Sweden’s landmark 1999 sex work legislation—presented as decriminalizing the seller of sex while criminalizing the client—is aggressively marketed as a “progressive solution” to prostitution internationally. Versions of the “Swedish model” have been implemented in Norway, Iceland, and Canada, and last week a version was adopted in Northern Ireland. The intention, we’re told, is to “reduce demand” for paid sex: shrinking, then ultimately abolishing, the sex trade.

It’s too bad that the reality of the law is not so simple, nor so uncomplicatedly progressive.

Prostitution is criminalized to varying degrees across much of the world. In the U.K., the exchange of sex for money is not in itself illegal between consenting adults, but almost everything around it is. In other places, such as Germany, the Netherlands, and most of Nevada, sex work has been legalized. Widely presented as a more tolerant and pragmatic approach, the legalized model still criminalizes those sex workers who cannot or will not fulfill various bureaucratic responsibilities, and therefore retains some of the worst harms of criminalization. It disproportionately excludes sex workers who are already marginalized, like people who use drugs or who are undocumented. This makes their situation more precarious, and so reinforces the power of unscrupulous managers.

In contrast, New Zealand has decriminalized sex work (the terminology is confusing, but the distinction is important). Instead of focusing on creating bureaucratic hoops for sex workers to jump through, decriminalization prioritizes sex workers’ safety and health —for example, making it possible for up to four people to work indoors in an informal collective without needing to do any paperwork, and, of course, without needing to fear arrest. The New Zealand model has been extensively praised by the U.N: The director of the U.N. Development Programme’s HIV, Health and Development Practice observed, in accidentally amusing phrasing, “I would like to be a sex worker in New Zealand.”

The mythos of the Swedish model is that it is producing a better, more feminist society. But a better society for whom?