Introduction

In 2014, Leeds initiated a radical change to local sex work policy and adopted a ‘managed approach’. The managed approach ended the enforcement and disruption of local sex work spaces and venues and took a ‘tolerant’ approach to street sex work by implementing a ‘managed zone’ of sex work within one of the previous two Red Light Districts (RLDs) of Leeds. The zone is defined by space and time. In the zone, sex workers and their clients are able to make contact and negotiate terms. However, within the confined area of a few streets, they are not permitted to conduct sexual services within the zone. Since its inception, the managed zone has had periodic review to assess the impacts. Findings demonstrated a dramatic rise in the reporting of crimes committed against them from the sex workers using the zone and increased engagement in health and social support services (Brown et al., 2019; Sanders & Sehmbi, 2015). The independent review of this highly contentious and controversial approach was released in July 2020 (Roach et al., 2020). In June 2021, Leeds City Council announced that the managed area and managed approach to sex work would end, and the focus of local sex work policy would shift back to the criminalisation of sex workers and increased partnership working to ‘help’ women who are street sex working and have complex needs to stop on street sex work. In addition, the clients of sex workers will be targeted through the use of anti-Social behaviour orders, public space protection orders and fines (Yorkshire Evening Post, 2021). This social policy turnabout and paradigm shift from enforcement to harm reduction and then to ‘rescue’ and client criminalisation reflects the growth of the end demand model of sex work policy in the UK and mirrors findings from my WCMT Fellowship travels that there is a systematic reduction of visible spaces of sex work with the aim of eradication of street sex work.

The negative focus on street sex work is misleading and yet receives disproportionate public and media attention. It is well documented that visible spaces of sex work and street sex work, in particular, are the most contentious, the most criminalised, and the most dangerous (Kinnel, 2006, 2008; Sanders & Platt, 2017; Cunningham et al., 2018). It has been researched and clearly evidenced that street sex work has the highest levels of violence and the least environmental protective factors for safety. An analysis of the limited available data of homicides in the UK between 1990 and 2016 revealed that there have been 180 sex workers murdered during that period. Eighty victims were street-based sex workers. However, they also evidenced a shift in the last 10 years with an increase in murders of indoor sex workers (59%) and a dramatic rise (5% to 50%) in the proportion of migrant sex workers murdered. The shift may be reflective of the changing modes of sex work and sex work populations in the UK, or as suggested it could be the result of targeted violence towards sex workers who are perceived to be vulnerable (Sanders & Platt, 2017). However, when street sex work is viewed from the sex worker perspective, it is clear that it is distinct from other modes of sex work: it is immediate and can be transitory. Street sex work does not require any prior investment of time or money, and it does not require access to technology or IT skills. A street sex worker does not need to pay for advertisements or spend time developing an online platform, and there is no prior engagement requiring time and emotional labour to arrange a transaction. These features are also true for sex workers in brothels, but for street-based sex workers, the working hours are flexible and not constrained by shifts; they can leave when they want or have earned the desired money. On receipt of payment for services, 100% belongs to the sex worker; there are no built-in fees for third-party involvement. An individual can engage in sex work on a ‘one off’ basis, relieve immediate financial need and leave no permanent record online (photos, telephone numbers and other details that can be linked to a non-sex worker identity) unless they are criminalised in the process. Under current UK legislation, criminalisation could be for soliciting on the streets, and for brothel workers; criminalisation for working together or in collaboration with others.

This project was initiated in 2016 and set out to explore what we could learn from European examples of the spatial management of sex work in different cities and integrate best practice examples into the discourse of visible sex work in the UK. In this article, I explore some of the findings from a project funded through a Winston Churchill Memorial Trust Fellowship. The main purpose of the fellowship was to explore the best practice in relation to different ‘managed approaches’ to visible (street and windows) sex work. Research questions addressed how the labour rights, terms and conditions of work, health and safety of sex workers were impacted by national legal frameworks and local policy.

The findings suggest that street and window spaces across Europe and within each regime model are under intense pressure and are being systematically reduced. They are increasingly becoming sites of contention and controversy. There are many pressures for visible sex work to become invisible. The reduction of visible spaces of sex work is often achieved through criminalisation or enforcement action with the intention to deter the sex working population from working in these spaces. This has led to an increased movement of sex workers between sex work spaces, sex work markets and modes of working. This has also resulted in new spaces of sex work that can be considered displaced as they are outside the remit of scoping research and service provision.

The findings reveal and demonstrate that the rise of the ‘oppression paradigm’ (Weitzer, 2010) where sex work is seen as inherently harmful has influenced the local policies and practices across the legal frameworks that take a ‘repressive’ or ‘restrictive’ (Ostergren, 2017) approaches to sex work. Findings also reveal that some aspects of visible spaces of sex work in ‘restrictive’ legal frameworks do include features that have positive impacts on the health and safety of sex workers. If these are regarded as only applicable to defined legal frameworks, we may overlook the benefits and opportunity they may offer if considered as transferable and viable options for other national and local approaches to managing sex work spaces. The article ends with a reflection of how the COVID pandemic has exacerbated the need for full decriminalisation to prevent poverty, destitution and violence.

Sex Work Regulation and Law

It is generally accepted that there are five typologies of sex work law across the globe that describe the range of political, social and moral positions on sex work:

  1. 1.

    Full criminalisation of sex work describes where all participants in the transaction: the sex worker, the client and third parties (managers, drivers and landlords) are all criminalised. Examples include the following: USA, S. Africa, Kenya, Uganda, Russia, Iran, Pakistan and China.

  2. 2.

    Partial criminalisation, where the buying and selling of sex are legal but associated activities are criminalised: soliciting, kerb crawling, working together and facilitating sex work; this is found in England, Scotland and Wales.

  3. 3.

    Regulation, legalisation or licensing. This model is associated with Germany, Netherlands and Nevada (USA). This describes a system of heavy regulation of legal strands of the sex industry with criminalisation for non-compliance. Requirement features might include the following: registration as a sex worker, health checks and testing, and employment in certain venues.

  4. 4.

    Asymmetrical criminalisation (‘Nordic model’, ‘Swedish model’, sometimes known as ‘end demand’) describes the criminalisation of the ‘buyers’ of sex and third parties, and in theory, the decriminalisation of selling sex. This model has expanded from Sweden, to Iceland, France, Israel, Northern and Southern Ireland.

  5. 5.

    The full decriminalisation of sex worker describes the legal framework found only in New Zealand and some Australian states where all parties are decriminalised and sex work is regulated through labour law. However, it is important to note that some sex workers will still be excluded from engaging in this decriminalised system due to their migration status).

However, the neutrality of this language does not reflect the reality of how the laws impact upon the lived realities of sex workers (Smith & Mac, 2018). An exploration of these legal models reveals that, in most countries, some aspects of sex work are illegal, for example, it may be legal to sell sex, but all other associated activities are criminalised (working together, advertising and soliciting), as in England, or there is a system of licensing, registering and testing in order to meet the legal requirements as in Germany. It is therefore important to not only view sex work within a legal framework but to explore what non-criminal legislation and administrative procedures impact upon sex workers. This is further complicated by regional differences determined by local or state laws or local policy within countries (Overs, 2017).

Ostergren (2017) problematises the usual categorisation of sex worker legal regimes and suggests that it is more useful to scrutinise policy as either repressive, restrictive or integrative. Ostergren’s typology is summarised here: Repressive regimes, such as full criminalisation and the Nordic Model are based on a moral, religious or radical feminist ideology. The eradication of sex work is the stated aim. Criminal law is used with bans on the sale and/or the purchase of sex, third parties and awareness-raising campaigns. Sex work operates illegally, and therefore, sex workers have no labour rights and will find it difficult to access health, social assistance and report crimes committed against them. In restrictive regimes, sex work is managed to limit it in order to protect society and those selling sex from harm. Commercial sex is viewed as negative in itself, but it operates with a more pragmatic approach. Criminal and administrative law is used to regulate the conditions under which sex work takes place, for instance employing laws against soliciting, zoning regulations and/or strict licensing systems. Sex workers can operate legally, but under conditions that are more restrictive than those of other service sectors. A clear example of this is the barring from other professions such as teaching and social work of anyone who has been registered as a sex worker, regardless of when and how long a person was engaged in the sex industry. An Integrative approach is based on collaboration and rights. The stated aim is integration in order to protect those selling sex from harm. Commercial sex is viewed as a multifaceted phenomenon containing negative elements. Sex workers are seen as a category of service providers who are subject to stigma and specific risks in their work. An integrative policy thus seeks to integrate the sex work sector into the existing social and legal structures with the aid of labour and administrative law and ‘codes of conduct’ for authorities and operators within the sector, including initiatives to combat the stigmatisation of sex workers and improve their working conditions (Ostergren, 2017 p13–15).

Academics in health and social sciences are increasingly scrutinising and critiquing sex work law and policy to harms caused by each model and which has the least harmful impact on the health and welfare of sex workers (Howard, 2018; Platt et al., 2018; Vanwesenbeeck, 2017). The global movement for sex worker rights views the full decriminalisation of sex work as the single most important step to full access to full labour and human rights (Pitcher & Wijers, 2014). This position is supported by local, national, international health, social and human rights organisations. These include the following: United Nations Development Programme (UNDP), Human Rights Watch 2019, the Joint UN Programme on HIV/AIDS (UNAIDS) UN Population Fund (UNFPA) and World Health Organisation (WHO) 2013, the Global Network of Sex Work Projects (NSWP) 2017 and the Global Alliance Against Traffic in Women (GAATW) 2018. Amnesty International (2018) stated that the full decriminalisation of sex work can reduce the violence and HIV and other health risks for sex workers, can address the discrimination and associated stigma, and bring sex workers into the protections and human rights guaranteed to all other individuals.

The ‘Nordic model’ introduced by Sweden in 1999 focuses on the demand aspect of sex work and criminalises the buyers of sex. It demands that the governance and regulation of prostitution should adopt an abolitionist position with the stated intention of suppressing demand and ultimately eliminating the ‘prostitution’ of women. There has been strong criticism of this model from the academic and professional quarters which have questioned the legitimacy of the approach, based on the appeal of an ideological position rather than evidence (Kulick, 2003; McMenzie et al., 2019; Weitzer, 2013). The rise of abolitionist sex work policies is seen as part of broader neoliberal framing of crime and policing, immigration and border control (Jahnsen & Skilbrei, 2018; Ward & Wylie, 2017) morality, social order and social engineering (Jordan, 2012). There are considerable concerns about the impacts on the lived realities of all sex workers of all gender identities. It has been documented that sex workers are still criminalised under this system; it has not reduced the number of sex workers, and it has not protected sex workers from violence, exploitation or trafficking. It has driven sex work underground and increased the marginalisation and stigmatisation of sex workers by individuals and state (Scoular, 2004; Dodillet & Ostergren, 2011; Hauksdottir, 2010; Baird, 2012; Jordan, 2012; Skilbrei & Holmström, 2013; Levy & Jakobsson, 2014; Levy, 2015; Phipps, 2016; Medicine du Monde, 2018; Graham, 2017, Vanwesenbeeck, 2017, Stevenson, 2018). Most importantly, this approach is overwhelmingly rejected by the sex working community. It has been vociferously opposed because of the increased health risks, violence, exploitation and stigma that results from criminalising sex work and driving it underground (STRASS & Medicins du Monde 2013, SWARM, 2013; Fuckforbundet, 2019; NSWP, 2020a, b; International Women’s Rights Action Watch Asia Pacific (IWRAW), 2020).

Methodology

This project was initiated in response to my professional and personal experience of the changing dynamics of sex work in the UK and in street sex work in particular. The main purpose of the WCMT Fellowship was to explore the best practice in relation to different ‘managed approaches’ to visible spaces of sex work (street and window). For the purposes of the study, I was mainly focusing on sex workers who provide in-person sexual services and work alone in visible spaces and how the legal framework and local policies impacted on the physical spaces, labour rights, terms and conditions of work, health and safety of sex workers. I wanted to explore:

  • The physical structure and social organisation of visible sex work spaces. This included the terms and conditions of street and window sex work in different cities, and the features of zoned areas; how they have been established; and how they have changed over time.

  • The unintended consequences of zoning, including displacement of sex work and sex workers into other spaces.

  • How this influences and affects service delivery. To look for practical solutions to the real-life complexities of working with sex workers and sex work issues.

This research takes the ontological and epistemological positioning that sex work is work and is informed from the sex worker rights paradigm. This position asserts that the safety of sex workers is directly related to their access to labour, civil and judicial rights and that this can best be addressed by the full decriminalisation of sex work. It places the lived experiences of current sex workers as the key informants of their experiences and needs and clearly demands that all policy, practice and research should be developed in consultation with current sex workers: ‘nothing about us, without us’.

Prior to travel, I conducted some preparatory research: I conducted a literature review of relevant sex work research, I reviewed the online directories of organisations delivering services in cities of interest, I sent a number of emails and introduction letters and I contacted and informed various sex worker-led organisations, service provider and research networks of my proposed travels and asked for personal recommendations. These were identified through the International Committee on Sex Worker Rights in Europe (ICRSE), the Global Network of Sex Work Projects (NSWP) and the European Network for the Promotion of Rights and Health among Migrant Sex Workers (TAMPEP).

Fieldwork, Travel and Being in Spaces of Visible Sex Work

As a WCMT Fellow, I spent 5 weeks in 2016 and a further 5 days in 2018 travelling across North West Europe looking at how street sex work is managed within different regulation regimes. I made field notes and observations of street and window areas of sex work in 10 identified cities in 5 countries (Belgium, Netherlands, Germany, Switzerland, France). I walked and made personal observations in 15 different sex work spaces in those cities. This included 6 city zones with window sex work spaces, 6 street sex work zones including 2 tippelzones, and 3 with a mixture of street and indoor flats. I spent 4 evenings at service drop-in sessions, talking informally to service users, 2 of which were in the tippelzone ‘living room’’ facilities. I visited and spoke to 13 different service delivery organisations and conducted 2 ‘walk and talk’ sessions with professionals in the sex working zones, and I led 4 staff group discussions and spent time with, spoke to and conducted semi-structured key informant interviews with 10 professionals, 3 individual sex workers and 1 independent academic. I attended one multi-agency community forum in Berlin and 2 conferences with sex worker activists from across Europe: ICRSE 3-Day Action Meeting In Brussels: The Human Rights of Migrant Sex Workers in Europe (November 2016) and the SNAP Festival Sex worker Narratives Arts and Politics for 3 days in Paris (November 2018).

Through my personal professional experience, I was aware that many factors could impede my access to sex work projects. They have always been very protective of their service users’ anonymity and will naturally avoid voyeuristic research or journalistic interest. I was therefore aware that personal recommendation may be needed to gain access. I hoped that, in addition to pre-arranged contacts, I would be able to make new local contacts through a snowball effect. I made video and/or audio recordings of some of the interviews, and for others, I made contemporaneous notes or reflections recorded afterwards on my phone or journal. A photographic record was made during my travels but not of any individual sex workers or their working spaces. Although there was no ethical approval process for the WCMT Fellowship, I adhered to the principles of ethical research (MMJ6) and endeavoured to ensure that my research had no harmful effect on participants, in line with the British Sociological Association (BSA), 2002.

On my return to the UK, the interviews were transcribed, coded and then tabulated according to emerging themes. Themes related to physical spaces, implications for service delivery, and impacts on sex workers lived realities. I continued with an extensive literature review. During this research, I have taken a dialogical approach; this was a research exercise but also an ongoing process. It has been difficult to know when to stop and say that it is finalised. In the 4 years, since the Fellowship, the process of gathering information and evidence, iteration and building knowledge, and the dissemination of that learning has been fluid and dynamic.

The Governance of Visible Sex Work in Europe

In the European countries visited, I saw many different models of the special management of visible sex work, not found in the UK. The consideration of these models can reveal knowledge that can contribute to the development sex work policy and best practice in the UK and beyond. In the UK, we associate visible sex work with street sex work in a red light district (hereafter, RLD). RLDs are usually defined as urban areas where there is a concentration of street sex workers, and in the UK, they are usually associated with areas of neglect, crime and disorder and viewed as marginal and immoral (Hubbard & Whowell, 2008; Weitzer, 2014). Hubbard et al., (2008a, b) assert that a common factor between nations who have adopted different approaches to managing prostitution is repressing the spaces of street prostitution. This is described as resulting in geographies of ‘exception and abandonment’ where the risks of violence and exploitation are greater.

European cities have sex work spaces that are one or a combination of the following. There are many examples of RLDs that have similarities to the situation in the UK; they fit the typology described above of unregulated places, maybe with some service provision through outreach, and with unknown levels of associated violence, exploitation and criminality. On my travels, I saw examples in Kurfürstenstrasse, Berlin, the streets of Charleroi, Belgium, and the Bois de Boulogne area in Paris.

Some red-light districts (RDLs) are integrated into central city locations and are an important feature of the night-time economy. In these circumstances, sex work in brothels, street and/or window spaces are integrated into an area with other sex orientated businesses including sex shops, strip clubs and adult movie cinemas along with other hospitality venues such as café’s, bars, restaurants and shops. Examples of this model that I explored included Amsterdam Central RLD, Frankfurt RLD and Quartier Pigalle RLD in Paris.

Other cities demonstrated a toleration of sex work throughout a city with an’exclusion’ zone where sex work is not permitted. This model is associated with the Swiss cities of Geneva and Zurich and the Swiss model of legalisation of sex work. The old city in Geneva is a very affluent area with historic and prime properties. The residents exerted pressure on the state to stop sex work in the locality and create an exclusion zone. Sex workers can work anywhere else in Geneva city with just a few rules: not within 30 m of a school or bus stop, and sex workers cannot widely promote or advertise their business.

In the Le Paquis area of Geneva and in Charleroi (Belgium), I also saw RLDs where sex workers solicit on the street outside a sex work residence. The sex workers rent the working space either individually or collectively. It was reported that many of the flats in Le Paquis are leased on high rent short-term agreements to transient groups of sex workers, who often also live in the premises. In Le Paquis, this type of sex work was integrated into an area of mixed businesses, family accommodation, shops and businesses. The women I spoke to in Charleroi selling sex in this way and spoke about the heavy inflated costs of renting a working space in addition to their private living costs.

Tippelzones are a designated area for street sex work where the buying and selling of sex. The first tippelzone was established in the Hague in 1983; the model was adopted in many cities across the Netherlands and other European cities. The development of the tippelzones of the Netherlands was a direct response to the needs of more marginalised sex workers: drug users, transgender sex workers, and those who cannot or choose not to work for whatever reasons, in windows, brothels, through agencies or independently online. Initially, there was free access to the zones, but in recent years, proof of local residence and registration have become common requirements. Typical features of a tippelzone can include all or some of the following: they are usually located outside of the city centre, are clearly identifiable and are defined by time and space restrictions. Drug use and dealing are prohibited. They include a designated space for the completion of sex work services. They have health and social support services readily available and on-site during operating hours, and some have on-site security present or on patrol. They often include traffic control systems and CCTV.

Window sex work spaces are common in Belgium and the Netherlands. These are managed by local authority systems of registration and licensing. These can vary greatly from each municipality, and consequently, this has resulted in considerable differences in terms and conditions of work for sex workers renting those spaces. They are usually small rooms for one person with a bed, sink and maybe other basic facilities.

The Reduction of Visible Spaces of Sex Work

Visible sex work spaces across Europe and within each legal regime model are being systematically reduced. This is achieved through the physical reduction of spaces of sex work, the limitation of permits, and police enforcement and criminalisation with the intention of deterring the sex working population. The assumption is that visible spaces of sex work are inherently problematic, and that by reducing them or eliminating them, sex workers who use them would either choose to exit, or transfer to working independently online.

However, the closure of tippelzones and window spaces across Europe has resulted in sex workers being displaced into irregular sex work spaces with increased risk of marginalisation and exploitation. Tippelzones were specifically intended for sex workers with complex intersecting social and economic needs. Key informants stated that they are concerned that the closures of these zones will displace the sex workers it was originally intended for the following: drug users, transgender sex workers, and those who cannot or choose not to work for whatever reasons, in windows, brothels, through agencies or independently online. In the Netherlands, there were eight tippelzones. Four have been closed: Amsterdam, the Hague, Rotterdam and Eindhoven. It is assumed that the sex workers who used these spaces have either stopped sex working, moved to different cities to work or changed their mode of working. At the time of this study (2016), four remained: Utrecht, Harlem, Groningen and Nijmegen. However, in 2021, Utrecht is now closing (NL Times, 2021); Nijmegen tippelzone remains but is constantly contested in local politics (Indebuurt, 2021).

In the Netherlands, all municipalities have a licensing system for brothels, and it is illegal to run a brothel without a licence. Between 2000 and 2016, the number of window brothels has been reduced by approximately one-third. The closures began in Amsterdam and Rotterdam. Local licensing policy changed, and the number of window spaces was reduced over time: as a brothel closed, the license was not replaced. In the tippelzone at Europalaan, Utrecht can accommodate 150 permit holders. At the time of my visit in late 2016, there were 60 active permits issued by the council. Permits that are not used are withdrawn, and strict regulations exist for new permits including the requirement that applicants must live within 30 km of the city. There is now a long waiting list of 4 to 5 years to get a permit. In 2012, the Mayor of Utrecht decided not to re-issues licences to the owners of the boats that were window sex spaces in Zandpad. Key informants estimate that 200–250 women lost their places of work within a few weeks. Some of them moved to working online but others were ‘scattered’ all over the country and into Belgium, Denmark and Germany were to find alternative sex work locations. The city authority has stated that it will build a new window area with the same number of licences: 162.

The RLD in Ghent has traditionally been located to the south of the city centre near a former railway station. There is no street sex work in Ghent. The 1990s saw intense police actions against trafficking and corruption in the RLD. In 2002, the local authority designated four streets for window sex work spaces. Since 2012, there has been a reduction in the licences to run a window in Ghent. When a property becomes available in the street window spaces, the licence is not renewed; they are allowed to sell to other businesses or close. In the 2015 Prostitution Plan, the city reviewed and enforced renovation of the windows to ensure some health and safety standards. Some closed as they could not meet the new standards within the 6-month time limit. This had the two-fold effect of improving the working conditions for sex workers in the windows but reducing the overall number even further. The windows in Ghent are now limited to location within a historic shopping arcade and one street.

The reduction of visible spaces of sex work is often achieved through criminalisation or enforcement action with the intention to deter the sex working population from using those spaces and push them out of the area or into online sex work. The city of Charleroi in Belgium is approximately 50 km from Brussels. It was a heavy industry city (mining and steel) but has been in decline for some decades. The RLD is situated directly across the river from the North Rail Station. The women work near the road junction and roundabout. There was a window area that has now been closed but some women rent properties in the nearby streets and stand on the street outside. The whole area is run down and dilapidated. There are local authority plans to regenerate the area and restore the historic buildings that line the river embankment. Enforcement is being used to deter and disperse the sex workers. On my visit, the project worker reported that there had been over 200 arrests in the area during the last 6 months. As we walked around the RLD talking to the women out working, the conversation centred on police activity: had we seen, or had any of the other sex workers had reported seeing the police in the area that day, the difficulty of trying to attract and negotiate with clients whilst also constantly keeping moving to avoid police attention, and general feelings of anxiety and stress, risk and risk taking, and the balance of this with the drivers to make some money.

The RLD in Brussels is located next to the city’s north train station, concentrated on Aarschotstraat and a few nearby streets. It is a run-down area with a large migrant population. Aarschot has 58 window buildings, with between 230 and 350 women working in the RLD. Since 2010, access to window space permits has been reduced and made more difficult to access. This combined with police actions against street sex workers has resulted in a RLD associated with abandonment and disorder (Weitzer, 2014). In contrast, other cities have invested in urban development of sex work spaces which has had desired outcome of restricting and containing the RLD away from city centres and business districts, enhancing the health and safety of the sex workers, and addressing the needs of other stakeholders.

The social ecology of a RLD is directly related to local government policy and law enforcement (Weitzer, 2014: 707). One example is Antwerp. Historically, Antwerp had a RLD that stretched across 14 or 15 streets of windows and bars, from the dock side on the river and into the city square. This has now been reduced to three pedestrian streets but with a comparable number of window sex work spaces. This was a coordinated, well-funded initiative by Antwerp city to move and contain sex work within an identifiable area, and at the same time redevelop and regenerate the now unused dock area of the city. This development has met the requirements of multiple stakeholders; there is less impact on residential properties, businesses and traffic. Most importantly, the zone has shown a real commitment to the health and safety of sex workers (Weitzer, 2014). The ambience of the area for both the sex workers and any clients or passers-by is strikingly different from Aarschot, Brussels.

The closure of tippelzones and window spaces may result in sex workers being displaced into irregular sex work spaces with increased risk of marginalisation and exploitation. Professionals I met expressed regret that the very model designed to meet the need of a particular population of sex workers, increase their health and safety, and offer some protections from exploitation is now being systematically eradicated. The drivers that are currently compelling sex workers to move to ‘indoor’ work and will force the transition for some, change their economic relationships with third parties, and for others, it will displace them into unmanaged, un-serviced, informal sex work spaces.

Key informants delivering health and social support to sex workers in the Netherlands and Germany all spoke of new spaces of street-based sex work appearing along major highways, around the railway stations and in the streets surrounding defined window areas. There has been little or no scoping research into these spaces, and if there are services delivering to these spaces, they are often drug and addiction services. They expressed concern that, without close regular contact to build relationships and trust, it is extremely difficult to assess the existence or extent of labour exploitation in these settings. Service professionals have regular contact with street and window sex workers, but outreach into flats and houses is more problematic. Often, there is a fast turnover of Individual sex workers at any brothel, and groups of sex workers move frequently using short-term lets especially in areas of high rent properties.

Gentrification has always been and continues to be a major driver for opposition to sex worker spaces and RLDs. Cities and councils across Europe are having the same discussions and debate. The city of Ghent, renowned for its beauty, has a traditional window RLD close to the city centre. Professionals delivering services report that there have been plans for the redevelopment and gentrification of the area since the 1980s. The windows were reduced, and new exclusive shops and cafes were introduced especially into the historic arcade. The businesses failed and the arcade is now a pedestrian window zone, separate but within the night-time economy. The health service practitioners I met in Ghent had been delivering services to sex workers in the windows for many years. They recalled the cycle of local opposition, plans for gentrification and calls for the dissolution of the window zone, resistance, and then adaptation, repeated over the last 25 years. Community resistance in support of the sex working community was also demonstrated as many residents had lived in the area for a long time and felt that sex work is suitably assimilated into the locality. The local sex work service providers decided that they would no longer participate in the continuous round of debate. As primarily health service providers, they felt that this not only misused their scare and valuable resources but that, by keeping a low profile, they are better able to continue to deliver services unhindered regardless of the changing local political climate to sex workers.

Weitzer (2014) exposes this relationship between the way a RLD is managed and the social background and political capital of the resident population. In his comparison between Brussels and Antwerp, he contrasts the ethnic and class status of local residents and their capacity to successfully pressure local authorities. Weitzer argues that the marginalised status of residents of Aarschot in Brussels has allowed the city to continue to take a ‘hands off’ approach to the RLD.

COVID-19 and the Impacts on Sex Workers

The COVID-19 pandemic and consequent economic crisis have starkly exposed the deepening inequalities in society. Many people worked throughout the crisis in essential roles that supported the operations of vital infrastructure. This included workers in all levels of health and social care provision, but also in construction, transport and the service industries. In the UK, the precarious economic positioning of many was revealed as millions drew the lottery of whether they were entitled to furlough pay, self-employment benefits and other state benefits such as universal credit, or whether they were expected to continue to work and place themselves and others in their families at increased risk.

The impacts of the crisis on the global sex working population have been enormous and devastating (Platt et al., 2020; Doctors of the World UK, 2021; SWARM, 2013). The NSWP have conducted a global survey and reported on the impacts of COVID on sex workers across the world (NSWP, 2020a, b). In most countries, whatever the legal status of sex work, there are issues of exclusion from basic civil and labour rights; sex workers are stigmatised and marginalised. Kate McGrew, co-convenor of International Committee on the Rights of Sex Workers in Europe (ICRSE) and Director of Sex Workers Alliance Ireland (SWAI) stated:

‘without state protection and labour rights, the most precarious sex workers face the hard choice between abiding the confinement rules by not working and selling sex to feed themselves and their families’ (ICRSE Webinar, 2020a).

The immediate loss of income was devastating for many sex workers. The precarious and unpredictable nature of earnings from sex work meant that many had little or no economic resilience for times of crisis. This was a common global experience during the COVID-19 pandemic for all sex workers in all sectors, from strippers, web-cammers, adult performers, and full-service sex workers (from the street to brothels), escort agencies and independent online workers. Some were able to make a successful change to providing online content while others were able to rely on other parallel employment or transition into mainstream employment. For those who were registered as self-employed or could claim welfare benefits, like many other people, they had some economic protection but application and delays meant long periods without any income. Documented and undocumented migrants were left stranded away from their home countries without any money or income. Irregular migrants face additional pressures of restricted movement, no recourse to public funds or assistance, and the threat of immigration detention and deportation (TAMPEP, 2020; ICRSE Webinar, 2020b).

In reference to housing and homelessness, for those already ‘included’ in normal civil arrangements, certain protections from eviction were put in place and emergency accommodation made available to those who were eligible. For many migrant sex workers (documented and undocumented) living in temporary accommodation and sometimes in the spaces they have rented for sex work, eviction was almost immediate (ICRSE Webinar, 2020a, b) Further housing issues have been observed in countries (e.g. Romania) as they received returning migrant sex workers. Large numbers of migrant sex workers returned home in a short space of time placing additional pressure on existing services (ICRSE Watch Party, 2020).

As health services were redeployed to meet the expected health crisis, access to health and sexual health services, and access to medication became increasingly hard. Again, this had a disproportionate impact on already marginalised sex workers: transgender and HIV-positive sex workers in particular.

Police enforcement operations, raids and arrests continued throughout the UK and across the world. In addition, sex workers faced the possibility of fines and arrest for breaching COVID restrictions. Many sex workers started working away from the usual spaces and taking more risks in order to secure any form of income. Calls for a halt to police enforcement from the sex work community were mostly ignored RedLight 2020, English Collective of Prostitutes (ECP, 2020, ECP, 2021). Police surveillance of sex workers increased across the world, and police brutality and corruption continued and worsened in countries where sex work is criminalised (BBC, 2020).

As the crisis deepened, the disparity between the experiences of sex workers under different legal frameworks for sex work became even more apparent. Armstrong (2020) describes how COVID-19 ‘illuminated’ the discriminatory impacts of sex work policies. Drawing on the differences of experiences and social protections for sex workers in New Zealand where there is decriminalisation, and the experiences of sex workers in criminalised regimes. The countries that have adopted the Swedish Model (Sweden, Iceland, France, Northern Ireland, Republic of Ireland, Israel) have seen the enormous barriers for the most disenfranchised sex workers to come forward and receive any help for fear of retribution and consequences post COVID-19. The COVID-19 crisis has revealed the huge risks associated with any form of criminalisation of sex work (McGrew in ICRSE, 2020). In contrast, sex workers in New Zealand and some Australian states where sex work is decriminalised (NSW) reported that the social protections in place before the COVID-19 crisis allowed the workers to receive state protection on par with workers in other industries and similar employment status.

ICRSE networks constantly and consistently witnessed, evidenced and cited the impacts of COVID-19 on sex workers across Europe. There have been regular coordinated webinars and meetings with sex worker–led and allied groups throughout the crisis, tracking and evidencing the impacts on sex workers across Europe. Luca Stevenson (Coordinator of the: ICRSE) cited how noticeable it is that the movements pushing the abolitionist discourse have not only been absent in their support to sex workers during this time of crisis but have led campaigns on social media denouncing the sex worker–led responses and sex worker community mutual aid schemes (Champion, 2020).

The global, regional and local sex working communities responded to the COVID-19 pandemic with immediate action. The impacts on an already highly marginalised, criminalised and victimised community were anticipated; hardship funds were started on local, regional and national levels with immediate effect.

Across Europe, this included the following: Utsopi, the sex workers’ union in Belgium, BeSD in Germany, Sex Work Call in Romania, Syndicat du travail sexuel (STRASS) in France, Sindicato OTRAS in Spain, PION in Norway and Red Edition in Austria. In the UK, this consisted of the following: Sex Workers Advocacy and Resistance Movement (SWARM) and ECP, Umbrella Lane in Scotland, and SWAI in Ireland (ICRSE, 2021b p13)

It was the sex working community and dedication of sex worker–led organisations and activists that have supported their own. The commitment, resilience, care and compassion of the sex worker community in their response to the most extreme challenges presented by COVID-19 have demonstrated the strength of the movement for the decriminalisation of all sex workers. Sex workers and sex worker–led organisations supported each other across national borders to advise and assist in the negotiation, development and administration of emergency relief. This included hardship funds, food parcels and voucher schemes, and medical supply networks (especially for transgender and HIV-positive sex workers. In addition, many groups produced online peer to peer information and support to negotiate social welfare pathways and health issues (including mental health), moving to working on online platforms and working practices for harm reduction if and when individuals chose to continue to work or return to work (ICRSE, 2021).

The expected economic recession post-COVID-19 will undoubtedly drive more people to consider and enter sex work. This will increase precarity of all sex workers. The ICRSE ask all service delivery organisations to:

  • Declare affiliation with sex workers rights movement

  • Work with sex workers and sex worker–led groups to include them in all stages of policy development

  • Support decriminalisation of sex work

Over the last few decades, the sex worker rights movement has emerged as an influential and powerful movement for social change. Alliances have been forged and formed through commonalities of experience of marginalisation, and together, they make a powerful challenge to global issues of access to health care, migration and border control, policing and social justice. Consideration of the struggles of sex workers has become crucial to all movements addressing human rights, equality and equity, and social justice (Smith & Mac, 2018).

Conclusion

During my travels as a WCMT Fellow, I experienced and was intrigued by the differing geographies of sex work spaces across Europe. The current focus on street sex work in the UK has parallels with the focus Europe wide on visible spaces of sex work. Street and other visible forms of sex work are still and continuously regarded as exceptional and inherently problematic spaces, that must be managed with eradication as the end goal. The reduction of visible spaces of sex work has led to an increased number of sex workers working independently and online, but it has also resulted in new spaces of sex work which can be considered ‘displaced’ and outside the remit of survive providers. The consequence of this is the material conditions of the sex workers, their access to health and support services, and recourse to law, social and criminal justice become invisible too. There are increasing divisions in the characterisation of sex working populations by their working spaces and modes or work. This is evident with discourse and within service delivery.

This research project suggests that local sex work policy, policing and service provision can be as important as the legal framework in determining the health and safety, access to rights and justice, and physical and material conditions for sex workers. The impacts of COVID on sex workers across Europe can be viewed as a ‘rehearsal’ for the conditions that would prevail under any further criminalisation. Ostergren’s (2017) framework reveals the unstated intentions, ideologies and aims as well as the direct impacts on sex workers of each type of regime. By using this to scrutinise sex work law and policy, it is apparent that the only framework that places the rights and health and safety at the centre is the full decriminalisation of sex work.