April 26, 2025
RE: Human Rights Watch Concerns Regarding Proposed Legislation to Expand Criminalization of Sex Work in Sweden
Dear Minister Strommer and colleagues,
We write on behalf of Human Rights Watch, an independent, international non-governmental organization that documents human rights abuses and advocates for an end to abusive practices and policies in over 100 countries worldwide. Human Rights Watch is committed to producing material that is comprehensively documented, verified and objective.
Human Rights Watch respectfully writes to present our concerns regarding one specific provision in the Swedish government's proposed legislation (prop. 2024/25:124) - namely, the proposed expansion of criminalized sexual services to include those performed remotely, such as webcamming. We understand that this proposal is part of a broader legislative package, and our concerns relate only to this provision.
This proposal will not protect anyone. Instead, it will endanger sex workers and other marginalized groups, worsen stigma, increase discrimination and violence, and push people into precarious situations.
Human Rights Watch shares with the proponents of the legislation their interest in ensuring robust legal frameworks against exploitation, including labor and sexual exploitation.
We are deeply concerned that the Swedish government’s proposed bill will entrench stigma, exacerbate inequality, and expand surveillance of private, consensual activity. It would primarily harm those who already face systemic discrimination and marginalization, including women, migrants, people living in poverty, and members of the LGBT community – particularly those whose intersecting identities or livelihoods place them at greater risk of exclusion and harm. Rather than offering protection, this legislation could strip these communities of critical means of survival and safety, undermining Sweden’s international obligations on human rights, including the rights to privacy, freedom of expression, health, and bodily autonomy. We have recently conducted research on what roles governments should play in regulating this work and feel the approach laid out in this bill is misguided and harmful.
Human Rights Watch has documented the serious harm caused by criminalization of all aspects of sex work, including in Greece, Tanzania, China, South Africa, where punitive laws and policies have driven sex work underground, increased exposure to violence, and reduced access to health, legal and social services. In Colombia, where sex work is not criminalized but remains unregulated in sectors, our 2024 report on webcam workers, found that the absence of labor protections created fertile ground for exploitative practices, including surveillance, coercion, and poor working conditions. Expanding criminal penalties to digital spaces only compounds these harms. In addition to deepening stigma and risk for sex workers, surveillance mechanisms introduced under criminalized regimes often extend well beyond their original intent.
By expanding criminal liability into digital spaces, the proposal would likely pressure online platforms to engage in proactive monitoring and content moderation to avoid potential criminal liability. This is not a hypothetical risk—precedents in other jurisdictions, including under the Allow States and Victims to Fight Online Sex Trafficking Act and Stop Enabling Sex Traffickers Act (FOSTA/SESTA) in the United States, show that vague or expansive criminal statutes can incentivize platforms to over-police content, restrict user activity, and engage in intrusive surveillance practices, often disproportionately affecting marginalized users.
The proposed legislation conflates exploitation with consensual sex work. Crucially, it fails to distinguish between coercion and agency—an erasure that has long plagued debates on sex work and undermines evidence-based policy making. Approaches rooted in feminist and human rights framework emphasizes that autonomy, consent, and safety are non-negotiable – both offline and online. Criminalizing individuals for consensual sexual activity, including digitally mediated work, is incompatible with these principles and compounds the marginalization already faced by sex workers.
Consent, bodily autonomy, and freedom from coercion are central to gender justice. When sex workers are surveilled, criminalized, and excluded from policymaking, their consent is rendered irrelevant. This is not protection, and, on the contrary, it may lead to Sweden’s violation of the right to life, privacy, and health.
If passed, this provision risks undermining core rights—such as the right to privacy, freedom of expression, and bodily autonomy—and may contribute to a troubling trend toward increased surveillance and criminalization of consensual digital activity. It is grounded in vague and overbroad legal concepts, inviting selective enforcement and exacerbating stigma.
Enforcement of such a provision would require surveillance technologies that, once normalized in the context of sex work, risk harming other groups. For example, we have seen how automated content moderation and opaque takedown systems—often justified as protective—have disproportionately affected LGBT youth and others sharing sexual health resources or exploring identity online. These dynamics illustrate how laws targeting sex work can generate broader, unintended human rights consequences.
All interviewees in our Colombia research described engaging in webcam work voluntarily, with many emphasizing that they had no desire to leave the industry but instead sought safer and fairer labor conditions under the law. However, the absence of secure and confidential reporting mechanisms, paired with the fear of retaliation, deterred many from reporting abuse—including coercion, exploitation, and potential trafficking or child exploitation within studio settings.
The report made clear that these harms do not occur in isolation—they are enabled by legal and regulatory systems that fail to recognize sex workers as rights-holders. Rather than seeking to eliminate sex work through criminalization, governments should engage with sex workers to establish labor and digital rights frameworks that safeguard their autonomy, ensure safe working conditions, and provide access to health and social services. Such an approach affirms sex workers’ agency and promotes their well-being within a broader public health and human rights framework.
This bill will not protect those it claims to help. Laws that claim to rescue often silence the very voices they purport to protect. In this case, the proposed expansion of Sweden’s criminalization model erodes privacy and free expression online, reinforces stigma, and risks deepening vulnerability for already-marginalized individuals. This proposed law is not only harmful and regressive—it is fundamentally incompatible with Sweden’s commitment to human rights, including freedom of expression, gender equality, and dignity for all.
Recommendations
Human Rights Watch is committed to upholding the dignity, autonomy, and safety of all individuals. We are deeply concerned by laws that criminalize consensual adult activity.
We encourage the Swedish government/Congress to respond to concerns about digital violence and exploitation, by focusing on strengthening accountability mechanisms for rights abuses by digital platforms operating in or contracting with individuals in Sweden. This includes ensuring that platforms employing sex workers, webcam performers, or other individuals in the commercial sex industry adhere to fair labor standards, transparent contract terms, and meaningful protections against coercion and surveillance.
We recommend the Swedish government:
- Withdraw the proposed amendment that seeks to expand criminalization of sex work including services performed remotely, such as webcamming. We urge the government to refrain from introducing any future legislation that further criminalizes consensual sex work, including digitally mediated forms of labor. Our concerns relate specifically to this provision within the broader legislative package and do not pertain to other areas addressed by this bill, such as hate speech, child sexual abuse material, or fraud.
- Engage in open, good-faith consultation with sex workers, digital rights experts, feminist groups, and human rights defenders—including those who are critical of Sweden’s “partial criminalization model” to ensure policymaking that upholds the rights and agency of those most impacted.
- Invest in rights-based alternatives, including access to healthcare, income support, housing, and legal protections for sex workers, including digital sex workers — rather than punitive or carceral measures.
- Ensure digital rights are upheld, including the right to privacy, expression, bodily autonomy, and freedom from disproportionate or indiscriminate surveillance. Regulation should focus on ensuring platforms meet their responsibilities under the UN Guiding Principles on Business and Human Rights, particularly around fair contracts, the right to breaks, and the right to data protection.
- Support international human rights standards, including the recommendations of the UN Working Group on Discrimination Against Women and Girls and CEDAW, which emphasize decriminalization, non-discrimination, and the importance of sex worker self-determination. These standards call for a shift away from criminalizing policies and toward holistic approaches that respect the lived realities of sex workers.
Sweden has long been regarded as a global leader in gender equality and human rights. That legacy is undermined when laws are enacted without centering the voices of those most affected. The criminalization of digital sex work does not protect—it punishes. It does not offer safety—it instills fear. It does not advance equality—it imposes paternalism and control. Furthermore, this bill may increase the risks of trafficking in persons by silencing the voices of sex workers, who are best placed to identify and report exploitation and trafficking.
Human Rights Watch joins the call to reject this misguided law and to build a society where rights, dignity, and safety are upheld for all.
Sex work is not a crime. Privacy is not a luxury. And the voices of sex workers must be heard—not silenced.
Yours Sincerely,
Macarena Saez
Executive Director, Women’s Rights Division
Human Rights Watch
Måns Molander
Nordic Director
Human Rights Watch
