European Sex Workers' Rights Alliance
ESWA
The European Sex Workers' Rights Alliance is a sex worker-led network representing more than 100 organisations led by or working with sex workers in 31 countries in Europe and Central Asia, as well as more than 150 individuals including sex workers, academics, trade unionists, human-rights advocates, and women’s rights and LGBT+ rights activists.
ID: 945226032621-91
Lobbying Activity
Response to EU Civil Society Strategy
5 Sept 2025
Sex workers across Europe encounter profound barriers to political participation and representation, stemming from deeply entrenched stigma, legal discrimination, and escalating political hostility. These challenges are exacerbated by various factors, including the influence of far-right ideologies, trans-exclusionary feminist narratives, and growing anti-gender movements, which often portray sex workers as a threat to traditional values or as helpless victims in need of rescue, thereby excluding them from meaningful societal and political engagement. The European Parliamentary Forum for Sexual and Reproductive Rights' "Next Wave Report" (2025) warns of the coordinated rise of ultra-conservative actors across Europe, whose campaigns target sexual and reproductive rights, LGBTIQ+ communities, and feminists. Though less often acknowledged, sex workers are also seen as part of this ideological crusade, portrayed as a threat to traditional family values and exploited as symbolic targets in moral panic campaigns.
Read full responseResponse to Gender Equality Strategy 2026-2030
30 Jul 2025
Sex work is a multi-gendered phenomenon, and sex workers of all genders and sexual orientations offer sexual services and many are actively involved in the sex workers rights movement. Cisgender women make up the majority of sex workers globally, including in Europe, for a variety of reasons. Some might decide to work in the sex industry because it allows for more flexible working hours and gives them greater control over their working conditions than other jobs, which are often important factors for mothers or women with caring responsibilities whose needs are not met in the mainstream labour market. Others find it more financially rewarding than low-paid, female-dominated professions. For manyespecially undocumented migrants, minority women, trans women, and women with disabilitiessex work may be one of very few viable income options. With low entry barriers and skills often learned outside formal education, it offers accessibility that other sectors do not. Sex work is deeply linked to female poverty and structural inequality in the labour market. Economic crises and austerity measures in Europe have led more women to enter sex work, often coming from undervalued professions like teaching, caregiving, or domestic work. Austerity disproportionately harms womenespecially women of colour, disabled women, single mothers and trans womenamplifying existing inequalities. These conditions reflect broader systemic failures that the current Gender Equality Strategy must address more directly. Please, see attached full feedback.
Read full responseResponse to LGBTIQ Equality Strategy
24 Jun 2025
In this feedback, ESWA focuses on a number of priority areas that are most relevant to our core mandate and summarise ESWA's key findings in the area of LGBTIQ sex workers' rights. Additionally, ESWA fully supports all the priorities, recommendations and legal, policy and budgetary actions identified by ILGA-Europe to protect and advance the fundamental rights of LGBTI people across all EU policy areas. Sex work is a multi-gendered phenomenon, and sex workers of all genders and sexual orientations offer sexual services and are actively involved in the sex workers rights movement. The homophobic and transphobic social climate LGBTIQ individuals live in and the social marginalisation they face is one of the main reasons why many LGBTIQ people use sex work as a livelihood option. Members of the LGBTIQ community are likely to face rejection from their family, obstacles to access to education and employment in the heteronormatively arranged social structures. In many countries, they therefore have limited economic and employment opportunities. This is particularly true for trans women, LGBTIQ people of colour or of migrant status, and those who had to become economically independent at an early age without any support from their family. It is within the broader context described in the attached feedback that the need to address the intersection between LGBTIQ rights and sex workers rights becomes urgent and unavoidable. Recognising the realities of LGBTIQ sex workers, affirming their agency, and ensuring their protection must be central to any comprehensive human rights and equality agenda in Europe. This includes integrating the voices and experiences of LGBTIQ sex workers into policymaking processes, ensuring access to justice and housing, and dismantling the intersecting structures of oppression that marginalise them. The European Union's LGBTIQ Equality Strategy provides a crucial platform from which to advance this intersectional approach, grounded in dignity, rights, and lived experience.
Read full responseMeeting with Raquel García Hermida-Van Der Walle (Member of the European Parliament)
5 Feb 2025 · Sex workers' rights
Meeting with Catarina Martins (Member of the European Parliament)
21 Nov 2024 · women's rights
Meeting with Frances Fitzgerald (Member of the European Parliament, Rapporteur) and Amnesty International Limited and
14 Sept 2023 · Directive on combating violence against women and domestic violence
Response to Preventing and combatting gender-based violence
18 May 2022
The European Sex Workers’ Rights Alliance (ESWA) welcomes the proposal of the Directive. In particular, ESWA applauds that attention is paid to the recognition that victims face heightened risk due to intersecting forms of discrimination and in particular for recognizing that undocumented migrant women and women sex workers are at increased risk of violence against women (VAW) and domestic violence (DV), and require targeted support as at-risk groups of victims.
ESWA also welcomes the definitions of the crimes covered by the proposed directive, in particular definitions of Rape (Art.5) and Non-consensual sharing of intimate or manipulated material (Art. 7), in which the absence of consent is the central and constitutive element. For sex workers, the concept of consent is key for their work. If agreed and consented conditions are violated, the incident should be defined as rape or sexual assault. Conflating all sex work with sexual exploitation undermines the agency of people to make informed decisions about their private and sexual life. The conflation is a dangerous attempt to outlaw the ability of certain groups of women to consent, and to control women’s body and women’s sexual behaviour.
ESWA welcomes paragraph 5 of the Article 16 on reporting VAW and DV that explicitly prohibits competent authorities from transferring personal data pertaining to the residence status of the victim to competent migration authorities. ESWA, however, regrets that this ban is limited to completion of the first individual assessment referred in the Article 18 and is not accompanied by any additional alternatives - especially when it comes to undocumented migrant victims or victims with dependant residence status. ESWA believes that the insufficient firewall between the justice system and immigration enforcement may be contrary to the general tone and ultimate aim of the Directive, the ambition of which is to be intersectional and explicitly recognize that undocumented migrant women are at heightened risk of violence and in need of targeted support (Art. 35).
ESWA applauds the Commission for listing undocumented migrant women and women sex workers among victims with specific needs and groups at risk in Article 35 (1). Listing sex workers as a group with specific needs and at increased risk of gender based violence in the Directive can improve the position of sex workers as victims in the entire EU. We however, expect a backlash against mentioning sex workers in the Art. 35. We strongly believe that different political understandings of sex work/ prostitution, and different terminological differences, should not lead to leaving sex workers - a group that faces high levels of gender based violence, a group that is highly discriminated, stigmatised and marginalised - behind, by removing them from the list of groups with specific needs or by de-classifying them as an at-risk group. We also urge the Commission, the MEPs and the Council to avoid using the term ‘women in prostitution’, ‘prostituted women’ or ‘prostitutes’ in this important Directive, since it has strong connotations of criminality and immorality and it is perceived by the sex working community as a demeaning and stigmatizing term, which contributes to further exclusion and marginalization.
ESWA calls also for listing LGBT women under the Article 35 (1)
Member States should meaningfully include impacted communities and groups at heightened risk of VAW in the development and implementation of preventive measures, into coordination and cooperation mechanism and evaluation of the VAW policies. It is only by meaningful inclusion of at-risk communities and partnership with community based organisations can we come to effective preventive and awareness raising measures and strategies. In the following Articles ESWA calls for going beyond cooperation with victim support providers and to meaningfully include and consult relevant affected communities: Articles: 27 (5), 36, 37 (7), 40, 41
Read full responseResponse to Amendment of the EU rules on victims’ rights
10 Jan 2022
ESWA welcomes the Commission’s initiative to revise the EU Victims’ Rights Directive. ESWA supports Option 2) b) Legislative initiative amending the Victims’ Rights Directive - Broader scope of the legislative amendments.
Access to justice for sex workers in Europe is a considerable challenge and a key area of wok for ESWA. ESWA published a report ‘Undeserving victims?’ Community report on migrant sex workers victims of crime that clearly reveals that there is still lack of implementation of the Directive in practice- mainly by the front-line police officers.
Recommendations include:
● As rightfully pointed out by the Call for feedback as well as by the EU Victims’ Rights Strategy, under-reporting of crime is one problem area, related to the lack of a safe environment and personal safety for victims. By amendment of the Article 5 Right of victims when making a complaint to introduce a mandatory firewall between access to the justice system and immigration enforcement. It is necessary to have same standard in all EU countries so that undocumented migrants can rely on the provisions of the Victims’ Directive without discrimination.
● Similarly, in cases of sex workers victims of crime, sex workers who face high levels of gender based violence, biased motivated crimes and hate crimes are afraid to rely on the criminal justice system due to risk of being prosecuted or fined themselves. The directive should be amended in a way to either introduce a non-punishment clause or insist on mandatory soft law measures that will enable highly criminalized and stigmatized communities to come forward and to report crime without fear or risk of negative repercussions.
● To amend Article 8 of the VRD Member states shall actively ally with community based organizations and NGOs working with marginalized or vulnerable communities to build trust and to effectively facilitate referral to victim support services and to increase reporting of crime.
● In addition to amend the VRD in a way that Member states have a stronger obligation to establish and maintain effective referral and coordination mechanism for victims of crime by involving representatives of organizations working with marginalized, vulnerable or criminalized communities- such as sex workers, migrants, LGBT, Roma, homeless, and other populations facing intersectional discrimination.
• To consider binding measures on how to hold all relevant state actors accountable for facilitating access to justice for marginalised communities, such as migrant sex workers. It can also introduce measures to enhance police accountability and transparency, and monitor their implementation by working with marginalised groups that are disproportionately policed.
● By amending Article 22 to recognize that crimes against communities facing intersectional discriminations are often bias motivated and such a group of victims should be considered as victims in need of individual assessment and specific protection needs.
● Consider introduction of crime prevention as part of the directive. Gender-sensitive and inclusive crime prevention strategies that are based on community empowerment and that involve populations facing intersectional discrimination such as sex workers, migrants, LGBT persons, Roma, and others at national, local, and municipal levels can be vital not only by preventing the crime, but also by building trust between marginalized communities and the public authorities. It can be an opportunity to roll out regional, local, and municipal policies and protocols that allow marginalised communities facing a higher prevalence of crime, to participate in designing specific anti-violence programs that benefit their communities. Such provision can increase crime reporting among members of marginalised communities as a consequence of raised trust to the public authorities.
Please, see the attached document to access all recommendations.
Read full responseResponse to Preventing and combating trafficking in human beings - review of EU rules
16 Sept 2021
The European Sex Worker’s Rights Alliance (ESWA) – previously the International Committee on the Rights of Sex Workers in Europe (ICRSE) - is a sex worker-led network representing 111 organisations and member groups in 35 countries across Europe and Central Asia.
ESWA understands and conceptualize trafficking in human beings as a broader migration, labour and social justice issue and advocates for addressing root causes of human trafficking as a priority. ESWA opposes a punitive anti-trafficking policy framework that addresses sex workers’ workplaces and their clients rather than traffickers. Sex workers fight exploitation and human trafficking in the sex industry, whilst having to deal with the harm of intended and unintended effects, caused by misused anti- trafficking and prostitution policies. ESWA calls for sex worker inclusive anti trafficking policies.
ESWA opposes the neo-abolitionist definition of prostitution/sex work as inherently violent and synonymous with sexual exploitation. This approach obscures the complex realities of sex workers’ lives and work arrangements, and in consequence fails to address the diversity of exploitative working practices that do occur in the sex industry .
Sex workers face high levels of violence, abuse and exploitation. They are also one of the groups at risk of human trafficking. Beyond individualised violence, sex worker communities face significant levels of structural violence of which societal stigma, surveillance, marginalisation, over-policing and systematic exclusion are integral parts. With limited or no access to public funding, sex workers and their organisations stand firmly against violence, exploitation and human trafficking. The most effective way to address exploitation is to improve the labour and social protections available to the workers involved and their ability to organise.
One of the proposed options by the European Commission is to undertake legislative action and to amend the 2011 Anti-Trafficking Directive in a way to introduce mandatory criminal sanctions against the users of the services provided by victims of trafficking. The current provision in the 2011 EU Anti-trafficking Directive is not mandatory and states may decide whether or not to criminalize the knowingly use of services of victims and to which extent. The criminalization of use of services provided by sex workers became the way how several EU member states interpreted the non-binding provisions of the EU Anti-Trafficking Directive- to criminalize clients of sex workers- regardless of whether or not sex worker was a victim.
ESWA is confident that such laws that extend the scope of the above provision to criminalize clients of all sex workers violate Art. 2, Art.3 and Art. 8 of the European Convention of Human Rights. In April 2021 the European Court of Human Rights registered the complaint of 261 migrant sex workers against France in a case M.A. and others vs. France (Request n. 63664/19) to assess the French law ‘against the prostitution system’. The case establishes serious doubts about compliance of such a law with the European Convention of Human Rights.
When assessing “end-demand“ prostitution and anti-trafficking policies, policy-makers need to conduct a thorough inventory of all sex work-related regulations, assessing their de facto impact on the safety and rights of those selling sex. In this process, sex workers must be consulted.
Include sex workers and sex worker led organisations into anti-trafficking policy development- including at the European policy level. Anti-trafficking policies would benefit from sex workers’ in-depth knowledge of the dynamics of the sex industry and encourage them to directly report on the intended and unintended effects of anti-trafficking policies on sex workers’ safety and rights.
As recognised by UNAIDS in their Guidance Note on HIV and Sex Work, sex workers are best positioned to refer women and children who are victims to services.
Read full responseResponse to EU Action Plan against migrant smuggling (2021-2025)
29 Mar 2021
Restrictive migration policies create situations in which human rights violations are more likely to occur. State policies that increase border control and surveillance, and reduce opportunities for safe and regular migration, overuse criminal justice response to migration, have created a market for irregular migration, due to increased reliance on smugglers and more dangerous and expensive routes. This increases risks of situations of debt bondage, forced labour and trafficking, as well as endangering lives.
There is a strong interrelation between human trafficking and migrant smuggling, although both phenomena are clearly distinguished in international definitions. It is usually unclear during the action of transportation or border crossing whether the relationship with the person facilitating border crossing will have the nature of smuggling- and thus will end in the destination country or whether it will continue and will lead to exploitation, forced labour or trafficking. It has been documented by numerous NGOs, international organisations and media that many migrants who aim to enter Europe have experienced abuse and severe exploitation already during their migration/transportation. In such instances, the line between migrant smuggling and human trafficking can be significantly blurred. Therefore the Action Plan against migrant smuggling should have strong linkages to the EU Anti-Trafficking Strategy and provide safeguards for vulnerable groups and people who became victims of different kinds of human rights violations en route, including by offering residence permits for humanitarian purposes.
Similarly to the Palermo Protocol, the Protocol on Migrant Smuggling complements the 2000 UN Convention on Transnational Organized Crime. The UN Protocol requires financial or other material benefit for migrant smuggling in order to be considered a crime. However, EU law allows Member States to keep the broad definition of smuggling, where the financial benefit requirement is not part of the base crime, but only as an aggravating circumstance. Furthermore, it lacks the inclusion of specific safeguards for victims of smuggling. For example, the Facilitation of Entry is criminal in Italy, Greece, the UK and Hungary and in the majority of EU Member States, even without intent to gain profit. Additionally, the exemption of humanitarian actors from criminalisation is only optional for EU Member States, although the Action Plan against migrant smuggling 2015-2020 included a commitment by the Commission to make a proposal in 2016 to “improve the existing EU legal framework […] avoiding risks of criminalisation of those who provide humanitarian assistance to migrants in distress”. As an effect, this has led to increased policing of humanitarian actors and civil society organisations that assist migrants. Besides civil society organisations, property owners and those who provide accommodation for undocumented migrants are also at risk of criminal liability for facilitating irregular stay. In certain Member States, the implementation of the Facilitation Directive is perceived to contribute to the social exclusion of both irregular and regular migrants. This has been defined as the “criminalisation of solidarity” by civil society organisations and human rights activists in recent years. Therefore EU Action Plan on Migrant Smuggling should integrate recommendations of the Fundamental Rights Agency (2014) report Criminalisation of migrants in an irregular situation and of persons engaging with them.
Read full responseResponse to EU Agenda to tackle organised crime (2021-2025)
15 Mar 2021
The International Committee on the Rights of Sex Workers in Europe (ICRSE) is a sex worker-led network representing more than 100 organisations led by or working with sex workers in 31 countries in Europe and Central Asia, as well as 200 individuals including sex workers, academics, trade unionists, human rights advocates, and women’s rights and LGBT rights activists. ICRSE opposes the criminalisation of sex work and calls for the removal of all punitive laws and regulations regarding and related to sex work as a necessary step to ensure that governments uphold the human rights of sex workers.
ICRSE understands and conceptualize trafficking in human beings as a broader migration, labour and social justice issue and advocates for addressing root causes of human trafficking as a priority. ICRSE opposes punitive anti-trafficking policy framework that addresses sex workers’ workplace and their clients rather than traffickers. Sex workers fight exploitation and human trafficking in the sex industry, whilst have to deal with the harm of intended and unintended effects caused by misused anti- trafficking and prostitution policies. ICRSE calls for sex workers inclusive anti trafficking policies and for inclusion of the fifth ‘P’ ‘policies that do not harm and do not exacerbate vulnerabilities’, that will complement prosecution, protection, prevention and partnership.
ICRSE opposes the neo-abolitionist definition of prostitution/sex work as inherently violent and synonymous with sexual exploitation. This approach obscures the complex realities of sex workers’ lives and work arrangements, and in consequence fails to address the diversity of exploitative working practices that do occur in the sex industry. Since sex work is not recognized as legitimate work in most European countries, majority of (migrant) sex workers are pushed outside the formal labour market and forced to perform their labour in the grey or underground economy. Similarly, in European countries with regulatory regimes non-EU sex workers are restricted from the regulated legal system and thus must work clandestinely. The other contributing factor is usually their undocumented status and fear from immigration authorities.
Read full responseResponse to Preventing and combatting gender-based violence
13 Jan 2021
ICRSE welcomes the possibility to provide feedback to the European Commission’s public consultation on Gender-based and domestic violence. We would like to take up this opportunity and provide recommendations based on our 15 years of experience and cooperation with sex worker-led organisations working at local and national levels.
Access to justice for sex workers in Europe is a considerable challenge and a key area of work for ICRSE. in November 2020, ICRSE published a report ‘Undeserving victims?’ Community report on migrant sex workers victims of crime that analyses 49 sex workers’ testimonies regarding policing, reporting a crime and access to justice in 10 EU countries. The report clearly reveals that there is significant lack of implementation of the EU Victim’s Rights Directive in practice, mainly by front-line police officers. The report also points out how specific prostitution laws and diverse municipal bylaws prevent sex workers victims of crime to enjoy protections and rights under the EU Victims’ Directive and consequently make sex workers more vulnerable to crime.
Migrant sex workers are estimated to comprise the majority of the sex worker population in Western Europe, and a significant segment of the community in Central-Eastern Europe. Sex workers bear a high burden of violence in Europe, including physical, sexual, and psychological violence. However, despite increasing recognition of violence against women and other marginalised groups as a human rights and gender equality priority by European Union (EU), crimes against sex workers that occur within and outside the context of sex work are frequently overlooked.
Read full responseResponse to Evaluation of the Victims’ Rights Directive
30 Dec 2020
ICRSE welcomes the possibility to provide feedback to the European Commission on the implementation of the Victims’ Directive. We would like to take up this opportunity and provide recommendations based on our 15 years of experience and cooperation with sex worker-led organisations working at local and national levels.
Access to justice for sex workers in Europe is a considerable challenge and a key area of wok for ICRSE. ICRSE published a report ‘Undeserving victims?’ Community report on migrant sex workers victims of crime that analyses 49 cases- sex workers’ testimonies regarding policing, reporting a crime and access to justice. This report has been based on the evidence collected in 10 EU countries. The report clearly reveals that there is still lack of implementation of the Directive in practice- mainly by the front-line police officers. It however, also points out, how specific prostitution laws and diverse municipal bylaws prevent sex workers victims of crime to enjoy protections and rights under the EU Victims’ Directive and consequently make sex workers more vulnerable to crime.
Sex workers bear a high burden of violence in Europe, including physical, sexual, and psychological violence. However, despite increasing recognition of violence against women and other marginalised groups as a human rights and gender equality priority by European Union (EU), crimes against sex workers that occur within and outside the context of sex work are frequently overlooked. Migrant sex workers are estimated to comprise the majority of the sex worker population in Western Europe, and a significant segment of the community in Central-Eastern Europe.
Read full responseMeeting with Helena Dalli (Commissioner)
14 Dec 2020 · Gender Based Violence and ILO convention on combatting violence and harassment in the world of work.