Table of contents
- Four models at a glance
- Comparison table
- Germany: regulation with compulsory registration
- Model and legal basis
- Who is criminalised
- Registration, health, licensing
- Stated rationale
- Debate and reform
- The Netherlands: municipal licensing
- Model and legal basis
- Who is criminalised
- Registration, health, licensing
- Stated rationale
- Debate and reform
- Nevada: licensed brothels as the exception
- Model and legal basis
- Who is criminalised
- Registration, health, licensing
- Stated rationale
- Debate and reform
- Sweden: the Nordic model
- Model and legal basis
- Who is criminalised
- Registration, health, licensing
- Stated rationale
- Debate and reform
- What the evidence shows
- Where reform is underway
- Method and date
- FAQ
Germany and the Netherlands treat consensual adult prostitution as a lawful, administratively regulated trade; Nevada tolerates it only inside licensed brothels in a few rural counties; Sweden makes it a crime to buy sexual acts and no crime at all to sell them. Four jurisdictions, four answers to a single question — and, since 2025, four reform debates that have all started to move.
What follows applies one consistent grid to all four systems: the underlying model, who is criminalised, registration and licensing duties, health rules, the stated rationale, the evidence, and the current state of reform. It takes no side. The claims are drawn from statutes, government and parliamentary sources, official statistics and peer-reviewed or state-commissioned research, and the whole piece is dated as of 16 August 2026.
Four models at a glance
Policy debates tend to sort national approaches into four families. Legalisation with regulation recognises prostitution as an occupation and wraps it in administrative conditions — the German path since the Prostitution Act of 2002, and the Dutch one since the brothel ban was lifted in 2000. A licensed exception to a general ban is Nevada’s arrangement: prostitution is a crime, except in county-licensed houses. The Nordic model, pioneered by Sweden in 1999, criminalises demand — the buyer — while leaving the seller untouched by criminal law. A fourth family, full decriminalisation on the New Zealand pattern, exists in none of the four jurisdictions, yet it shapes every reform argument, not least through the policy adopted by Amnesty International in 2016.
The vocabulary is slippery. “Legal” in Germany means something quite different from “legal” in Nevada, and “decriminalisation” is routinely used as a synonym for “legalisation” although the two mean different things: decriminalisation removes the criminal offences and governs the sector through general employment and business law plus targeted conditions — New Zealand still requires operator certificates and imposes health-and-safety duties — whereas legalisation erects a dedicated regime of registration, licensing and control. Our wiki category covers the terminology; this article is about the systems themselves.
Comparison table
| Dimension | Germany | Netherlands | Nevada (USA) | Sweden |
|---|---|---|---|---|
| Underlying model | Legalisation with regulation | Legalisation with municipal licensing | General ban with licensed exception | Nordic model: purchase banned |
| Principal legal basis | ProstG (2002); ProstSchG (in force 1 July 2017) | Lifting of brothel ban (1 October 2000); municipal by-laws (APV) | NRS 244.345 (1971); NRS 201.353/201.354; NAC 441A | Penal Code ch. 6 s. 11 (since 1 January 1999) |
| Who is criminalised | No one, for consensual adult prostitution; coercion, trafficking and exploitation are crimes; breaches of the ProstSchG are administrative offences | No one, for consensual prostitution from age 18; coercion, exploitation and minors are crimes; unlicensed businesses face administrative sanctions | Sellers (NRS 201.353) and customers (NRS 201.354) outside licensed houses (misdemeanour); no exception at all in Clark County | The buyer only (up to one year in prison); selling is not an offence; procuring is |
| Registration / licensing | Personal registration with counselling interview; permit required for every prostitution business, including agencies | Business licence from the municipality; no national register of sex workers | County licence for the brothel; work permit under county rules, usually with sheriff registration | None — the state licenses nothing it defines as exploitation |
| Health rules | Mandatory health counselling (annual; six-monthly under 21); condom requirement | Municipal, usually via the GGD; no testing obligation | Compulsory recurring HIV and STI testing; condom requirement | No statutory conditions; exit and social programmes instead |
| Stated rationale | Strengthen self-determination, improve working conditions, detect coercion | Control voluntary prostitution, combat abuses | County self-government, public health, protecting the tourism image of the big cities | Gender equality; prostitution framed as male violence against women |
| Reform status (Aug 2026) | Evaluation June 2025; commission since Nov 2025 also reviewing other models | Wrs bill abandoned by letter of 13 May 2026; separate measures, minimum age 21 planned | Debate at county level; advertising constraints; state-wide immunity bill (AB 209) vetoed in 2025 | Since 1 July 2025 remote/online purchase also criminal; opposed by rights and sex-worker groups |
Germany: regulation with compulsory registration
Model and legal basis
Germany chose legalisation in 2002: the Prostitution Act declared contracts for sexual services no longer contrary to public morals and opened the door to social insurance. Regulation in the strict sense arrived with the Prostitute Protection Act (ProstSchG), in force since 1 July 2017. Its two pillars are personal registration for anyone selling sexual services (section 3) and a permit requirement for every prostitution business (section 12) — a category the Act defines in section 2(3) to include not only brothels but vehicles, events and, explicitly, placement agencies.
Who is criminalised
Nobody, where adults act voluntarily — neither the person selling nor the person paying. Human trafficking, forced prostitution and exploitation remain crimes under sections 232 et seq. of the Criminal Code, and since 2016 so does taking advantage of a coerced person’s predicament as a customer where the customer knows of it or recklessly fails to recognise it (section 232a(6)). Failing to register, operating without a permit or ignoring the condom rule are administrative offences under the ProstSchG itself, not criminal convictions; under section 33 the fines run up to €10,000 for operators working without a permit and up to €50,000 for customers who breach the condom requirement.
Registration, health, licensing
Registration is done in person at the competent authority, followed by an information and counselling interview; the certificate is valid for two years (one year for those under 21) and can be issued under an alias. A health counselling session — annual, or six-monthly for under-21s — is a precondition, and the Act is explicit that it is counselling, not compulsory examination. Operators must present an operating concept, prove their reliability and meet minimum standards for premises. The results are measurable: according to the latest release from the Federal Statistical Office, roughly 32,300 people held valid registrations at the end of 2024 — up 5.3 per cent on the year, but well below the 40,400 recorded before the pandemic. Seventeen per cent were German nationals and 36 per cent Romanian. Of 2,250 permitted businesses, 93 per cent were brothel-type premises and five per cent placement agencies. Unregistered activity, the office notes, is by definition invisible to these figures.
Stated rationale
Three aims were written into the legislative record: to strengthen the sexual self-determination of people in prostitution, to improve their working conditions, and to detect coercion and trafficking earlier through the mandatory contact with a public authority. The counselling interview is meant to be the window of trust that plain trade law never provided.
Debate and reform
On 24 June 2025 the federal government presented the Bundestag with the statutory evaluation of the ProstSchG, carried out by the Criminological Research Institute of Lower Saxony. Its verdict: the goals have been partly achieved, and 64 recommendations follow. Counselling services regard the registration and ID card obligations as stigmatising and a deterrent; advocates of the Nordic model consider the entire approach misconceived — the report is attacked from both directions, which says something for its independence. Since 24 November 2025 a Prostitute Protection Commission has been sitting, and the ministry states that it will look explicitly at “other approaches to dealing with prostitution” and at the international research record. For the first time since 2017, whether Germany stays with the regulatory model is a live question.
The Netherlands: municipal licensing
Model and legal basis
On 1 October 2000 the Netherlands repealed the general ban on brothels and struck the relevant articles from the Criminal Code. Consensual adult prostitution has been lawful ever since — the Dutch government puts it plainly: legal, as long as it involves sex between consenting adults. Regulation sits with the municipalities, which license sex businesses through their general by-laws, decide on locations and attach conditions. Unlike Germany, there is no national registration duty for the people who do the work.
Who is criminalised
Nobody, for consensual prostitution from the age of 18. Coercion, exploitation, trafficking and any prostitution involving minors are criminal offences. Running a sex business without a municipal licence draws administrative sanctions, and street prostitution outside a designated zone is unlawful wherever the municipality has said so.
Registration, health, licensing
Sex workers from the EEA and Switzerland may work employed or self-employed; third-country nationals only as freelancers. An “opt-in” arrangement with standard working conditions allows someone to work for an operator without an employment contract. Health provision is organised locally, usually through the municipal health service (GGD), with education and voluntary check-ups — there is no testing obligation. The Ministry of Justice’s evaluations of 2002 and 2006 found that every municipality had introduced licensing and was inspecting the licensed sector, while the police had little capacity left for anything outside it — the central finding of the WODC study.
Stated rationale
Six aims were declared in 2000: control voluntary prostitution through municipal licensing, prosecute exploitation more forcefully, protect minors, protect prostitutes, separate prostitution from criminal activity, and reduce prostitution by people without a right of residence. The formula was simple — sex work is work, and abuses are crime.
Debate and reform
For more than fifteen years The Hague tried to add a nationwide permit for each individual sex worker — most recently through the Sex Work Regulation Act (Wrs), tabled in 2021, which proposed a central register, an eligibility interview and criminal liability for clients of unlicensed workers. In the letter “Ambities landelijk sekswerkbeleid” to the House of Representatives dated 13 May 2026 (parliamentary paper 34.193, no. 21) the cabinet dropped the bill: its aims are still shared, but it contained too many contested choices, as the Centre for Crime Prevention and Safety summarises. Individual measures take its place: a separate law raising the minimum age to 21, a study into a “pimping ban”, an identity check for new sex-work advertisements in force since 1 April 2026, a Municipal Supervision of Sex Businesses bill (Wgts) now before the House of Representatives, and increased funding for exit programmes. The WODC is evaluating the programme to strengthen sex workers’ social and legal position, with results expected in 2027. The Netherlands therefore stays with legalisation — tighter at the edges, but without a register at its core.
Nevada: licensed brothels as the exception
Model and legal basis
Nevada is the only US state where prostitution can be legal — and the word “can” is the whole model. NRS 244.345, on the books since 1971, allows counties with fewer than 700,000 residents to license brothels by local ordinance and expressly forbids licensing in counties above that line. Clark County — Las Vegas — is thereby excluded by statute; Washoe County (Reno) and several others prohibit brothels by their own choice. What remains is a patchwork of ten counties in which licences are possible and, by consistent counts from early 2026, around twenty operating houses scattered across a handful of rural areas.
Who is criminalised
Both parties — anywhere outside a licensed house. NRS 201.353 makes it an offence for the seller, and NRS 201.354 for the customer, to engage in or solicit prostitution unless it takes place in a licensed brothel; the charge is a misdemeanour, and a felony where a minor is involved. Street solicitation is illegal state-wide. A visitor who assumes prostitution is lawful in Las Vegas has it exactly backwards.
Registration, health, licensing
The brothel needs a county licence; workers need a work permit under the rules of the county concerned — typically with registration and a background check at the sheriff’s office, though the details vary from county to county. Chapter 441A of the Nevada Administrative Code prescribes compulsory, recurring tests for HIV and other sexually transmitted infections; condom use is required by law, and an operator who keeps employing someone who has tested positive is civilly liable. NRS 201.380 keeps brothels 400 yards from schools and churches, and NRS 201.390 keeps them off principal business streets. It is the strictest health regime of the four — and the narrowest in reach: the great majority of Nevadans live in counties where prostitution is entirely prohibited.
Stated rationale
Grown out of nineteenth-century mining towns and formalised in 1971, the arrangement carries two motives: county self-government — the decision belongs to local boards, not the state — and a determination to keep legal prostitution out of the tourist metropolises. Public-health testing was added later as the regulatory justification.
Debate and reform
The argument is not conducted in Carson City but county by county: licences can be withdrawn by ordinance or ballot, and the number of houses has been declining for decades. There is also friction with federal law: since the disappearance of the classic online classified sites and federal legislation against online sex trafficking, even licensed businesses struggle to find lawful advertising channels. The one recent state-wide initiative targeted enforcement rather than the brothel model itself: Assembly Bill 209 would have granted sex workers immunity from prostitution charges when they call for medical help; both chambers passed it in 2025, and Governor Lombardo vetoed it on 5 June 2025. No move to expand or abolish the licensed model was pending as of August 2026.
Sweden: the Nordic model
Model and legal basis
On 1 January 1999 Sweden became the first country to criminalise the purchase, but not the sale, of sexual services — the provision now sits in chapter 6, section 11 of the Penal Code. Norway and Iceland (2009), France (2016), Ireland (2017) and others followed, and “Nordic model” or “sex buyer law” has become the international shorthand. On 1 July 2025 an extension came into force: the offence is now called purchase of sexual acts and, as the Riksdag records, expressly covers acts carried out remotely, without physical contact — via webcam, for instance.
Who is criminalised
Only the buyer, who faces up to one year in prison. The person selling commits no offence and is treated, in policy terms, as a potential victim. Procuring (section 12) and knowingly letting premises for prostitution are separate offences with considerably higher sentences. Since July 2025 it is also an offence to pay someone to perform a specific sexual act live or to order online — whether it is shown in real time or recorded for the buyer to view later. The law is expressly not a general ban on pornography: publishing one’s own content, and buying material that was not individually commissioned, remain lawful, as the Law Library of Congress notes.
Registration, health, licensing
None. The state licenses and registers nothing it classifies as a form of exploitation. In place of conditions there are social and exit services, municipal counselling units and programmes aimed at buyers. Health care is part of universal provision, not a precondition for working.
Stated rationale
The 1998 government bill placed prostitution within an understanding of gender-based violence: a society serious about equality, it argued, cannot recognise buying access to another person’s body as a legitimate transaction. Demand is the lever — reduce it and trafficking loses its market. The 2025 extension was justified in the same terms: the sex industry has moved online, and the law must follow.
Debate and reform
Domestic support for the law is high; the criticism comes from sex-worker and human-rights organisations. Amnesty International, after its own country studies, recommended decriminalisation in 2016 and objected specifically to criminalising buyers on the grounds that it pushes sex workers into riskier conditions. The 2025 online extension was rejected by the European Sex Workers’ Rights Alliance and Human Rights Watch, and legal scholars are asking how it sits with Article 8 of the European Convention on Human Rights — after the Strasbourg court in 2024, in M.A. and Others v. France, declined to strike down the French purchase ban, as the Verfassungsblog traces.
What the evidence shows
Less than either camp claims. The most defensible statement is this: no model has reliable data on the overall size of prostitution, because unregulated or illegal activity escapes measurement — Destatis says so explicitly for Germany, and the Swedish evaluation concedes the same.
- Sweden: The government inquiry SOU 2010:49 found street prostitution had roughly halved after 1999 while rising in neighbouring countries, and inferred a normative effect of the ban — while acknowledging the limits of the data (summary at the US Office of Justice Programs). A 2026 replication study by Adema, Folke and Rickne in Evaluation Review also failed to confirm two widely cited papers that had attributed a rise in rape to the purchase ban: it found methodological discrepancies and no evidence for the claimed increase — while stressing that this does not amount to a precisely estimated zero effect.
- Netherlands: The WODC evaluations credited the licensed sector with functioning oversight and very few minors, but found no improvement for prostitutes under the control of others and weak enforcement outside the licensed sector — the origin of the long search for a national register that has now been abandoned.
- Germany: The 2025 KFN evaluation judges the aims partly met; registration figures sit below every estimate of actual activity, which the law itself does not measure, and counselling services report displacement into unregistered settings.
- Nevada: There are indications of low infection rates within the licensed sector under mandatory testing; but that sector is so small that nothing about the state’s prostitution market as a whole can be inferred from it.
Ask about causation and the same problem appears everywhere: countries that choose different models differ in other ways too, and the outcome variable cannot be counted. Further analyses of this kind are collected in our Research & Statistics category.
Where reform is underway
Three of the four systems have shifted within fourteen months. Sweden extended its model into the digital sphere in July 2025, becoming the first jurisdiction to criminalise paying for commissioned sexual acts online. The Netherlands, in May 2026, ended a decade and a half of attempts at national registration and turned to minimum age, supervision and advertisement checks. Germany evaluated its law and set up a commission that keeps the frame open — from refining the ProstSchG to fundamentally different approaches. Nevada is the only one of the four whose legal framework is unchanged — and even there, the sole state-wide attempt of 2025, an immunity law for sex workers seeking help, foundered on the governor’s veto rather than in the legislature.
Method and date
All information is current as of 17 August 2026. Sources are limited to statutes, government and parliamentary publications, official statistics and peer-reviewed or state-commissioned evaluations; positions taken by advocacy organisations are identified as such. Figures for the unregulated market have been deliberately omitted where they rest on estimates without a traceable method. The article will be updated when the law changes. As a placement agency, Ivana Models works exclusively with independent, self-employed escort models and, in Germany, falls under the permit regime of the ProstSchG described above — anyone curious about how that operates day to day will find answers in our escort service FAQ and on the About us page; questions about this article are welcome via the contact page, daily from 09:00 to midnight, also via Telegram.
FAQ
Yes. Consensual adult prostitution is legal and has been regulated by the Prostitute Protection Act since 1 July 2017: individuals must register in person, and operators and placement agencies need an official permit. Coercion, trafficking and exploitation are criminal offences.
The Nordic model criminalises the purchase of sexual acts but not their sale. Sweden introduced it on 1 January 1999; buyers face up to one year in prison. Since 1 July 2025 the Swedish ban also covers paid sexual acts performed remotely, for example via webcam.
No. Nevada permits prostitution only in licensed brothels in counties with fewer than 700,000 residents (NRS 244.345). Clark County, which includes Las Vegas, is above that threshold, so both selling and buying are offences there. Washoe County, home to Reno, also prohibits brothels.
Legalisation permits prostitution under a dedicated regime of registration, licences and health rules — the German and Dutch approach. Decriminalisation removes the criminal offences and governs the sector through general law plus targeted conditions; New Zealand is the usual reference and still requires operator certificates and health-and-safety duties. None of the four jurisdictions compared here is fully decriminalised.
Yes. Consensual prostitution between adults aged 18 and over has been legal since the brothel ban was lifted on 1 October 2000. Municipalities license sex businesses; there is no national register of sex workers. The government plans to raise the minimum age to 21 through a separate law.
Undecided. The federal government presented a scientific evaluation with 64 recommendations in June 2025, and since November 2025 a Prostitute Protection Commission has been reviewing the law, including alternative models. No draft bill had been tabled as of August 2026.

















