Regulating Adult Services Websites: When Protection Risks Produce Harm

The regulation of online sex work is once again attracting political attention in the UK. During the passage of the Crime and Policing Bill, proposals were introduced which sought to significantly alter the legal landscape surrounding the commercial sex industry.

Alongside proposals to criminalise the purchase of sexual services, amendments sought to criminalise enabling or profiting from another person’s prostitution, including through the operation of websites hosting advertisements for sexual services. Although these proposals were not ultimately incorporated into the legislation, the future of adult services websites remains firmly within contemporary policy debate.

This debate has intensified following the publication of the Independent Anti-Slavery Commissioner’s 2026 report, Behind the Profile: Sexual Exploitation and Trafficking Through Adult Services Websites. The report examines the role of adult services websites (ASWs) in facilitating sexual exploitation and trafficking and identifies significant concerns surrounding platform design, third-party control of profiles, verification processes and mechanisms for identifying and reporting exploitation (Independent Anti-Slavery Commissioner, 2026).

These findings raise legitimate questions about the responsibilities of platforms operating within the commercial sex industry. However, proposals to criminalise or prohibit adult services websites also require consideration of the role these platforms play within consensual sex work. In particular, the policy debate must distinguish between sex work undertaken by consenting adults and sexual exploitation or trafficking. While these experiences can exist within the same online environments, they are not interchangeable categories.

The presence of exploitation on adult services websites provides a compelling case for addressing exploitation. It does not, in itself, demonstrate that removing the websites would make sex workers safer. Existing research instead suggests that online technologies have become embedded within the safety strategies and working practices of many sex workers. Consequently, restricting access to these platforms may cause unintended harm to precisely those whose safety such policies purport to protect.

The movement of sex work online

Digital technologies have significantly altered the organisation of sex work in the UK. Adult services websites enable workers to advertise services, communicate directly with prospective clients and organise bookings without necessarily relying upon physical advertising spaces or third-party intermediaries.

Beyond the Gaze project, a major UK study of internet-based sex work involving researchers from the Universities of Leicester and Strathclyde, documented the importance of digital technologies to the organisation and safety of contemporary sex work. Its findings demonstrated that online spaces are not merely advertising platforms but form part of a broader infrastructure through which workers manage privacy, communicate with clients and implement safety strategies (Sanders et al., 2018).

Online communication provides an opportunity for workers to interact with prospective clients before meeting them in person. It can allow boundaries and services to be discussed in advance, provide opportunities to identify concerning behaviour and enable workers to decline a booking before entering a physical environment with a prospective client. Online screening and warning systems cannot eliminate the possibility of violence, but they can provide additional information that helps workers assess risk.

The importance of these mechanisms is also reflected in sex workers’ own evidence to Parliament. In written evidence submitted to the Crime and Policing Bill Committee in March 2025, one UK-based sex worker described adult services websites as “a vital safety tool”, explaining that they enabled them to work independently, vet clients and avoid street-based or third-party-dependent work (UK Parliament, 2025a, para. 9). The worker further explained that they personally used ASWs to “advertise, vet clients, and negotiate the terms of my work” (para. 16).

A separate independent sex worker, who reported having worked within the UK sex industry for five years, similarly emphasised the importance of online screening. In their evidence to the Committee, they stated that “the ability to screen clients through online services is crucial to my personal security” (UK Parliament, 2025b). Their evidence also highlighted the broader functions of digital safety infrastructure, including sharing warnings about dangerous individuals and maintaining communication with support networks.

These accounts reinforce an important distinction within the policy debate. Adult services websites are not experienced by workers solely as spaces in which advertisements are purchased and displayed. They form part of the practical infrastructure through which risk is assessed and working conditions are managed.

Criminalisation and displacement

One of the central difficulties with prohibiting adult services websites is displacement. Criminalising a particular method of advertising does not remove the economic circumstances which lead someone to sell sexual services. For workers experiencing financial precarity, the disappearance of a platform does not eliminate the need to earn income.

Restrictions on online advertising may therefore alter how sex is sold rather than whether it is sold. Workers who previously advertised independently may migrate to smaller platforms, private messaging networks or less visible online spaces. Others may become increasingly dependent upon third parties who can provide access to clients. Some may move towards forms of street-based solicitation. The precise effects would inevitably differ between workers, and it would be inappropriate to suggest that any single outcome would occur universally. Nevertheless, displacement is a foreseeable consequence which must form part of an assessment of any proposal to prohibit online advertising.

This concern is particularly visible within the evidence sex workers themselves submitted during scrutiny of the Bill. One worker stated that removing online services would leave workers with fewer options other than street-based work or reliance upon third parties, both of which they considered to increase exposure to violence and exploitation (UK Parliament, 2025b).

Another submission, made by a sex worker in April 2025, described the internet’s role particularly succinctly: “The internet is how we screen, negotiate, and say no” (UK Parliament, 2025c). The significance of online infrastructure therefore extends beyond advertising. It can encompass the processes through which workers establish boundaries, communicate expectations and decide whether a booking takes place at all.

The same worker argued that banning adult services websites would not prevent exploitation but would remove a mechanism through which independent workers currently manage their autonomy and safety. Their evidence described ASWs as providing “a crucial safety infrastructure for independent sex workers” by facilitating advertising, boundary-setting and screening without requiring reliance upon third parties (UK Parliament, 2025c).

These are personal accounts rather than, in themselves, empirical proof of the effects that any future prohibition would produce. Nevertheless, they provide important evidence about how workers currently use online infrastructure and the mechanisms which legislation may disrupt. When combined with wider research concerning internet-based sex work, they demonstrate why the impact of prohibition cannot be assessed solely according to whether advertisements disappear from particular websites.

Independence and third-party involvement

The relationship between adult services websites and third-party involvement also requires careful consideration. One justification advanced for greater regulation is that websites can enable individuals to profit from the sexual exploitation of others. The Independent Anti-Slavery Commissioner’s report identifies concerning examples of third-party profile control and other indicators potentially associated with exploitation (Independent Anti-Slavery Commissioner, 2026).

Such concerns warrant regulatory and criminal justice responses where exploitation is occurring. However, they should not obscure the capacity of online advertising to facilitate independent working.

A sex worker able to create and control their own profile, communicate directly with prospective clients and organise their own bookings may have less need for another person to facilitate those activities. Criminalising the infrastructure through which independent advertising occurs therefore creates a potential contradiction. A policy intended to reduce third-party profiteering may simultaneously make it more difficult for some workers to operate without third-party assistance.

This tension is apparent within the testimony of a British disabled independent sex worker who submitted evidence to Parliament in 2025. The worker explained that they had entered sex work after developing Long COVID and becoming unable to work full-time, and that sex work had allowed them to remain financially independent while working around their available energy (UK Parliament, 2025d, para. 3). Describing their use of ASWs, they stated that the platforms allowed them to “work independently, vet clients, and avoid street-based or third-party-dependent work” (para. 9).

This testimony is particularly relevant to discussions of third-party exploitation because it demonstrates that the relationship between workers and online platforms is not uniform. The fact that a platform can be used by a perpetrator to advertise somebody who is being exploited does not mean that a worker controlling their own advertisement is experiencing the same relationship to that platform.

Effective regulation needs to be capable of recognising both.

Exploitation requires a response, but prohibition is not the only response

The findings of Behind the Profile should not be minimised. The report identifies substantial concerns surrounding sexual exploitation and trafficking facilitated through adult services websites, including weaknesses in verification processes, anonymous buyer access, third-party profile control and mechanisms through which exploitation can be identified and reported (Independent Anti-Slavery Commissioner, 2026). These are serious issues.

However, recognising those harms does not require the conclusion that consensual adult sex work and sexual exploitation should be governed through identical interventions.

There are important regulatory questions concerning the responsibilities of platforms. These include the adequacy of age and identity verification, processes for identifying third-party control, mechanisms for reporting suspected exploitation, cooperation with law enforcement and support services, and the responsibilities placed upon companies which financially benefit from hosting advertisements.

A regulatory framework focused upon these issues is conceptually different from one which seeks to remove adult services websites altogether. The distinction matters because prohibition potentially removes the platform from consensual workers as well as from perpetrators of exploitation. Regulation can instead seek to identify and disrupt exploitative practices while preserving legitimate safety mechanisms used by workers operating independently.

Visibility can also have protective value

There is an additional complexity in treating the visibility of online sex work solely as a source of harm. Adult services websites can also provide information used to identify exploitation.

UK law enforcement has increasingly developed approaches which use information available through adult services websites to identify indicators of vulnerability and potential trafficking. The Government has funded specialist intelligence work in this area, while the Independent Anti-Slavery Commissioner’s own research demonstrates how information drawn from online advertisements can be analysed to identify patterns potentially indicative of exploitation.

The visibility of the online market, therefore, creates a paradox. It can provide opportunities for exploitation, but it can simultaneously make aspects of that exploitation observable. If restrictions result in advertising migrating to fragmented, encrypted, or overseas platforms, visibility may be reduced. This should not be presented as an inevitable consequence of prohibition, and further empirical evidence would be necessary to establish precisely how markets would respond. Nevertheless, displacement into less visible environments represents a legitimate concern when assessing the likely consequences of regulation.

Towards evidence-based regulation

The contemporary debate surrounding adult services websites illustrates a broader difficulty within sex-work policy. Measures intended to protect people from exploitation can themselves alter the working conditions of people selling sex consensually. This makes precision particularly important.

Sexual exploitation and trafficking require robust intervention. People subjected to coercion, violence or trafficking require effective routes to safety, specialist support and meaningful access to justice. Platforms which knowingly facilitate exploitation or fail to respond appropriately to clear indicators of it should be subject to scrutiny.

At the same time, consenting adult sex workers should not become collateral damage within policies designed to address exploitation.

Existing evidence demonstrates that digital technologies have become integrated into the ways many sex workers advertise, communicate, screen and organise their work. The evidence submitted to Parliament by workers themselves provides an important additional dimension to this research.

One UK worker warned that further criminalisation would “undermine the few tools I have to keep myself safe” (UK Parliament, 2025a, para. 17). This is not a claim that adult services websites eliminate risk, nor that exploitation does not occur through them. It is an argument that the regulatory consequences for consensual workers must form part of any assessment of their future.

There is considerable scope for stronger platform governance, improved reporting mechanisms, appropriately designed verification procedures, better cooperation with specialist organisations and targeted enforcement against those responsible for trafficking and exploitation.

Most importantly, regulatory development should include meaningful consultation with sex workers themselves. People directly affected by legislation possess knowledge about working practices, safety strategies and the likely behavioural consequences of regulatory change which cannot be obtained solely through analysing advertisements or prosecuting exploitation after it occurs.

The existence of exploitation within online sex markets demands a policy response. However, the success of that response should ultimately be measured by whether people are safer, rather than whether sexual services become less visible.

Criminalising an advertisement may remove it from a website. It does not necessarily remove the circumstances which led the person behind it to sell sex. Without careful consideration of displacement, independence and existing safety practices, policies intended to prevent exploitation risk producing new forms of vulnerability for sex workers themselves.