Interest groups criticized the law, which they claim penalizes and endangers prostitutes and a constitutional complaint was filed in June 2017.

In the case of renewal of the registration certificate, it must be shown that a health consultation took place annually - for prostitutes under the age of 21 every six months - (§5(5) parts 2 and 3 ProstSchG).

Upon request, the Office may issue a supplementary alias attestation, in which the real name is replaced by a pseudonym to protect the identity of the person (§5 Abs.

[6] In its coalition agreement, the SPD, the CDU and the CSU decided in 2013 to regulate and introduce "regulatory control options" on the one hand "to better protect women from trafficking and forced prostitution " and on the other to "punish the perpetrators more consistently".

The demand of the Union to reintroduce compulsory medical examinations for prostitutes,[7] was as well as the requirement for a minimum age of 21 years[7] was not included in the law.

[7] In the explanatory memorandum to the bill, which the Federal Government submitted to the Bundestag in May 2016, it was explained that prostitution was "an economic sector in which substantial revenues are generated and which [...] follow the intrinsic laws of the market economy".

"[8] In particular, it lacks "binding minimum standards for the protection of the health and safety of those working there" and legal bases for controlling the operators of prostitution trades.

[8] At the same time "it must be taken into account that frequently prostitution is carried out by persons who are in a particularly vulnerable or stressful situation and who are therefore unable to defend their rights in an autonomous manner.

Many states - including Baden-Württemberg, Berlin, Hamburg, Rhineland-Palatinate and Saxony - were unable to create the necessary structure by 1 July 2017,[3] in particular to hire the necessary staff.

Shortly before the introduction of the law, the Berlin prostitute counselings centre and advisory board Hydra criticised that the obligation to register had "created a horrendous fear" because it was unclear what happened to the data and who had access to it.

The assumption that a woman would report a dependency relationship to the authorities - this argument was advocated by the Lower Saxony Social and Women's Minister, Cornelia Rundt (SPD) in 2015[9] - was dismissed by Buntenbach-Henke as "pure utopia.

[19] In a similar vein, Minister of Family Affairs Manuela Schwesig (SPD) said after the law had been passed that the obligation to register was not aimed at self-directed sex workers, but necessary to protect women who were lured to Germany and then disappeared in brothels.

[10] The North Rhine-Westphalian Minister of Health and Emancipation, Barbara Steffens (Greens), argued against this view as early as 2015 in a statement on the draft bill submitted at that time.

[6] In addition, Steffens criticized her counterpart, the Bremen Social Senator Anja Stahlmann (Greens), in that the state takes the law with the right to label women and men as prostitutes.

[3][22] In addition, according to Starostik, the lack of condoms is an "inadmissible interference with the intimate personal sphere", which makes it unreasonable for the brothel operators to be in control.

[24] The Frankfurter Rundschau announced in February 2019, Doña Carmen has filed a lawsuit against the Prostitute Protection Act at the European Court of Human Rights in Strasbourg.