the
possibility is made use of, but the act mentioned is described in a problematizing way.
The 2003 yearly report of the social project Prostitutionsgruppen in Malmö, e.g., states:
“When we come across foreign women who do not belong in Sweden, we contact the
immigration police” (Prostitutionsgruppen Malmö 2003, p. 5). They do not say whether
this excludes giving them the same assistance other women in street prostitution are
offered, but it does not sound as if they do. There are many other references in media
coverage indicating that non-Swedes found in the prostitution market are sent out of
the country (see, e.g., Expressen 2003). A report by the Rikskriminalpolisen (2002, p.
25), evaluating the effect of the prohibition of buying sexual services on trafficking,
observed that it is a problem that the law only permits, but does not require, rejection
of people suspected of coming to the country to sell sex.
hibition that was made national in 2003 and was introduced as a way
to promote safety in public places (Marttila 2008). As street prostitu-
tion in Helsinki is dominated by foreign women, it can be argued that
the move toward criminalizing it effectively introduced a two-tiered
prostitution market in which the ethnic “others” on the streets are
being prosecuted, while Finnish women work indoors in a privileged
niche market (Marttila 2008; Penttinen 2008). Criminalizing the buy-
ing of sex only within organized prostitution networks affects the mar-
ket for foreign women’s prostitution much more than that for legal
residents, as foreigners are less able to work unorganized in Finland.
Distinguishing foreign from “Finnish” prostitution through criminal-
izing the buying of sex within organized prostitution networks and the
ban against street prostitution has practical and ideological conse-
quences. Buying sex from foreigners is made to seem more morally
wrong and risky, while buying sex from Finnish women is sanctioned.
Similar legislation has been discussed in Norway. The Oslo city
council voted to criminalize certain aspects of prostitution as a way to
rid Oslo of it (Skilbrei 2009). This move is part of a wider European
development of sanitizing and abolishing prostitution from public
space (Tani 2002). Under this policy, people selling sex are treated as
responsible for prostitution.
Stopping possible sellers of sex at the border and prohibiting certain
forms of prostitution as a public nuisance and security problem send
different signals than does a national approach in which the seller is
portrayed as the victim of prostitution, not the perpetrator. In all these
exceptions to the “Nordic approach to prostitution,” the sellers’ “for-
eignness” is effectively made relevant and the prostitution policies are
thereby ethnicized (Marttila 2008). We return to this contradiction
below.
II. History
No country approaches prostitution in a vacuum. In hindsight, distinct
regimes or models appear to cross borders. The initial impetus for
problems the policies set out to deal with may seem national and spe-
cific at the time, but in different times throughout history, different
means of control and assistance seem relevant and appropriate. When
European countries came to see prostitution as a risk factor in the
spread of sexually transmitted diseases in the nineteenth century, many
replaced prohibitionist policies with regulation, thus condoning certain

forms of prostitution in order to prevent deterioration of public
health.9 This approach has to be understood in the light of discourses
on sexuality, gender, health, and control. It also has to be understood
as a sign of the influence of medical discourse in the social engineering
of nineteenth-century Europe, making it possible temporarily to re-
place moral sensitivities with pragmatic harm-reduction efforts (Greve
2005). Two centuries later, we can analyze how this framework
“spread” from country to country, and how it was based on acceptance
of inequalities of gender and class that seemed progressive at the time.
We can also see the injustice being done to the women subjected to a
strict control regime for the benefit of the greater good.10 The chal-
lenge is to look at current prostitution regimes in just as contextualized
a way, freed as much as possible from contemporary “taken-for-grant-
edness” and political controversies. Toward that goal, we give a detailed
account of developments in prostitution markets, debates, and policies
in recent decades, and of perspectives and fields of knowledge, in order
to explore how what politicians and others know and think about pros-
titution influences policy development. We pay special attention to
how knowledge production and policy debates influenced each other
in order to identify blind spots in the current approaches to prostitu-
tion.
Prostitution has been regulated in a variety of ways in the Nordic
countries in recent decades: regulation, criminalizing the selling of sex,
and regulation of immoral behavior in public space. We trace the his-
tory of the contemporary policy regime to the late 1970s when societal
changes in gender norms and sexual mores led people to question func-
tionalist approaches to prostitution and the sexual double standard that
guided them (see, e.g., Prieur 1985).11 The women’s liberation move-
ments put gender inequalities on the societal agenda. The increased
9
The regulation of women in prostitution meant that they were registered as “public
women.” Within this system, women selling sex were kept under control, both in
prostitution and in their private lives, while men buying sex were not seen or treated
differently from other men.
10
For analysis of the regulation frameworks in place in the bigger cities in Nordic
countries from the early nineteenth to the early twentieth century, see Schiøtz (1977),
Pedersen (2001), Svanström (2006a), and Markkola (2007).
11
This process cannot be understood in terms of a linear historical development.
Traces of the logic in the regulation approach and the functionalist approach are present
in later periods in both social and legal terms.
importance accorded expressive sexuality did not fit well with crimi-

nalization of instrumental sex for money in prostitution. These devel-
opments coincided with the growth of the public sector and reconcep-
tualization of relations between the state and its citizens. Women
increasingly sought paid employment. Tasks formerly performed in the
private sphere, such as childcare and care for the elderly, were trans-
ferred to the public sphere and reconceived as a public responsibility.
Norms were renegotiated, and that changed how many areas of society
were understood and governed through criminal justice and social
work. It was in this normative climate that feminists began to question
men’s rights to women’s sexuality and the middle class’s rights to the
working-class body. The question how to regulate prostitution came
under debate.
The preceding description is more valid for Norway and Sweden
than for the other Nordic countries. Although the same developments
marked Danish society in the late 1970s, the emphasis on expressive
sexuality did not lead to demands that prostitution be seen as a public
responsibility in the same way (Prieur 1985) but reinforced the view
that sexuality, even of the paid variety, is a private matter (Lautrup
2002; Balkmar, Iovanni, and Pringle 2009).12 The Finnish development
also was different. Margaretha Järvinen (1990) studied government
control of women involved in prostitution in the years 1945–86. She
observes that prostitution was a more invisible phenomenon in Hel-
sinki than in the other Nordic capitals. As late as 1984, a white paper
concluded that prostitution was not a social problem to any large extent
( Järvinen 1990). Lack of visible prostitution may have made it a less
self-evident issue for feminist activism. The opposite also may be true:
lack of interest by feminist activists in prostitution may have rendered
prostitution invisible.
Prostitution came increasingly to be viewed as a social problem and
a state responsibility, particularly in Norway and Sweden. Reduction
in prostitution became an explicit goal and a basis for policy discus-
sions. Whether individual-based or structural explanations are empha-
sized varies over time and between countries. In Norway and Sweden
12
In 1967, Danish political parties regarded prostitution as a social problem (Ras-
mussen 1987). Defining prostitution as a social problem did not entail discussion of
possible legal intervention but was rather understood to signify that it was not a legal
problem. In Sweden and Norway, defining prostitution as a social problem was the
starting point for identifying a need for legal intervention to complement this defi-
nition.
approaches to prostitution in the 1970s and 1980s shifted from a focus

on individual problems and poverty to a focus on class and gender-
based inequalities as causes of problems and poverty, and therefore also
of prostitution. In Sweden, gender was given a greater emphasis than
in Norway, where the class perspective has been stronger. The seller
is perceived as the participant in prostitution with the fewest resources
and with limited opportunities to choose another life (e.g., Larsson and
Månsson 1979; Høigård and Finstad 1986).13 In Denmark, individual-
based explanations of prostitution remain common (Bjønness 2008).
This may be because psychology has played an important role in the
study of prostitution, while sociology and criminology have been more
important in Sweden and Norway (Balkmar, Iovanni, and Pringle
2009).
In the following pages we discuss recent approaches to prostitution
in the Nordic countries, looking into how and why changes unfolded.
Sweden receive particular attention because criminalization in 1999
makes Sweden a particularly interesting example and because ideolog-
ical developments played larger roles there than in the other countries.
The Swedish development was an important point of reference in the
other Nordic countries and anticipated common Nordic developments.
Few changes in legislation on prostitution have attracted so much at-
tention and caused so much debate, both within and outside the Nordic
countries. There are many reasons, one being that the law cut into
burning issues in the ongoing international debate on prostitution, par-
ticularly issues of public control and regulation (Månsson 2002).
Selling sex is legal in all the Nordic countries, but that does not
make it legitimate or regularized. In Denmark, Sweden, and Norway,
women and men in prostitution lack such civil entitlements as pension
or parental insurance or sickness allowance, even though they are ex-
pected to pay tax. Several European countries have regularized pros-
titution in the last decade to ensure the rights of women and men in
prostitution as workers. Such an approach can be seen as pragmatic
and as reducing harm; it is also necessary to view it ideologically, with
prostitution being framed as work. By contrast, in the Nordic countries
13
This reconceptualization also has to be seen in the light of international devel-
opments. The UN Convention on the Elimination of All Forms of Discrimination
against Women (CEDAW), launched in 1979, explicitly referred to women’s rights to
not be exploited in prostitution (art. 6). Several feminists, particularly Kathleen Barry,
wrote on prostitution as inherently exploitative. Stig Larsson mentions Kathleen Barry
as someone who related to prostitution in a “Scandinavian way” (1990, p. 4).
prostitution is viewed as an expression of gender or socioeconomic

inequality and in Norway and Sweden is often seen as comparable to
rape, domestic violence, and incest (Skilbrei 2001; Ekberg 2004).
A. Sweden
In Sweden, prostitution was understood as the product of a lack of
gender equality in society, something not voluntarily chosen but caused
by structural, cultural, and personal inequality and abuse (Regering-
skansliet 2002). Although prostitution had not been explicitly referred
to as violence before the law was introduced in 1999, the government
had viewed it “as closely related to violence against women” (Dodillet
2009; Justitiedepartementet 2010). By 2002 the government explicitly
defined prostitution as men’s violence against women (Regeringskans-
liet 2002). Gender was considered the main reason for prostitution;
differences between individuals and groups in prostitution seemed less
important: it is as women that people became victims of prostitution.
This position has been portrayed as the only correct one for feminists
to take.14 Mona Sahlin, then minister for equality, explained to a jour-
nalist: “If you are a feminist, you cannot relate to prostitution in any
other way than to see it as male domination” (Huldén 2003).
Several scholars have written on the process that led to criminali-
zation of clients in 1999 (Gould 2001; Kulick 2003; Olsson 2006; Svan-
ström 2006b; Dodillet 2009). What is evident in all these analyses is
that it is necessary to look, not only at the political debate and the two
white papers preceding the law, but also at how changes in ideology
toward prostitution occurred within a larger societal debate during the
1960s and 1970s.
Since 1999, Sweden’s attempt to do away with the “world’s oldest
profession” through criminalizing clients has often been criticized.
Those who view commercial sex as a legitimate commercial sector of
society and who argue for the acceptance of prostitution as work have
been especially critical. Others, focused on the possible negative con-
14
When prostitution is defined in this way, any prostitution other than women selling
sex to men is made invisible. The law that prohibits the purchase of sexual services is
gender neutral but is often referred to in gendered ways, as if it applies only to certain
forms of prostitution. Gunilla Ekberg writes (2004, p. 1187): “This Law recognizes
that it is the man who buys women (or men) for sexual purposes who should be
criminalized and not the woman.” Ekberg was at that time a special adviser on pros-
titution and trafficking to the Swedish government and the organizer of the work on
the governmental action plan on these issues.
sequences for people selling sex, have criticized the law as based on
inaccurate assumptions about prostitution and the power relations
within it. To those, however, who view prostitution as an expression of
men’s sexual exploitation of and violence toward women, the law is a
major breakthrough and an important step toward a more gender equal
society.
The normative goals of the law have also been criticized. Don Kulick
(2003) argues that the normative use is especially important in Sweden
and differs from how the purpose of such laws are framed in many
other countries. A Norwegian governmental working group on the
regulation of the purchase of sexual services criticized the normative
rationale in Sweden and argued that whether the law is substantially
sound should be more important than the need to “send a signal”
(Norwegian Ministry of Justice and the Police 2004). The law has also
been criticized for aiming not only to accomplish gender equality but
also to achieve other less noble causes relating, for example, to certain
forms of migration and moral decay (Gould 2001; Kulick 2003; Träsk-
man 2005).
B. Finland
Discussions in Finland and Norway were focused more on practical
considerations and less on the normative function of the law. In Fin-
land, politicians needed to address an increase in prostitution involving
foreign women and a fear of organized crime involved in trafficking
(Marttila 2008). This need links the Finnish debate and practice more
closely to issues of ethnicity and nationality. The Finnish prostitution
market has been remarkably international since the early 1990s. Given
that the prostitution of Finnish women and men is not generally de-
scribed as being so serious a problem as prostitution involving foreign
sellers, the Finnish model seemed appropriate from a Finnish perspec-
tive.
C. Norway
The increasing internationalization of prostitution markets was of
concern in Norway in the late 2000s, as were the potential effects of
the Swedish law on buying sex and the perceived problem of finding
good ways to combat trafficking ( Jahnsen 2008). The starting position
in Norway has long been that people selling sex are vulnerable and
have few opportunities to choose work other than prostitution.15 The

purported root of this vulnerability has varied over the last 30 years.
Gender inequality and gender norms have been important explana-
tions, but never the only ones. In earlier discussions there was a strong
focus on class inequalities; later, more emphasis was laid on global
inequality as a cause of prostitution and trafficking ( Jahnsen 2008).
The increased numbers of foreign prostitutes in Norway created much
pressure to find new solutions (Stenvoll 2002; Skilbrei 2009). The final
debates that led to the vote in favor of criminalization had a strong
pragmatic flavor. Prostitution was hotly debated throughout the 2000s,
but debate seems to have been more heated in Norway than elsewhere.
Yvonne Svanström (2006) describes a consensus in perspectives on
prostitution in Sweden within research and feminist organizations,
which seems to have influenced views among the general public. This
consensus did not happen in Norway. Proponents of criminalization
describe being criticized by social workers, feminist organizations, and
researchers (Håland and Stø 2009). In Norway, the debate was fierce
and polarized, with proponents both sides arguing that they knew best
what would produce less harm for people selling sex ( Jahnsen 2008).
Several competing explanations have been given for the Norwegian
criminalization: long-term efforts by feminist organizations (Håland
and Stø 2009), grassroots efforts within the political parties (Bergstø
2009), and fears of unwanted migration ( Jahnsen 2008).
D. Iceland
Criminalization in Iceland seems to have been strongly linked to
feminist perspectives, with the radical feminist organization Stigamót
playing a prominent role (Halldórsdóttir 2009). Swedish officials and
debaters visited Iceland on several occasions to attempt to influence
the political will to criminalize the purchase of sex also in Iceland, and
the Swedish example was prominent. Feminists and female members
of parliament were particularly active in the debate (Atlason and Gud-
mundsdottir 2008; Halldórsdóttir 2009). Little has been written on the
introduction of the ban on purchasing sexual services in Iceland.
15
Debates in Norway parallelled those in Sweden, and on several occasions the
Norwegian approach to prostitution was described as more radical then the Swedish.
See, e.g., Lihme (1992, p. 14), who discussed prostitution policies under the headline:
“We find the two opposite poles of European prostitution policies in Amsterdam and
Oslo, respectively” (our translation).
E. Denmark
A ban on the purchase of sexual services has been discussed in Den-
mark. It is, however, an open question how great the support is for
such a law, as Danish society seems to be ambivalent toward prosti-
tution. In public debate, one can hear both the “liberal” argument that
prostitution belongs in the private sphere and the “radical feminist”
argument that prostitution as such is exploitative and that any purchase
of sex should be punishable (Lautrup 2002; Bjønness 2008). Marlene
Spanger (2008) has argued that in Denmark, unlike in Sweden and
Norway, feminism was not an important perspective in debates on
prostitution policies until the emergence of recent concerns about traf-
ficking.
Danish politicians are concerned to emphasize the responsibility of
clients, but only a few years ago clients were not seen as a part of “the
problem with prostitution.” In 2005, the Danish authorities proposed
a holistic effort (Socialministeriet 2005),16 in which clients are not men-
tioned even once. Support for criminalizing the purchase of sexual ser-
vices seems to have grown lately, a development Marlene Spanger
(2008) relates to the increased number of foreign prostitutes in Den-
mark. In Denmark, more than in the rest of the Nordic countries,
individual explanations for prostitution are still influential (Bjønness
2008), perhaps because psychologists are central in the development
of knowledge about prostitution. Criminologists and sociologists play
greater parts in Norway and Sweden (Balkmar, Iovanni, and Pringle
2009).
III. Social Problems Need Social Work

Prostitution and the parties involved are not regulated by legal mea-
sures alone. Sellers have increasingly been targeted by social interven-
tions aimed at assistance and harm reduction. Defining women selling
sex as a target group for social intervention builds on a redefinition of
prostitution as a relation in which the seller is not a willing participant
but a victim. Prieur (1985) pointed to such a possible future develop-
ment: “There is a clear connection between being seen as respectable
clients within the framework of social services and being seen as victims
16
The Danish title (Et andet liv: Regeringens forslag til en helhedsorienteret indsats på
prostitutionsområdet) translates to “Another life: The government’s proposal for a ho-
listic effort in the field of prostitution.”
within the framework of criminal justice systems” (p. 9). The crimi-
nalization of clients and the targeting by social work of people selling
sex can thus be seen as two sides of the same coin.
The increase in targeted social services started in Sweden in 1977
when a social work project in the city of Malmö sought to offer exit
strategies to women in prostitution (Månsson 1981; Larsson 1983).
Following this project, several others were established in Sweden and
a welfare-oriented approach to prostitution was adopted. Measures and
interventions focused on giving support to professionals and to people
in prostitution (Holmström 2008).
In Norway, social initiatives grew out of concerns about visible pros-
titution, especially youth prostitution, around 1980 (Finstad, Fougner,
and Holter 1982). Social initiatives directed at people selling sex grew
out of general concern about individual marginalization; class, gender
and inequality; social workers’ knowledge of prostitution; and research,
especially work by Høigård and Finstad (1986; published in English as
Backstreets [1992]). In Denmark, the prostitution services program, the
Nest, was established in Copenhagen in 1983. Since then social work
directed at prostitution has been highly developed in Denmark.
Social initiatives can be understood in terms of a political movement
toward decriminalization; growing support by governmental and non-
governmental organizations for persons involved in prostitution; and a
developing view by politicians, bureaucrats, and the general public of
the person selling sex as a victim. Such a view is linked not only to the
idea of prostitution as harmful but also to ideas about the influence of
structural, cultural, and individual power issues on recruitment into
prostitution.
Important differences in what services have been given priority in
the last 30 years seem to reflect differences in approaches to prosti-
tution and the people involved in it. Social services offered in Sweden
are to a great extent directed at enabling women and men to exit pros-
titution ( Justitiedepartementet 2010, p. 49).17 In Denmark, Finland,
and Norway, social work initiatives have harm reduction as an explicit
starting point. Harm reduction entails basing assistance on what needs
people themselves define rather than focusing only on promoting exit.
Harm-reduction strategies in relation to prostitution include handing
17
Even though both men’s and women’s prostitution is the target for social work,
women’s prostitution gains far more attention.
out condoms and lubricants and offering free medical assistance. Such
strategies are controversial in Sweden, where social workers feel an
obligation not to facilitate, and thus promote, prostitution (Skilbrei and
Renland 2008).
The introduction of prohibitions against buying sexual services has
influenced how social work is argued for and how it operates. In Swe-
den, Finland, and Norway the laws criminalizing the purchase of sexual
services were accompanied by social initiatives to support persons who
wanted or had to exit prostitution because the laws would negatively
affect the lives of people selling sex (Skarstein 2008).
In recent years local, municipal initiatives in Sweden have offered
harm-reduction interventions (Holmström 2008). Developing a harm
reduction approach within local municipal social initiatives can be in-
terpreted as a breach of the dominant discourse concerning social ini-
tiatives and prostitution ( Justitiedepartementet 2010) and as an adap-
tation to the more pragmatic approaches.
There are thus important differences in the execution of social work
between, and even within countries. Social work is described as central
to the approach in all the Nordic countries, but what is meant by that
differs significantly.
IV. Knowledge Production

Knowledge production involving academic researchers has been a ma-
jor feature of social work organizations in the Nordic countries. The
Malmö project in 1977, for example, was initiated by sociologists who
participated in the social outreach work. A similar process of exchange
and interplay between social scientists and social workers took place in
Norway a few years later (described by, e.g., Finstad, Fougner, and
Holter [1982]). The style of work exhibited strong similarities with the
research method known as action research. Järvinen (1990) describes a
shift in the approach to prostitution when a feminist perspective
emerged during the 1970s and 1980s. The feminist tendency was a
development in many Western countries, but she describes it as par-
ticularly strong in the form of “the new Nordic prostitution research”
(p. 14). Gender inequality was seen as a major reason for prostitution,
as were symbolic aspects of the gender order (p. 17). Individual child-
hood trauma continued to be included among reasons for women’s
prostitution, but they too were placed within a wider framework of

gender and class.
Social work and related research problematized a phenomenon that
in the 1960s and 1970s was generally understood within a functionalist
approach or described in apolitical terms ( Järvinen 1990). Why pros-
titution existed seemed self-evident, both in the period of regulation
and afterward; it often was explained by a discrepancy between supply
and demand for sex outside prostitution. Why women chose to be
involved in prostitution needed more explanation and was often linked
to individual childhood traumas and to poverty, abuse, disease, and
alcoholism.
This background is relevant for understanding current approaches.
The existence and strength of the functionalist perspective in the Nor-
dic countries is vital to understanding the later developments in the
legal approach, social work, and research. Several have argued that
today’s lack of interest in nuances and insistence on a definition of
prostitution as gendered violence in Sweden must be seen as a reaction
to the previous functionalist and liberal approach. Hanna Olsson
(2006) describes the period before the late 1970s as a liberal sex epoch
which influenced attitudes toward prostitution. This sexual liberalism
meant that the client in prostitution was understood as someone who
had problems finding sexual partners without paying and who had the
right to a sex life (Olsson 2006). Later changes in attitudes have to be
viewed in this light, Olsson argues, as a reaction to a position that was
taken too far.
Don Kulick (2005) also deals with the origin of current understand-
ings of prostitution in Sweden and changing ideological and legal ap-
proaches. Kulick argues that sexual liberalism in earlier decades pro-
duced reactions that led to changes in public debate. He dates it to an
earlier period than Olsson, going back to the 1950s and 1960s to find
sexual liberalism as an ideology, whereas in the 1970s the debates on
sexuality increasingly came to be about power. Susanne Dodillet (2006)
argues that the shift toward viewing prostitution within a societal con-
text and linking it to power came earlier, showing that even in the era
of sexual liberalism, the boundaries between accepted and unaccepted
sexual acts and sexualities were strong and that power relations were
seen as a relevant perspective.
As a reaction to the functionalist approach, social workers and schol-
ars wanted to document the marginalization of many people involved
in prostitution and how prostitution needed to be contextualized in

power relations.
Knowing what past perspectives have been applied to prostitution is
central to framing the knowledge produced at different times, not least
why some issues are given priority and others not. Even today, much
knowledge production is concerned with detailing exploitation in pros-
titution and the lack of alternatives among people selling sex.
The development of research with strong links to social initiatives
is an important element of early knowledge production about prosti-
tution in the Nordic countries and remains so today. Social initiatives
themselves produce a great deal of knowledge. In recent years social
service providers have continuously been commissioned to study pros-
titution. The Swedish National Board of Health and Welfare is, for
example, commissioned to collect data concerning the scope and de-
velopment of prostitution and social initiatives carried out at the local
level. Another example is Norway’s Pro Centre, appointed the coun-
try’s national resource center on prostitution in 1994.
A significant trait of the knowledge produced about prostitution in
the Nordic countries is that it describes social marginalization of peo-
ple selling sex in great detail, which has offered vital knowledge for
developing targeted social work. This close link between research and
social work and thus to the needs of people involved in prostitution is
a strength of the knowledge base in the Nordic countries.
But there are also problems. One is that the knowledge base may
not be as sound as more purely academic research. Stig Larsson (1990,
p. 5) contends that education for social workers is not research-based
in all countries, for example, not in Norway; as a result some of the
early work on prostitution consisted more of descriptions than of sys-
tematic evidence. Second, this knowledge is closely related to social
work, which means it includes groups being targeted by social inter-
ventions—particularly women in street prostitution. There is signifi-
cantly less knowledge about women and men engaged in less visible
forms of prostitution, transacted, for example, through the Internet or
in indoor locales such as brothels and massage parlors. In Norway,
where Norwegian women mainly sell sex indoors and foreign women
in the streets, knowledge about Norwegian women in prostitution is
less well developed and systematized than knowledge about foreign
women.
Producing knowledge about prostitution through social work and
social scientific research has consequences for what type of knowledge

is developed. Biases affecting what parts of the prostitution market and
what actors are made visible can have serious consequences for policy
debates and implementation. Prostitution taking place off-street, men
selling sex, and Nordic women involved in prostitution are much less
visible in knowledge production and public debate. These groups are
less likely to be taken into consideration in the development of legal
measures and social interventions. Prostitution is constructed as pri-
marily or only a certain type of social problem: the phenomenon’s
complexities and variations may be ignored (Pettersson and Tiby
2003). Particularly in Sweden, knowledge was for a long time devel-
oped almost exclusively through social work research directed at Swed-
ish women selling sex on the street. The Danish approaches to social
work and knowledge production seem to be quite different and have
produced much knowledge about indoor prostitution (see, e.g., Ped-
ersen and Heindorf 2000; Haansbæk 2001; Christensen and Barlach
2004).
Knowledge about the scope, forms, and experiences of men’s pros-
titution is scarce. There is a long history of not treating men’s pros-
titution as a problem, and most forms of regulation have not applied
to men. In some instances, men’s and women’s prostitution have been
regulated by separate acts; preparatory work leading to the law sepa-
rates the two forms of prostitution. A Danish white paper on prosti-
tution from 1955, for example, argues that the authorities should work
to prevent men selling sex because prostitution could lead to social
problems for them but describes women’s prostitution as a result of
social problems (Greve 2005, p. 13).
Nordic social workers and researchers have focused on the clients.18
Whereas the male clients within the functionalist approach were seen
as acting on biological needs that for different reasons were not met,
the perspective in more recent Nordic prostitution research is linked
to norms and inequalities in society as a result of which access to
women’s bodies through prostitution was not only possible but nor-
malized ( Järvinen 1990). This shift in perspective was the starting point
18
Since the mid-1980s, there have been at least 13 more or less extensive Nordic
studies of men’s demand for prostitutes; most are qualitative studies based on in-depth
interviews with sex buyers (Borg et al. 1981; Persson 1981; Månsson and Linders 1984;
Varsa 1986; Prieur and Taksdal 1989; Andersson-Collins 1990; Hydén 1990; Lantz
1994; Sandell, Pettersson, and Larsson 1996; Lyngbye 2000; Smette 2003; Kippe 2004;
Lautrup 2005).
for an emerging focus on the role of clients in prostitution and for

debates on how to work against normalization. Research on clients is
also said to be lacking internationally (Raymond 2004).
The preceding description is especially applicable to Norway and
Sweden. Less knowledge from research is available in Denmark, Ice-
land, and Finland, for several reasons. Nell Rasmussen (1987) claimed
that it has been difficult to obtain funding for research on prostitution
in Denmark, a claim repeated 21 years later by Jeanett Bjønness (2008),
even though quite a lot of knowledge has been produced through social
work and interventions. This lack of research-based knowledge is in
contrast to the other Nordic countries, and something that has been
explained by, among other things, more liberal attitudes toward pros-
titution ( Jensen et al. 1990).
V. Linking Prostitution Policies and Market

Developments
We have explored some differences and similarities in how prostitution
is constructed as an object for legal intervention, as a social problem,
and as an object of knowledge in the Nordic countries. In this section,
we turn to relations between policy interventions and developments in
prostitution markets.
It is difficult to say anything conclusive about the relationship be-
tween prostitution law and the size and composition of the prostitution
market. Internationally, prostitution laws differ substantially, and so do
the prostitution markets, but there does not seem to be a strong re-
lationship between the two. It evident that there are many other factors
at play. One important one is how prostitution is addressed by other
than legal measures.
To understand the development of prostitution policies, it is neces-
sary to consider debates and developments in adjacent policy areas. It
is similarly important to understand the role that changes in the pros-
titution market have played in policy reform. Assumptions about de-
velopments in the prostitution market are often succeeded by debates
on what policies to adopt and taken as evidence of the appropriateness
of the policies in place. Parts of the prostitution markets are continually
surveyed to detect changes in their size and composition. Reports of
changes and increases typically raise concerns about a persistent or
worsening condition, pressuring authorities to deal with the issue

(Holmström and Skilbrei 2008).
The Nordic markets have changed dramatically in the last decade.
In the following discussion we present what is known about the mar-
kets in which women sell sex to men. Little is known about other
markets, such as men selling sex to men. The people being counted
are women who have been in contact with social programs and initia-
tives or who openly advertise for clients in magazines or on the In-
ternet. There are no reliable estimates of the size of such markets. The
figures given below attempt to describe what debaters believe they
know and to discuss the validity of some of this knowledge.
Political and economic changes have played a part in how markets
have developed. Growing global inequality and changes in border pol-
icies between Western Europe and former Soviet areas and Eastern
Europe have led to an increase in the number of women from these
areas in prostitution. Nordic prostitution markets have become in-
creasingly international during the last 10 years. There has been a
significant inflow of women from Central and Eastern Europe, and
also from Southeast Asia and Western Africa (Lehti and Aromaa 2006;
Holmström and Skilbrei 2008).19
There are differences in these developments among the Nordic
countries. In Finland, the number of foreign women in prostitution,
particularly women from Estonia and Russia, began to increase in the
early 1990s (Penttinen 2008). Eastern European women continue to
make up a large part of the Finnish prostitution market (Marttila 2008).
According to Anna Kontula (2005), around 8,000 persons were in-
volved in prostitution in Finland in 2005. Among these, approximately
4,500 were believed to be foreigners visiting Finland temporarily and
3,300 to live in Finland permanently. In Norway, the composition of
the prostitution market has changed dramatically, especially since 2001.
Through 2001, Thai women were the largest group of foreign women
in prostitution (Brunovskis and Tyldum 2004). Most Thai women in
prostitution came to Norway through family reunification with Nor-
wegian spouses and entered prostitution only after some time, often
19
Human trafficking is a recent development in many countries. Trafficking for
prostitution has drawn the most attention in policy development, media debate, and
research (Di Nicola 2007). To what extent and in what form trafficking to the Nordic
countries take place is difficult to estimate. Several scholars have criticized the lack of
empirical evidence (see, e.g., Kelly and Regan 2000; Agustı́n 2007).
years, in Norway. Eastern European women constituted a new and

large group from 2001 until 2004, when Nigerian women started to
show up in street prostitution in the largest cities (Skilbrei, Tveit, and
Brunovskis 2006). In 2007, 30 percent of all women in prostitution
with whom Norwegian social workers came into contact were from
Nigeria (Pro Centre 2008). There are estimated to be about 3,000
women selling sex to men (Tveit and Skilbrei 2008).
In the wake of the 2009 criminalization of the purchase of sex in
Norway, the composition of the prostitution market may have changed
somewhat, but it is too soon to tell whether these changes are lasting.
The market has come under surveillance by social workers, researchers,
police, and the media. Street prostitution has decreased in Oslo but
not in the other largest cities, and there appear to have been decreases
in indoor prostitution. Six months after the new law, street prostitution
in Oslo was said to have returned to the same level as the previous
year (Aftenposten 2009), but there have been reports of a decrease in
Bergen (Bergen kommune 2010). Most agree that it is too soon to
conclude what the law’s effects have been.
The Danish market has also been marked by an increase in foreign
women, but of more diverse composition than in Finland and Nor-
way.20 In Denmark in 2009, fewer than 40 percent of all women in
prostitution were reported to be of foreign origin: from Eastern Eu-
rope and West Africa, but also from South America and Southeast Asia,
especially Thailand. According to the Danish Research Centre on So-
cial Vulnerability (Videns- og Formidlingscenter for Socialt Udsatte) the
number of people in visible prostitution in Denmark was estimated at
around 5,500 in 2009. Among these around 3,300 were assumed to be
engaged in indoor prostitution, and the rest in street prostitution (So-
cialministeriet 2009).
The Danish and Norwegian estimates are uncertain, like all esti-
mates on prostitution, but are not controversial. The estimates in Swe-
den are more controversial, particularly in relation to claims been made
since 1999 about the possible effects of the ban against the purchase
of sexual services. Opinions have been divided about the effects of the
law on the size of the market and on the ways selling sex is experienced
20
Prostitution markets in Finland and particularly Norway are made up of women
from many different countries, but with large groups of certain nationalities.
by the sellers. We discuss the estimates in Sweden in some detail be-

cause the developments there attract a great deal of attention.21
The results of the evaluation were published in 2010. The evaluation
concludes that the implementation of the law has had an impact on
the situation of the Swedish prostitution market (there has been a de-
crease in street prostitution) as well as on people’s attitudes to pros-
titution (according to a survey conducted in 2008). However, these
conclusions have been debated and criticized. The main criticism con-
cerns the methodology used in the evaluation (the knowledge base used
in the evaluation is weak) and thus the validity of the claims made
about the effect the law has had on the development of the prostitution
market and attitudes. There had been many calls for such an evalua-
tion, but the law’s sponsors vigorously argued that none was necessary
(Träskman 2005). Nevertheless, the Swedish authorities commissioned
several reports on the law’s effects: three from the National Board of
Health and Welfare (Socialstyrelsen 2000, 2004, 2007), one from the
National Council for Crime Prevention (Brottsförebyggande rådet
2000), and yearly reports from the National Bureau of Investigation
(Rikskriminalpolisen 1999, 2000, 2001, 2002, 2003, 2004, 2005, 2006,
2007, 2009). Before the law was introduced (Regeringens proposition
1997/98), the prostitution market in Sweden was considered small
compared with that in European countries and the 2010 evaluation
reached the same conclusion 11 years later ( Justitiedepartementet
2010).
According to Swedish social workers, there were about 300 persons
in street prostitution and another 300 persons on the Internet (So-
cialstyrelsen 2007). The 2010 evaluation concludes that the law
achieved its goals of reducing the size of the prostitution market and
trafficking and changing attitudes toward prostitution. Drawing from
social initiatives in the three largest cities, the report finds that street
prostitution today is half the size it was before the law, with between
300 and 430 persons identified in prostitution each year. It also finds
no evidence that Internet-based prostitution has increased. In other
words, the evaluators see no reason to assume that 300–400 more per-
sons than 10 years ago are active in indoor prostitution each year. On
21
Fewer women in prostitution does not mean less prostitution. Nord and Rosenberg
(2001) reported that the price per customer had decreased by 50 percent since the
introduction of the law, which meant that women sell sex more frequently than before
(p. 6).
the basis of attitude surveys conducted in 1996, 1999, 2002, and 2008,22
the report argues further that more men and women now believe buy-
ing sex should be a criminal offense. Another conclusion, based on a
statement made by the Swedish police, is that the law prevents traf-
ficking.
These conclusions have met with considerable skepticism (see, e.g.,
Agustı́n and Persson 2010). Critics note that the conclusions are based
on weak empirical grounds, including the evaluators’ lack of a valid
baseline from before 1999 for comparisons. They argue that the esti-
mates of changes in attitudes are too weak to base conclusions on, and
that the conclusion that the law reduced trafficking is unsubstantiated.
Claims of positive effects were also criticized before the evaluation. It
has been argued that a decrease in street prostitution implies little
about overall development but rather that prostitution may have moved
to other places and other technologies (Bernstein 2007; Munro and
Giusta 2008; Hagstedt, Korsell, and Skagerö 2009).
It is difficult to evaluate the different views. The overall figures for
prostitution in Sweden are very low. So long as the evaluation does not
describe and discuss the figures relied on, however, it is difficult to take
them at face value, especially because there are many accounts of pros-
titution taking place beyond the streets—forms of prostitution that the
estimates do not acknowledge. The ingenuity of people involved in
prostitution is great, and there is evidence that people selling sex in
Sweden have sought ways to establish contact with prospective clients
outside the realms of police and social workers. The Stockholm police,
for example, reported in 2005 that women were using their own cars
to transport clients to apartments where prostitution takes place (Af-
tenposten 2005). Four weeks after the law was introduced, prostitution
was reported taking place in taxis (Riksdag 1999). It is claimed that
prostitution contacts through ordinary Web sites have increased and
that prostitution in Sweden is being advertised from Danish Web sites
(Scaramuzzino and Weman 2007). Use of the Web makes it increas-
ingly difficult to establish the size of the prostitution market, as does
the dispersal observed in 1999 of street prostitution in Stockholm from
the traditional Malmskillnadsgatan to smaller streets and other areas
(Brottsförebyggande rådet 2000). Prostitution is also reported to take
22
See Lewin (1998) and Kuosmanen (2008) for details of the 1996 and 2008 polls.
Polls conducted in 1999 and 2002 by the public opinion and social research consultancy
SIFO are reported online at http://www.research-int.se/Public/Reports/Index.aspx.
place along roads outside cities, such as in Småland. Danish social

workers and police claim that the Swedish criminalization has led to
more prostitution in Copenhagen, a city only a short drive from
Malmö, and Norwegian prostitution markets have been said to have
experienced an influx of Swedish clients, according to a Danish tabloid
newspaper (Berlingske Tidende 2004). Court cases described in an ap-
pendix of the evaluation indicate that contact between sellers and buy-
ers was established outside traditional prostitution arenas; for example,
in a case involving 13 Estonian women, contact was established in a
pizzeria ( Justitiedepartementet 2010, p. 287). The claim that indoor
prostitution has not increased also seems questionable. Increases in
Internet-based prostitution are mentioned in the evaluation but not
discussed. It is reported that Internet-based prostitution in Malmö
doubled from 2008 to 2009 alone ( Justitiedepartementet 2010, p. 110).
Prostitution markets in Denmark, Norway, and Finland are highly
international. Swedish prostitution markets are also increasingly so,
and it is reported that half of the women identified in street prostitu-
tion are of foreign origin ( Justitiedepartementet 2010, p. 108). Despite
an inflow of women from a number of countries, primarily from East-
ern Europe but also from Nigeria and Thailand, a welfare department
report in 2007 found no large groups of foreign-born women in street
prostitution (Socialstyrelsen 2007). However, groups of women from
countries in the former Soviet Union are identified in large trafficking
and pimping/procuring cases throughout the 2000s and also in some
court cases against purchasers of sex. The 2010 evaluation describes
several such cases. In a pimping/procuring case from 2003, at least 35
mainly Estonian women were identified ( Justitiedepartementet 2010,
p. 285). In a case from the same year, a group of Estonian women is
described to have sold sex 1,117 times in 2000–2002 (p. 286). Similar
cases went to court in later years; Estonian and Russian women are
mentioned in several. This suggests that the number of women from
the former Soviet Union involved in prostitution in Sweden is signif-
icant.
It seems clear that foreign women constitute an important part of
the prostitution markets in the Nordic countries. Some settle there
while others continue to travel between different countries, including
their home country ( Jacobsen and Skilbrei 2010). There is also move-
ment across the Nordic borders, with prostitutes alternating between
countries (Penttinen 2008).
Parallel to the internationalization of the Nordic prostitution mar-

kets has been an increase in people selling and buying sex at indoor
venues, such as massage parlors and apartments (Holmström and Skil-
brei 2008). This development has been in process since the late 1980s
(Skilbrei 2001) but has escalated in the last 10 years through the wide-
spread use of mobile phones and access to Internet advertising. In Den-
mark, for example, prostitution is today channeled through massage
parlors and escort services to a greater extent than before (Rasmussen
2007, p. 34). Mobile and Internet access are not unique to Denmark.
In Sweden, prostitution in less visible arenas such as the Internet,
apartments, and massage parlors is also assumed to have increased dur-
ing the last 10 years (Socialstyrelsen 2007; Justitiedepartementet 2010).
In Finland, the greatest part of the prostitution market is found off-
street, a development that must be seen in the light of recent legal
changes criminalizing street prostitution (Marttila 2008). In Norway,
street prostitution became less important during the 1990s as new in-
door prostitution markets were formed (Skilbrei 2001). Street prosti-
tution increased again during the 2000s, when foreign women, partic-
ularly from Nigeria, seem to have had difficulty establishing themselves
indoors. Still, there is reason to believe that the indoor market far
exceeds street prostitution (Tveit and Skilbrei 2008). It is even more
difficult to offer conclusions or even assumptions about Iceland. Over-
all, little is known about prostitution there, but evidence suggests that
some striptease bars offer prostitution (Atlason and Gudmundsdóttir
2008).
Today’s prostitution markets are highly differentiated. This fact
poses a challenge to any attempts to estimate their size. Although a
great deal of prostitution in the Nordic countries is assumed to take
place indoors, the figures and estimates concerning the scope of pros-
titution are mostly based on observations of street prostitution (Holm-
ström and Skilbrei 2008). Knowledge about prostitution is therefore
distorted. The market in Denmark, for example, looks more interna-
tional than it really is when only street prostitution is observed, since
most prostitution takes place indoors and more Danish women and
men are active there (Rasmussen 2007). In some countries, counts and
estimations are also made of the size of the market that advertises on
the Internet, but knowledge about indoor prostitution is not as readily
available as knowledge about street prostitution, not only because it is
less visible, but also because people selling sex on the street are more
likely to seek the services of social workers.
VI. Is There a Nordic Prostitution Regime?

We have described how prostitution is dealt with through legal mea-
sures and social interventions. We have described some developments
over time in what is being done about prostitution and how the in-
volved parties are changing. These measures and developments have
been linked to developments in the Nordic prostitution markets, show-
ing how changes such as increasing internationalization influence
which policies seem appropriate and feasible. It is necessary to link the
measures chosen and developments over time to ideological positions
and movements.
The idea of combating prostitution through a legal focus on sex
buyers has gained ground in four of the five Nordic countries. How-
ever, the reform was promoted for different reasons in the different
countries, and the “problem of prostitution” is thus constructed dif-
ferently in the different countries. Social work approaches directed at
persons selling sex differ between the countries and so does the im-
plementation and use of various control measures, such as bans against
prostitution in public space (Finland) and immigration law (Denmark,
Finland, and Sweden). The Swedish law was initiated within a feminist
discourse, focusing on the demand side of prostitution and aiming at
protecting both society and the sellers.
However, the laws have been introduced within somewhat different
ideological and empirical contexts. Even though the introduction of
the ban can be understood within the frame of social policy and the
politics of gender (forming a common regime), legal reforms can also
be understood as pragmatic solutions to the diverse development of
the prostitution markets in the different Nordic countries.
In this essay we relate the development of legal policy to the dra-
matic changes that the Nordic prostitution markets have undergone in
the last decade. One important process is an ongoing internationali-
zation of the Nordic prostitution markets. A parallel process is the
differentiation of the prostitution markets, mainly due to technological
developments. Taken together these processes have affected how the
Nordic states deal with prostitution.
Knowledge produced through social scientific research and social
work informs how prostitution is addressed in the Nordic countries.

In the late 1970s, a critical social scientific research perspective for-
mulated the question of prostitution in terms of social problems and
social policy. This welfare-oriented approach developed over 30 years
and can be described as specifically Nordic. One side of the approach
is an ideological shift toward redistributing the responsibility of pros-
titution from sellers to buyers.
Discussions of models of prostitution policy need to take account of
detailed knowledge about the national contexts. There is a need to
contextualize global discussions and phenomena and to enrich current
theoretizations and concepts with local knowledge (Connell 2007; Paa-
sonen 2009). Models of prostitution policy often disguise differences
such as those we have identified. The intersection between principled
and pragmatic arguments and between different forms of inequality is
central in the development of a future agenda for research. Lumping
the prostitution policies in the Nordic countries together under the
heading of “a Nordic regime of prostitution policies,” or as neo-
abolitionism, hides more than it conveys. A wide variety of measures
is in use. Even though they may seem similar from afar, there are great
differences up close. Even so, it remains correct to contend that the
approaches to prostitution in the Nordic countries have more in com-
mon with one other than with most other countries.
Prostitution policies are argued for as a means to change more than
the prostitution market itself. This fact is particularly evident in Swed-
ish policy developments, but the argument that criminalizing the pur-
chase of sex will change attitudes outside the realm of prostitution is
also made in the other Nordic countries. The policies are implemented
not only to change the prostitution market in the short run but also
to change attitudes that influence gender relations, and the prostitution
market, in the long run. The debates about what the laws are designed
to accomplished build on a very optimistic view on the power of law.
Criminalization in Sweden was meant to accomplish attitudinal
changes and market changes in Sweden as well as attitudinal changes
in other countries. That is a tall order.
Prostitution policies are the product of ideological differences and
frictions. Reasons for prostitution are discussed in terms of structural,
cultural, and individual problems linked to gender norms, gender in-
equalities, marginalization, and class. As a legal problem, prostitution
stands out as an area that needs to be regulated through dealing with
international organized crime, victims’ rights, migration, and demo-

cratic deficiencies in sending countries for prostitution-related migra-
tion and trafficking (e.g., discrimination against women and ethnic mi-
norities). During recent decades there have been two parallel processes:
an ideological process paying attention to gender equality and the de-
mand side of prostitution and a pragmatic process focusing on how to
handle increasingly internationalized prostitution markets.
The conceptualization of a person selling sex as someone who should
be met with social interventions and not criminalization preceded the
increasing internationalization of prostitution markets. The increased
focus on clients proceeds and conjoins these developments. The
emerging interest in and focus on the client can be linked to political
and social changes from the early 1980s onward and to increasing fears
of changing prostitution markets, unwanted migration, and trafficking.
Changes in how the Nordic countries meet third-party involvement
are linked both to the internationalization of the markets and the chal-
lenges that poses and to how policies come to be decided internation-
ally and implemented nationally.
Globalization and the emergence of new markets are challenging our
perspectives on and approaches to prostitution. These processes are
also likely to lead to a diversification and perhaps also a hierarchization
of prostitution, since differences between indoor prostitution and street
prostitution, and between national and foreign prostitution, influence
what laws are adopted and how they are implemented. The Nordic
countries are handling the prostitution issue differently, because of who
the sellers are. There is a danger that a hierarchy may develop, for
example, in Sweden where a recent study suggests that the police are
more ready to intervene in prostitution involving foreign women, as
they define such prostitution as “worse” than national prostitution (Sir-
ing 2008).
In Norway, most police work on prostitution is performed by an
organized crime unit. They have a particular mandate for trafficking
and focus on prostitution involving foreign women. That policies, even
those developed toward the prostitution market as a whole, are in prac-
tice directed more toward “foreign” prostitution than “Nordic” may
lead to an increased stigmatization of already vulnerable groups (Skil-
brei 2009). In Denmark, the ban against foreigners’ prostitution is said
to make life more difficult and dangerous for Nigerian women selling
sex, as they have to keep away from authorities, even when they them-
selves have been subjected to violence and rape (Holm 2007).
A problem with an approach that gives priority to one perspective
is that it renders other sources of inequality invisible (Scoular and
O’Neill 2008). Prioritizing gender thus means that other reasons for
prostitution or consequences other than gendered ones are not ad-
dressed or acknowledged in the debate and in policy development and
implementation. Changes in the prostitution market toward an increas-
ing internationalization thus have implications not only for developing
appropriate legal and social measures and specialized tools and services
but also for the knowledge produced. The challenge is to take the
emerging diversity of markets into consideration when discussing and
debating prostitution. It is also necessary to develop new analytical
frameworks. Since today’s prostitution market is increasingly interna-
tionalized, focusing on migration law, labor law, border control, and
migration processes would generate valuable new knowledge on the
situation of people in prostitution.
Svanström (2006b) points to an increasing diversification of perspec-
tives on prostitution in Sweden in research and organizations in recent
years, as the voices heard are becoming more diverse. This does not
necessarily mean that the feminist and structuralist approach is disap-
pearing. Järvinen describes the onset of a third kind of knowledge pro-
duction related to prostitution; the social interactionist perspective,
which emerged in the 1970s and 1980s. The terms and perspectives
are deconstructed and put a particular emphasis on analyzing prosti-
tution control. An important starting point is that prostitution exists
within a continuum of acts and that prostitution can be expressed and
experienced in many different ways. One can also interpret this ap-
proach as a constructionist one, in which the exploration of what is
included in the definition of prostitution and how the parties involved
in prostitution are construed by “us” are just as important as questions
about how prostitution as such is experienced. An increased focus on
discourse does not exclude other perspectives but can be viewed as a
supplement.
The description here deals solely with developments within the Nor-
dic countries. There is reason to believe that men and women from
the Nordic countries buy sex abroad as well. Just as globalization has
left its mark on Nordic prostitution markets, it has also laid the ground
for easier and cheaper travel to destinations with thriving prostitution
markets. Little is known about Nordic citizens’ involvement in pros-

titution abroad, so it is impossible to say anything about the size of
the phenomenon and how it plays out. In the age of globalization, it
would be obtuse to concern ourselves only with the acts Nordic citizens
commit at home. A challenge to future research is to develop methods
to study how and to what extent Nordic citizens buy sex abroad.
Negotiations are underway in the Nordic countries about how pros-
titution should be dealt with and how to combine today’s emerging
legal approach with a definition of prostitution as a social problem.
This issue can be posed as a dilemma between harm reduction and
zero tolerance. Exploration of the relationship between legal and social
solutions is a way forward for research. This is an area where the
Nordic region offers a unique history, and where the value of Nordic
comparisons is most visible.
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Is There a Nordic Prostitution Regime?

Author(s): May-Len Skilbrei and Charlotta Holmström

When the Icelandic Parliament criminalized the purchase of sex1 in the

tinued to be legal. Finland introduced a partial ban on purchasing sex

technologies, shifts in where prostitution occurs), estimates of the size

I. The Current Legal Approaches

was to criminalize buying of sex from victims of trafﬁcking or from

replaced prohibitionist policies with regulation, thus condoning certain

importance accorded expressive sexuality did not ﬁt well with crimi-

approaches to prostitution in the 1970s and 1980s shifted from a focus

prostitution is viewed as an expression of gender or socioeconomic

have few opportunities to choose work other than prostitution.15 The

III. Social Problems Need Social Work

IV. Knowledge Production

prostitution, but they too were placed within a wider framework of

in prostitution and how prostitution needed to be contextualized in

social scientiﬁc research has consequences for what type of knowledge

for an emerging focus on the role of clients in prostitution and for

V. Linking Prostitution Policies and Market

worsening condition, pressuring authorities to deal with the issue

years, in Norway. Eastern European women constituted a new and

by the sellers. We discuss the estimates in Sweden in some detail be-

place along roads outside cities, such as in Småland. Danish social

Parallel to the internationalization of the Nordic prostitution mar-

VI. Is There a Nordic Prostitution Regime?

work informs how prostitution is addressed in the Nordic countries.

international organized crime, victims’ rights, migration, and demo-

markets. Little is known about Nordic citizens’ involvement in pros-

Aftenposten. 2005. “Svensk lov stopper ikke sex-kjøp.” October 27.

Bernstein, Elisabeth. 2007. Temporarily Yours: Intimacy, Authenticity and the

man Trafﬁcking: Focus on Clients, edited by Andrea Di Nicola, Andrea Cau-

mark.” In Baggader: Om prostitution, penge og kærlighed, edited by Cecilie

Siring, Annelie. 2008. “Sexhandel, Sexköpslagstiftning och myndighetsför-

Border Prostitution in Northern Norway, 1990–2001.” European Journal of

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