I saw it in the US when it opened and it was rated R. I was a pre-teen.
I can only remember two movies that were rated X that were relatively tame: Midnight Cowboy and Alice's Restaurant.
I saw Midnight Cowboy as an X but didn't see Alice's Restaurant until it was an R (or even an M, the precursor to GP, PG and PG-13.
I'm guessing the male rape scene with Pacino is the reason for the rating. It has some boobs also, but hard to see it getting an X for that.
shareI was working in a movie theater when this was released, and it was rated R. The only X that was released while I worked there was Last Tango in Paris. Scarecrow was definitely an R.
The Haunted Man, by Dori Davis: Sometimes it's the living who torment the dead
Amazon.com
If midnight cowboy was released in 2016 it would be pg and shown in grammar schools
shareUhhhh....no it wouldn't. Midnight Cowboy is still an adults only film, even by today's lax standards.
I think the OP is from the UK. It was rated X in the UK, which in those days was pretty much the equivalent of an R rating in the United States.