Which countries have implemented the Nordic model for prostitution laws?
Executive summary
The Nordic model — criminalizing purchase of sex while decriminalizing those who sell it and coupling that change with support services — was pioneered by Sweden in 1999 and has since been adopted in multiple countries in whole or in variant form, most commonly cited as Sweden, Norway, Iceland, Canada, France, the Republic of Ireland and Northern Ireland, and Israel [1] [2] [3] [4]. Claims about its global spread are contested: scholars and advocates note important legal and practical differences between jurisdictions that are often glossed over in public debate [5] [6].
1. Origins and the basic definition of the model
The approach was developed in Sweden in 1998–1999 as part of a policy framing prostitution in terms of gender inequality; Sweden’s law made it illegal to buy sex but not to sell it, a legal framework that clinics and advocates describe as both punitive toward buyers and protective in theory toward people selling sex [1] [7] [8].
2. Countries widely reported to have adopted the model
Multiple reputable summaries list a common set of adopters: Norway and Iceland passed similar buyer‑criminalization laws after Sweden (often cited as 2009 for both), and several non‑Nordic states later implemented comparable statutes — Canada , France , the Republic of Ireland , Northern Ireland and Israel are repeatedly named in news and policy literature as having adopted versions of the Nordic model [2] [3] [4] [9].
3. How different sources enumerate adopters
Advocacy groups and informational sites commonly list Sweden, Norway, Iceland, Canada, France, Ireland and Northern Ireland — and often Israel — as jurisdictions that have implemented the model in full or in part [10] [3] [11]. Academic and policy briefs likewise point to France, Canada and Israel among more recent adopters while noting the model’s European spread beyond Scandinavia [2] [4] [9].
4. Disputes over what “adopted” actually means
Scholars caution that there is no single, uniform “Nordic model in practice”; some researchers argue that only a few countries truly implemented the model as Sweden intended and that national variations — in wording, enforcement, welfare supports and migration or policing contexts — change the law’s effects substantially [5] [6]. Amnesty International and sex‑worker rights organizations have reported harms after some adoptions, and researchers have documented differences in outcomes across France, Ireland and Canada, underscoring that “adoption” can mean very different legal packages and enforcement regimes [1] [2].
5. Borderline cases and countries sometimes included or excluded
Lists from campaigning groups and government briefings sometimes add jurisdictions such as Northern Ireland, Finland, South Korea or proposals under consideration in Italy, Luxembourg and others; other analyses exclude some of these because laws are partial, enforced differently, or accompanied by punitive measures affecting sellers [10] [5] [12]. This divergence explains why some sources report eight or nine adopters while critics insist the coherent Nordic model exists only in a smaller set of jurisdictions [2] [6].
6. Bottom line: a concise answer with a caveat
The straightforward inventory most frequently cited in the reporting names Sweden (the originator), Norway and Iceland (early Nordic adopters), and later Canada, France, the Republic of Ireland, Northern Ireland and Israel as jurisdictions that have enacted buyer‑criminalization laws described as the Nordic model [1] [2] [3] [4]. However, every claim of “adoption” requires the caveat that legal language, enforcement practice, and accompanying social services vary widely — and those variations are central to debates about the model’s effects [5] [6].