Challenging demand for prostitution: international evidence review

This rapid evidence review assesses and synthesises evidence on international approaches to challenging demand for prostitution.

5. Impacts and enablers of challenging demand

This chapter synthesises the evidence on impacts and possible enablers of the approaches outlined in Chapter 4, paying particular attention to the central objectives underpinning challenging demand approaches identified previously, namely to:

  • reduce demand for prostitution;
  • improve the lives of women and men involved in prostitution through support that reduces harm and/or helps exit;
  • change social attitudes towards the commodification of (primarily female) bodies.

Given the evidence gaps outlined in Chapter 3, discussion is limited to describing associated impacts and enablers. Further research is needed to determine direct causality between the trends described and challenging demand interventions. The evidence describes similar trends outlined in the 2017 international evidence review commissioned by Scottish Government with regards to a drop in on-street prostitution, a rise in recorded crime and charges, and changes in social attitudes in favour of challenging demand.

As described in Chapter 2 and 3, there are a number of evidence gaps which should be borne in mind when reviewing the report findings in this section, most notably, a scarcity in research on the prevalence of purchase and selling, a reliance on small qualitative studies, and a lack of research and data on support service use and the effectiveness of national awareness campaigns. These gaps notwithstanding, the evidence points to a number of factors which may strengthen implementation of challenging demand approaches and which can be summarised as follows:

Table 3. Summary of enablers of challenging demand referenced in the literature
Targeting Demand Sustained and accessible support provision Changing social attitudes
  • Intelligence-led police operations aimed at detecting purchasers and identifying harder to reach groups involved in the sale of sex.
  • The adoption of enforcement policies (e.g. expunging previous convictions for selling sex) aimed at building trust among women and men involved in prostitution in addition to increased victim-centred / trauma-informed training to change culture and improve cooperation.
  • Partnership between specialist support providers, enforcement agencies and advocacy groups to improve information sharing and co-develop national operational guidelines.
  • Use of existing networks of support service providers to facilitate multi-stakeholder cooperation.
  • The provision of sustained, free and accessible, person-centred, holistic and trauma informed support services aimed at building trust with women and men involved in prostitution and fostering cross-agency coordination.
  • Strategies aimed at fostering culture change among the wider public and key stakeholders.
  • Inclusive policy that fosters support and collaboration with adults with lived experiences of selling sex.
  • Awareness courses on the dangers of prostitution aimed at those with experience of buying sex.

Targeting demand

Attempts to capture the impact of challenging demand legislation on reducing demand tend to focus on trends in detected cases of purchase. The evidence shows there has been a sustained rise in recorded crimes and charges for purchase related offences in a couple of jurisdictions, echoing findings made in the 2017 international evidence review (Malloch et al. 2017)[67]. The exact causes for the trends identified, however, remain unclear but could be attributed to a number of factors such as changes in police approaches to targeting and detecting purchasers.

Statistics cited in Gaudy and Le Bail's 2020 comparative summary of three evaluations of the French legislation including the government's 2019 national review[68], show an increase in the numbers charged for all offences related to prostitution. The latter rose from 799 in 2016 to 2,072 in 2017 and 1,939 in 2018 and contrasts with the decline in numbers charged for soliciting seen in the years running up to the introduction of the legislation from 3,290 in 2004 to 780 in 2015 (Gaudy & Le Bail 2020: 9).

Official statistics cited in a Department of Justice and Equality funded study conducted by the Sexual Exploitation Research Programme (SERP) at University College Dublin, show that the number of recorded crimes related to purchase went up from just 10 in 2018 to 92 in 2019 (a rise of 820%) (O'Connor & Breslin 2020: 81). The authors note that these figures contrast with a steady decline in recorded crimes related to brothel keeping since 2017, as well as a significant drop in recorded crimes related to "soliciting, loitering and living on the earnings of the prostitution of another" since 2014 from 79 to eight (O'Connor & Breslin 2020: 77). A similar albeit modest rise in recorded crimes was cited in the National Women's Council consultation submission for the Republic of Ireland's (RoI) ongoing national evaluation. Official statistics cited show an "increase of 171%" in recorded crimes related to the purchase of sex, with numbers increasing from only 15 in the first quarter of 2019 to 87 in 2020 (National Women's Council 2020: 8).

Exactly what might be contributing to the trends described, however, remains under-examined in the literature. The authors of the SERP study suggest that the decline in soliciting related crimes is likely a consequence of the decriminalisation of soliciting for the purposes of selling and shifts in policing priorities towards increased targeting of purchasers (O'Connor & Breslin 2020). Meanwhile the European Commission's Study on the gender dimension of trafficking in human beings which draws from face-to-face interviews with 10 Swedish stakeholders including enforcement officials, suggests that increases in the numbers of people apprehended and convicted in Sweden may have been the result of increased investment in enforcement (European Commission 2016: 127).

In terms of evidence on undetected cases of purchase the picture is less clear. Interviews with service providers and women and men involved in prostitution highlight a perceived drop in the number of "clients" (Le Bail et al. 2018: 32). The study, based on 70 semi-structured interviews with "sex workers", 24 interviews with grassroots organisations, focus groups and workshops with 38 people involved in prostitution and a supplementary survey (n=583), showed that the majority of interviewees displayed high levels of awareness of the legislation and had noticed an increase in fines and decline in clients due to heightened police presence (Le Bail et al. 2018: 32).

Little is known about the effects of challenging demand on deterrence more widely which may be the reflection of difficulties in evidencing it empirically (Malloch et al. 2017: 28). A "client survey" conducted for the Northern Irish (NI) 2019 evaluation suggests the deterrence effect may be low (n=1,276; 1,083 based in the RoI and 193 in NI) (Ellison et al. 2019). Just over half of respondents (53.5% in NI and 54.2% in the RoI) stated that the law had made no difference to the frequency with which they purchased and that they planned to continue to buy sexual services at the same rate (Ellison et al. 2019: 127). Only 11.6% (NI) and 10.8% (RoI) stated they were likely to be dissuaded from purchasing (Ellison et al. 2019: 127). These figures are not dissimilar to the proportion who stated they had changed their behaviour in Swedish survey conducted between 2011 and 2014 (less than 10%) (Östergren 2018: 178). In NI, surveyed clients reported an increase in online purchase compared to before the law's introduction (from 50.3% to 74.5% in NI) (Ellison et al. 2019: 122), however, the same survey did find a notable drop in the numbers of clients who reported having paid for street based prostitution in both jurisdictions (Ellison et al. 2019: 123).

The NI survey results also indicate a lack of awareness of the legislative provisions among purchasers and a lack of contact with enforcement. A substantial minority stated they were not aware that the law had changed in both jurisdictions (27.9% in NI and 23.7% in the RoI) (Ellison et al 2019: 125). In NI, 75.9% stated that access to commercial sexual services was just as easy as before implementation (Ellison et al 2019: 128). This number was higher in the RoI, with 83.1% stating they felt the law had little impact on purchase and ease of purchase (Ellison et al 2019: 128). The vast majority reported never having had contact with the police for purchase of sex related offences (97.5%) (Ellison et al 2019: 12).

Table 4. Reported purchaser contact with police
  Frequency (n) Percentage
Northern Ireland
Never 117 97.5%
Yes, arrested 1 0.8%
Yes, cautioned 1 0.8%
Yes, only spoke to 1 0.8%
Total 120 100%
Republic of Ireland
Never 720 92.4%
Yes, arrested 1 0.1%
Yes, cautioned 6 0.8%
Yes, only spoke to 42 5.4%
Total 779 100%

(Ellison et al. 2019: 131)

The generalisability of these figures, however, is limited given the survey's distribution via "adult service websites" and "escorting sites" which may mean there is an over-representation of the views of those who continue to purchase. They do nevertheless align with similar figures found in Huschke and Ward's analysis of a "client" survey in NI (n=446) which had been conducted prior to the legislative changes, showing that only seven per cent stated they would stop paying for sex if it was illegal (Huschke & Ward 2017: 4)[69]. Concerns with the representativeness of this second sample were, however, also flagged by the authors, once again emphasising the methodological difficulties in accessing and researching purchaser views and behaviour.

Issues around evidence gathering may be a contributing factor behind the low numbers of convictions seen in NI and ineffective deterrence[70]. The 2019 evaluation commissioned by the Ministry of Justice Northern Ireland reported 23 recorded crimes relating to Article 64A, 15 arrests for offences related to purchase and two prosecutions and convictions for serious sexual offences against women involved between 1st June 2015 and the 31st December 2019 (Ellison et al. 2019: 11)[71].

The picture in Sweden is similarly mixed. Whilst the 2017 review found indications of increased deterrence as a result of the criminalisation of purchase, recent qualitative research examining the views of 29 purchasers in Sweden in 2018 showed that for some, criminalisation had "added to the thrill of buying sex", whilst for others social stigma and criminality increased feelings of shame and fear of exposure (Grönvall et al. 2021: 662). No information on the distribution of these views among interviewees was provided, however, the small sample means the findings could not be generalised. The insights nevertheless draw attention to a complex array of contributing factors which may be driving continued purchase.

The 2019 French government report noted that participant evaluations of the awareness course aimed at purchasers suggested that a large majority had "changed their view of prostitution by the end of the course" (Gaudy & Le Bail 2020: 9). The European Commission's Study on the gender dimension of trafficking in human beings, also cited research conducted in Sweden by the National Board of Health and Welfare in 2012 which found the KAST service users had reduced alcohol and drug consumption (European Commission 2016: 127). Given the small number of interviews (n=10) and lack of methodological insights into the study, however, the generalisability of these insights on purchaser behaviour and course attendees is limited.

Possible enablers and lessons learned

Due to the limited nature of available research examining the impacts of challenging demand approaches on reduction, the identification of proven success factors is difficult. Enablers and lessons learned referenced in the literature primarily centre on improved ways of targeting purchasers, gathering intelligence and increasing cooperation among women and men involved in prostitution.

A number of enforcement practices were identified by police officials as being conducive to increased detection in the RoI. Interviewed officials from the Garda National Protective Services Bureau (GNPSB) in the SERP study referenced above, highlighted the importance of brothel raids and intelligence driven "days of action" in gathering necessary intelligence, raising public awareness and accessing harder to reach women and men involved (O'Connor & Breslin 2020). Days of action conducted across six divisions[72] in April, September and November 2019 by 'Operation Quest'[73] led to the identification and questioning of almost 100 suspected purchasers and were referenced by both the High Level Working Group in its interim review[74] and the SERP study as examples of good police practice (O'Connor & Breslin 2020: 106; Shannon 2020)[75].

The same SERP study, however, also noted the potentially traumatising effects of police raids for women and men involved in prostitution, raising concerns around a lack of adequate cooperation by those involved. Service user records (n=144) taken from the Health Service Executive's (HSE) specialist Women's Health Service (WHS) between 2015 and 2018 indicated that women involved experienced these raids as "frightening" and "humiliating" (O'Connor & Breslin 2020: 95).

Interviewed GNPSN officials recognised these concerns, highlighting the need for a "culture change" and greater embedding of a challenging demand approach across Garda operations as well as increased trust building with the women they encountered (O'Connor & Breslin 2020: 101). They identified a number of practices they were engaging in to improve trust among women and men involved such as welfare checks, targeted phone messaging notifying women and men involved of their support during the Covid-19 pandemic (O'Connor & Breslin 2020: 85). They also stressed their support for expunging past convictions related to soliciting for the purposes of selling as a way of recognising the importance of shifting the burden of criminality from women and men involved in prostitution (O'Connor & Breslin 2020: 86). This looks like it may be gaining momentum. In 2021 the Minister for Justice announced plans to expunge previous criminal records for the selling of sex with the view to "firmly assert" a commitment to supporting victims of exploitation[76].

In addition to these initiatives, the High Level Working Group interim review also stated that the Garda has been in the process of developing multi-lingual resources to be distributed to women contacted through raids that inform them of the law, the role of Gardaí and available support, as well as increasingly referrals to specialist support services such as Ruhama (Shannon 2020: 10). In its recommendations, it emphasised the need for continued resourcing of police training in "cooperation with specialist services to ensure a gender specific, victim-centred and human rights approach" (Shannon 2020: 11). The SERP study similarly recommended continued "trust building" and development of "positive relationships with women" through welfare checks and training of Gardaí to "ensure culture change" (O'Connor & Breslin 2020: 106).

The effectiveness of these initiatives remains to be seen but they nevertheless signal possible lessons learned around facilitation of collaboration and trust building with women and men involved in prostitution and resonate with some of the literature on other jurisdictions which similarly points to the importance of trust-building with women and men involved to target demand.

Cooperation between enforcement agencies and peer support organisations was also highlighted as a possible enabler of increased cooperation in a study examining trends in violence and harassment reported by "sex workers" (Campbell et al. 2020). The mixed methods study examined 14,370 reports of crime made by "sex workers" on between 2015 and 2019[77], a third party "reporting" and "alerting scheme" for "sex workers" in both the RoI and NI (Campbell et al. 2020: 283). The authors who are critical of challenging demand legislation in Ireland, found two to threefold increases in reports of non-criminal incidents such as "suspicious behaviour", "sought vaginal/anal sex without condom", "unauthorised photography/recording" and "maliciously reported you to police/authorities". They also found two to fourfold increases in crime incidents such as "assault with a weapon, "attempted robbery", "caused damage to property", "robbery" and "requested illegal acts, e.g. underage sex" (Campbell et al. 2020: 298). From their sample the total number of respondents who stated having reported to the police was only 40. They suggested that temporary rises in crime reporting could "usually" be attributed to specific work done by specialist services to support reporting to the police, drawing attention to the importance of service providers as possible gatekeepers to increased reporting (Campbell et al. 2020: 306).

The authors note limits in the study's findings such as a possible over-focus on work-related victimisation to the exclusion of non-violent encounters as well as a reliance on data from a third party reporting system which does not necessarily reflect the experiences of all women and men involved in prostitution in Ireland (Campbell et al. 2020: 284). Similar conclusions, however, were drawn in the NI review (Ellison et al. 2019: 157) and in the French national evaluation which stressed the need for the strengthening of the role of advocacy and support organisations engaged with women and men involved to improve support for "victims of rape, sexual assault, and violence" through for example, increased liaison with public prosecutors in order to help victims of crime to report incidents (Gaudy & Le Bail 2020: 16).

Amnesty International's recent and highly critical report on the effects of the implementation of the RoI's legislation on women and men involved, makes similar recommendations (Amnesty International 2022). Interviewed "sex workers" and experts called for the separation of An Garda Síochána officers tasked with enforcement and those used for reporting as a potential facilitator of increased reporting of violent incidents by "sex workers" (Amnesty International 2022: 36). The report recommended the development and embedding of policies "that build trust between An Garda Síochána and sex workers" (Amnesty International 2022: 59).

Examples of best practice with regards to mechanisms for improved cooperation may be found in Sweden where concerns with organisational problems impacting "effective action" have contributed to increased focus on fostering greater collaboration across stakeholders through bodies such as the National Task Force against Prostitution and Trafficking (NMT) (Erikson & Larsson 2019: 6) [78]. According to Erikson & Larsson's analysis of policy and interviews with governors from the Ministry of Justice, CABS, the NMT and Platform[79], initiatives such as the NMT have sought to improve partnership between public agencies and NGOs, acting as an "intermediary […] between rule makers and the implementation of policy" and filling "gaps" in the absence of "operational guidelines" in the existing legislation through activities such as information sharing (Erikson & Larsson 2019: 8). The NMT includes agencies such as Social Services, the Police Authority, the Swedish Migration Agency, and the Swedish Prosecution Authority and adopts a flexible approach necessary to adequately "focus on victims, and work on a case-by-case basis" (Erikson & Larsson 2019: 8). Key benefits highlighted in the study have been the development of a close relationship between public and private actors across networks, the development of "mutual trust which has heightened coordination and improved operational capacity for assisting victims" and greater incorporation of victims' perspectives in the development of programmes and collaborative networks (Erikson & Larsson 2019: 12-14). The authors also note, however, that a possible weakness of such close collaboration may be a lack of independence between civil society and government agencies.

Impacts on human trafficking

Recent research also draws attention to a possible relationship between challenging demand approaches and decreased human trafficking in line with the Scottish Government 2017 evidence assessment findings (Malloch et al. 2017). Quantitative research examining the relationship between the prevalence of sex and human trafficking and differing legislative approaches towards prostitution as well as the results of a difference-in-differences[80] analysis of Norway's implementation of a Nordic model, found a significant negative correlation between challenging demand approaches and trafficking levels (Hedlin 2017). The author notes the need for caution in the interpretation of these findings given major gaps in human trafficking data which only accounts for reported cases of trafficking. Moreover, changes in reported cases of trafficking do not necessarily mean an increase of victims but could reflect improved reporting mechanisms and there are difficulties in determining the effects of prostitution approaches on reporting practices (Hedlin 2017).

The European Commission's study cited previously which drew from face-to-face interviews with 10 Swedish stakeholders including the Chancellor of Justice, National Rapporteurs on Trafficking, specialist anti-trafficking police officers and academics, found that interviewees regarded the purchase law as a central tool in their capacity to "address" trafficking (European Commission 2016: 125-127). Half of those interviewed claimed that the purchase legislation "provided different entry points to gather intelligence on sexual exploitation and trafficking" necessary for "targeted investigations, surveillance, and prosecutions" (European Commission 2016: 127). Further evidence on day-to-day implementation and its overlaps with human trafficking detection, however, is needed to support these findings.

Supporting women and men involved in prostitution

Evidence providing insights into the effectiveness of provisions in supporting women and men involved in prostitution is hindered by similar difficulties seen with regards to purchase. Reliable estimates of the numbers of women and men involved are difficult to establish and little continues to be known about the impact of service provision on the prevalence of prostitution, particularly for those who sell sex indoors and online. Available research on support provisions is largely based on small-scale qualitative research examining the experiences of services users and providers, limiting an assessment of evidence on the accessibility and reach of available support.

In keeping with findings from Sweden and Norway outlined in the Scottish Government evidence review in 2017 which showed a notable drop in the numbers engaged in on-street prostitution[81], evidence in NI suggests there has also been a decline in on-street prostitution since the introduction of challenging demand legislation The national evaluation estimated that as few as 5-10 women continued to be involved in on-street prostitution, down from 20 which had been estimated in 2014 (Ellison et al. 2019: 80). The new numbers are, however, based on estimates made by a support worker from the Belfast Commercial Sex Workers Service (BCSWS) which operates a weekly drop-in service to women and therefore may not capture those who do not access the service. Moreover, the authors note that on-street prostitution in NI has historically been low and further research into online and indoor forms of prostitution is needed.

In the case of France, the Central Office for Fighting Against Trafficking in Human Beings (OCRTEH), a police department dedicated to investigating procuring and collecting data on "sex work", estimated that between 18,000 and 20,000 women and men were involved in on-street prostitution in 2011 (Darley et al. 2018: 99). Recent estimates of numbers of women and men involved in on-street prostitution to compare these pre-implementation estimates with the numbers involved post-implementation were not found. Interviews with representatives of grassroots organisations suggest that while they have noted a drop in purchaser numbers, a similar decrease has not been in seen in the number of people they support with the exception of Maison de View du Rousillon and the Comité des TDS in Perpignan and the Planning Familial in Aude which reported a significant decrease (Le Bail et al. 2018). The authors note that enforcement in this region has been particularly strict, suggesting that increased targeting may be key to reducing numbers of women and men involved in prostitution (Le Bail et al. 2018: 38).

In terms of service provision, a review of the French legislation's implementation which examined extensive documentary data and eight interviews with women's rights delegates in charge of overseeing and organising the exit programme at "depártement" level, noted unanimous consensus among delegates that the exit programme had been beneficial to those able to access it (St. Denny 2020). Interviewees claimed that the programme had been helpful in aiding exit by giving applicants the possibility of finding alternative means of income and accessing professional training. The 2019 French national evaluation suggested that in most cases the exit programme had enabled users to find initial albeit insecure forms of alternative employment (Gaudy & Le Bail 2020: 24). How accessible the programme is, however, remains unclear.

The Le Bail et al. evaluation, similarly found that the majority of interviewees (70 "sex workers" and 24 members of "sex worker" organisations) who wanted to leave thought the exit programme was a positive thing even if more than half had not yet heard of it and there was some misinformation on the available support provisions (Le Bail et al. 2018: 56). The study also showed that the support provided in the exit programme aligned with the needs most identified by interviewees such as papers, housing and training (Le Bail et al. 2018: 56). Moreover, the majority of the women and men interviewed in the study expressed desires to do something else, pointing to the potential of the exit programme in further supporting people involved to find alternative means of income.

A second study conducted by SERP in the RoI focused on the experiences of those involved in prostitution and its impact on health and well-being of those accessing the Women's Health Service (WHS). The study noted that interviewed service users viewed the WHS as "invaluable" and were "thankful" it existed and was free to access (Breslin et al. 2021: 82). Of those in the sample of WHS user records who attended the WHS more than once (n=100), 71% expressed a desire to exit (Breslin et al. 2021: 86). Meanwhile, a participatory research study conducted by Sex Work Alliance Ireland (SWAI) which included a small survey of people who sell sex (n=24), found that the majority of respondents thought that the law did not prevent people from entering prostitution (n=16) (SWAI 2019: 13). The main reasons reported by participants for entering "sex work" was because it offered more money or flexible hours than other jobs (n=20) and half stated they had left "sex work" for a period of time (n=12) (SWAI 2019: 33). In response to a question asking them what they would need in order to leave "sex work", the most commonly selected answers were financial stability (n=15), a well paid job (n=14), and secure accommodation (n=13), again highlighting the importance of socio-economic factors in entry and re-entry into prostitution (SWAI 2019: 44). The small sample of respondents means caution is needed when interpreting the generalisability of these findings, however, research examining gaps in support provision in Chapter 6 echo some of these conclusions.

No national figures for numbers of women and men involved in prostitution accessing support services were found for any of the countries, limiting the assessment of the effectiveness of support provisions more widely.

Possible enablers and lessons learned

With regards to support for women and men involved, enablers (i.e. factors facilitating challenging demand implementation) referenced in the literature revolved around issues of collaboration, accessibility and continuity. Women's rights delegates in charge of overseeing and organising the exit programme at "depártement" level in France, suggested that an important factor in the successful delivery of the exit programme had been the existence of an established network of organisations aimed at tackling prostitution prior to the organisation of regional committees (St Denny 2020). Interviewees noted that where there was a lack of pre-existing networks or specialist organisations able to gain accreditation, the establishment of regional committees was harder (St Denny 2020: 9-10). Further issues around committee collaboration were raised in the three reviews summarised by Gaudy and Le Bail which found that there were reports of mistrust and suspicion among committee members and civil society organisations (2020: 19). Interviewed representatives of accredited organisations in the 2019 government stressed the potential of the exit programme as a means for increased cooperation between relevant stakeholders and the development of a "common culture between State services and civil society organizations" (Gaudy & Le Bail 2020: 20).

Research examining specialist support provision in the RoI, also placed an emphasis on greater cross-agency coordination as a helpful means of fostering ongoing service use by women involved in prostitution. The O'Connor and Breslin SERP study which analysed 144 WHS user records, interviews with Ruhama frontline workers and case studies, suggested that the appointment of case-workers for women through a case-focused approach was helpful in minimising women's recounting of traumatic experiences to multiple services (O'Connor & Breslin 2020: 57). The authors noted that the service linked women with other required services, coordinated support and provided consistent advocacy on behalf of the user which was important given the complex and wide-ranging needs presented by the women involved (O'Connor & Breslin 2020: 57). In the case studies alone, they found that recorded contacts made by Ruhama "with or on behalf of each woman ranged from 168 to over 1,300, with an average of 560 contacts per person across the ten case studies", stressing the complex and ongoing needs of the women accessing specialist support providers (O'Connor & Breslin 2020: 57)[82].

Breslin et al.'s SERP analysis of women's experiences in the "Irish sex trade" which focused specifically on women's health needs and experiences, found that service users frequently expressed feelings of "entrapment" due to the same financial pressures which had led them into prostitution and regularly spoke of "taking breaks" (2021: 88). The authors noted that this non-linearity of involvement pointed to a continuing need for free and accessible dedicated specialist health services for women involved in prostitution, as well as increased trust-building with women to foster continued service use and the development of tailored plans (Breslin et al. 2021: 24). Women tended to access services at times of crisis or when in need of accommodation, financial support, access to health care and legal advice. Once those immediate needs were addressed women could then choose to continue to access services for longer-term support.

Key enablers identified in the study included the "appointment of a psychologist", the adoption of "holistic", "case"-focused and "trauma-informed approaches", and increased support and supervision of frontline workers to ensure facilitation of trust-building with service users. Catalysts for exiting identified in the study included "tipping points" such as "becoming pregnant, having a baby, a close relative falling ill, contracting a STI, or other health related problems caused by prostitution" (Breslin et al. 2021: 86). The study also found that the majority of women accessing support services were migrants with past experiences of living in poverty and some had experiences of childhood abuse and neglect, domestic violence and many experienced mental health problems. The women involved in indoor prostitution, were highly mobile, many had no fixed abode and some were undocumented (Breslin et al. 2021: 21-28). Those supported by Ruhama frequently required help with accommodation, financial support, access to health care and legal advice, again drawing attention to the wide range of socio-economic and health needs similarly highlighted in Le Bail et al.'s 2018 study referenced above.

The non-linearity of exit and the need for "holistic" approaches were also flagged in another study funded by HIV Ireland and conducted in collaboration with the Irish Sex Work Research Network (ISRN) and the Sex Workers' Alliance Ireland (SWAI) between June 2019 and May 2020. The research which examined female "sex worker" interactions with healthcare providers through participatory research methods with 21 women and men involved, found there was demand for holistic medical services able to take into account service users' frequent inability or lack of desire to exit, emphasising the complex entry and exiting trajectories of those involved (Ryan & McGarry 2021: 6-7).

A flexible approach enabled the development of "innovative" responses to support provision (Breslin 2020: 22) in the wake of the COVID-19 pandemic. For example, recent research conducted by SERP which included interviews with service providers from Ruhama described the establishment of new services such as the delivery of emergency packs of essentials to women around the country, online support such as a parenting support group, a self-care group and an evening social group. The interviewees found that the online approaches had increased the service's reach to a larger cohort of women than usual (Breslin 2020: 22), indicating the potential importance of online support provision in increasing accessibility.

Increased outreach initiatives, support packages, hardship funds and paid return flights for migrant women and men involved were listed in Pro Sentret's report on experiences of the Covid-19 pandemic's handling in Norway, Finland, Sweden and Denmark (Renland et al. 2020). As of June 2020, 91 persons had benefited from the hardship fund which was offered by service provider and "sex work" advocate PION and aimed those whose sole source of income was "sex work" (Renland et al. 2020: 23). Concerns were raised by the report authors about the potentially stigmatising nature of these forms of support, however, and the effects of the restricted accessibility to normal welfare services on those involved. Further research is needed to determine the broader impacts of these support packages on supporting women and men involved in prostitution.

There was a paucity in research examining the effectiveness of mainstream support provision and significant concerns surrounding possible shortcomings in services were referenced in the literature particularly in relation to capacity and help for migrant women and men involved. These are unpacked in Chapter 6 where the focus is on barriers to implementation.

Changing social attitudes

Evidence on the normative effects of the legislation suggests there may be high levels of acceptance among the wider public in favour of challenging demand legislation in France, Sweden and Norway. A survey conducted in France in 2019 by Ipsos and commissioned by the Coalition Abolition Prostitution International found that the majority of respondents were positive about the legislation (representative sample of 1,005 respondents aged 18 and above) (Ipsos 2019). 78% of respondents thought that Law No. 2016-444[83] was a "good thing" compared to 22% who thought it was a "bad thing". Moreover, 73% of respondents thought the legislation was helping people to exit prostitution and 63% believed it helped support the fight against criminals exploiting prostitution. Two in three respondents and three in four female respondents opposed its repeal. A large majority of respondents thought that those involved in prostitution were more often victims of criminal networks and did not enter prostitution freely (83%) and 65% thought that prostitution should not be possible in a society which advocates gender equality. The findings contrast markedly with previous studies conducted before demand legislation which had shown high levels of support among the general population for the previous regulationist model. Figures cited in the literature, suggest support for the previous regulationist model was as high as 75% in 2013 (St. Denny 2020).

Some of the literature shows higher levels of support for criminalisation in Norway and Sweden compared to jurisdictions where purchase is regulated as opposed to criminalised. A comparative study conducted in 2014 of eight jurisdictions including France (pre-legislation), Norway and Sweden[84] examining attitudes towards the purchase of sex in different "prostitution regimes" found that in countries where purchase was prohibited, people who viewed gender equality as important were less accepting of purchase (Jonsson & Jakobsson 2017: 58). The study which analysed results from an internet survey (n=16,948) suggests that Swedish and Norwegian respondents held the most negative attitudes toward buying sex. The authors note, however, that the sample is not representative of the overall populations of the countries included in the study.

Determining the causal mechanisms at play behind these trends is, however, difficult as it remains unclear if these attitudinal trends are products of the legislative changes made or contributing factors behind the embrace of particular legislative models. Indeed, little evidence examining the effectiveness of national campaigns or public education and training initiatives aimed at changing social attitudes was identified. Research conducted in Sweden in 2008 which analysed the views of elite party members on the role of gendered perceptions in the development of political strategies aimed at changing legislation in favour of challenging demand, noted that interviewees stressed the importance of framing prostitution as a societal and equality-based issue. Other enablers mentioned in the study included gaining support among male counterparts as well as fostering cooperation among women across party lines to obtain necessary buy-in across parties (Erikson 2019). The study did not, however, assess the effectiveness of these strategies.



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