PRIKAZ UREĐENJA PROSTITUCIJE U ŠVEDSKOJ, NJEMAČKOJ I SLOVENIJI S OSVRTOM NA HRVATSKO RJEŠENJE*
REVIEW OF THE REGULATION OF PROSTITUTION IN SWEDEN, GERMANY AND SLOVENIA WITH REFERENCE TO THE CROATIAN SOLUTION

Summary/Abstract: In the context of possible finding (some future) optimal way of regulating prostitution in Croatia, the experiences of other countries should certainly play a significant role, which in their specificity correspond to the dominant trends that are represented (or spread) throughout the EU. Primarily this is about the Swedish model of prostitution (abolition), the originator of the “Nordic model”, a legal system that since the adoption of the law in 1999 shifted the focus from sexual service providers (prostitutes) to users, and thus tried to abolish prostitution in society. Then, there is the German solution from 2002, when prostitution became legal and a regular profession, free choice of risky occupation, and the example of Slovenia, where prostitution is not prohibited but not regulated (decriminalization) either. All analysed models of prostitution show the efforts of states to find the most acceptable model of obviously “inevitable phenomena”, while the current and dominant trend of abolitionists according to the “Nordic model” is a novelty for which it is rather uncertain and ungrateful to predict how it will develop. On the other hand, the highlighted problems that occur in the analysed countries indicate that there is no simple and “successful” solution to this layered problem, and that the model of criminalization (currently in force in Croatia) represents only one (in addition to others current around the world) of possible ways (attempts) of finding the optimal solution.

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