Prostitution laws by country fall into five broad models: full legalization with government licensing, decriminalization, buyer-only criminalization (the Nordic Model), total prohibition, and partial legality where the sale itself is lawful but most surrounding activity is not. The model a country picks decides who faces criminal liability, what paperwork exists, and whether workers can call the police without risking arrest themselves. The practical gap between the ends of the spectrum is enormous. A transaction that generates tax revenue in one country can bring a prison sentence in another.
Legalized and Regulated
A small group of countries treats sex work as a regulated industry with licenses, taxes, and workplace safety codes.
The Netherlands
The Netherlands lifted its ban on brothels on October 1, 2000, by removing the prohibition from the Dutch Criminal Code.1UK Parliament. House of Commons – Prostitution – Home Affairs Committee Brothel operators must obtain local permits and comply with zoning, building, and health and safety rules. Workers are treated as self-employed or employees for tax and social security purposes. Municipalities oversee the industry the way they would restaurants or hotels.
Germany
Germany’s Prostitutes Protection Act (Prostituiertenschutzgesetz) took effect in July 2017. Every sex worker must register with local authorities and complete a health counseling session before receiving a registration certificate. Operators need licenses, criminal background checks, and compliant facilities. Breaking the registration rules can bring administrative fines of up to 10,000 euros, and operators who fail to verify their workers’ registration face steeper penalties.1UK Parliament. House of Commons – Prostitution – Home Affairs Committee Some advocates argue the paperwork pushes workers into informal arrangements.
Decriminalized
Decriminalization removes criminal penalties and leaves ordinary labor, health, and business law to govern the industry. It is lighter on bureaucracy than legalization and heavier on worker autonomy.
New Zealand
New Zealand’s Prostitution Reform Act 2003 was the first national full decriminalization. It repealed criminal penalties for the buying and selling of sexual services between adults and reframed the industry as an occupational health and safety matter. Individual workers and small cooperatives of up to four people need no license. Larger commercial operations must obtain an operator certificate from the Registrar of a District Court, who runs a criminal background check for serious offenses such as violent crimes or drug trafficking.2New Zealand Ministry of Justice. Apply for a Brothel Operator Certificate There are no mandatory health checks or government registries for individual workers.
Australia
Australia regulates sex work state by state, and the map has been shifting toward decriminalization. Victoria’s Sex Work Decriminalisation Act 2022 abolished the state’s licensing system and brought the industry under standard business and workplace rules.3Victorian Government. Decriminalising Sex Work in Victoria Queensland followed in August 2024, repealing its Prostitution Act 1999 and winding up the Prostitution Licensing Authority. Sex work businesses in Queensland are now subject to the same regulations as any other business.4Queensland Department of Justice. Sex Work Industry Decriminalisation Other states still maintain older licensing or prohibition approaches.
The Nordic Model
The Nordic Model criminalizes the buyer and treats the seller as a victim. The idea is to shrink the market by penalizing demand while leaving workers free of criminal liability.
Sweden
Sweden introduced the approach in January 1999 as part of a broader package on violence against women. Under Chapter 6, Section 11 of the Swedish Penal Code, purchasing a sexual service is punishable by a fine or up to one year in prison. The maximum was doubled from six months in 2011. The seller faces no criminal liability for the transaction and can pursue civil damages against the buyer.
France
France adopted its version with Law 2016-444 in 2016. Buyers face fines of up to 1,500 euros for a first offense and 3,750 euros for a repeat. The law decriminalized the sale of sex and funded exit programs. If a buyer’s offense involves a minor, the penalty can reach five years in prison and a 75,000-euro fine.
Canada
Canada’s Protection of Communities and Exploited Persons Act took effect in December 2014 after the Supreme Court struck down the country’s earlier prostitution laws. Purchasing sexual services is a crime everywhere in Canada.5Government of Canada. Protection of Communities and Exploited Persons Act Fines escalate based on how the Crown prosecutes and whether the offense occurred near a school, park, or religious institution; the maximum sentence on indictment is five years.6Justice Laws – Government of Canada. Criminal Code RSC 1985 c C-46 – Section 286.1 Sellers are not prosecuted for the sale, but advertising sexual services remains a criminal offense.
Total Prohibition
In prohibitionist systems, everyone involved in the transaction faces criminal liability. Penalties span a wide range.
United States
Nearly every U.S. jurisdiction criminalizes buying, selling, and facilitating sex work. A first-time solicitation conviction commonly carries fines from several hundred to several thousand dollars and jail time of up to a year. Repeat offenses or acting as an intermediary often trigger felony charges with multi-year prison sentences. Undercover operations target both buyers and sellers.
Nevada is the exception. Licensed brothels operate legally in 10 of the state’s 16 counties, but not in Clark County (Las Vegas) or Washoe County (Reno). Any sex work outside a licensed brothel is still a crime, even in Nevada.
Saudi Arabia and Similar Jurisdictions
Saudi Arabia treats any extramarital sexual activity as a criminal offense, commercial or not, with penalties that can include lengthy prison sentences and corporal punishment.7United States Department of State. 2024 Trafficking in Persons Report – Saudi Arabia Buyer and seller are treated alike. Foreign nationals convicted of these offenses typically face deportation after serving their sentences.
Partial Legality: The United Kingdom
Some countries sit in a confusing middle ground where selling sex is lawful but almost everything around it is not. England and Wales are the clearest example. Selling sex in a private setting is not a crime. Soliciting in a public place is, under the Street Offences Act 1959, with fines rising to £1,000 for repeat offenses.8Legislation.gov.uk. Street Offences Act 1959 Buyers who solicit from a street or public place, including from a vehicle, commit a separate offense under Section 51A of the Sexual Offences Act 2003, also punishable by fines up to £1,000.9Legislation.gov.uk. Sexual Offences Act 2003 – Section 51A Running a brothel, defined as any premises where more than one person sells sex, is illegal, and so is controlling prostitution for gain, which targets third-party organizers.10The Crown Prosecution Service. Prostitution and Exploitation of Prostitution A worker operating alone from a private flat is lawful. Add a second worker or move the business into public space and criminal liability kicks in.
US Federal Law Reaches Across Borders
Two features of U.S. federal law affect people whose activities are entirely lawful where they live.
FOSTA-SESTA and Online Platforms
The Allow States and Victims to Fight Online Sex Trafficking Act, signed in 2018, carved an exception into Section 230 of the Communications Decency Act. Platforms can no longer claim immunity when their services are used to promote or facilitate prostitution or sex trafficking.11United States Congress. HR 1865 – Allow States and Victims to Fight Online Sex Trafficking Act Under 18 U.S.C. § 2421A, operating an online platform with intent to promote or facilitate prostitution carries up to 10 years in federal prison, rising to 25 years if the conduct involves five or more people or shows reckless disregard for sex trafficking.12Office of the Law Revision Counsel. 18 USC 2421A – Promotion or Facilitation of Prostitution Major platforms shut down personal ad sections after the law passed. Because U.S.-based platforms dominate the global internet, workers in countries where their work is legal lost access to screening tools and advertising they had relied on.
Immigration Consequences
Under 8 U.S.C. § 1182, a person who has engaged in prostitution within the past 10 years is inadmissible to the United States, regardless of whether the activity was legal where it occurred.13Office of the Law Revision Counsel. 8 USC 1182 – Inadmissible Aliens The same 10-year bar applies to anyone who profited from or facilitated prostitution. A legally registered sex worker in Germany or the Netherlands can be denied a U.S. tourist visa, green card, or asylum based on lawful activity at home.
No conviction is required. Consular officers and border agents can apply the bar based on admissions in interviews or other evidence. For noncitizens already in the United States, a prostitution-related conviction may qualify as a crime involving moral turpitude, which can trigger deportation if the conviction occurs within five years of entry and carries a potential sentence of one year or more. Two such convictions at any point after admission can independently trigger removal.