European Sex Workers’ Rights Alliance (ESWA)’s response to the European Commission’s Gender Equality Strategy 2026-2030:
Background:
In November of 2025, The European Parliament approved an amended version of the FEMM Committee's report shaping the Commission’s upcoming Gender Equality Strategy, with input from the Committee on Civil Liberties, Justice and Home Affairs. The report was substantially more ambitious than the finalised Gender Equality Strategy released by the European Commission in March 2026, but continued to present a contradictory approach to sex workers' human rights.
In our open letter sent to MEP’s involved in drafting the report of the FEMM Committee, ESWA highlighted the Committee’s failure to meaningfully consult with sex workers in its drafting, urging institutions and member states to include sex workers in the development of policies that affect their lives. The lack of sex worker representation in the drafting was clear throughout several of the report’s arguments, such as its call for strengthened services for sex workers, which were conditional to so-called ‘exit programmes’. While the report did acknowledge that sex workers face specific human rights violations, including social exclusion and discrimination, it perpetuated harmful language throughout, referring to ‘prostitution’ as opposed to sex work².
The Strategy acknowledges inequalities faced by other marginalised identities, including women with disabilities, migrant women, women in situations of financial vulnerability, LBTIQ+ women, Roma women or women in rural and remote areas. Sex workers are often overrepresented within many of these groups due to underlying precarity, and indeed the struggle for sex workers rights is indivisible from those impacting other marginalised groups referred to within the Strategy. Failing to address sex workers’ human rights directly, creates a dangerous gap, leaving room for ant-rights rhetorics. Similarly, exclusion of key groups concerned leads to policy that fails to deliver the equality it claims to promote.
Our message is simple: A Gender Equality Strategy that excludes sex workers cannot claim to promote equality.
Evidence-based and rights-based policy cannot be built without the meaningful and inclusive participation of the people it concerns.
In continuing to push for an approach that protects everyone’s rights, safety, and bodily autonomy without stigma and without discrimination, ESWA presents a complimentary roadmap to achieving Sex Worker Inclusive Gender Equality.
A future-proof Gender Equality Strategy must explicitly safeguard bodily autonomy, reject criminalisationand and by-laws that harm, and guarantee that sex workers are fully recognised as rights-holders within the EU’s equality framework.
Contents of our Sex Worker Inclusive Gender Equality Roadmap are based off of ESWA’s initial submission to the FEMM Committee and mirror the Roadmap Principles set-out within the Commission’s final Gender Equality Strategy, released in March 2026.
The Sex Worker Inclusive Gender Equality Strategy is also available as a Fact Sheet!
OVERARCHING PRINCIPLES:
- FRAMEWORKS: transformative justice, anti-racism, migrant justice, disability-justice, socio-economic equity.
- RIGHTS-BASED-LEGISALTION: Full decriminalisation of sex work , and repeal of by-laws used to target sex workers (loitering, public nuisance etc.)
- FUNDING: Invest in sex worker rights organisations and community-led service design and delivery
- PARTICIPATION: Meaningful participation of sex worker-led organisations in all EU policy processes affecting their lives.
Roadmap Principle 1: Freedom from gender-based violence - the right to security and dignity
- Redistribute policing resources to strengthen community-based safety models;
- Include consent in context of sex work (such as protection from lack of payment and stealthing) in consent-based definition of rape under VAW Directive;
- Promote evidence-based interventions on violence against sex workers in transposition of VAW Directive to Member States;
- Install firewalls for safe reporting for migrants to law-enforcement;
- Implement regularisation mechanisms for all undocumented migrants in EU;
- Enforce monitoring and accountability mechanisms for police violence;
- Decriminalisation of personalised drug possession and use, and adoption of “no punishment” model;
- Address harmful stereotypes that perpetuate stigma about sex work.
Building on EU strategy - sex workers' inclusion in:
- Trusted Flagging and regulatory dialogue with VLOPS;
- Anti-trafficking Strategy;
- Victim’s Rights Strategy
- Consent education (Article 35 VAW Directive)
Roadmap Principle 2: The highest standards of physical and mental health
- Co-design stigma reduction training for healthcare providers;
- Disaggregate health data on sex workers as a key population and ensure data protection;
- Firewalls between health systems, law enforcement and immigration authorities;
- Stigma free access to SRHR services for sex workers;
- Rights-based transformation of mental health services;
- Access and rights-based approach to gender affirming care;
- Access to health insurance without discrimination as to sex worker status;
- Accessible harm-reduction services, e.g. safe consumption sites, needle-exchange, drug-testing, and evidence-based treatment.
Building on EU strategy - sex workers' inclusion in:
- Initiative with WHO on women’s health (2026);
- Commission’s Initiative on access to contraception;
- Systemic data collection to improve the evidence base on SRHR;
- Study on closing the women’s health gap related to conditions such as menopause (2028);
Roadmap Principle 3: Equal pay, economic empowerment and financial independence
- Overturn policies excluding sex workers from financial services.
- Install Universal Basic Income not contingent on citizenship, or other qualifiers;
- Enable affordable housing schemes, overuling anti-sex work discrimination clauses, and installing housing-first approach programmes.
Building on EU strategy - sex workers' inclusion in:
- Stress test of Directive on self-employment (2028);
- Monitoring of pension gap under Social Scoreboard and 2027 Report on Adequate Social Protection in Old Age;
- Commission’s study on housing inequality and discrimination, as well as Housing Summit and Housing Alliance;
- Proposed Council Recommendation on housing exclusion;
- Anti-Poverty Strategy.
Roadmap Principle 4: Work-life balance and gender equality in care
- Safeguards against separation of children from carers based on sex working status;
- Financial recognition of care-work, affordable childcare, and provision of child-care for non-traditional hours;
Building on EU strategy - sex workers' inclusion in:
- Implementation Dialogue on Care and the European Care Deal.
Roadmap Principle 5: Equal employment opportunities and adequate working conditions
- Full labour rights for sex workers, regardless of employment or migration status
- Protection of autonomy and decision making for sex workers’ employment contracts (e.g. right to refuse clients or sex acts);
- Expunge criminal records and recruitment discrimination relative to sex work;
- Facilitate self-managed spaces and cooperatives to ensure safe locations for sex work;
- Include digital forms of sex work in the Platform Work Directive, to protect from algorithmic discrimination, and technology-facilitated violence.
- Protect adult content creators in Digital Services Act (DSA).
Building on EU strategy - sex workers' inclusion in:
- EU Strategic Framework on Health and Safety at Work (2028).
Roadmap Principle 6: High-quality and inclusive education and training
- Address stereotypes against sex workers and provide comprehensive, age-appropriate sexual education inclusive of sex work”
- Provide non-conditional education and career development programmes for sex workers.
Roadmap Principle 7: Active, equal and safe participation in public and political life
- Support sex workers’ self-organisation, freedom of assembly and capacity to unionise;
- Recognise Sex Worker’s Rights Defenders as Women's Rights and Human Rights Defenders in EU policies and funding frameworks;
- Harness DSA to prevent algorithmic discrimination against sex workers, disabled people, trans people, and racialised communities;
- Safeguard against discrimination in EU Funding Evaluations, ensuring diversity of evaluation panels, & transparency mechanisms for rejected applicants.
Building on EU strategy - sex workers' inclusion in:
- Study on online networks, spheres and narratives targeting young men and boys (2028) - e.g. narratives promoting whorephobia;
- Policy Practice Joint Event on misogyny and incel ideology among young people via EU Knowledge Hub on the prevention of radicalisation.
Roadmap Principle 8: Institutional mechanisms that deliver on gender equality
Building EU on strategy - sex workers' inclusion in:
- Gender Action Plan IV (2028-2034);
- EIGE’s Gender Mainstreaming Helpdesk;
- Commission research on gender equality via HorizonEurope
- Mutual Learning Programme on Gender Equality & High-Level Group on Gender Mainstreaming.
¹ According to the 2024 UNAIDS Terminology Guidelines, sex work refers to the consensual exchange of sexual services between adults for money or goods. This definition distinguishes sex work from trafficking and coercion, centring consent, autonomy, and agency. UNAIDS and the Global Commission on HIV and the Law explicitly discourage the use of terms such as “prostitution”, “prostitute”, or “prostituted women”, which are associated with deviancy, criminality, and victimhood. A growing number of international and regional bodies—including WHO, ILO, UNFPA, UNDP, the UN Working Group on Discrimination against Women and Girls, Amnesty International, Human Rights Watch, and Council of Europe institutions—support the term sex worker, in line with rights-based and non-stigmatising language that reflects the self-identification of the community.
² Community-led organisations, human rights experts and former Council of Europe Commissioner for Human Rights Dunja Mijatović all align with the 2024 UNAIDS Terminology Guidelines, defining sex work as the consensual exchange of sexual services between adults for money or goods. This definition distinguishes sex work from trafficking and coercion, centring consent, autonomy, and agency. UNAIDS and the Global Commission on HIV and the Law explicitly discourage the use of terms such as “prostitution”, “prostitute”, or “prostituted women”, which are associated with deviancy, criminality, and victimhood. A growing number of international and regional bodies—including WHO, ILO, UNFPA, UNDP, the UN Working Group on Discrimination against Women and Girls, Amnesty International, Human Rights Watch, and Council of Europe institutions—support the term sex worker, in line with rights-based and non-stigmatising language that reflects the self-identification of the community.
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