Behind the Paddle
Welcome to "Behind the Paddle", the podcast that explores the fascinating world of sex across a wide spectrum of topics; from LGBTQ+ and feminine power, to kink, sex work and the adult industry. We aim to inform, inspire and entertain, featuring expert interviews, compelling stories, and thought provoking discussions.
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Behind the Paddle
E92: The Nordic Model vs. Decriminalization
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Behindthepaddle podcast takes listeners inside one of the most polarizing debates in feminist and political history: the Nordic Model versus decriminalisation of sex work. With personal testimony, global case studies, and voices from sex-worker–led groups like SWARM, Scot-PEP, and Umbrella Lane, this episode dismantles myths, exposes the harms of Ash Regan’s proposed “End Demand” Bill in Scotland, and contrasts it with New Zealand’s evidence-based model of decriminalisation. From health and human rights to stigma, migration, class, and survival, Two Roads makes clear that this isn’t about abstract law it’s about dignity, safety, and the right to choose our futures.
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Hello and welcome back to Behind the Panor Podcast with me, Paulson Victoria. So today we are going to be talking about the Nordic model, boo, and decriminalization. Yay! So this is actually the second time we're recording this because I just I felt like when I first recorded it, I didn't do it justice. Because I want to include as much information as possible, so I feel like this might be a little bit of a long episode. It is really clear-cut about which is safer for sex workers and therefore sex workers. Spoilers, it's decriminalization. So two very different visions. One says rescue women from men. That's the Nordic model. The other says respect workers as workers. We're gonna unpack both in all their complexity, not just through government reports, but through statistics, human rights research, and the lives of those already at the margins. Migrants, trans women, people of colour, disabled workers, and LGBTQ communities. Because this isn't a debate about abstract law, it's a debate about safety, survival, and dignity. And it shouldn't really be a frickin' debate in the first place, where we're talking about freedom to do what we want to do with our own bodies, where there is no coercion whatsoever, we are choosing to do sex work for one reason or another, and we are going to go into that today. So why does sex work law matter? Well, sex work law reaches into the most intimate corners of people's lives. It decides whether a worker can rent a flat without the fear of eviction, whether a migrant woman can call the police if she's attacked, or if she'll face deportation instead. Whether a trans woman on the street is treated as a civilian or as a disposable nuisance. The law doesn't just police sex work, it polices stigma, health, migration, gender, and class. I know this personally. Under Scottish law I was charged with brothel keeping under section eleven five of the nineteen ninety-five Act. My crime was simply renting a flat and letting other women work there with me, So we could be safe. There was no exploitation, no trafficking, no coercion. Yet the law treated us as criminals. Even two women working together is considered a brothel in the UK. That means the law punishes safety itself. It pushed me, a single mother, into instability, not protection. And that's why this debate matters. These laws decide whether we survive with dignity or whether we're punished for it. So the current UK law on prostitution slash sex work, prostitution itself, excluding sexual services for money between consenting adults is not illegal. However, many associated activities are criminal offences, soliciting in public places, curb crawling, which is someone in a vehicle soliciting a person in a street for prostitution, keeping a brothel that includes operating premises where more than one person offers sexual services, controlling or profiting from someone's prostitution, pimping. In Scotland, controlling prostitution for gain, and that can include profiting from someone else's prostitution. And that also can include partners. So when I was charged with brothel keeping, my partner at the time was actually charged with assisted brothel keeping and profiting from a sex worker. In Northern Ireland, buying sexual services is illegal. We're going to go into more detail about that soon. And of course, associated offenses like brothel keeping, controlling prostitution, especially for gains. Again, if you are with somebody who is a prostitute, then you're you're not a good person, you know. That's illegal. Similar to England and Wales as well. The Nordic model began in Sweden in 1999, ooh, the year that was born. Parliament declared prostitution to be a form of quote men's violence against women. Its architects argued that no woman could freely choose sex work. Well, I've actually been doing sex work freely for eight years, so that's debunk there. Therefore, women in prostitution would not be punished, but men who purchased sex would be criminalized. This framing became a cornerstone of what was called Swedish state feminism. Sweden imported it proudly as a moral model for the world. Keep that in mind. Moral. Within two decades, Norway, Iceland, Canada, France, Ireland, Northern Ireland, and Israel had adopted versions of the Nordic model. Today it is debated in the UK and United States and a few other places in the world. Should we really have this Nordic model? Should everybody have it? Well, we're gonna dive in. So the origins of decriminalization. Four years later, in 2003, a very different approach emerged from across the globe. New Zealand passed the Prostitution Reform Act. It removed criminal penalties from both selling and buying sex, while maintaining laws against coercion and under 18 prostitution and trafficking, which is all illegal in general. The philosophy was clear: sex workers work, workers deserve labour rights, health protections, and freedom from police harassment. The reform followed decades of sex worker organizing, particularly by the New Zealand Prostitutes Collective, who insisted that dignity and safety could only come through rights, not rescue. Now, the Nordic model people love to say that they're here to rescue us. But we don't want rescuing. We want rights. The Nordic model is a moral lens. It sees sex work as inherently violent, frames women as victims and men as exploiters. It relies on stigma to deter demand. Whereas decriminalization, a pragmatic lens, sees sex work as labour, frames workers as agents, relies on health, labour, and human rights frameworks. These are not just policy differences, they are worldviews. One rooted in paternalistic protection, the other rooted in trust in workers' voices. Now in France, two years after the Nordic model was adopted, Moud Sainz de Monde, doctors of the world, surveyed 583 sex workers. 63% reported their living conditions had worsened. Who would want the Nordic model when you have this statistic right here that their living conditions have worsened already? 42% reported increased violence from clients, police and the public. So it's very clear the sex workers do not hold the power here. 38% said condom negotiation had become harder. I think that speaks for itself. Who has the power? There are clients out there who want to have unprotected sex. And they're pushing for it because they know that the sex workers need the money to feed their family, to feed themselves, to pay their bills. And so of course, clients are gonna then negotiate, they're gonna negotiate rates, they're gonna negotiate safety. Who would want that? In Ireland, the Sex Workers Alliance documented a 220% increase in violent crimes reported by sex workers in the two years after the 2017 law. And in Norway, Amnesty International found that immigration workers were disproportionately evicted, harassed, and assaulted. With one trans woman saying, If I am beaten, I cannot go to the police, they will deport me instead. Juno Mack and Molly Smith in their book Revolting Prostitutes describe how Nordic laws created what workers call a rapist's market. When cautious clients left, predatory ones remained. One woman explained that she had to accept riskier men for less money because her rent didn't vanish with the law. Only her safety, only her safer clients did. And I can tell you criminalization breeds danger. When I was charged for working collectively, I lost the protection of safety in numbers. I was punished for trying to reduce harm. Now imagine adding client criminalization on top of that. Clients rushing, scared of arrest, means less time for screening, less power to insist on condoms and screening, less chance to walk away. That's not safety, that's risk multiplied. I had no idea what I was going to do for work when my safe space got taken off of me by the police. The police did no due diligence in seeking evidence that there was any coercion, any trafficking, any pimping, none of that. At the end of the day it didn't matter. What mattered was the fact that I was using the space with another woman. And that's why I was targeted. Because I wanted safety and I wanted to give safety to others. The police also took my mobile phone, so they took my communication. And they took all of my condoms. Every single one of them and my lube. Which puts my job at even more risk. And then when I was thrown into the cells crying my eyes out, I asked a police officer dead in his eyes, What am I meant to do? How am I meant to pay my bills? And this police officer, heartless as he is, looked at me and said, Your pockets just won't be so flush. It's disgusting. In New Zealand, the picture is different. A 2008 government review found the majority of sex workers felt more able to refuse clients. Around 90% reported awareness of their legal rights. There was no evidence of increased violence. Workers also reported being able to negotiate condom use more effectively and felt safer contacting police after assault. And I'll tell you now, I'm not gonna feel comfortable even looking at the police. I still have PTSD from how they treated me. I fear every time I hear a knock at the door that it's them, even though I haven't done anything wrong, I still have that fear. The UN AIDS warns criminalizing clients undermines HIV prevention. Rushed transitions reduce safety. Workers lose bargaining power. The WHO, World Health Organization, and UN AIDS explicitly call decriminalization essential to fighting HIV. New Zealand and Sweden outreach workers report condom use dropping because clients demand secrecy. And they just don't want to. The clients have that power in a way to say, Do you want this money? Then I don't want to use protection on my penis. That's what power the clients have. In New Zealand, health outcomes improved with no rise in STD prevalence. Migrant sex workers are most vulnerable. In Nordic model countries, police raids, evictions, and deportations are routine. Annasty documented Nigerian and Romanian women in Norway living in constant fear. In revolting prostitutes, you know the Hors Bible, a Nigerian woman in France described being locked out of her flat after police tipped off her landlord, leaving her homeless overnight in the name of protection. LGBTQ plus communities face unique harms. Trans women disproportionately are policed, and gay men's sex work is erased from discourse. Disabled workers and clients are silenced. The Nordic model ignores the role sex workers play in disability justice for both survival and intimacy. Under decriminalization in New Zealand, stigma does remain, but these communities can access services without criminalisation. Now, I'm not saying decriminalisation is the holy grail. Migrant workers still face visa restrictions. A reminder that decriminalization is not a cure for all, but it does reduce harm. In Scotland, I've seen how policing already targets the most marginalized migrants, trans workers, women of colour. Umbrella Lane's research in 2021 found nearly half of sex workers wouldn't report crimes to the police out of fear. I mean I know right now, I wouldn't. For migrant and trans workers, that fear is even sharper. I felt that fear myself. When the law brands you a criminal for survival, how can you trust the police to protect you? As Swarm put it in their consultation response, telling sex workers there is no difference between a safe client and a client who subjects us to violence is a frightening obstruction of reality. If we're told that every encounter is violent, then how are we able to speak out about the real violence we face? And polling backs us up. In a 2024 Ugov survey, almost 7 in 10 Scots said the government should focus on protecting sex workers' health and safety, and on offering support to those who want to exit, not on criminalising clients. Only 14% backed new laws to stop people exchanging sexual services for money. At the same time, 82% said stigma against sex workers in Scotland is real and significant. That shows the public understands stigma is the danger, not workers themselves. So human rights positions. Amnesty International supports full decriminalization. World Health Organization calls decriminalization essential for public health. UNAIDS states criminalization fuels HIV spread. The Global Alliance Against Traffic in Women warns Nordic model harms migrants more than it helps. Every major human rights and health organization rejects the Nordic model, and yet the government continue to embrace it, often for political theatre. They really are trying their best with throwing absurdities around like sex work, like the Online Safety Act. We don't need protecting when it comes to our freedom. It is our right to do what we like with our bodies. It's not harming anybody. There is much bigger problems out there like homelessness. There's children starving. There's people struggling to heat their homes. There's single parents who can't even afford childcare so they can work. The benefit system is absolutely crazy. There is so many more bigger problems out there. And the government is putting a blanket over our eyes and saying, yes, sex workers having freedom. That is the problem. No. Fix the government. Fix what is going on within the main bits. We don't need fixing. Sex workers don't need fixing. Sweden's claim was bold. The law would reduce trafficking by reducing demand. No buyers, no business, no exploitation. But reality is messier. Sweden's 2008 evaluation admitted it had no reliable trafficking data. It measured visibility, not exploitation. European Network of Sex Work Projects gave no evidence the Nordic model reduces trafficking. The Global Alliance Against Traffic in Women said anti-trafficking raids often harm migrants more than they help. The data simply doesn't support the Nordic promise. And when politicians talk about trafficking, I hear my own story erased. I was criminalized not because I was trafficked, but because I worked with other women. We weren't victims. We were supporting each other. As I said, trafficking is already illegal. Coercion is illegal. But laws like section 11.5 make no distinction. They lump survival, solidarity, and trafficking into the same criminal category. That is not protection. In case studies, France shown that there was no trafficking reduction, but widespread evictions and violence. In Ireland, police framed raids as anti-trafficking. But workers were deported, not protected. Northern Ireland criminalization of buyers did not shrink the sex trade. Instead, sex work shifted online and more underground, with workers reporting more isolation, more stigma, and more fear. Demand didn't disappear. From revolting prostitutes, a Romanian sex worker in Norway explained she avoided the police at all costs, not because she was trafficked, but because she feared deportation. New Zealand. A 2008 review found no increase in trafficking post decriminalization. Enforcement resources focused on genuine coercion. Anti trafficking is often a cover for border policing. Migrant women of colour are branded as trafficked, while Where autonomy is erased. The Nordic model doesn't just regulate sex work, it regulates migration, poverty, and race. Across the globe, the sex work debate has fractured feminism. On one side, abolitionist feminists who insist that prostitution is always violence, always exploitation. They see criminalization as a form of protection, a way to declare that no woman could ever be for sale. On the other, sex worker-led feminists, who argue that criminalization itself is violence, they insist that survival strategies are not invalid, and that what harms most is stigma and law. This divide is not abstract. It shows up in Scotland today through Ash Regan's prostitution offences and support bill. As a single mother, that charge, brothel keeping, it didn't rescue me. It threatened my child's stability and my ability to survive. That is what these laws really do. And that is the law which is in play today. They don't protect, they punish. For working class women, sex work is often survival. For disabled workers, it may be one of the only forms of income available. I pick sex work because I'm autistic and I have ADHD. I have had a like quote unquote normal job for a good few years. I didn't very much enjoy working under somebody. I didn't enjoy people bending the rules where the rules were really flat out and straight. I didn't enjoy my boss picking favorites. I didn't enjoy any of that. And I didn't enjoy the bullying in the workplace that can happen. I also get burnt out quite a lot. So me doing sex work enables me to be able to be flexible, not just for myself, but also my child. I get to pick my working hours. It gives me so much flexibility and I love it. Ash Regan's bill also promises exit support, but history shows us those services rarely arrive, or they're so limited that almost no one can access them. Sweden, France, Ireland, the promises were hollow. In Scotland, we already have housing shortages, underfunded mental health care, and strained welfare? Unless these problems are fixed for everyone, exit support will remain empty words. And you have to remember that once you get a prostitute caution or a charge on your criminal record, it will be there. And it will stay there. So how are people who have a criminal record of prostitution meant to exit when no job will actually pick them because they have a criminal record? So this is something which if I did want to exit sex work, I would have massive trouble doing. During the pandemic, the government announced a hardship fund, but sex workers couldn't safely access it. Applying meant outing yourself to authorities, risking police, immigration, or social services. For a single mother, the risk losing your child is too great. And there has been records and evidence of social work taking away children from sex workers just because they are a sex worker. So many of us had to turn to grassroots like Umbrella Lane and Swarm just to survive. This government announcement of a hardship fund. It was I barely heard about it. It was not advertised greatly or anything like that. And that's the reality. Support schemes rarely reach us, while criminalization always does. As Swarm explained, while brothels are criminalized, sex workers must choose between legally working alone or working with a friend for safety and risking arrest. That choice between danger and criminalization is no choice at all. And in Revolting Prostitutes, they point out exit services without housing or income are not exits at all. One woman in Sweden put it simply, I didn't need a lecture, I needed rent money. Umbrella Lane's research during lockdown showed the same. Sex workers excluded from government hardship funds had to rely on peer-led emergency relief just to survive. Those who should have been protected were instead abandoned. The Nordic model has become an export, held up as feminist progress. Ash Regan wants Scotland to join Sweden, Norway, Ireland, France, Canada. But what actually gets exported is stigma, eviction, deportation. Regan herself defended her bill by saying I quote, be prepared for this. If women were in cellars with locked doors, how would the pointers get to them? So stupid. She said this in the Herald. Critics called it naive, even offensive, and just it's stupid. Because the truth is, people are already working in hidden, unsafe places, pushed there by stigma and law. Criminalising clients won't stop that. It will intensify it. If clients are criminalized, violence will rise. We've seen it everywhere. Just look at the facts. In Ireland, violent attacks rose by 220% after the law changed. In France, they found 63% of workers said their living conditions deteriorated, and 42% faced more violence. In Northern Ireland, sex work didn't disappear. It moved further underground. Stigma grew and safety shrank. Annasty has warned again and again that these laws don't reduce demand. They just make the work more secretive, more dangerous, more deadly. And listen to what Scott Pep, sadly not here anymore, and Umbrella Lane have said directly. Criminalizing clients makes sex workers poorer and therefore more desperate. It means sex workers are pushed to accept clients they might otherwise reject, or to go into cars more quickly, with less time to make a safety assessment. It means workers have to meet clients in darker or more isolated areas, because we have to cater to clients' fear of arrest and meet him somewhere more hidden. Such a law is a gift to those who want to harm us. It's a rapist charter. Sadly, Scott Pep isn't here anymore because sex worker-led organizations, anything to do with sex work is not funded. If you support sex worker organizations, the government will pull your funding. Because under the government, sex work is violence against women and girls. And so if you are an ally, if you're an organization and you're an ally to a sex worker or an organization, you will get your funding pulled. Which is why it seems like we don't have the support because people can't say they support us because the government stops free speech. They stop freedom. There's another problem. Enforceability. Even Scotland's own Crown Office has warned that Ash Regan's bill could be unenforceable in practice. How do you prove the purchase of sex in a private setting? How do you gather evidence without invasive surveillance, sting operations, or frawling through workers' private lives or social media? We've seen this play out elsewhere. In Northern Ireland, prosecutions under similar laws have been vanishingly rare, not because sex work ended, but because the offence is almost impossible to police. What emerged instead was a climate of fear. Clients became more secretive, meetings shifted further underground, and workers were left with fewer chances to screen clients or refuse. And what does that mean? It means the law becomes symbolic, a political gesture dressed up as protection. The real burden falls squarely on sex workers. More stigma, less safety, fewer options. As one Scottish worker told Umbrella Lane, we are the collateral damage in laws that pretend to save us. It's not protection, it's posturing. It's a policy that looks good on paper to those outside our world, but delivers nothing but increased danger to those of us living within it. As Swarm themselves warn, taking our clients away does not magically deliver us into a new life free from exploitation, but rather makes us poor and hungry and heavily dependent on the few clients that are left. Their words remind us this bill would not rescue women. It would abandon them to greater poverty, deeper stigma, and heightened risk. New Zealand shows us there is another road. In 2003 they chose decriminalization. They didn't erase laws against trafficking, coercion, or underage prostitution. Those remain crimes. But they removed penalties for consenting adults, both buyers and sellers. That shift, simple on paper, changed everything. A government review five years later found that over 90% of workers reported stronger legal and safety rights, the number of workers who fell able to refuse clients rose significantly. Crucially, there was no increase in trafficking and no exploitation in sex work markets, despite opponents' fears. And workers were at the table shaping that law. The New Zealand Prostitutes Collective, a peer-led organization, ensured that reform was not just about legal language, but about lived realities. The result? A framework that recognizes sex workers as right holders, not victims or criminals. Ash Regan's bill with its criminalization of clients is being sold as protection. But lived experience, my own with the current law, and that of workers across the world with the Nordic model shows that it would mean more danger, more stigma, more silence. Repealing loitering offences is progress. Squashing old convictions is essential. But unless Scotland confronts the deeper harm of criminalization, nothing will change. Decriminalisation is the model Scotland should follow. Not one that criminalizes survival. Not one that treats mothers like me as criminals for trying to work safely. But one that sees us as people with rights and gives us the tools to live, to protect ourselves and to choose our own futures. Sex workers don't need more police at our doors. I already have PTSD from whenever people knock at my door, I think it's the police, even though I've done nothing wrong. We need rights. We need safety. We need the ability to work together without fear. To raise our children without charges hanging over us. To call the police when we are attacked without fearing arrest or deportation. New Zealand has shown that decriminalization doesn't create chaos. It creates safety. It allows choice. It's not perfect. But it makes justice possible. In 2014, a sex worker sued their brothel employer for sexual harassment. The tribunal found that over a period of three months, her brothel boss subjected her to sexual harassment. The ruling emphasized that being a sex worker does not remove the right to a harassment-free workplace. Sex workers are entitled to the same protections under employment law as people in other industries. She won. She successfully sued her boss for sexual harassment. Will we ever be able to do that here in the UK? Over any job. Never mind sex work. In the United Kingdom already, landlords can be criminally liable if they knowingly permit their property to be used for sex work. This means if a landlord is aware a tenant is using a flat for sex work, they risk prosecution for brothel keeping, even if only two sex workers share it for safety. Many sex workers have been evicted without notice once landlords discover their work, even in places where sex work itself isn't illegal. Landlords are pressured by police or fear criminal liability. The choice before Scotland and before all of us is simple. Do we keep repeating the mistakes of Sweden, France, Ireland, Canada? Or do we listen to those most affected and choose a path grounded in evidence, dignity, and rights? Sex workers are clear. We don't want rescue. We want rights. And it's time to finally listen. Thank you so much for listening. This has been Behind the Panel Podcast with me, Paulson, Victoria. If you enjoyed this episode, please leave a like, please follow, please leave some stars on whatever you're listening to. Please share wherever you can. And if you have any ideas for the next topics, please write in. You can support Scotland for D Crim. We have an Instagram, we have our own website. Please go and help us. And if you are kind enough, please donate. Bye.