Sex work legislation has long been a topic of global debate, with varying models implemented across different countries. The so-called "Nordic model," which criminalizes the purchase of sex in an effort to reduce demand, has been the prevailing legal framework in Ireland since 2017. However, new research from Victoria University of Wellington, New Zealand, sheds light on the deeply ingrained stigma and discrimination that sex workers in Ireland face compared to those in other jurisdictions, particularly New Zealand and Scotland. The findings suggest that the Nordic model is not only ineffective but also harmful to the well-being of sex workers. A critical reassessment of Ireland’s legal approach is urgently needed, as decriminalization, as seen in New Zealand, offers a more humane and practical alternative.
Stigma and Structural Violence in Ireland
The research, led by Dr. Lynzi Armstrong, a senior lecturer in Criminology at Victoria University of Wellington, involved interviews with 70 sex workers across Ireland, Scotland, and New Zealand. Among these, 24 participants were from the Republic of Ireland, and their experiences revealed the most profound sense of stigma, isolation, and discrimination. Structural stigma—prejudice embedded within social systems and institutions—was a recurring theme throughout the study. In Ireland, sex workers described a pervasive sense of shame and judgment, far more intense than in New Zealand, where sex work has been decriminalized since 2003.
This stigma in Ireland is not just a social issue but is built into the laws themselves, according to the report. Participants spoke of structural violence—forms of harm, abuse, and oppression facilitated by institutional policies—saying that the legal framework under the Nordic model directly exacerbates their marginalization. Many of the sex workers interviewed recounted experiences of abusive and demeaning treatment in a variety of settings. Often, this mistreatment stemmed from another person being aware of their involvement in sex work, which illustrates how the stigma surrounding sex work seeps into personal and professional relationships.
What is particularly striking is the role of the Catholic Church in shaping public opinion and maintaining control over sex workers' lives. The Church’s influence perpetuates a conservative, moralistic narrative that vilifies sex workers, reinforcing their isolation from mainstream society. This institutional power, coupled with Ireland’s legal framework, compounds the stigma and discrimination faced by those in the sex work industry.
The Harmful Impact of the Nordic Model
The research is unequivocal in its condemnation of Ireland’s current legal approach to sex work. None of the Irish participants had anything positive to say about the country’s legislative framework. In fact, many emphasized that the Nordic model, which criminalizes the purchase of sex, had worsened their situations, making them more vulnerable to violence, exploitation, and discrimination.
Adopted by Sweden in 1999, the Nordic model is intended to reduce demand for sex work by penalizing clients rather than sex workers themselves. While this may seem like a progressive approach, it has had the opposite effect in practice. By pushing the industry further underground, the Nordic model has made it more difficult for sex workers to operate safely. Clients, knowing they face criminal charges if caught, are less likely to report any abusive or violent behavior to the authorities, leaving sex workers more isolated and vulnerable.
A report by Amnesty International, published two years ago, highlighted the “chilling effect” that the Nordic model has had on sex workers’ human rights in Ireland. The fear of arrest or harassment has driven sex workers into more precarious working conditions. Many feel they have no choice but to work alone, which increases their exposure to violence. This is particularly dangerous in Ireland, where trust in the gardaí (police) has plummeted among sex workers. The adversarial relationship between sex workers and law enforcement, fostered by the current legal framework, prevents those in the industry from seeking protection or justice when they are harmed.
Linda Kavanagh, a spokesperson for the Sex Workers Alliance Ireland (SWAI), has been vocal about the dangers posed by the current laws. She has stated that there is “a mountain of evidence” from sex workers showing that violence and fear have escalated since the criminalization of clients in 2017. According to Kavanagh, “Working safely and working legally are now incompatible, under the law.” Sex workers are forced to choose between operating within the law and protecting their own safety, a situation that is both unjust and unsustainable.
Legislative Review: Delayed and Lacking Transparency
In 2021, Senior Counsel Maura Butler began a review of Part 4 of the Criminal Law (Sexual Offences) Act 2017, which criminalized the purchase of sex in Ireland. However, due to her workload, Butler was unable to complete the review. The material she had collected was passed to the Department of Justice’s Data and Research Unit, which is currently finalizing a report on the law. Despite the ongoing review process, there has been a lack of meaningful consultation with sex workers, according to the SWAI. Kavanagh and other advocates have repeatedly expressed frustration at the lack of transparency, arguing that the voices of those most affected by the law—sex workers themselves—are being ignored.
The SWAI’s calls for full decriminalization are backed by evidence not only from sex workers but also from the academic research conducted by Dr. Armstrong and her team. The research includes ten key recommendations, with the foremost being the full decriminalization of sex work. This, the report concludes, would improve the health, safety, and well-being of sex workers and serve as a crucial step toward reducing the stigma they face.
Decriminalization: A Better Way Forward
New Zealand provides a compelling alternative to the Nordic model. In 2003, the country passed the Prostitution Reform Act, which decriminalized sex work, aiming to safeguard the rights of sex workers and improve their working conditions. Since the implementation of this law, New Zealand has been held up as a model of progressive sex work legislation. The decriminalization approach treats sex work as a legitimate form of labor, enabling those in the industry to access health and safety protections, report violence without fear of arrest, and work in safer environments.
The research conducted by Dr. Armstrong shows that sex workers in New Zealand experience significantly less stigma and discrimination than those in Ireland. By decriminalizing sex work, New Zealand has created a legal and social environment in which sex workers are viewed as active agents with rights and protections, rather than passive victims. This shift in societal perception is critical for reducing the structural stigma that plagues sex workers in countries like Ireland.
Decriminalization also allows sex workers to organize collectively, which can enhance their bargaining power with clients and employers. By operating within a legal framework that acknowledges their rights, sex workers can negotiate better working conditions and, most importantly, ensure that their safety is prioritized. In contrast, the Nordic model criminalizes clients, which pushes the industry into the shadows and forces sex workers into increasingly dangerous situations.
There is also evidence that decriminalization improves public health outcomes. When sex workers are not afraid of legal repercussions, they are more likely to access health services, including regular testing for sexually transmitted infections (STIs). In New Zealand, the decriminalization of sex work has contributed to better sexual health for both workers and their clients, as workers can openly discuss and practice safe sex without fear of arrest.
The Catholic Church’s Role in Perpetuating Stigma
One cannot discuss the stigma surrounding sex work in Ireland without addressing the profound influence of the Catholic Church. As noted in Dr. Armstrong’s research, many of the Irish participants in the study highlighted the Church’s role in shaping public narratives about sex work. The Church’s moral authority has historically cast sex work as sinful and immoral, reinforcing the stigma that isolates sex workers from the broader community.
This cultural backdrop of shame and guilt exacerbates the difficulties sex workers face, making it harder for them to seek support or even discuss their experiences openly. The Church’s teachings have contributed to a legal environment in which sex workers are criminalized and ostracized rather than supported and protected. The influence of the Catholic Church in Ireland’s legal and social systems has created a climate where sex workers are viewed not as individuals deserving of rights, but as symbols of moral decay.
Decriminalization offers a way to challenge and dismantle these outdated moral frameworks. By treating sex work as legitimate labor, rather than a moral failing, the state can help to shift public opinion and reduce the harmful stigma that sex workers face. In countries like New Zealand, where the decriminalization of sex work has been implemented, sex workers are less likely to be viewed through a lens of moral judgment and are instead seen as individuals with the same rights and protections as any other worker.
A Call for Reform in Ireland
The research from Victoria University of Wellington provides a powerful argument for why Ireland must move away from the Nordic model and toward a more humane and effective approach to sex work legislation. The current laws are harming sex workers, increasing their vulnerability to violence, and reinforcing the stigma that isolates them from society. The experiences of sex workers in New Zealand show that decriminalization offers a better path forward—one that respects the rights of workers, improves safety, and reduces stigma.
As Ireland’s Department of Justice finalizes its report on the 2017 law, it is crucial that the voices of sex workers are at the forefront of the discussion. Their lived experiences should guide the country’s approach to sex work, and the evidence is clear: decriminalization is the most effective way to protect sex workers and ensure their health and safety. The Nordic model, with its focus on criminalizing clients, is not only failing to achieve its goals but is also actively harming the very people it claims to protect.
Ireland stands at a crossroads. It can continue down the path of criminalization, perpetuating harm and stigma, or it can choose a different direction—one that recognizes sex work as labor, decriminal