Different legal systems deal with combinations of physical, psychological, sexual, economic and controlling behaviour in different ways. Some have a specific coercive-control/domestic-abuse offence; others prosecute the individual acts and treat the overall pattern as an aggravating factor.
Comparative chart — selected jurisdictions, 2026
| Jurisdiction | How multidimensional abuse is treated | Maximum / statutory penalty for a relevant offence |
|---|---|---|
| Spain | Habitual physical or psychological violence against a spouse/ex-spouse or qualifying family member is a specific offence. The law also permits separate punishment for the individual acts making up the violence. | 6 months–3 years imprisonment, plus possible weapons prohibition and other consequences; separate offences can carry additional penalties. BOE |
| England & Wales | Controlling or coercive behaviour is a criminal offence covering repeated/continuous controlling behaviour with a serious effect. The statutory domestic-abuse definition expressly includes physical, psychological, economic and verbal abuse. | Up to 5 years’ imprisonment, a fine, or both. Legislation.gov.uk |
| Scotland | The Domestic Abuse (Scotland) Act 2018 specifically criminalises a course of abusive behaviour, designed to make clear that abuse can be a pattern rather than one incident. | Up to 14 years’ imprisonment, or a fine, or both. Legislation.gov.uk |
| Ireland | Coercive control is a standalone criminal offence where the behaviour knowingly and persistently controls the victim and has a serious effect. | Up to 5 years’ imprisonment, a fine, or both. Irish Statute Book |
| France | Repeated psychological harassment of a spouse, ex-spouse or partner is criminalised. Repeated violence against a spouse/partner is also subject to aggravated penalties. | Psychological harassment: 3 years/€45,000, rising to 5 years/€75,000 in specified circumstances and 10 years/€150,000 where it results in suicide or attempted suicide. Habitual violence can reach 30 years where death results. Légifrance |
| Portugal | Domestic violence expressly includes repeated or non-repeated physical or psychological mistreatment, deprivation of liberty and sexual offences against qualifying family/partner victims. | Generally 1–5 years’ imprisonment; 2–5 years in specified circumstances involving a child; 2–8 years for serious physical injury and 3–10 years where death results. Diário da República |
| Queensland, Australia | A particularly notable example: a standalone coercive-control offence covers a course of domestic violence occurring more than once, intended to coerce/control and reasonably likely to cause harm. The legislation expressly encompasses physical, psychological, economic and coercive conduct. | Up to 14 years’ imprisonment. Other offences arising from the same course can also be charged, although the coercive-control sentence cannot be made cumulative with those imprisonment sentences. Queensland Legislation |
| Brazil | Brazilian criminal law specifically recognises psychological violence against women, including threats, humiliation, manipulation, isolation, blackmail and control of decisions. Domestic bodily injury is separately aggravated. | Psychological violence: 6 months–2 years + fine; domestic bodily injury: 2–5 years, with substantially higher penalties for serious injury. Planalto |
| New Zealand | The Family Violence Act expressly recognises psychological abuse and patterns of violence and provides extensive protection-order mechanisms. It does not create one general standalone criminal offence called coercive control equivalent to Scotland or Queensland. | Breach of a protection order: up to 3 years’ imprisonment; underlying criminal acts are prosecuted separately. Legislation New Zealand |
| Canada | Canada does not currently have a single general criminal offence labelled “coercive control.” Domestic/intimate-partner violence is prosecuted through offences such as assault, threats, sexual offences and stalking, while abuse of an intimate partner is an aggravating sentencing factor. | Penalty depends on the underlying offence; intimate-partner status can increase sentencing severity. Department of Justice Canada |
| United States | There is no single nationwide “multidimensional abuse” offence. Federal law covers particular conduct such as interstate stalking/domestic violence, while most domestic-abuse prosecutions are governed by state law. | Varies enormously by state and offence. Certain federal VAWA offences can carry 5 years to life, depending on the seriousness of injury. Department of Justice |
What the comparison reveals
There is a very significant international difference in whether the law recognises the abuse as a pattern.
The newer legislative approach is increasingly moving away from:
“Was there one physical assault?”
towards:
“Was there a sustained course of behaviour used to control, intimidate, frighten, restrict or dominate another person?”
England and Wales, Scotland, Ireland and Queensland are particularly clear examples of this approach. England and Wales’ statutory guidance expressly recognises that coercive behaviour can exist alongside economic, psychological, physical and verbal abuse, and describes coercive control as something that can involve many different types of abusive behaviour. GOV.UK
Queensland goes particularly far in this respect. Its legislation defines domestic violence to include physical/sexual, emotional/psychological, economic, threatening and coercive behaviour, and its coercive-control offence allows the prosecution to rely on a course of conduct rather than treating every individual act as a completely separate event. Queensland Legislation
The maximum sentence is not the sentence a perpetrator automatically receives.
A court will consider factors such as the seriousness and duration of the behaviour, physical and psychological injury, threats, strangulation, sexual violence, financial exploitation, children being exposed, previous convictions, escalation, breach of orders and other aggravating or mitigating circumstances.
Multidimensional abuse may involve numerous individual criminal acts, but in jurisdictions that recognise coercive control, the law can also address the cumulative pattern—the combination of behaviours and the control they exert over the victim’s life.
That is an important distinction because the harm produced by a decades-long pattern of intimidation, psychological abuse, financial control and physical violence cannot always be understood adequately by looking at each incident in isolation.
This is a comparative overview, not legal advice; legislation and sentencing rules change, and the precise offence depends on the facts and jurisdiction.
