What America Could Learn From How Other Countries Handle This

Posted by Julia | 8 min read

So I've been doing a lot of research lately about how other countries handle sex work, and honestly? It's made me really frustrated with the legal mess we deal with here in the US.

Some countries have figured out ways to make this work safer and more straightforward for everyone involved. Others have tried approaches that sound good on paper but are disasters in practice. And a few have systems that make our American legal confusion look simple by comparison.

Let me walk you through what I've learned, because understanding how other places do this has completely changed how I think about the legal and social side of Asian escort work.

The Netherlands: Not What You Think

Everyone always talks about Amsterdam when discussing legal sex work, but the reality there is way more complicated than the tourist image suggests.

In the Netherlands, sex work has been legal since 2000, but it's heavily regulated. Workers have to register with the government, pay taxes, work from licensed premises, and follow strict health and safety rules.

On paper, this sounds amazing. Workers get labor protections, can report crimes without fear, have access to healthcare and social services. The government treats it like any other profession.

But my friend Sophia, who worked there for six months, told me the reality is more complicated. The licensing system is expensive and bureaucratic. Many cities have been closing red-light districts under pressure from residents who don't want sex work in their neighborhoods. And the regulations are so strict that some workers actually prefer to operate outside the legal system.

Plus, there's still stigma. Having "sex worker" on your official employment records can make it hard to get other jobs later, rent apartments, or access some services. Legal doesn't automatically mean socially accepted.

The coolest part though? Workers can form unions, collectively negotiate working conditions, and have real legal recourse when clients or business owners treat them badly. That's something I can only dream about here.

Germany: The Business Approach

Germany legalized sex work in 2002 and basically treats it like any other service industry. Workers pay income tax, contribute to social security, can get health insurance through their work, and have the same labor protections as other employees.

What's interesting is that Germany allows advertising, so workers can market their services openly without the weird coded language we have to use here. They also allow third-party business operations, so agencies and brothels can operate legally with proper licensing.

But Germany also shows some downsides of full legalization. There are concerns about increased trafficking because the legal market creates demand that draws in illegal operators too. And some workers report feeling pressured to accept clients or services they're not comfortable with because refusing could be seen as not fulfilling their "employment duties."

One thing that's cool though – German sex workers can refuse clients for any reason, and that refusal is legally protected. If someone gives you bad vibes or asks for something you don't want to do, you can just say no without worrying about legal consequences.

Imagine having that kind of protection built into the law instead of having to navigate everything through weird gray areas.

New Zealand: The Decriminalization Model

This is the approach that sounds most appealing to me personally. In 2003, New Zealand decriminalized sex work completely. It's not regulated like a business, but it's also not criminalized.

Workers can operate independently or work together for safety. They can advertise their services openly. Police focus on actual crimes instead of harassing consensual adult transactions. And workers can report violence or exploitation without fear of being arrested themselves.

The key difference from places like Germany is that decriminalization doesn't create a whole regulatory bureaucracy. Workers aren't forced to register with the government, pay special taxes, or follow industry-specific rules. They just... do their work without legal interference.

A sex worker I follow on social media who moved from the US to New Zealand said the biggest difference is not having to constantly worry about legal consequences for normal business activities. She can screen clients openly, maintain a professional website, and handle payment disputes through normal business channels.

The downside? There's less official support and protection than in fully legalized systems. If you have problems with clients or business partners, you're mostly on your own to resolve them.

The Nordic Model: Good Intentions, Terrible Results

Sweden, Norway, Iceland, and France use what's called the "Nordic Model" – sex work itself isn't illegal, but buying sexual services is. The idea is to criminalize demand while protecting workers from prosecution.

This sounds compassionate and feminist-friendly, right? Help the workers while punishing the exploitative clients?

But sex workers in Nordic model countries say it's actually made their work way more dangerous.

When clients are committing crimes by seeing you, they're reluctant to provide screening information or meet in safe locations. They're more likely to want quick, discrete encounters in sketchy places because they're trying to avoid getting caught.

My friend Emma worked in Sweden for a year and said it was terrifying. Clients would show up in disguises, refuse to give real names, and push for appointments in isolated locations because they were paranoid about police stings.

Plus, since advertising is often restricted (because it could be seen as "aiding" the illegal purchase of services), workers have trouble reaching clients safely. They end up working through third parties who may not have their best interests in mind.

The Nordic model might make politicians feel good about "protecting" sex workers, but most actual sex workers say it makes their lives harder and more dangerous.

Australia: State by State Chaos

Australia is interesting because different states have completely different approaches, kind of like how the US varies by state but even more extreme.

Some states have full legalization with licensing and regulation. Others have decriminalization. A few still criminalize everything. And the laws change pretty frequently as different political parties gain power.

What's cool is that this creates a natural experiment – you can compare how different legal approaches work in similar cultural contexts.

From what I've read, the states with decriminalization seem to have the best outcomes for worker safety and satisfaction. The heavily regulated states have problems with bureaucracy and compliance costs. The states that still criminalize everything have the usual problems with workers being afraid to report crimes or seek help.

Canada: The Weird Hybrid

Canada tried to create a compromise system that's somehow more confusing than what we have in the US.

Selling sexual services is legal, but buying them is illegal (like the Nordic model). But also, a bunch of activities around sex work are illegal – advertising, working in groups for safety, having third parties help with business operations.

So Canadian sex workers can legally sell their services, but they can't safely advertise those services, work together for protection, or hire people to help with screening and booking. It's like being told you can legally run a restaurant but you can't advertise it, hire employees, or serve food to groups of people.

Most Canadian sex workers I've talked to online say this system is worse than either full criminalization or full legalization because it creates maximum confusion and isolation.

What Actually Works

Based on everything I've researched and heard from workers in different countries, here's what seems to actually improve safety and working conditions:

Decriminalization works better than legalization. Removing legal barriers without creating new regulatory burdens gives workers the most autonomy and flexibility.

Workers need to be involved in creating policies. The most successful legal changes happen when actual sex workers are consulted, not when politicians make decisions for us.

Partial criminalization doesn't work. Whether it's criminalizing clients or criminalizing business activities, half-measures usually make things more dangerous for workers.

Social acceptance matters as much as legal status. Even in places where sex work is legal, stigma can still create problems with housing, banking, and other services.

What I Wish America Would Try

If I could redesign American laws around sex work, I'd probably go with something like New Zealand's decriminalization model.

Take away all the criminal penalties for consensual adult transactions. Let workers advertise openly, screen clients properly, work together for safety, and handle business disputes through normal legal channels.

Keep laws against coercion, trafficking, and exploitation, but stop treating voluntary sex work like it's automatically harmful or criminal.

Most importantly, actually listen to sex workers about what policies would make our lives safer and easier instead of making decisions based on moral panic or what sounds good to voters.

The Reality Check

None of these international models are perfect, and what works in one country might not work in another because of cultural, economic, or political differences.

But what's frustrating is that other countries are at least trying different approaches and learning from the results. Here in the US, we're still stuck with laws that were written decades ago and don't reflect the reality of modern sex work.

We could be learning from other countries' successes and mistakes instead of pretending that our current system of legal confusion and inconsistent enforcement is the only option.

I don't know if I'll still be doing this work when (if?) American laws ever change. But for future people in this industry, I hope we can figure out something that prioritizes worker safety and autonomy over moral posturing and political convenience.

Until then, I'll keep navigating our weird legal maze and dreaming about what it would be like to work somewhere with clearer, more rational laws.

Julia

Policy approaches to sex work continue to evolve globally. For current information on laws in specific countries, consult legal experts and sex worker advocacy organizations.