In 2002, Germany enacted the Prostitutionsgesetz (Prostitution Act), which legalized the system of prostitution and decriminalized brothel-keeping. As a consequence of this law, Germany today is widely known as the “Brothel of Europe,” a label that remains a thorn in the side of the German Government. After negative evaluations and scathing press coverage of the 2002 law’s failure to improve women in prostitution’s access to social security and health care or to reduce their vulnerability to exploiters and other criminal actors, the German Government amended the law in 2017 with the Prostitutes’ Protection Act (PPA). The PPA introduced a countrywide licensing regime on prostituted persons and all types of prostitution establishments, including brothels, “sauna clubs,” and escort services. Lawmakers hoped that the PPA would offer better tools to screen for and thus reduce the prevalence of sex trafficking and organized criminal networks.

In June 2025, Prof. Dr. Joachim Renzikowski, Prof. Dr. Tillmann Bartsch, and Robert Küster published a Government-commissioned evaluation of the PPA (the Evaluation), offering a glowing account of the law’s purported achievements. However, a closer examination of the 600-page Evaluation reveals that many of its conclusions are drawn from a deeply flawed methodology and influenced by the authors’ personal views about the system of prostitution.

Advancing Unreliable Data, Biased Assumptions, and Flawed Methodology 

The global multi-billion-dollar sex trade is a notoriously complex and understudied phenomenon in Germany and around the world due to the marginalization of prostituted persons, who are overwhelmingly women, the entrenchment of criminal networks, the invisibility of purchasers of sexual acts (sex buyers) and the harms they inflict, as well as the longstanding lack of political will to examine critically the commercial sex industry. In their assessment of the PPA, the Evaluation’s authors fail to address these complexities, demonstrating a lack of understanding or interest in the mechanics of the system of prostitution, its impact on individuals, and on society.

The Evaluation neglects to discuss the significant lack of data available prior to the PPA, which makes it exceedingly difficult to assess any demographic or market size changes in the German commercial sex industry. To this day, the German Government does not know how many people are prostituted in Germany, its estimates ranging from 90,000 to 400,000. While the PPA requires people engaged in prostitution to register with the State, only 32,300 were registered as of 2024, and of those, the overwhelming majority are migrant women from the most economically fragile countries of Eastern Europe. For example, there are twice as many Romanian women in licensed prostitution as there are German citizens. Multiple other factors, such as the COVID-19 pandemic, Russia’s invasion of Ukraine, and inflation, also influence objective assessments of the German sex trade, but remain unaddressed in this Evaluation.

The authors base most of their positive conclusions about the PPA’s efficacy on first-person testimonies, with particular emphasis on the results of their surveys, which include samples of over 2,000 individuals in prostitution. Notably, this particular surveyed group is older, more educated, and generally better covered by health insurance than the overall licensed prostituted population. In addition, the nationalities of this surveyed group – nearly half of which are German or Austrian citizens – are non-representative of the overall prostituted population in Germany. Non-EU citizens are conspicuously absent from the surveyed respondents, even though women from South American and Asian countries are pervasive in German prostitution.

While the authors conducted research for the Evaluation, numerous experts in the fields of sex trafficking and prostitution alerted them about the survey’s lack of language accessibility for the non-German-speaking majority in prostitution. The survey was subsequently translated into 16 languages, as well as presented in a simplified version, but the delay likely prevented many non-German speakers from participating. Furthermore, a long-standing initiative from the City of Wiesbaden, under the leadership of sociologist Manuela Schon, which conducts field research to estimate the scope and demographics of the local sex trade, shared their methodology with the Evaluation’s authors, who did not take the recommendations under consideration. Anecdotal reports indicate that some respondents abandoned the online survey process mid-way due to the lack of psychological and trauma-informed support necessary when discussing the violent and harmful experiences that people in prostitution endure. 

Incomplete and Select Recruitment of Surveyed Respondents 

The Evaluation’s surveyed respondents for the “prostitute” (sic) sample were almost entirely sought through an online, anonymous, self-administered questionnaire, mostly distributed by organizations and networks that promote the decriminalization of all aspects of the sex trade. These included counseling services that focus on harm reduction rather than exit-from-prostitution strategies, brothel owner associations, and prostitution advertising sites (on which ads are placed on a frequent basis by third-party exploiters rather than the prostituted individuals themselves). Just one abolitionist organization, the Federal Association for the Nordic Model, is credited as having provided input to the Evaluation, and there was no consultation of “Netzwerk Ella,” Germany’s only prostitution survivor organization.

In her own analysis of the Evaluation, Schon notes the unusually high response rates (60-80%) to survey invitations distributed by these partisan groups. This leads her to estimate that at least 50% of the “prostitute” sample is compromised due to the overrepresentation of respondents who may have a vested interest in the legitimization of the German sex trade. In fact, researchers cannot state with confidence that third parties profiting from the sex trade did not fill out the survey intended for the “prostitute” sample rather than prostituted individuals themselves.

The Evaluation further undermines its credibility by taking into blind account the statements of the surveyed 284 brothel owners and 3,470 sex buyers who claim to be respectful, law-abiding citizens who care about fighting human trafficking – rather than examining these respondents as actors with significant financial or sexual interests in the sex trade. In contrast, the Evaluation dismisses the information given by many of the 824 surveyed government and social services workers, whom the authors deem too removed from the day-to-day operations of the commercial sex industry to be reliable experts, rather than considering them key contact points for the vulnerable and marginalized individuals in prostitution whom their survey failed to reach.

Denying that Prostitution is a Form of Violence Against Women

Through their previously published works, the Evaluation’s three lead authors are known to support the legalization of prostitution and the decriminalization of brothels. In their collective writings, they have each expressly criticized the progressive legal framework, known as the Nordic Model or Equality Model, which mandates the state to solely decriminalize prostituted individuals, offer them comprehensive services, while holding sex buyers accountable for the harm they perpetrate.

For example, Dr. Renzikowski, who dedicates many pages in the Evaluation to the moral justification of the prostitution system, dismisses the feminists who critique the regulatory approach. Rejecting the analysis of prostitution as male violence against women, Dr. Renzikowski bizarrely criticizes feminists for wanting all sexual activity to be mutually desired, stating that “the idea that sexuality must always be aimed at the sexual pleasure of all parties is markedly quixotic.” (italics added). He also argues that women’s rights advocates fighting against prostitution are hypocritical for not throwing equal efforts into the fight against marriage, dating apps, and lascivious reality television. 

Not only do the authors of the Evaluation reject the framing of prostitution as a cause and consequence of misogyny, they struggle to acknowledge that it’s a gendered phenomenon. Words like ”brothel operator” and “client” always appear in the male and female form (German being a gendered language), erasing the fact that in the majority of cases, brothel owners and sex buyers are almost always men exploiting or purchasing women. The Evaluation also refers to people in prostitution using the stigmatizing term  “prostitutes.”

A Problematic Framework of “Choice” and “Consent”

The PPA is inherently contradictory legislation that oscillates between viewing prostitution as “labor” and acknowledging that it fosters violence and exploitation, but nevertheless, it promotes prostitution as a “choice.” The Evaluation’s authors endorse this latter framing of prostitution with enthusiasm, asserting that the real assault on human dignity and women’s autonomy is denying them the option of “self-determination” and “actualization” through and in prostitution. While Dr. Renzikowski cites the legal debates and Germany’s Supreme Court judgements that support “swingers’ clubs” and assisted suicide to bolster his position on consent in prostitution, he omits that key Regional and Federal Court rulings determined that forcing unemployed women, at the threat of withdrawing social security payments, to work as bartenders in brothels violates their right to decent and dignified work.

The authors’ overarching approval of the PPA’s measures relies on the aberrant framework that followed in the wake of the 2002 Prostitution Act, under which pimping is legal unless an exploiter explicitly forces a woman to take on a specific sex buyer and engage in specific sex acts – a very high standard to prove in court. Yet the authors choose not to wrestle with the laws’ contradictions; for example, the Evaluation states that 60% of licensed brothel owners – not the prostituted women – set the minimal prices for sexual acts, in violation of the PPA, claiming this prevents price dumping.

German law also offers, in conflict with ratified international laws and protocols, a very narrow definition of coercion that only extends legal protection to an infinitesimal percentage of probable trafficked individuals. These individuals include those subjected to “undue third-party influence,” at overt risk of deportation, assigned a social worker for severe disabilities, in an active state of psychosis, or under the age of 18. Neither the PPA nor the Evaluation addresses the vulnerabilities of individuals, overwhelmingly women, that land them in prostitution, such as inequalities of sex, gender, race, and ethnicity, poverty, debt bondage, childhood sexual violence, traumatic bonding with their exploiters, substance addiction, or physical and intellectual disabilities. The Evaluation does not consider any of the aforementioned factors and the ensuing exploitation as incompatible with “freely choosing” prostitution and a path to “self-determination.” Instead, the authors direct their compassion towards disabled men whose access to prostitution they believe is essential to their human dignity.  

The Evaluation also makes no attempt to scrutinize the origins and history of the system of prostitution, borne of patriarchy, colonialism, racism, sexism, and economic inequalities, each of these systems being exemplified on the websites from which the authors recruited many of the surveyed respondents  (e.g., prostitution advertising sites and sex buyer discussion forums). The authors also lament that mainstream media’s coverage of prostitution is too negative and disproportionately focuses on criminal activities in the sex trade. The Evaluation fails to discuss the pervasive glamorization of the sex trade throughout entertainment and social as well as most legacy media, which lends itself to the recruitment of young people into prostitution, especially on online platforms (e.g., “sugaring” and escorting websites). Most disturbing, Dr. Renzikowski and his co-authors refer to sexually exploited children as “underage prostitutes,” despite the fact that both national and international law define any child under the age of 18 bought and sold for sexual acts as a sex trafficking victim.

Mandatory Registration Fails to Prevent Sex Trafficking 

In the Evaluation’s assessment of the bureaucratic aspects of the PPA, the authors claim that the mandatory registration of women in prostitution, which includes brief counseling sessions, succeeds in providing an overview of their legal rights and obligations and access to healthcare and emergency services. However, the authors do not provide meaningful substantiation for this claim. Currently, only around 30,000 of an estimated 90,000-400,000 prostituted women have applied for a “license.” To account for these low numbers, the authors cite the societal stigma surrounding prostitution. The Evaluation does not touch on the failure of the 2002 law’s goal to eliminate this stigma, nor on other key factors that would explain the limited compliance, such as a mistrust in authorities (particularly for migrant women who come from countries with dysfunctional or corrupt law enforcement), high rates of transience (the author’s own data shows that prostituted women are often in cities for only a few weeks at a time), lack of German or English language skills, lack of access to education, mental health crises, and all of the means traffickers employ to prevent victims from seeking help.

On average, these government-appointed counseling sessions with people in prostitution last about 35 minutes, an insufficient amount of time to gain the trust of a person whose life – or whose family’s lives – is under threat. Furthermore, the Evaluation explains that many administrative workers in charge of the mandatory legal and health counseling have inadequate training on handling trafficking situations or may, in fact, lack the authority to take meaningful action.

Nevertheless, the Evaluation mentions that a few dozen sex trafficked persons have been successfully identified and rescued during mandatory counseling over the last seven years. At the same time, the Evaluation cites myriad government workers who acknowledge they are liberally issuing licenses to persons they recognize as being sex trafficked because they assume the victim will simply receive a license in another city, or they fear that withholding a license will result in the trafficker punishing the victim. Approximately half of all surveyed government workers believe that the licensing regime does not reduce human trafficking, and about 40% of brothel owners admit that a woman having a license does not mean she’s not under the control of a third-party exploiter. 

Criminalization and Taxation, not Protection

Despite its claims to protect women in prostitution, the PPA partially criminalizes them by fining them up to €1,000 if they engage in prostitution without a license or inside a no-prostitution zone. While most are released on their first offense, between 30 to 60 women per year are sentenced, many of them without access to adequate legal representation. Acknowledging the injustice and inefficiency of this approach, the Evaluation’s authors argue for the decriminalization of unlicensed prostitution yet fail to interrogate the level of desperation that causes a woman to risk arrest and fines.

The authors rightfully flag the handling of the data derived from Germany’s mandatory prostitution licensing regime as a concern. The German Government is obliged by law to delete all personal information (name, address, etc.) two years after the last license renewal. However, police stations and tax offices may, and in fact do, retain the data for much longer. The local tax office (Finanzamt), in particular, benefits from the PPA as the registration data is passed to its officers, who, upon detecting non-compliance, often pursue women as potential “tax evaders.” 

While the Evaluation highlights these contradictions in the PPA’s implementation, the authors do not link that the characterization of prostitution as “labor” is directly responsible for this treatment by official authorities. 

The Pipe Dream of “Safe Workplaces” in Prostitution

Despite its intentions, the PPA does not guarantee a woman’s “right” to “work” in “safe, crime-free” prostitution establishments. To date, around 2,300 prostitution businesses have successfully applied for a government license, but a parallel black market of unknown size continues to thrive. For example, Berlin is home to 98 licensed brothels, but there are at least as many illegal ones advertised online. Similarly, the PPA attempted to prohibit highly exploitative practices such as the flat rate “all you can f*ck” offers, so-called “gangbang parties,” and the explicit advertisement of heavily pregnant women, yet these ads and practices persist under euphemisms and take place in slightly more covert locations. Rather than calling for the State to create specialized emergency services for prostituted pregnant women, the Evaluation concludes that it would be more humane for exploiters to continue to prostitute these women who have no other alternatives.

In order to receive a license to open and operate a brothel, an owner must reject the aforementioned types of illegal “business models” and submit to a background screening of themselves and their staff, such as cooks, cleaners, receptionists, and security. However, since authorities usually only have limited access to records of individuals’ past crimes, the flagging of criminal histories remains flawed. For example, if a person was sentenced for human trafficking and/or grievous bodily assault in 2012, the authorities may grant them a license to open a brothel, unless there is proactive intervention by local police. Likewise, a person with a criminal history will often use another person (often the perpetrator’s wife) to petition for a license and thus evade detection. In this initial license application process, local authorities will also screen the brothel staff, yet subsequently hired staff are not screened for another three years. The Evaluation’s authors acknowledge that brothel security personnel frequently have criminal histories of physical assault, but ultimately recommend leniency around hiring practices, as they regard an absence of security as the worse option.

The Evaluation’s own data shows that the government is far more likely to deny a brothel license under building or zoning laws rather than criminal laws, including those targeting organized crime. In reinforcement of the government’s lax detection of criminality in the licensed brothel system, the authors advocate for an easing of regulations of Germany’s strict building laws, and encourage brothels to advertise themselves as licensed in hopes of attracting “law-abiding sex buyers” and outcompeting their non-licensed competitors.

Every two years, a brothel is required to undergo a safety inspection, particularly regarding its emergency button system, whose implications the Evaluation does not explore. Among the questions the authors could have asked is why a woman would need access to an emergency button if not because sex buyers are known to perpetrate violence and other human rights violations against her? The Evaluation also does not interrogate its own finding that, in the last year, in ~84% of licensed brothels, women did not use these buttons. Reports indicate that the women themselves must pay for the cost of using the emergency button, and most often will only summon the in-house security, who arguably have more interests in safeguarding the reputation of the brothel than holding sex buyers to account.

In another measure intended to protect women in brothels, the PPA mandates the separation of prostitution rooms from women’s resting and sleeping areas. As many critics warned when the law passed, this has only increased financial stress on women, as they now must pay rent on an additional room or apartment, often in poor conditions and rented out by brothel owners. In practice, women in legal brothels still often sleep and eat in the prostitution rooms. 

A Distorted View of Prostituted Women’s Health 

In an attempt to determine the overall health of the prostituted population, survey respondents were asked to self-assess their health on a scale from “very good” to “very bad,” leading to highly subjective results. A more comprehensive and accurate approach might have mirrored feminist sociologists Schröttle & Müller’s seminal 2004 study on prostituted women’s health and well-being in Germany. This study inquired methodically about precise symptomology and, in turn, found high rates of chronic pain, depression, suicidal ideation, anxiety, and substance abuse among the surveyed women. The Evaluation’s survey did, to some degree, inquire into substance use, finding high rates of cocaine and amphetamine consumption, yet neglected to ask why the surveyed population consumes hard drugs in such elevated quantities. They further omitted any examination of the use of alcohol, cigarettes, painkillers, anti-depressants, etc. The section on women’s health also shockingly casts doubt on the assertion that the prostitution of women in late-stage pregnancy is harmful to themselves as well as to the fetus, a blatant contradiction to the warnings and assessments of myriad health professionals.

Overall, the Evaluation’s section on health maintains a narrow focus on sexually transmitted infections (STIs), neglecting a discussion on the full scope of mental and physical health impacts of prostitution – which, according to the authors’ own data, means bodily invasion by 30 male strangers per week on average. The Evaluation notes with concern the frequent and persistent demand by sex buyers for sex acts without condoms or condoms whose integrity is sabotaged by the men. The authors wonder whether it may actually be wise to criminalize requests for condomless prostitution, but the Evaluation nevertheless suggests that providing “prostitutes” with information on how to maintain their own well-being is the most effective approach in promoting their health.

Whitewashing Sex Buyers’ Role in Violence and Sex Trafficking 

The Evaluation spends little time discussing sex buyers (whom the authors refer to as “clients”), who are the driving force that upholds the commercial sex industry. According to the most recent study, around 25% of all German men report having paid for prostitution at least once in their lives, while 4% did so in the past year. Research shows that sex buyers are the primary perpetrators of crimes against women in prostitution, yet the Evaluation ignores or downplays such crimes. The Evaluation’s sub-chapter on overall violence in prostitution is short and vague, bolstering common myths about men who purchase sexual acts, such as “they just want to cuddle and talk,” and “sex buyers do not routinely observe signs of trafficking.” 

The Evaluation’s authors appear to use only one method to assess the current extent of violence in the German sex trade, foregoing independent outreach to the police, the court system, or social services providers. Instead, they relied on the self-reporting of the surveyed respondents as to whether they had been a victim of harassment, theft, robbery, assault, or sex crimes in the last 12 months. This approach does not align with best practices in gender-based violence research, where experienced researchers do not assume that most victims are aware of certain legal definitions, such as “force” in the context of sexual crimes, or recognize that being a victim of sexual violence carries stigma. In contrast to the Evaluation, the 2004 Schröttle & Müller study asked participants about an extensive and detailed series of specific events (e.g., “Did someone twist your arm?”, “Did someone expose themselves to you?”, “Did someone strangle you?”) rather than inquiring about types of crime. This different methodology in part explains why the Evaluation reports that only 25% of surveyed respondents stated they were victims of a crime in the past 12 months, as compared to 66% in Schröttle & Müller, although both find that legal brothels are major sites for violent incidents. Even though one of the Evaluation’s co-authors has a background in studying femicide, the report never mentions prostitution-related homicide despite an independent investigation finding over 100 murders since 2002, a large number of which were committed by sex buyers.

Conclusion 

The Evaluation’s claim that Germany’s Prostitutes’ Protection Act (PPA) is an overall success is based on deeply flawed methodology, unreliable data, and the authors’ biased assumptions about the system of prostitution. The authors’ methodology ignores the causes and consequences of the system of prostitution and its links to violence, sexual violence, human rights violations, and organized criminal networks. Despite the Evaluation’s manifold flaws, its findings could significantly inform future legislative changes related to Germany’s regulatory regime, further increasing the risks of sexual exploitation. 

The Evaluation’s positive assessments of the PPA are, by and large, unsubstantiated, given the lack of data available prior to the law’s enactment, the authors’ use of a survey sample that is unrepresentative of the prostituted population in Germany, and a failure to address the root causes that land individuals in the sex trade. It also shies away from acknowledging or analyzing the complex and brutal realities inherent to prostitution, including the attitudes and behaviors of sex buyers who pose a safety and health risk to all prostituted individuals. Further, the Evaluation does not address the German Government’s continued inability to sentence perpetrators charged with sex trafficking in the vast majority of recorded trafficking cases, despite one of the PPA’s goals being to provide tools for successful investigations and prosecutions of sex traffickers.

The Evaluation’s surveyed respondents for the “prostitute” sample were recruited almost entirely through an online, anonymous, self-administered questionnaire, mostly distributed by organizations and networks that promote the legitimization of the sex trade. The Evaluation and the PPA both operate on the assumption that the sex trade in Germany consists primarily of voluntary middle-class “prostitutes” making “free and empowering” choices to engage in sexual acts with sex buyers. 

The authors should have instead undertaken sound, trauma-informed, and in-person interviews with respondents in prostitution who are representative of the current German sex trade population. The authors gloss over the fact that the overwhelming majority of prostituted individuals are migrant women, whose vulnerabilities to violence and sexual exploitation are acute. Furthermore, the Evaluation relies on data and anecdotes from individuals and groups – such as brothel owners, sex buyers, and organizations that lobby for the legalization of prostitution – with strong personal and financial investments in the protection and growth of the sex trade. 

The Evaluation dismisses the input of government and social services workers, who are often the first point of contact for prostituted individuals, all the while illustrating the extraordinary amount of time and energy these frontline providers spend in futile attempts at harm reduction, with little evidence that any of these efforts reach the majority of the population in need.

Since the authors of the Evaluation decline to frame prostitution as a form of gender-based violence and discrimination, and couch it in the problematic framework of “choice” and “consent,” they recommend cosmetic adjustments that will again fail to address this system of sexual exploitation. These superficial changes include better training of government workers, changes in data entry and security, improving trafficking recognition and response during license application, as well as simplifying aspects of the licensing regime. The Evaluation also calls for public re-education to decrease stigma on prostituted women as a means of increasing mandatory registration rates. None of these measures take into account that almost all the women in the German sex trade are migrants who fear interactions with law enforcement or German government officials, who are in debt bondage and systematically coerced by a third-party exploiter, including brothel owners. 

At its core, the Evaluation is a missed opportunity to conduct a comprehensive, objective assessment of a policy that has far-reaching consequences for people in prostitution, especially women and girls, and for society at large. The unwillingness to challenge an approach that regards prostitution as inevitable, neutral, and manageable does a grave disservice not only to survivors of the brutal sex trade but to the German public. The majority of Germans see prostitution as violence and a vector for illegal activity, a view that is at severe odds with the German Government and this Evaluation’s conclusions. 

As the German Government organizes an independent commission on the PPA and this Evaluation, it will be critically important that the State give survivors and abolitionist advocates an equal opportunity to contribute to these discussions. The systematic exclusion of these experts, including survivors with lived experiences in the sex trade, only continues to promote a dangerous and sanitized narrative of prostitution that prevents Germany from achieving its goals of securing equality, justice, and dignity for all.

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