Comparison with neighbouring countries: how different is the Netherlands?
This piece accompanies our pillar Sex positivity in the Netherlands in 2026 and offers a concise comparison between Dutch regulation of sex work and that in four comparable countries: Germany, Belgium, France and Sweden. The aim is contextual: for Dutch people travelling internationally and for international readers who want to understand the Dutch position.
We do not pass a normative judgement on which model is "better" — that is a political and ethical question that lies well outside our role as a platform. What we do is describe the factual legal and practical situation per country, in 2026.
The Netherlands: regulation with legalisation
The Netherlands has operated a legal-regulation approach since 2000. Key features:
- Legal: Sex work is a regular profession for self-employed persons aged 21 and over.
- Regulated: Licensing requirement for commercial sex premises (brothel, club, window prostitution). No licensing requirement for independent providers without a commercial premises.
- Not punishable for clients: Clients of an adult, voluntarily working provider are not punishable.
For a detailed treatment see our pillar Escort work and Dutch law.
Germany: regulation with legalisation, different implementation
Germany has legalised sex work since 2002 via the Prostitutiongesetz; in 2017 the Prostituiertenschutzgesetz (ProstSchG) was introduced, bringing additional regulation.
Key differences from the Netherlands:
- Mandatory registration. German providers must register nationally and receive a "Hurenausweis" (officially: Anmeldebescheinigung). This remains a controversial point in 2026; sex work organisations argue that the registration system makes providers more vulnerable to stigmatisation.
- Mandatory health consultation. Providers must receive mandatory health consultations before working. In the Netherlands this is not mandatory (though available via Soa Aids Nederland).
- Clients not punishable. As in the Netherlands.
The German model is closer to the Netherlands than most other countries, but the administrative burden is considerably higher. For Dutch providers considering working in Germany, this is an important factor.
Belgium: fragmented, federally amended since 2022
Belgium has a more complex situation. Sex work was tolerated but not explicitly legalised until 2022. A legislative change in 2022 officially removed sex work from the Criminal Code (decriminalised it). Implementation is still ongoing:
- Federal: Sex work has not been a criminal offence since June 2022. Providers can formally register as self-employed sex workers.
- Municipal: Whether a licensing requirement for commercial premises applies varies by municipality. Antwerp, Brussels and Liège each have their own rules.
- Client position: Clients are not punishable.
For a Dutch person travelling to Belgium, this means the legal basis is comparable, but the practical implementation is less standardised. In 2026, Belgium sits somewhere between the Netherlands and Germany in terms of bureaucratic intensity.
France: Nordic model since 2016
France has operated the Nordic model since April 2016. Key features:
- Providers not punishable. Providing sex work is not a criminal offence.
- Clients are punishable. Purchasing sexual services is an offence (€1,500 fine first time, €3,750 on repetition).
- No licensing framework as in the Netherlands or Germany — there is no working framework in which providers can be placed.
In practice, this has made work considerably more difficult for providers. Providers must work in less safe circumstances (quick, unscreened appointments to protect the client from arrest). Research by MdM (Médecins du Monde) has reported an increase in violence against providers in France since 2018.
For a Dutch provider considering travelling to France for work: this is not advisable in 2026. The legal context creates risks that are not proportionate to the potential earnings.
Sweden: the original Nordic model
Sweden has operated the Nordic model since 1999 and is the "parent variant":
- Providers not punishable.
- Clients are punishable. Since 1999, purchasing sex has been a criminal offence.
- Intermediation punishable. Operating or arranging an appointment for others is prohibited.
Sweden has the longest track record of the Nordic model and is internationally often cited as evidence of the model's viability. Independent researchers (such as Petra Östergren and researchers at Lund University) have, however, raised criticism of the claimed success in later years; they argue that the model's claims are overstated and that the underlying data are less clear-cut than the Swedish government asserts.
For a Dutch provider, working in Sweden — as in France — is not realistic in 2026.
Comparison table (summary)
| Country | Provider | Client | Intermediation | Licensing |
|---|---|---|---|---|
| Netherlands | Legal (21+) | Not punishable | Licence required | Per municipality |
| Germany | Legal, registration mandatory | Not punishable | Licence required | Federal and municipal |
| Belgium | Decriminalised (2022) | Not punishable | Varies by municipality | Municipal |
| France | Not punishable | Punishable (€1,500+) | Punishable | n/a |
| Sweden | Not punishable | Punishable | Punishable | n/a |
What this means for clients
For clients travelling internationally:
- Netherlands: No legal concerns provided the provider is of age and working voluntarily.
- Germany: Comparable to the Netherlands in terms of client position.
- Belgium: Comparable but with greater variation by municipality.
- France: Clients risk a fine. This is not a rhetorical concern; since 2016 more than 12,000 fines have been issued as of 2026.
- Sweden: Clients face comparable risk.
What this means for providers
For independent providers considering working internationally:
- Germany: Workable but with considerable administrative burden.
- Belgium: Workable since 2022; less bureaucracy than Germany.
- France and Sweden: Not realistic to treat as a regular working environment.
- Other EU countries: Varies by country; this overview is not exhaustive.
What the future may bring
At EU level, a proposal for a Directive on commercial sexual exploitation was published in 2025 that could oblige member states to adopt certain elements of the Nordic model. This directive had not been adopted as of 2026. Should it be adopted — and that is a significant "if" — it could have effects across all EU member states, including the Netherlands.
In the Netherlands, the Wet Seksuele Dienstverlening (WSD) is also in preparation as a successor to the WRP. Whether and when this law will be adopted remains uncertain as of early 2026.
Further reading
- Sex positivity in the Netherlands in 2026 (the pillar)
- Escort work and Dutch law — Dutch regulation in detail
- European Sex Workers' Rights Alliance — for international policy and provider rights