On Problems with the Nordic Model of Prostitution

Mark McDougall’s December 2024 article for The Herald covered the protests by sex workers over the proposal by Alba MSP Ash Regan to introduce the ‘Nordic Model’ of prostitution law to Scotland. Advocates claim that this law would criminalise the purchase of sexual services, but not the providers of such services – which punishes those who keep this trade going, and helps those working in the industry to get out. This model is also touted as a means of ending sex trafficking.

So why do the providers have an issue, you may ask? It’s not a question of money, as the more cynical among you may suppose. The answer touches on the whole concept of women’s rights, which the Nordic Model has demonstrably undermined everywhere it has been implemented.

When put into practice, criminalising clients means that otherwise law-abiding ‘clients’ are less likely to provide custom to sex workers, who may not be in a position to take on alternative forms of employment, and due to stigma and other factors aren’t able to access the help needed to exit the sex trade that is often promised. So to make a living, they have to be less choosy about the sort of clients they take on, even if said clients are more aggressive and violent.

Far from helping sex workers, such legislation only serves to make them more vulnerable to harm.

The island of Ireland provides plenty of evidence of the failure of this ‘Nordic Model.’ Northern Ireland has had such legislation since 2015, in the form of the Human Trafficking and Exploitation Act which was advocated by Lord Morrow. And the Republic of Ireland has the Criminal Law (Sexual Offences) Act 2017. In both jurisdictions, the results of this legislation – in force for nearly a decade now – are clear.

• In Northern Ireland, since the legislation was introduced, there have been 75 arrests and only 1 conviction. However, according to Women’s Aid, the number of trafficking victims they supported increased from 47 in 2021 to 230 in July 2023.
• Furthermore, Women’s Aid stated in November 2024 that they now receive one referral per day to support a trafficking victim – this was after a case was reported of two trafficking victims being rescued from a south Belfast flat.
• Meanwhile, in the Republic of Ireland, by 2020 crime against sex workers had increased by 90% and violent crime in particular had increased by 92%.
• A 2022 research piece conducted by Amnesty International uncovered that the legislation has facilitated abuse of sex workers, that the state has failed to protect sex workers, and that sex workers have a marked distrust of the Gardaí (the Irish police force), leading to a lot of crimes which sex workers suffer being unreported.
• One major exception to this, which made headlines, was when Romanian sex worker Geila Ibram was murdered in April 2023 by a ‘client’ in Limerick.
• An October 2024 report from Victoria University in Australia concluded that the current legislation in Ireland negatively impacted the health, safety, and wellbeing of sex workers, and it needed to be changed to reverse these effects. The report also noted that sex workers in Ireland faced more stigma than those working in New Zealand and – notably – Scotland.
• On November 28th 2024, it was announced that 14 Czech women were charged with operating a prostitution ring in Ireland and Northern Ireland from 2019.

Such are the consequences of the Nordic Model on the island of Ireland – the same Nordic Model that Ash Regan wants to inflict on Scotland. It is a failure at combatting sex trafficking (which should be illegal) and it is a failure at protecting women involved in the sex trade (who should be protected). No wonder that Scotland’s sex workers have no desire to repeat the experiment in Scotland.

However, while statistics, academic reports, and relevant news items are important, they serve only to give a largely quantitative picture – it also helps to have a qualitative picture. Ideally, from someone who has actually worked in the Irish sex industry. This was recently provided by a young Czech writer called Anna Rajmon, who published her memoir Elis – Irish Call Girl in June 2024. Her book and story have been featured and well-reviewed by several legitimate media outlets, such as the Irish Examiner, Global Comment, the Midwest Book Review, the Story Circle Network, and Slugger O’Toole.

And Elis – Irish Call Girl deserves such critical praise as it has earned – it is an excellent, informative, well-written, and emotionally raw testimony of how horrific Ireland’s appalling sex industry really is. Rajmon’s memoir merits serious attention, as her account is representative of many women involved in the sex industry – in Ireland and elsewhere.

While Rajmon uses sarcasm to lighten her dark tale, she pulls no punches about the realities of her experiences in the sex trade, nor in communicating her disdain for the trade. Her stance on sex work was made clear in a September 2024 article she penned for Writing.ie:

“There are many books on this topic – some are grim, and others portray stories from the world of prostitution as if it were something normal and acceptable. But what is acceptable about trading freedom for money? What is normal about using a human body as if it were an object?”

These words relay a visceral contempt for sex work which Ash Regan would be hard-pressed to disagree with. Unlike Regan, however, Rajmon knows what she’s talking about, having endured nearly four years as a “service provider” in Ireland’s dismal prostitution scene – regulated by the very legislation Regan champions.

Rajmon’s memoir outlines in startling detail the torturous experiences she had which brought her to hold sex work in such contempt. A series of toxic relationships with unfortunate financial consequences left Rajmon, a young single mother, with an urgent need to provide for her family. In this regard, Rajmon is representative of many women who enter sex work. As an English sex worker, Charlotte Rose, told ITV in 2019:

“The majority of people that have to work are single mothers and they’re doing this work to be able to provide for their children…”

In early 2020, with no other viable options open to her, Rajmon signed up with an escort agency based in her native Czech Republic, who would ‘support’ her as an escort touring Ireland – her hope was to make enough money to settle her debts and put food on the table. (It does not appear to be the same agency that was cracked down on by the Czech and Irish authorities in November, however, as some of the escorts Rajmon worked alongside are still advertising on the Irish escort websites).

Again, Rajmon was operating as many women entering sex work do – after all, few enter this business with any knowledge of how it really works, and usually get in touch with established agencies which they expect will support and guide them. Unfortunately for Rajmon, things would be far less straightforward for her.

The ‘support’ that this exploitative and grasping agency provided Rajmon with is like the support a rope provides a hanged man with. Rajmon was advertised by the agency as an ‘independent escort’ on the Irish escort websites, and ordered to travel to various apartments, B&Bs, and hotels via public transport across the island of Ireland, north and south. The accommodation was booked by the agency, who would funnel an endless queue of clients which she was compelled to “service.” Rajmon had no say in how any of this was organised, and no idea who was coming to her door, or what they would do – and more often than not, the results were unpleasant.

Rajmon is careful to mention that she did have decent clients who treated her well, and one in particular was instrumental in getting her out of prostitution for good. However, her extremely detailed accounts of the vicious assaults and cruel humiliations which were inflicted on her make for genuinely distressing reading. The pitiless attitude of the escort agency only compounded this horrific situation, as they ordered her to “go make some money, babe” – no matter if she had been beaten or raped only moments before (something which, sadly, happened several times). As Rajmon herself so eloquently puts it:

“Somewhere, I heard the phrase, ‘When money talks, no one checks the grammar.’ That’s what this was all about – money, money, and more money. For money, girls sacrificed their own lives; for money, they risked sexually transmitted diseases; for money, they were willing to step beyond their convictions. For money, the agency treated us like trash thrown on the street; for money, they were willing to risk our health, safety, and everything else, and for money, they had a few select girls they treated decently. It was never about people, morals, or decency.”

It is clear from her own account that Rajmon was not one of those “few select girls.” The gruesome avarice and callousness of the escort agency, combined with the barbarous and demeaning treatment meted out to her by many of her more loathsome clients, left her traumatised. Bear in mind – all of this happened in Ireland and Northern Ireland, both places where the Nordic Model was in force, which undermines any plausibility to the claims that advocates such as Ash Regan make that sex workers are safer with it.

Rajmon had no recourse to safety from either the agency or the clients under the Nordic Model – all she could do was endure her experiences. And no exit services helped her get out of the Irish sex trade – to reiterate, it was the kindness of a former client who she befriended that provided her with an escape route.

It should be made clear, however, that Anna Rajmon does not push any activist agenda with her book – her motives are not born of politics, but of simple human decency. As the Irish Examiner noted, Rajmon wrote Elis – Irish Call Girl as a means of processing her trauma, and also to shed light on what is happening in Ireland’s ghastly sex trade. Rajmon herself would not dispute these motives, but she states in the introduction to her book that she also wrote it as a warning to other young women in similar circumstances not to follow this path: “The parts of you that it takes away,” she sadly writes in her introduction, “you will never be able to replace.”

If Ash Regan is sincere about ending “a system of exploitation that leaves lasting scars,” it’s difficult to see why she is championing legislation which demonstrably makes things worse for the women she purports to protect. It’s not difficult to see why those same women object to Regan’s proposals, however – they know the truth of Rajmon’s account, and her experiences will reflect their own if Regan has her way.

That truth is something Regan herself seems determined to avoid learning, however. In August 2024, The National reported that Regan published a consultation document in support of a bill that would introduce the Nordic Model. This document put forward evidence that the Model had reduced prostitution in Sweden and Norway – however, it left out evidence from Northern Ireland, where a 2019 review from its Department of Justice concluded that the Model had failed. (And the evidence for the Model working in Sweden and Norway is much weaker than is widely reported, rendering Regan’s entire case suspect).

The Northern Irish Department of Justice review stated that there was “no evidence that the offence of purchasing sexual services has produced a downward pressure on the demand for, or supply of, sexual services” and that the law had “contributed to a climate whereby sex workers feel further marginalised and stigmatised.” The review corroborates Rajmon’s account perfectly, and no one who is serious about championing women’s rights would want to introduce such a situation anywhere.

Which begs the question: why does Regan want to introduce such a situation to Scotland?

A possible answer was recently provided by a sex worker rights activist based in Ireland, Gaye Dalton. In a January 2025 interview with Slugger O’Toole, Dalton (herself a former sex worker) stated that: “Sex sells, moral panic sells even better, both are a handy “go to” to distract from the desperate need to resolve the real, underlying social issues that are responsible for a significant number of people trapped in selling sex with no viable way out…cry “pimps and traffickers” loudly, and often, enough and the people of privilege are off the hook and free to give each other awards for doing nothing of the slightest use or benefit and, too often, a load of harm.”

You do not need to endorse sex work itself to endorse the rights of sex workers to be treated like human beings, however. Anna Rajmon herself is no advocate of sex work, and a careful reading of Elis – Irish Call Girl makes that clear. But the harrowing experiences she had were enabled by the very legislation that Ash Regan wants to introduce to Scotland. And while Rajmon is no activist, nor is she someone who wants what she suffered to be endured by anyone else. As she writes in Elis – Irish Call Girl:

“Can you imagine being raped, beaten, lying on a bed of tears, and simply swallowing the suffering that happened to you and standing in a humiliating outfit by the door smiling at your next ‘owner,’ who decided to rent your body for the next few dozen minutes? I wouldn’t wish it upon anyone to experience.”

It’s unlikely, sadly, that Ash Regan will find it within herself to learn any lessons from those with first-hand experience of sex work like Charlotte Rose or Gaye Dalton, let alone even contemplate reading Anna Rajmon’s insightful and sobering memoir.

But for anyone who does want to seriously understand the implications of Regan’s proposals for Scottish sex workers, Rajmon is a necessary read. What happened to her has happened to many other women working in the Irish sex trade, and it continues to happen now. And it will happen to the women working in Scotland’s sex trade too, unless informed action is taken.

Paying heed to those who understand the topic first-hand would be a good start, and I can think of no better starting point than Elis – Irish Call Girl.