Prostitution is illegal in roughly 100 countries, but the countries where prostitution is illegal do not all approach it the same way. Four broad models dominate: full criminalization of both buyer and seller, buyer-only criminalization known as the Nordic model, prohibitions rooted in Sharia law that treat the activity as a form of extramarital sex, and systems that classify it as an administrative violation rather than a crime. Penalties range from fines of a few hundred dollars to flogging, long prison terms, or death.
Countries That Criminalize Both the Buyer and the Seller
Full criminalization is the most common approach worldwide. Everyone involved in the transaction can be arrested.
In Kenya, Sections 153 and 154 of the Penal Code make it an offense to live off the earnings of prostitution or to solicit in public.1Kenya Law. Kenya Penal Code Chapter 63 South Africa criminalizes engaging in sexual acts for reward under its Criminal Law (Sexual Offences and Related Matters) Amendment Act, with convictions typically bringing community service, fines, or jail time.2South African Government. Criminal Law (Sexual Offences and Related Matters) Amendment Act 32 of 2007
The Philippines kept prostitution a standalone offense under Article 202 of the Revised Penal Code when it decriminalized vagrancy in 2012.3Lawphil. Republic Act No. 10158 A first conviction brings a short detention or modest fine, with harsher sentences for repeat offenders.4Supreme Court E-Library. Republic Act 10158 – An Act Decriminalizing Vagrancy South Korea passed legislation in 2004 that punishes both sides of the exchange, with additional penalties for anyone who facilitates or profits from the trade.
Thailand layers its penalties under the 1996 Prevention and Suppression of Prostitution Act. Public solicitation carries a fine of up to 1,000 baht. Being present in a prostitution establishment for the purpose of buying or selling sex can bring up to one month in jail. Advertising sexual services carries up to two years in prison and a fine of up to 40,000 baht, and sentences reach six years when minors under fifteen are involved.5International Labour Organization. Prevention and Suppression of Prostitution Act, B.E. 2539 (1996)
Enforcement across these countries varies dramatically. Thailand has a highly visible sex industry that operates alongside its criminal laws, while South Korea runs periodic crackdowns on red-light districts.
Countries That Punish Only the Buyer
Under the Nordic model, buying sex is a crime but selling it is not. Sweden pioneered the approach in 1999 with its Sex Purchase Act, now codified at Chapter 6, Section 11 of the Swedish Penal Code; buyers face fines or up to one year in prison.6Swedish Government Official Reports (SOU). SOU 2010:49 – Prostitution in Sweden Norway adopted Section 316 of its General Civil Penal Code in 2009, and Iceland passed its own buyer ban the same year.
France joined in 2016 with fines of €1,500 for a first offense and €3,750 for repeat buyers. Canada’s Protection of Communities and Exploited Persons Act, passed in 2014, criminalizes purchasing sexual services anywhere in the country and also bars third parties from profiting off or advertising the sale of sex.7Parliament of Canada. Protection of Communities and Exploited Persons Act (S.C. 2014, c. 25) The law shields sellers from prosecution while making every transaction illegal on the buyer’s side.8Department of Justice Canada. Fact Sheet – Prostitution Criminal Law Reform: Bill C-36, the Protection of Communities and Exploited Persons Act
Ireland adopted the approach in 2017 through its Criminal Law (Sexual Offences) Act, which imposes escalating fines on buyers.9Irish Statute Book. Criminal Law (Sexual Offences) Act 2017, Section 25 Northern Ireland had already criminalized paying for sex in 2015, with penalties reaching a fine, up to one year in prison, or both.10nidirect. Paying for Sexual Services Israel became the most recent notable adopter in 2020, with administrative fines starting at NIS 2,000 for a first offense and criminal prosecution available for persistent offenders.
Police in Nordic-model countries generally focus on arresting clients and connecting sellers with social services rather than prosecuting them.
Countries Governed by Sharia Law
Where Islamic law shapes the criminal code, prostitution falls under the broader prohibition on sexual relations outside marriage, known as zina. Iran’s Islamic Penal Code treats zina as a criminal offense, and because prostitution is inherently extramarital, it is automatically covered.11GOV.UK. Country Policy and Information Note: Zina (Sex Outside of Marriage and Adultery), Iran, April 2026 Saudi Arabia applies the same framework under its interpretation of Sharia, with punishments reported to include flogging for unmarried offenders and stoning for married ones.12United States Department of Justice. Saudi Arabia: Treatment of a Man Who Had Sexual Relations
The United Arab Emirates criminalizes prostitution through its Federal Penal Code. Article 368 prescribes imprisonment for anyone who habitually engages in prostitution, and separate provisions target those who entice others into the trade, operate brothels, or profit from another person’s sexual labor. Sentences for enticing a minor into prostitution start at two years and can reach ten years or more when coercion is involved.13Anti-Slavery Law. United Arab Emirates Federal Law No. 3 of 1987 – The Penal Code Afghanistan under Taliban governance classifies zina as a hadd offense with punishments the regime considers divinely mandated and non-negotiable.
These systems make no distinction between buyer and seller. Both parties have committed the same underlying offense: sex outside marriage. Enforcement often extends beyond police to religious authorities and morality bodies.
Countries With Administrative Penalties Instead of Criminal Charges
Some countries ban prostitution without treating it as a crime. Russia is the clearest example. Under Article 6.11 of the Russian Code of Administrative Offences, engaging in prostitution carries a fine of 1,500 to 2,000 rubles, while profiting from another person’s prostitution brings a slightly higher fine or up to fifteen days of administrative detention.14WIPO. Code of Administrative Offences of the Russian Federation No. 195 Organizing or running a prostitution operation crosses into criminal territory with much harsher penalties.
China follows a similar pattern. Under Article 66 of the Public Security Administration Punishment Law, individuals face administrative detention of up to fifteen days and fines of up to 5,000 yuan. These are not criminal convictions, but the consequences are real: in China, an administrative record for prostitution can result in denial of a residence permit, effectively ending a foreign national’s time in the country.
Countries That Ban the Activities Around Prostitution
A few countries occupy a gray area where exchanging sex for money is not directly penalized, but nearly everything around it is. Japan’s 1956 Anti-Prostitution Law formally prohibits prostitution without punishing the act itself. Articles 7 through 12 target solicitation, running a brothel, procuring, and coercing someone into the trade. Individual sex work exists in a technical loophole while the commercial infrastructure is criminal.
India’s Immoral Traffic Prevention Act of 1956 follows comparable logic. The law criminalizes running or managing a brothel, procuring someone for prostitution, and soliciting in public. Brothel management brings one to three years for a first offense and up to five years for repeat convictions. Procuring a person carries three to seven years and can reach life imprisonment when the victim is a child. Selling sex as an individual, outside a public setting and without a brothel context, is not itself penalized.
Prostitution Laws in the United States
Prostitution is illegal throughout nearly all of the United States, enforced primarily at the state level. Every state except Nevada and Maine criminalizes both buying and selling sex. Nevada permits prostitution only in licensed brothels within certain rural counties; outside those zones it remains a crime.15Wikipedia. Prostitution in Nevada Maine decriminalized selling sex in 2023 while keeping the purchase illegal, effectively adopting its own version of the Nordic model.16Maine.gov. Governor Signs Reckitt Bill to Partially Decriminalize Prostitution
Penalties vary but follow a common pattern. In New York, prostitution is a class B misdemeanor carrying up to three months in jail.17New York State Senate. New York Penal Law 230.00 – Prostitution Florida treats a first offense as a second-degree misdemeanor, with escalating charges for repeat violations.18Florida Statutes. Florida Statutes 796.07 – Prohibiting Prostitution and Related Acts Most states impose fines of a few hundred to a few thousand dollars and possible jail time for first-time offenses, with repeat convictions or offenses involving minors reaching felony level. Many jurisdictions offer diversion programs, sometimes called John Schools, that let first-time buyers avoid a conviction by completing an educational course.
Federal Prostitution Laws
Two federal statutes reach beyond state borders. The Mann Act criminalizes transporting someone across state lines for the purpose of prostitution.19Cornell Law Institute. Mann Act The 2018 FOSTA-SESTA law added 18 U.S.C. § 2421A, which targets website operators who intentionally promote or facilitate prostitution. Running such a platform carries up to ten years in federal prison, rising to twenty-five years if the operation involves five or more people or contributes to sex trafficking.20Office of the Law Revision Counsel. 18 USC 2421A – Promotion or Facilitation of Prostitution and Reckless Disregard of Sex Trafficking
Immigration Consequences
A prostitution conviction creates serious problems for non-citizens. Under 8 U.S.C. § 1182(a)(2)(D), any foreign national who has engaged in prostitution within ten years of applying for a visa or admission is inadmissible to the United States. The provision also covers anyone who has profited from or procured another person for prostitution within that window.21Office of the Law Revision Counsel. 8 USC 1182 – Inadmissible Aliens Even an admission to the conduct without a formal conviction can trigger inadmissibility.
Exceptions for Trafficking Victims
Across many of these countries, people convicted of prostitution-related offenses may qualify for relief if they were trafficking victims rather than willing participants. In the United States, most states offer some form of record relief for survivors through vacatur, expungement, or sealing. At the federal level, the Trafficking Victims Protection Act and the Justice for Trafficking Victims Act provide frameworks for formally identifying victims as survivors rather than criminals. Nordic-model countries build victim support directly into enforcement, coordinating law enforcement, social services, and health professionals so that sellers are referred out of the system rather than prosecuted.