E-I response to Irish Government public consultation process on the future direction of legislation on prostitution

About E-I (E-I) is an escort website and the most popular of the Irish escort websites.

E-I was established in 1998 and it has been operated by E Designers since 2004.

E-I is an escort advertising business, escorts pay to advertise on the website.  There is sometimes confusion about what E-I does, with people thinking E-I is like an escort ‘agency’ and that the escorts advertising on the website work for E-I or are under E-I’s control in some way.  This is not the case.

E-I is a business that makes money providing escort advertising services to escorts.  Some people feel that it is wrong for any business to make money providing services to escorts, that to do so is morally wrong.  If this is your opinion, then we respectfully accept that this is your personal view.

E-I is operated by a UK company (E Designers Ltd. is registered in England & Wales No. 4923492 & VAT No. GB 834015458).  E-I’s business, advertising escorts, is legal in the jurisdiction E-I operates in.

E-I operates just like a ‘normal’ business.  All laws are adhered to.  All taxes are paid.  Etc.

E-I gets a lot of unfair negative press in Ireland.  Often nasty untrue things are said about E-I, like that there are persons involved in E-I who are or were previously criminals.  These things are not true.  A further problem for E-I here is that there are a number of other websites which also call themselves “Escort Ireland” or have similar names and have been shown to be operated by persons with criminal convictions.  Invariably people read these news articles and imagine that they all are about, when in fact they are not, but as the journalist has only said a website called “Escort Ireland” and not specified the domain name, we cannot even complain.

As the operator of an Irish escort website, we would like to make a submission to this consultation and share some of our views.  We have knowledge of the escort industry in Ireland.  A team of staff work on E-I, amongst our staff we speak many languages –Czech, Spanish, Italian, Hungarian, Polish, Romanian, Portuguese – and from early until late 7 days a week our offices are a hive of activity, with our staff constantly speaking to escorts, on the phone, by email and on message boards.

To us, escorts are our customers, and they are also a group of people we like, respect and care about.  Many E-I staff would regard escorts they have gotten to know as friends as well as customers.  Also some E-I staff are former escorts and have personal first-hand experience of working as an escort.


E-I would be very happy to invite representatives of the Irish government to visit our offices in the UK and see what we do.  We believe that this would be very useful and hope the Committee will consider arranging this. We are also happy to answer further questions the Committee may have.

Escort vs. Sex Worker / Prostitute

We generally refer to our customers as ‘escorts’ as this is what the majority of our customers identify as.  Many people believe ‘escort’ simply means prostitute.  We do not attempt to convince anyone that escorts don’t frequently provide sexual services to their clients, but we would say that the concept of ‘escort’ and charging for ‘time and companionship only’ is one that can work well, in that it makes it clear to the client that they are not paying for a sexual service, and if the escort finds them unclean or disrespectful or for any other reason does not wish to engage in any sexual act with them, it is absolutely the right of the escort not to do so, the client having handed over money does not entitle the client to any sexual service.  Many escorts also tell us that in fact many of their clients are seeking companionship more so than sex, and that ‘escort’ is a much better term for this reason.

For the purposes of this document we will generally use the term ‘sex worker’ as this is a broader more recognised term, which can include not only people who identify as escorts, but also those who identify as massage service providers, dominatrixes, prostitutes etc.  We will also use the term prostitute at times.  This is a long used term for persons who provide sexual services in law etc.

This Consultation

The Government produced a balanced discussion document for this consultation, something we would like to commend the Government for.  We would also like to state that we have contacted the Committee Clerks with questions on a few occasions and always found them very helpful.  Sex workers have also told us that they too have found the Committee Clerks very helpful.

However we feel the reality is that this consultation has come about because of lobby groups wanting to see the purchase of sex criminalised, and, despite the good will the Government has shown, this is a process that works for those lobby groups, but does not work for sex workers.

We do not think it is reasonable to imagine that a good number of sex workers from a broad range of backgrounds are going to be in a position to go through a 59 page document with 74 questions many of them with multiple parts, and respond to this consultation.  We note that English is not the first language of many sex workers.

Even more concerning is that sex workers are unable to make submissions anonymously, they are required to provide their name, address, phone and email, and it is a public process so all this information can be released to the public.  Sex workers have said to us that Committee Clerks have been helpful regards this issue and offered to redact personal information from their submissions from possible public view.  This is good, but it is not necessarily reassurance enough for many sex workers, who are naturally very worried about possibly being identified as a sex worker.

Sadly sex workers are horribly discriminated against, shamed, harassed and abused in society.  This is why a public consultation followed by public hearings is simply not a viable option for most sex workers.  We believe that the most important voices in this debate should be the voices of sex workers, but a consultation like this is not going to do enough to enable their voices to be heard.  It should also be noted that anti-sex work organisations, most notably Ruhama, are Government funded, but there is not equal funding or equal existence of organisations that advocate for the rights of sex workers, which is another disadvantage for sex workers.


We believe, if you want to get an accurate view of sex work in Ireland, you need independent research on sex work in Ireland.  However we do not have any.

In 1980 a report was published called Girls on the street: the need for a ‘Welcome’ (c.1980) by Jim Finucane, National Chairman of Young Fine Gael and research officer to Michael Keating TD. This report really gave a voice to the women selling sex on the streets of Dublin at that time.

In the 1990s five prostitution reports were published by Health Boards, but there has been no independent research on female indoor sex work (the main type of sex work) in the last 10 years.

The SAVI Report in 2002 included a section that looked at women working in street prostitution. However the researchers did not in fact speak to any sex workers.  Ruhama acted as “spokespersons” for the prostitutes instead.  In 2004 a report on male prostitution was published by a Health Board.  In 2005 The Next Step Initiative Report was published by Ruhama.  Ruhama also published Annual Reports from 2005-11.  In 2009 Drug Use, Sex Work and the Risk Environment in Dublin was published by: NACD (National Advisory Committee on Drugs). Participants in this research were exclusively English speaking street-based drug-using sex workers in Dublin.  Also in 2009 Globalisation, Sex Trafficking and Prostitution, The Experiences of Migrant Women in Ireland was published by the Immigrant Council of Ireland (ICI).

Research on female indoor sex work has been left exclusively to Ruhama and ICI for the last decade.  Government funding has paid for much of the research, certainly the majority of Ruhama’s, but the Government has never conducted any research into indoor female prostitution itself, nor has there been any other independent research by academic or other organisations.  Ruhama is a joint initiative of the Good Shepherd Sisters and Our Lady of Charity Sisters. The ICI was established by Sr Stanislaus Kennedy of the Religious Sisters of Charity and their research into prostitution has been funded by the Religious Sisters of Charity.  Indoor female sex work research has been left to the Church, though paid for by the Government by in large, for over a decade now.   This is not acceptable.

Unbiased research into indoor sex work in Ireland is urgently needed. It’s been done in the UK and many other countries in recent years. We did it before in the late 1970s. It can be done here again.

We do not view this consultation as an alternative to proper research being conducted.   We believe independent research should also be carried out urgently and the Government should step up and make sure this happens, and to bring in new laws without doing this would be very wrong.

Our Current Laws

The Government has stated that the present rationale for criminal legislation on prostitution is protection of society from a nuisance and public order perspective and the protection of prostitutes from exploitation, and that current laws do not seek to regulate the purchase of sexual services between consenting adults in private.  We do not think this is a bad basis for legislation.

We do feel the views of sex workers are the views that need to be heard more than any others here.  It is sex workers who will be most greatly impacted by any changes to prostitution legislation.  It is the lives of sex workers which many rest in the hands of this consultation and following processes.

There are situations where sex work can impact negatively on a community, like a case of street sex work taking place in an unsuitable public area.  Of course it is very important the public’s views are taken into account here, as that is a situation where the public can be negatively impacted.  Others also have views to contribute, general members of the public, moral lobbyists, customers of sex workers, those who work with sex workers, but surely it is more important that sex workers are listened to than any other group here?  This is why we feel it is so important more is done to get sex worker views and proper independent research into indoor sex work before laws are changed.

Outdoor Sex Work & The Law

We are in the position where we do not have much knowledge of outdoor sex work and we are hopeful that others who do and who care about the well-being of outdoor sex workers will be taking part in this consultation.  For this reason we will not be putting forward views on outdoor sex work.

Indoor Sex Work & The Law

We strongly believe that indoor sex workers should not be forced to work alone in order to work legally, as they are, under our current brothel keeping laws.  We believe Ireland’s current laws on brothel keeping should be changed in order to allow sex workers to legally work with a friend for reasons of safety.  We regard this as the single biggest problem with our current prostitution laws and something that is hugely negatively impacting on indoor sex workers.  Forcing sex workers to work alone to work legally, and criminalising those who don’t, cannot be right.  These laws are putting the safety of sex workers at risk and making sex workers have to live in fear of the police.

We would like to refer to a study carried out by Turn Off the Blue Light and available at the following address:  This study found that 91% of people convicted of brothel keeping offences in Ireland from 2008 – 2011 (to 27 July) would appear to have been sex workers, and not owners or managers of brothels who have sex workers working for them.  This research is also provided as an attachment to this document.

We also note that it is an offence to advertise as a prostitute in any form.  We do not believe sex workers should be criminalised for advertising.

Criminal Records

We believe there should be legal measures in place to enable sex workers with criminal records for soliciting/loitering or advertising or brothel keeping (where it was a case of their working with a friend for safety only) to seek to have these expunged to enable them to not have to live with the negative impacts of having a criminal record for prostitution.

The Swedish Model

We oppose the “Swedish Model” of criminalising the purchase of sex.  We believe criminalising the buying of sex would only serve to drive sex work further underground and make it more dangerous for everyone.  We do not believe criminalising the purchase of sex would significantly impact on the numbers of persons buying and selling sex, but we do believe it would change the industry.

It has been illegal to buy sex from someone who has been trafficked since the Criminal Justice (Human Trafficking) Act 2008, so there is already a law against paying for sex with trafficked persons.

In our experience, currently most sex workers are independent.  We feel if there was further criminalisation and the industry became more underground and dangerous, it is likely fewer independent sex workers would choose to work in Ireland, and these sex workers would be replaced by sex workers much more likely to be working for someone else.  The Swedish Model increases abuse and exploitation and it would be very sad to see the sex industry in Ireland reduced to this.

Further we believe sex workers should have the right to choose to remain in sex work or leave sex work, and should not be labelled victims against their own beliefs or have other people’s beliefs forced on them.

We also believe there is nothing wrong with someone paying for sexual services and most clients are decent people in our experience.  We do not think adults should be prosecuted for privately paying other consenting adults for sex.

We would further note that quite a number of escorts who work in Ireland also visit Sweden and E Designers also operates escort websites in Sweden.

Other Models

We are against Total Criminalisation.  We think Decriminalisation, as in place in New Zealand, appears to work very well.  We would hope that, as the Government organised a visit to Sweden, it would also organise a visit to New Zealand or otherwise investigate this model.  We regard Decriminalisation as preferable to Legalisaion & Regulation and more suitable for Ireland.


We would like to see more policing of the sex industry, more Garda resources in this area, but directed at exploitation and trafficking, not consenting adults.

We would like there to be a dedicated Garda Sex Worker Liaison.

If the Swedish Model were introduced, we do not believe it would be widely enforced.  We do however believe it would hamper policing of the sex industry due to it pushing it more underground and clients likely to be no longer willing to cooperate with police.


We feel there has been a lot of hysteria about trafficking in the Irish media and we need real facts.  This is another reason we urgently need independent research into indoor sex work.

We do believe there is abuse and exploitation of some sex workers in Ireland by third parties, which may or may not meet the legal definition of trafficking.  This is a key reason we state we believe more policing, directed at abuse in the sex industry, is needed.

Child Prostitution

We are not aware of any case of a child ever having been advertised on E-I to date.  We use age verification technology and human procedures with the aim of preventing this possibly happening.


The treatment of sex workers and violation of their privacy by some newspapers, magazines, TV and radio stations is disgusting and causing huge harm to sex workers and their families.  This needs to be addressed by the Government or the Press Ombudsman.

We also believe all sex worker victims of crime or witnesses of crime should be entitled to anonymity.  The possibility of being identified as a sex worker in the media as a result of reporting a crime or being a witness in a court case is stopping sex workers reporting crime.

Mobile Phones & Internet

We are against legislation to shut down sex workers mobile phones and/or sex worker websites.

We also believe any attempts to do this would be extremely difficult, time consuming and ultimately not work.  The issue of shutting down or blocking websites is especially complex.  For this reason we are attaching two separate articles to our submission on these two issues, also available online at:

Some Statistics

The number of unique escorts that have been advertised on E-I from 1st March 2012 through to 31st August 2012 (last 6 months):

Females – 2196
Males – 77
TVs – 72
TSs – 70
Duos – 28
Couples – 5

We would be pleased to provide further statistics on request.

E Designers is currently coordinating a blog about the Irish 2012 prostitution consultation at

One thought on “

  1. This is excellent stuff.

    With unlimited assistance from the gutter press, people have a very wrong idea about E-I. Let me put it in perspective for you. Not so very long ago “In Dublin” magazine served exactly the same purpose as E-I and taking inflation into account, charged considerably more for it.

    The idea of using the concept of charging only for time and company as a stopgap to deal with issues of consent in the current legal limbo (“no” means “NO” but how does that apply in contract law?) is absolutely inspired and well worth considering as a starting point upon which to base civil law regulation.

    The treatment of sex workers by the gutter press is often worse in it’s impact as well as after effects than rape (yes I have been violently raped, and not in the context of sex work, but I would rather go through that again, more than once, than be “exposed” in a tabloid,) and yet “Turn Off the Red Light” and Ruhama consistently use government funds to endorse and encourage these exposures. .

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