The dissertation project analyses the question of the regulation of prostitution from a human rights perspective. The starting point for this analysis is the legal situation in Germany and France. The question of whether prostitution is a phenomenon that should be step by step eradicated from society or rather requires destigmatization and normalization as “sexwork” remains a topic of intense debate and public controversy.

Since a French law reform in 2016, completely opposing legal systems have been introduced an assessed in Germany and France. Since a certain degree of harmonisation of legislation on prostitution within Europe would favour countering negative side effects of prostitution, such as sex tourism and human trafficking, the question arises if one of the systems is better suited to serve as a model. 
In order to answer this question both models will be comparatively analysed according to human rights standards. The principles of national constitutional law and international human rights law, especially the European Convention on Human Rights (ECHR), serve as the standard for this analysis.

Starting from a focus on the individual legal protection of persons working in the field, the aim is to contextualise the relevant legislation and develop a minimum standard that must be guaranteed in any case when dealing with the prostitution/sex work.