You have full access to this open access article. The so-called Nordic model to respond to prostitution has been considered in legislative debates across Europe and internationally, and hailed by some as best practice to tackle sex trafficking and is believed to support gender equality. Yet, when we interrogate the utilisation of the Nordic countries laws by law enforcers, it is not being implemented as per the law. It has been claimed that a Nordic model to respond to prostitution exists after Sweden, Norway, Iceland and Finland introduced legislation that made the purchase of sex a criminal offence.
This model has subsequently been hailed as a successful policy approach across many international and European countries, and has led some nations to enact similar laws. This policy approach is identified by some as best practice and has thus been identified as a progressive policy approach to follow internationally. Its widespread consideration in legal and policy prostitution debates demonstrates the gravitas of an apparent coherent and unified approach to prostitution and that the Nordic model has international import.
It is therefore unsurprising that other countries have looked to this model for inspiration. The Republic of Ireland Minister for Justice and Equality, Deputy Frances Fitzgerald identified the model as an approach to follow when debating the Republic of Ireland bill, before it became law [ 3 ]. In Canada, the model was discussed throughout parliamentary debates before the purchase of sexual services was made a criminal offence [ 4 ].
Yet, when we interrogate Nordic countries prostitution laws and the utilisation of these laws by law enforcers, it is apparent that the laws are not being implemented. This therefore throws the claim that there is a united and compelling approach to prostitution into doubt.
Rather, evidence suggests that the approaches in these Nordic countries are disparate, and that Norway, Finland and Iceland encountered many problems and challenges when they adopted the policy approach taken by Sweden. In particular, law enforcers do not utilise and apply the law. In this article, we undertake a systematic review of the Nordic countries implementation of the law to criminalise the purchase of sex. Our original contribution to these debates draws on policy transfer and comparative law literature, as well as academic research that has documented post-legislative implementation debates.
