05 Jan 2024, 00:00

This article references sexual assault.

Is it time to rethink the age of consent in the UK? In the wake of allegations made against comedian Russell Brand, many are calling for sexual consent laws to be reformed.

A joint investigation by the Sunday Times, the Times and Channel 4's Dispatches uncovered the allegations of four women who accused Brand of committing various forms of sexual assault. He denies the allegations and maintains that all his relationships were “consensual.”

One woman, ‘Alice’, alleges that Brand, then 31, instigated a relationship with her in 2006 when she was 16. As the age of sexual consent in the UK is 16, this is legal – even if some of the other behaviours Brand is accused of (such as grooming and sexual assault) aren't. Now in her thirties, Alice is calling for the age of consent to be reconsidered.

In a column for the Sunday Times, Alice wrote, “There was nothing my parents could do to stop the relationship with Russell; no legal recourse.”

She continued, "I believe 16 and 17-year-olds should be allowed to explore their sexuality but without undue influence from much older people," she wrote. She suggested that “staged consent” laws could be introduced, meaning the age of consent would remain at 16, but it would be illegal for over-21s to engage in sexual activities with under-18s.

The World Population Review defines the age of consent as the “minimum age at which a person is considered legally competent to consent to sexual acts.”

However, consent laws are notoriously complex, and the age of consent varies considerably depending on which country or region you happen to live in. For example, some US states have ‘close-in-age’ (or ‘Romeo and Juliet’) laws, which can exempt or lower the penalties for those who engage in sexual activity with someone under the legal age of consent – providing they are also under the age of consent or significantly close in age.

It's also important to note that in many countries, the age of sexual consent is higher for homosexual sexual activity than it is for heterosexual. In some countries, homosexual activity is criminalised altogether and, in many cases – including Iran, Northern Nigeria, Saudi Arabia, Somalia and Yemen – punishable by death.

Here, we explore how the UK's age of consent compares with the rest of the world, from countries without a legal age limit, such as Saudi Arabia, Yemen, and Afghanistan, to those with a much higher age of consent, such as Bahrain, South Korea, and Nepal.

Countries with no age of sexual consent:

There is no age of consent in some countries, including Iran, Libya, the Maldives, Pakistan, Saudi Arabia, and Qatar.

In these countries, it's illegal to engage in sexual activity outside of marriage (per Age of Consent). As such, they have laws stipulating an age of consent to marriage. In many countries where sex before marriage is illegal, the age of consent to marry is higher for men than it is for women. For example, in Qatar, the minimum legal age of marriage is 16 for girls and 18 for boys.

Even in countries with a minimum age of consent to marriage, the courts can still grant approval for individual cases where the parties(s) are underage.

Countries with ages of consent under 16:

Most countries require young people to be at least 14 before engaging in sexual activity, with some notable exceptions: In Nigeria, the age of consent is 11; in Angola and the Philippines, it's set at 12; and it's 13 in Niger, Burkina Faso, and Japan – although the latter's consent laws vary depending on which region you're in.

Many European countries, including Italy, Hungary, Germany, Albania, Serbia, and Montenegro set the age of consent at 14. This is also true of a number of South American countries, including Peru, Bolivia, Brazil, Columbia, Ecuador and Paraguay.

The age of consent is also 14 in Bangladesh, China, Myanmar, and Chad.

The age of consent rises to 15 in Thailand, France, Poland, Sweden, Greece, and Croatia – as well as Iceland, Denmark, and Honduras.

Countries with ages of consent 16+:

The UK sets the age of consent at 16 – along with Spain, Russia, South Africa, Canada, Australia, and Israel.

Finland, Norway, New Zealand, Jamaica, Barbados, Bahamas, Luxembourg, and Cuba also set the age of consent at 16.

The age of consent varies by state in the USA: 31 states set the age of consent as 16, eight set it at 17, and 11 set it at 18. According to Age of Consent, 26 states have close-in-age laws, which legalise “sexual activity between underaged participants if they are close enough to one another in age.”

The age of consent rises to 17 in Ireland, Mexico, Cyprus, and Nauru; and 18 in India, Egypt, Vietnam, Kenya, Uganda, Argentina, Iraq, Chile, and Vatican City.

The age of consent is 20 in South Korea and Nepal and 21 in Bahrain.

GLAMOUR has reached out to Russell Brand for a comment. This feature will be kept updated.

For more information about emotional abuse and domestic abuse, you can call The Freephone National Domestic Abuse Helpline, run by Refuge on 0808 2000 247.

For more information about reporting and recovering from rape and sexual abuse, you can contact Rape Crisis on 0808 500 2222.

If you have been sexually assaulted, you can find your nearest Sexual Assault Referral Centre here. You can also find support at your local GP, voluntary organisations such as Rape Crisis, Women's Aid, and Victim Support, and you can report it to the police (if you choose) here.

For more from Glamour UK's Lucy Morgan, follow her on Instagram @lucyalexxandra.

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