The Good Law Project (GLP) has started a campaign against Sex Matters, saying that it has identified “46 examples” of Sex Matters “spewing hate”, including “harassment and discrimination”, which it says “breaks charity law”. It says it has submitted a formal complaint to the Charity Commission.

You can also leave us a message with your donation and let us know if it is okay for us to publish it (anonymously).

Sex Matters was founded as a human-rights charity to create space for debate and understanding of laws and rights concerning sex and gender identity. We think that there are conflicts of rights and that it should be possible to talk about them openly and freely. We believe that this is how everyone’s rights can be protected, and institutions can be held to account.

As Akua Reindorf KC wrote in the Reindorf Review in 2020: 

“The mere discussion of what ‘trans rights’ entail cannot be regarded as a violation of those rights in a context where the proper extent of those rights is clearly not settled either in law or in public opinion… and where there is a potential conflict of rights.”

Sex Matters and the wider movement we are part of have had some success in making it easier and safer to talk: in person and online, at work and in Parliament, in the media and in courts. And some people don’t like that. 

What does GLP think is “hateful”?

GLP has not published its complaint or shared its 46 examples with us but it has published a selection of quotes and links on its website. When we looked at what it had identified as “inappropriate and offensive” conduct it was simply a set of examples of us pointing out the serious harms done by those promoting gender identity.

They include a powerful and insightful speech given by Sex Matters’ director of advocacy, Helen Joyce, at the Genspect Bigger Picture conference in September 2024, where she argued that the new belief system based on gender self-ID has co-opted and corrupted the language of rights  and is harming women, children and vulnerable people, and breaking medical and scientific thinking.

As Helen explained (emphasis here and throughout added by GLP):  

“Self-ID means that a man who strips off in front of naked women in a supposedly women-only space is doing something right and proper if he identifies as a woman… This is not just a destruction of human rights, it’s a full reversal. And it’s not just any old human-rights violation, it’s state-sanctioned sex crime – voyeurism and indecent exposure – and an Article 3 violation. The European Court of Human Rights has ruled that being forced to undress in front of someone of the opposite sex violates Article 3 – the right not to suffer torture, inhuman or degrading treatment. And note that Article 3 is an absolute, not qualified, right.”

We published the speech, together with the one she gave at the first Genspect conference, in Killarney in 2023, in a booklet called Sex, gender identity and human rights, which we sent out with our Christmas cards in 2024.

GLP also highlights a letter from Sex Matters to Bridget Phillipson, at the time the Minister for Women and Equalities, sent in May 2026 to welcome the new EHRC Code of practice on services, public functions and associations.

In the letter, Sex Matters’ chief executive, Maya Forstater, raises concerns about the section in the new code on “asking about sex”. The section warns service providers against challenging people who appear to be using the wrong facilities. As the letter explains, this will enable situations where sex-based harassment is allowed. We said:

“There is no legal basis for this instruction, which in effect licenses men to enter women’s facilities and claim that it is inappropriate, and possibly unlawful, to challenge them. Telling women (and staff supervising single-sex spaces) that they must second-guess themselves when they become aware of a man engaging in the deviant behaviour of accessing a female-only space is unwanted conduct related to the protected characteristic of sex. It ‘violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment’. Section 111 of the Equality Act 2010 makes it unlawful to instruct, cause, or induce another person to commit an act of discrimination, harassment or victimisation.”

GLP also complained about an interview of Maya Forstater on Talk TV in January 2026 concerning the Hampstead Ladies’ Pond. 

In the interview she answers the interviewer’s question about what the problem is if a man who “feels they’re in the wrong body” uses the women’s pond, but changes “discreetly” in a cubicle:

“The ponds aren’t very discreet. They’re communal, open changing rooms and open showers. What you can’t do is let someone in and then say: ‘But you can’t use those changing rooms. You have to use a discreet changing room.’ If you let someone in, you let them in on the same rules as everyone else. At the same time, if there are women using the communal changing rooms and showers, they’re naked. If somebody walks past, the man might be dressed, but he’s walking past naked women. That’s a situation of harassment. You can’t let that happen. You have to have clear rules about who’s allowed into those kind of situations, and it’s really obvious what the decent rules are.”

GLP also highlights an interview of Sex Matters’ director of campaigns, Fiona McAnena, in January 2026 on GB News. 

The interviewer asks why some men insist on using the Ladies’ Pond instead of accepting the “amicable” solution of the mixed pond. Fiona says: 

“I think there are a number of answers to that. Some people would say that this is a voyeurs’ charter. If any man can declare he’s a woman, it’s not the nice, decent, respectful men who are going to come into the Ladies’ Pond. It’s a different kind of man. There may be some men who genuinely think that what they feel makes them like a woman. But we can’t see their thoughts or their feelings. All we can see is their bodies and their behaviour. Some women would say it is an intentional act of violation of women’s boundaries, and that those men enjoy it. I couldn’t say. All I know is that, as you say, they have a choice. They could be respectful. They could allow us all our privacy, and they’re making a conscious choice not to.”

GLP included in its complaint a personal interview of barrister Naomi Cunningham in Holyrood magazine while she was chair of Sex Matters, which Sex Matters’ CEO had promoted. In the personal and moving interview she talks about her journey and what motivated her to get involved in legal work in this area. Naomi said:

“Rage does still fuel me because there are so many things to be profoundly angry about: the grooming of children into mental ill-health and physical mutilation; the gas-lighting; the bullying and silencing and cancelling; the corruption of so many of our institutions; the sheer waste of time, money and energy on dealing with such obvious nonsense.”

And GLP complained about a quote from Helen about Girlguiding in an article in The Telegraph: 

“By thinking it could redefine sex and make up its own rules, Girlguiding UK showed no concern or understanding for girls’ rights and boundaries. But it also failed to think clearly about what boys confused about their sex really need, which isn’t validation in a falsehood. This shameful episode of harming children in the name of ‘inclusion’ went on for far too long, but at least it is now drawing to an end.”

It also complained about an interview on Talk TV in which Helen said it was wicked to lie to children and to subject them to sterilising medical treatment:

“You don’t put people in boxes just because of what sex they are, but you do not lie to them either. So these people committed real human rights abuse against vulnerable children. And now that they’re really dragging their feet on admitting that fact. Children need honesty, and they need boundaries from the adults around them. They need adults to keep the world safe and accurate for them. To tell them what’s what, to make sure that they grow up safe and secure and confident.”

GLP complained about an article on Helen’s personal Substack about schools too. Helen wrote:

“In this issue I’m going to pick up the question of how to stop schools spreading genderism. Schools are by no means the only place children are picking up this neo-religion, and I don’t underestimate the difficulty – teachers have been indoctrinated in it for at least a decade, and in some countries for much longer. But the education system is the main vector of infection that is, at least theoretically, under the direction of authorities and open to the influence of parents and voters.”

Sex Matters is proud of its work

The governing document of Sex Matters commits it to three aims:

1. to promote human rights where they relate to biological sex
2. to advance education about sex and the law
3. to promote the sound administration of the law in relation to sex and equality in the law.

We take our charitable purpose and the human-rights framework seriously. We don’t say things to be offensive but to raise awareness of harms and of human-rights issues. We hope the Charity Commission watches and reads our output. 

There is nothing in the clips and quotes we have seen from GLP that we are not proud of saying. We believe that lying to children and vulnerable people about sex undermines safeguarding, that subjecting them to sterilising treatment based on a false promise of changing sex is a grave human-rights abuse, and that allowing men who wish they were women to use women-only services undermines women’s human rights to fairness, safety and dignity. 

We set this all out in our human-rights framework, which we submitted to the regulator when we applied to be a charity. As we explained:

“These abuses of human rights and patterns of discrimination often arise from misunderstandings and misrepresentations of human rights and equality frameworks themselves. For example any recognition of the sex of a person who identifies as transgender is labelled as ‘harassment’.

“In order to resolve conflicts between the rights of women and those of transgender people, these conflicts need to be identified and discussed openly and clearly. Where conflicts or rights are ignored or made unspeakable, rights may be undermined.”

We explained why clarity about sex matters for human rights again in the Supreme Court in 2025, when we intervened in support of For Women Scotland: 

“For example, in the case of a rape crisis service, it is self-evident that women using the service would want and reasonably expect to find a female-only space. The presence of a biological man in such a situation effectively destroys the purpose of such a service and, worse still, can serve to retraumatise the very women for whom the service is intended to be provided. The impact on women of facing (or hearing) male individuals in women’s refuges or counselling services can be devastating. Many women self-exclude from the services, or are compelled to pretend that men are women, at great cost to their mental health.”

Our arguments were accepted by the Supreme Court, and we were specifically thanked for making them.

And we are preparing to make the case again in November 2026 when the Hampstead Ponds case comes back to court. 

We have published long-form legal analysis explaining why the Supreme Court judgment does not remove, diminish or breach the rights and protections of trans people, and an illustrated easy-reading version of the law. We have produced a model policy for schools in line with statutory safeguarding guidance, as well as guidance for the media on reporting on sex and gender identity. Every week we discuss issues on our podcast and we answer hundreds of email queries every month.

GLP says we have ignored our responsibility to serve the general public. We think that what it actually objects to is that we have done too much.

Donate to support Sex Matters

The post Is talking about human rights “hateful”?  Judge for yourself appeared first on Sex Matters.

It says that “schools and colleges should consider whether pupils would be best supported by a policy on social transition which explains the steps that a school or college will go through when a child requests support.” School governors and leadership teams will therefore be thinking about what policy to adopt, in line with the guidance, over the summer holidays and at the start of the autumn term. 

But the most important aspect of the new guidance is extremely positive: it places significant constraints on what a school can accommodate in response to a family’s or child’s idea of “social transition”. It does this by placing for the first time, three vital principles within the statutory safeguarding framework:

1. All children’s sex must be recorded accurately in every situation throughout their school career.
2. All relevant staff must be aware of every child’s sex.
3. Schools must never allow any child to use toilets or changing rooms for the opposite sex. 

Taken together, these three principles mean that schools will need to refer to all children by their sex routinely. Since KCSIE constitutes part of the statutory framework within which Ofsted operates, any policy that contradicts these principles is likely to come up during school inspections, either because the inspector spots the infraction or because parents bring it to the inspector’s attention.

However, the guidance still suggests schools respond to requests to accommodate “social transition” by working through complex legal justification exercises on a case-by-case basis. Its biggest flaw is that it suggests “full social transition” (which it doesn’t define) may be undertaken by a school, albeit “very rarely”. 

The model policy is designed to help schools set clear expectations for all pupils, families and staff, and to explain the legal constraints which mean they cannot accommodate requests to be treated as the opposite sex. School and college leaders who follow it can feel confident that their policies are in line with KCSIE and do not subject any children to unlawful direct or indirect discrimination under the Equality Act 2010.

If you are a school governor, work in a school or have a child in school in England, you can send our model policy to the senior leadership team and share it with the governing body. It is published under a creative commons licence, which means that they are free to adopt it and adapt it as they wish.

The post Updated school model policy: send to your child’s school appeared first on Sex Matters.

The Charity Commission should clarify that every charity must follow the Equality Act and ensure that trustees have an accurate, lawful understanding of its purposes as set out in its governing document. This includes where that refers to women and girls or men and boys, to sex or sexual orientation, and to equality and human rights. 

Read our letter to the Charity Commission

Dear Dame Julia Unwin,

On 8th July Amnesty International UK, together with Amnesty International UK Section Charitable Trust, published a report entitled A growing threat: the anti-rights movement in the UK. This presented 117 organisations and grassroots groups as an “organised anti-rights movement targeting the rights of women and LGBT+ people”. After widespread criticism Amnesty has withdrawn the report for review, but it has not apologised. A sister report, Like a snowball: the growth and impact of the gender critical movement in the UK (May 2026), made similar accusations. That remains live (with a list of organisations included in the technical annex). 

The impugned organisations include several charities, as well as other groups defending the rights of women, girls, children and gay, lesbian and bisexual people; charities and organisations concerned more broadly with human rights; Christian charities and organisations; organisations of parents and clinicians concerned about paediatric transition; grassroots women’s-rights organisations doing vital work domestically and internationally with vulnerable women and children; and a rape crisis centre and support service for female survivors of male violence.

The characteristic that unites them all is that they are associated with the “gender critical” belief that there are two sexes, that human beings cannot change sex and that sex matters. 

Smearing groups as “anti-rights” because of their philosophical or religious beliefs, as Amnesty does, paints a target on those groups. Calling for the Charity Commission, funders and the media to subject them to less favourable treatment because of their beliefs – as the most recent report does – is an explicit call for these groups to be subjected to unlawful discrimination. 

Discrimination and disadvantage experienced by women and girls is persistent, endemic, and deeply entrenched. It ought to be shocking that one of the country’s most respected human-rights charities is openly campaigning for systematic unlawful discrimination against groups that stand up for women’s rights. But the prejudice displayed in Amnesty’s report is ubiquitous in the charity sector.

The Like a snowball report openly laments that the application of the Equality Act has “contributed to the normalisation of all manifestations of gender critical belief”. The Amnesty employees who wrote it and signed it off, and those who have been giving interviews, making conference presentations and producing social-media content with the same discriminatory message, may not have thought they were doing anything wrong because this form of unlawful discrimination is the norm in large parts of the sector. Anyone who speaks out about this discrimination is risking their career or position on a charity board. 

As you have set out in your speeches and to Parliament, charities may hold different and sometimes competing views, and the role of the Commission is to ensure that they are well governed, operate within their remit, pursue their agenda appropriately and do so in a civil way.

But charities that have adopted a discriminatory approach to individuals with gender-critical beliefs, stereotyping those individuals as harmful or hateful, are acting unlawfully, as shown in the cases of Forstater v Centre for Global Development and Adams v Edinburgh Rape Crisis Centre. Charities that refuse to comply with the law are not well-governed. And a sector that systematically misunderstands the law is a problem for its regulator.

While other sectors are getting on with complying with the Equality Act following the For Women Scotland judgment, senior leaders and trustees across the charity sector have been acting as if the law does not apply to them.

Amnesty International UK, which explicitly described itself as a registered charity in its application to intervene in the For Women Scotland case, tested its proposed interpretation of the law with the highest court in the land. It was found by the Supreme Court not to be inclusive, but rather to be incompatible with a “workable” and “coherent” legal system for protecting women, gay, lesbian and bisexual people and transgender people from discrimination. 

The court agreed with For Women Scotland, Sex Matters, LGB Alliance and the other lesbian interveners that the terms “man” and “woman” in the Equality Act 2010 refer to sex, not self-declared gender identity or paperwork, and that services provided only for women or only for men must be provided on the basis of sex. Transgender people remain protected from discrimination and harassment in work, education, service provision, premises and associations, on the basis of both sex and gender reassignment. The new EHRC guidance provides detailed explanations of how mixed-sex and single-sex services can be provided lawfully in a way that treats everyone with respect.

In human-rights terms, although rights are universal, the rights to freedom of expression and to privacy, to freedom of association and to manifest beliefs are qualified and may be constrained by lawful mechanisms in a democratic society. 

Debates over how to reconcile women’s rights and transgender people’s rights are debates of this kind. 

Does Article 8 of the European Convention on Human Rights, which protects private life, mean that men who wish they were women have the right to undress in women’s changing rooms? Or does it mean that women and girls have the right to change in female-only spaces?

Is describing someone as a man when he wishes to be referred to as a woman a breach of dignity and of rights? Or is it simply stating ordinary facts that must be recognised in order to protect the dignity, privacy and autonomy of women and girls?

The Equality Act 2010 represents the settled, democratically agreed balance of rights in Britain. It recognises that men who identify as “trans women” remain men for the purpose of the law concerning sex discrimination, and therefore for the provision of lawful separate sex services, including by charities.

Amnesty’s longstanding argument that “trans women are women” and that there should be no debate about this is in opposition to the law and other people’s human rights. 

The trustees of Amnesty International UK Section Charitable Trust are far from alone in allowing intolerance, prejudice, ideological fervour, fear of being blacklisted in the sector and conflicts of loyalty between their duty to their charity and the principle of trans allyship or trans-identifying friends and family to take hold in the charities they govern. There have been several instances of charities and their leaders publicly smearing those with gender-critical beliefs and advocating that they be excluded from the sector and from society:

• On 21st April 2021, around the time when LGB Alliance was awarded charitable status, the then chief executive of NCVO said: “This step will be painful and dangerous for transgender people harmed by the views and actions of the Alliance.” NCVO later rejected applications from both LGB Alliance and Sex Matters for membership, and admitted us only when we issued a discrimination claim against it. 
• In June 2021 leaders of LGBTQ+ charities, including Stonewall, Mermaids, LGBT Foundation, LGBT Consortium and Gendered Intelligence, published an open letter expressing frustration and disappointment at the Equality and Human Rights Commission’s intervention in the Forstater case to say that “gender critical” beliefs are a protected philosophical belief.
• On 3rd July 2023 the “I Stand with Trans” pledge, which referred to gender-critical beliefs as “anti-trans hate” and called on charity leaders to “stand united together against this hate”, was signed by chief executives of several major charities and many smaller ones. The signatories included the chief executives of NCVO, Co-op Foundation, Teenage Cancer Trust, LGBT Foundation, Young Trustees Movement, the Children’s Society, Alzheimer’s Society, Samaritans and Charity Finance Group as well as several major charity recruiters.
• On 3rd December 2025 15 mental-health charities, including the Children and Young People’s Mental Health Coalition, Mental Health Foundation, Mental Health Matters, Mental Health UK, MHFA England and Mind, wrote to the Minister for Women and Equalities arguing against the protection of single-sex services on the basis of sex, and instead for the inclusion of people on the basis of gender identity. They called for the government to halt the EHRC guidance.
• In January 2026 a group called Third Sector Against Transphobia published an open letter describing those who want to see single-sex charities pursue their objects “transphobic groups and individuals”. 

It is now 15 months since the Supreme Court clarified that sex in law means what it always did, and that this interpretation is essential for protecting women’s rights and gay and lesbian rights. But the boards and senior leadership teams of many charities are still professing to be confused. Others are frightened of being blacklisted in the sector if they acknowledge that the law is clear and stand up for fairness and dignity for women and girls. The result is that across a range of services and activities, charities whose purpose is to benefit women, are using resources to benefit men who identify as women (see Murray Blackburn Mackenzie’s report).

Penny Wilson, writing on behalf of Third Sector Against Transphobia, recently wrote to the Charity Commission claiming that charities do not know how to comply with the law, and calling for more time and for charity-specific guidance.

There is no need for more detailed guidance. The charity sector is not above the law. If a service or facility is provided only for women, only for men or for both sexes, this has the same meaning whether that service is being provided by the public, private or voluntary sectors. Employees, service users and other individuals all have the same human rights. The charity sector needs to understand that the individuals and groups it has derided as “transphobes” and tried to exclude from public life are simply expressing a view that is in line with the Equality Act.

This is not a case of “both sides” needing to disagree well, but of systematic discrimination and harassment by some of the country’s most powerful and respected charities. It is happening openly and under the nose of the regulator. 

We call on you to show leadership and reset expectations across the sector by making a statement. The Charity Commission needs to clarify that every charity must follow the Equality Act and ensure that its trustees have an accurate, lawful understanding of its purposes as set out in its governing document. This includes where that refers to women and girls or men and boys, to sex or sexual orientation, and to equality and human rights. 

The commission should stand up against the culture of intolerance and discrimination towards people who express ordinary, lawful beliefs that has taken hold across the sector, and which has been demonstrated in the Amnesty reports.

It is unacceptable for a charity to call people or other organisations transphobes, bigots or anti-rights for using clear sex-based language, asking that the Equality Act be respected, raising concerns about safeguarding or medical evidence, being Christians or adhering to religious sexual ethics, just as it would be to commit unlawful discrimination and harassment on the basis of any other protected characteristic.

It does no favours to individuals who identify as transgender or to children exploring their identity to encourage them to think that the law does not apply to them or that they can disregard other people’s rights. 

Yours sincerely, 

LGB Alliance 
FiLiA
Sex Matters
For Women Scotland
CAN SG
Genspect
Thoughtful Therapists
Children of Transitioners
Get the L Out UK
Gender Critical Greens
Labour Women’s Declaration
Legal Feminist
Lesbian Strength
Merched Cymru
OBJECT – Women Not Sex Objects!
Older Feminist Network
Protect and Teach
Trans Widows’ Voices
Virago Women’s Workshop
LGB Alliance Cymru
Conservatives for Women
Fair Play For Women
Gay Men’s Network
Let Women Speak (formerly Standing for Women)
The Lesbian Project
Transgender Trend
Women’s Declaration International (WDI)
Murray Blackburn Mackenzie
Women’s Rights Network (WRN)
LGB Christians
Liberal Voice for Women
ScotPAG Scottish Professionals Advising on Gender
SEEN in HR
SEEN in STEM
SEEN in Journalism
SEEN in Sport
SEEN in Health
TU SEEN
SEEN in Publishing
Third Sector SEEN

The post The Charity Commission must act appeared first on Sex Matters.

Published on 8th July 2026, and removed just days later on 10th July, the Growing threat report is a new low for a once-great organisation founded on the rigorous gathering of evidence and the defence of free expression.

A sister report Like a snowball: the growth and impact of the gender critical movement in the UK, published in May 2026, remains live online and bemoans the normalisation of  “all manifestations of GC belief, including misgendering and talking about trans people with reference to their ‘biological sex’ and trans women as ‘biological males’.”

Amnesty’s public expressions of animosity and unevidenced slurs towards those with gender-critical views not only harm the reputation of gender-critical groups but also create a hostile environment for its own gender-critical staff, and set the organisation in opposition to its own charitable objects. 

Amnesty made a submission in the 2025 case of For Women Scotland v Scottish Ministers: its proposed interpretation of the Equality Act was rejected by the Supreme Court, which judged that it would undermine the protection of rights, making the legal protections against sex discrimination, sexual-orientation discrimination and gender-reassignment discrimination “incoherent” and “unworkable”.

Rather than admit that its approach took a wrong turn, Amnesty has doubled down.

The Growing threat and Like a snowball reports present gender-critical views as “transphobia” and groups such as the Gay Men’s Network and Beira’s Place rape crisis centre as shady, nefarious and driven by misogyny and homophobia. 

Stephanie Davies-Arai of Transgender Trend received a British Empire Medal for services to children for her work exposing the harms of unevidenced gender medicine. For Women Scotland won the Scottish Herald’s Public Campaign of the Year and the Emma Humphreys Memorial Prize given by the Centre for Women’s Justice. LGB Alliance, Sex Matters and FiLia are registered charities, recognised as pursuing goals in the public interest.

Following Mermaids’ failed attempt to have LGB Alliance struck off the charity register, the Charity Commission explicitly warned: 

“Demonising and undermining those who think differently is not acceptable behaviour from any charity on our register.”

The affected organisations are not letting the matter drop with a quiet deletion. Amnesty’s postbag is full of letters and its board members are facing calls to:

• provide the specific evidential basis relied upon for these classifications, or admit that none exists
• withdraw both reports in their entirety
• issue a public apologies to the individual groups smeared, as well as to its own gender-critical staff and supporters
• commit to comprehensive training for staff and trustees on UK equality and discrimination law.

It is time for Amnesty’s leadership to look honestly at legal reality, respect the pluralism of human rights advocacy, and engage in constructive dialogue rather than defamation.

What the letters said

Children of Transitioners and Trans Widows’ Voices said:

“The inclusion of small, grassroots victim-support organisations such as ours within a report describing an ‘anti-rights movement’ risks serious reputational harm, may deter vulnerable women and children from seeking support, and creates the impression that the experiences and human rights of the people we support have been discounted.”

For Women Scotland said:

“On page 2 of your report, however, you claim that the ruling has contributed to a “significant decline in protections for LGBT+ rights” with no reference to the fact that the Judges considered lesbian, gay and bisexual rights as well as the rights of those covered by gender reassignment and concluded that a certificated sex interpretation would be hugely damaging to these groups.”

Gay Men’s Network said:

“We consider that your report is a deeply silly and malicious piece of low politics designed to ‘evidence launder’ a list of undesirable gay and lesbian organisations and actors such that it can be quoted by those who seek, (like you) to control gay and lesbian free speech and open discourse.”

LGB Alliance said:

“Having lost the argument at the UK Supreme Court, Amnesty has now taken the extraordinary step of branding LGB Alliance (along with For Women Scotland and numerous other organisations) part of an ‘anti-rights’ movement. It somehow neglected to add the Supreme Court.”

Sex Matters said: 

“Allowing individual staff, campaigning teams or activists to use Amnesty’s name to launch campaigns that are not based on a solid understanding of human rights and the Equality Act is a reckless approach to governance and reputational, regulatory and legal risk, and a diversion from your mission.”

JK Rowling said:

“Beira’s Place hasn’t sent anything. Yet.”

Read all the letters

• Beira’s Place statement
• Beira’s Place letter
• CAN-SG
• Children of Transitioners and Trans Widows’ Voices
• FiLiA
• For Women Scotland
• Gay Men’s Network
• Genspect
• Keep Prisons Single Sex
• Labour Women’s Declaration
• Legal Feminist
• Lesbian Strength
• LGB Alliance
• LGB Alliance Cymru
• Liberal Voice for Women
• Merched Cymru
• Murray Blackburn Mackenzie
• Protect and Teach
• Safe Schools Alliance
• ScotPAG
• SEEN in Health
• SEEN in Journalism
• SEEN in Publishing
• Sex Matters
• Third Sector SEEN
• Thoughtful Therapists 
• Transgender Trend
• Women’s Rights Network

The post Amnesty faces backlash appeared first on Sex Matters.

It includes sections on single-sex spaces (paragraphs 105–116) and single-sex sports (paragraphs 95–98), as well as a long section on “children questioning their gender” (paragraphs 252–282). 

In December 2023, under the previous government, the Department for Education published draft guidance on “gender questioning” children, to which we gave a score of 76 percent based on our published scoring framework.

We said it should:

1. support schools in line with the law
2. provide coherent, consistent guidance across the education system
3. direct schools to collect sex-based data
4. uphold the Admissions Code
5. uphold single-sex spaces
6. uphold single-sex sports
7. avoid undermining safeguarding
8. rule out full social transition in school
9. uphold freedom of belief and speech
10. support clear sex-based rules and consideration for gender non-conforming children.

We have applied the same scoring framework to the new guidance and it comes in at 79 percent, with the improvement largely due to it being brought into the statutory safeguarding framework and having been made shorter and clearer. 

There are, however, still some concerning aspects. Although the guidance is in line with the Equality Act in making clear that separate-sex facilities are not negotiable – no child may be permitted to use spaces designated for the opposite sex, no matter how that child identifies – it tries to reconcile this firm principle with the idea of “social transition” at school. 

It defines this as facilitating “the child presenting as the opposite biological sex”, despite ruling out steps such as using opposite-sex facilities or being recorded as being the opposite sex. But by raising the possibility of “social transition” in school, it opens the door to negotiation and pressure, even though any school that works through the guidance accurately will inevitably conclude that the only fair and safe way to set policies that differentiate between girls and boys is to be clear who the girls are and who the boys are.

Helpfully, KCSIE says that schools should not initiate social transition, which should stop activist teachers promoting it. But it still leaves schools having to negotiate with activist parents who want their child to “socially transition” at school, and who may be highly motivated.

1. Support schools in line with the law 

7/10 – The guidance has been put on a statutory footing and ties into existing sex-based laws and regulations, including the Equality Act and regulations concerning school premises. It says that school governing bodies and proprietors:

“must have regard to this guidance, ensuring policies, procedures and training in their schools or colleges are effective and comply with the law at all times.” 

By putting the advice about use of single-sex facilities within KCSIE, the government has placed compliance within the remit of school inspections. The result will help clamp down on activist teachers promoting transition.

The new gender-related material within KCSIE is shorter and clearer than the previous draft guidance, but it suggests that children may in rare instances be able to undertake “social transition” in school, which it defines as facilitating “the child presenting as the opposite biological sex”.

2. Provide coherent, consistent guidance across the education system 

7/10 –The guidance is clear that schools cannot allow children of any age to use opposite-sex toilets and changing facilities, or (in most situations) to play sports designated for the opposite sex. It applies to all schools, both state and independent, and will be covered by the inspection regime. 

It also makes clear where the Equality Act and regulations concerning school premises apply differently to 16–19 academies that are outside the “further education” sector. It says that these colleges may be covered by part 3 or 5 of the Equality Act 2010 and still need to comply with the law. 

The guidance will form part of the inspection of safeguarding, where leaders are expected to “take an effective, whole-school approach”. However, while in practice it rules out many aspects of “social transition”, it still suggests that children may (rarely) transition at school, including what it calls “full social transition” at primary school. It does not explain how this can be consistent with the rest of the guidance.

3. Direct schools to collect sex-based data

10/10 – The guidance is clear that no child can change their sex at school, and under the section on “correct information” it states that:

“schools and colleges are legally required to record a child’s biological sex accurately wherever it is recorded.”

4. Uphold the school admissions code 

7/10 – The guidance does not mention admission to single-sex schools (the previous version made clear that schools are not required to admit a girl “as a boy” to a boys’ school or a boy “as a girl” to a girls’ school). It should be obvious that it is not possible to safeguard a girl in a boys’ school or a boy in a girls’ school while pretending that child is the opposite sex. 

The guidance does address the question of children already “in stealth” at school. It says:

“Schools and colleges should be particularly conscious of the vulnerabilities of children who have fully socially transitioned from an early age and may be living in stealth (that is, school or college friends/staff may be unaware of their biological sex). The Cass Review emphasised that these children are likely to approach puberty in a fearful and anxious state. Schools and colleges should involve the designated safeguarding lead in these cases.”

The idea that a child can be admitted to school “in stealth” as the opposite sex is not consistent with the legal requirement that all children’s sex must be correctly recorded wherever sex is recorded (such as in the admissions register and school information system). 

5. Uphold single-sex spaces

10/10 – The guidance has a clear, dedicated section on the law on school premises in relation to toilets, changing rooms and residential accommodation, which it ties into the safeguarding inspection framework: 

“In line with the responsibilities of schools and colleges to adhere to the highest standards of safeguarding for the children and young people in their care, alongside obligations under the School Premises (England) Regulations 2012 and the Education (Independent School Standards) Regulations 2014, schools must not allow pupils into toilets, changing rooms, or boarding or residential accommodation designated for the opposite sex, with no exceptions. Colleges to which part 6 of the Equality Act 2010 applies should follow the same principles.”

6. Uphold single-sex sports

7/10 – The guidance correctly says: 

“Where schools have implemented single-sex sports as being necessary for safety reasons, there should be no exceptions and pupils must not be allowed to participate in sports designated for the opposite sex. Colleges should follow the same principles.”

But it also says:

“Where there are no safety concerns and a child makes a request relating to how they participate, schools and colleges will need to consider the request in light of the advice on ‘considering requests for support with social transition’. This means that the school or college would need to take into account all the relevant factors, including whether supporting social transition is overall in the best interests of the child, as well as considering the impact on other children and the aim of creating safe and fair environments for children to participate in PE.”

We don’t think there is any basis for this. Whether for fairness, safety or the encouragement of girls in sport, single-sex sports should be single sex. Gender non-conforming children should not be discriminated against or harassed in participating in sport with their own sex. 

While there is a general principle that decisions about children should be made with the child’s best interests paramount, this part of the guidance appears to consider making complex clinical decisions in the context of deciding which PE team a child can play on. 

The guidance does recognise (at paragraph 275) that both fairness and safety are legitimate aims for separate-sex sports. 

7. Avoid undermining safeguarding 

8/10 – Putting the guidance into the statutory safeguarding framework is a big step forward. However, including the possibility of “social transition” and the concept of “gender” is inconsistent with the parts of the guidance that are clear about sex. It will provide opportunities for organisations to continue to undermine safeguarding by encouraging children and their families to think that children may be able to “present as the opposite sex” during their school career. 

The guidance also misses the opportunity to underline that gender identity should not undermine sex-based rules and behaviour codes in other parts of the guidance, such as harmful sexual behaviour – harassment, coercion or sex by deception – by trans-identifying pupils, and those children’s vulnerability to online harms and radicalisation. Any child disclosing that they are considering adopting or have adopted a cross-sex identity is disclosing a safeguarding risk. 

It does not mention other safeguarding risks such as children breast-binding and taking off-label banned drugs or “DIY” cross-sex hormones.

8. Rule out full social transition in school

7/10 – The guidance rules out large parts of what is commonly included under that label, such as recording a child as the opposite sex, allowing them to use opposite-sex facilities and letting them participate in most sports with children of the opposite sex. 

But it uses the term “social transition” 31 times, and leaves the door open for other, undefined, aspects of social transition to be negotiated. This presumably means pronouns and uniform, although they are not covered in any detail.

Paragraph 275 explains that schools and colleges should consider how their policies affect children with the protected characteristic of gender reassignment, both when developing policies and when considering requests to be exempted from following them. When a rule or policy places a gender-questioning child (and other gender-questioning children) at a disadvantage compared with those who are not gender-questioning, the school or college should consider: 

(1) Does the policy have a legitimate aim, for example, safeguarding or fairness in sport?

(2) Is the policy a proportionate means of achieving that legitimate aim? This will involve considering: 

• whether there is another way of achieving the same aim. Might a policy be adopted or an exception made that still achieves that aim? 
• the impact of the rule, or of making (or not making) an exception on the child themselves and anyone else affected. The school or college should balance the impact of agreeing to the child’s request against the impact of refusing their request, taking into account all the relevant factors. This will include taking into account the school or college’s judgment about whether supporting social transition is in the child’s best interests and the best interests of other children.

In practice, if schools refer to children by words used for the other sex or allow them to wear the opposite sex’s uniform it will be difficult to maintain clear expectations and rules. 

9. Uphold freedom of belief and speech 

7/10 – The guidance says: 

“The school or college should also make sure that children and their families are aware that while the school or college will appropriately sanction any cases of bullying or harassment, and take a strong stand against bullying, the school or college must also be conscious of the rights of pupils and staff in relation to their religion or belief. However, schools and colleges supporting social transition might consider discussing options with pupils and staff such as using names instead of pronouns.”

This is the only mention of pronouns in the guidance. 

10. Support clear sex-based rules and consideration for gender non-conforming children 

9/10 – The guidance says that:

“schools and colleges should consider adopting policies across school and college life that maintain flexibility and avoid rigid rules based on gender stereotypes.” 

Avoiding gender stereotypes is a good principle. But encouraging “flexibility” while suggesting that children may be able to undertake social transition creates ambiguity and room to negotiate. 

Total 79%

The post Keeping children safe in education: better than before appeared first on Sex Matters.

The guidance concerns the rare cases of sexual assault involving deception as to sex. We say the guidance is unlawful because it conflates the concept of subjective gender identity with objective sex and is confusing and incoherent. 

The CPS asserts that “questions of deception and consent may involve more complex issues where the suspect is trans or non-binary”. This is wrong in law and could lead to both over-prosecution and under-prosecution, as well as encouraging young people to believe that their asserted gender identity overrides their sex in relation to other people’s sexual consent and sexual orientation.

That the CPS is defending its guidance is perhaps not surprising when you realise how deeply embedded in CPS policies and guidance is the idea of keeping trans people’s sex a secret and forcing others to pretend they have changed sex. 

Twenty years ago the police and CPS were still willing to recognise the role of sexual fetish in cross-dressing and transgenderism. As guidance from the Association of Chief Police Officers said in 2005:

“Not every male or female that dresses as the opposite gender (transvestite) do so because they wish to permanently be defined in the opposite gender (e.g. transgender). Some do it as a fetish or for sexual gratification, some are simply driven by an unexplained urge to dress as a woman and are considered to be transvestites, but will have no desire to change their gender.”

The criminal justice system then embarked on a long process of forgetting, offence-taking, confusing itself with ever-changing terminology and ignoring the law.

An institution loses its way

In 2007 the CPS published its Policy for Prosecuting Cases of Homophobic and Transphobic Hate Crime. It defined “transphobic” as:

“A fear of or a dislike directed towards trans people, or a fear of or dislike directed towards their perceived lifestyle, culture or characteristics, whether or not any specific trans person has that lifestyle or characteristic. The dislike does not have to be so severe as hatred. It is enough that people do something or abstain from doing something because they do not like trans people.”

It defined a transphobic incident as: 

“Any incident which is perceived to be transphobic by the victim or by any other person.”

The CPS did not consider that women might rationally fear men who overstep boundaries, or that people might be free to “do something or abstain from doing something” because of a person’s sex, not because of a generalised dislike of trans people. 

In 2013 the McNally case established that deception as to sex could vitiate sexual consent. But the CPS was too busy taking directions from trans organisations to be clear about the law. 

In 2014 it published the CPS Transgender Equality Management Guidance which drew on advice from the civil service trans and intersex network “a:gender”, and the lobbying groups GIRES, Press for Change and Mermaids. 

This document wrongly said:

“Under this legislation [the Data Protection Act 1998], data relating to an individual’s gender reassignment (which includes a change of gender status and name) is classed as ‘sensitive information’, and therefore attracts a higher degree of protection than usual, especially when a Gender Recognition Certificate is held (see Gender Recognition Act below).”

This is the same mistake the EHRC has made in its new draft code for service providers this year.

In its Guidance on Prosecuting Cases of Homophobic and Transphobic Crime (which included guidance on cases with transgender suspects), the CPS said: 

“Whether the trans person is a victim, witness or defendant, the CPS’ policy is that the person will be addressed in terms that reflect his or her present gender status. So, a trans woman, although having a birth certificate that shows her to have been born a male, should be addressed and charged and/or indicted, if appropriate, as a woman.”

In July 2019 the CPS published a Trans Equality Statement, the aim of which it said was to “sustain the confidence of communities”. It boasted that: 

“The CPS has worked for a number of years with a wide range of Trans organisations nationally and locally.”

and stated that: 

“Prosecutors should address Trans victims, witnesses and defendants according to their affirmed gender and name, using that gender and related pronouns in all documentation and in the courtroom.”

The Trans Equality Statement says that “misgendering” is a potential basis for a transphobic hate crime. And the prosecution guidance on homophobic, biphobic and transphobic hate crime says that the police and CPS “have agreed to treat unauthorised breaches under s22 Gender Recognition Act 2004 as potential hate crimes if the alleged victim or any other person perceives them as such”. That means that simply referring to a trans person’s sex is viewed as a potential “hate crime” by the CPS and police. 

In 2020 the CPS produced an education pack for secondary schools, which promoted the idea that “wearing anti-LGBT+ badges or symbols” and “showing or distributing anti-LGBT+ leaflets, comics or other propaganda” could be hate crime. The pack had been developed with Stonewall and Gendered Intelligence.

One of the teaching exercises featured a video scenario where an adult male wearing women’s clothing goes into the women’s toilets. Two young women at the sinks whisper their discomfort: “What’s he doing in here? This is the Ladies.”

The class discussion guidance says: 

“Ask the students what happened in the clip. Thinking about how the girl in the clip was treated, can the class understand why she might have felt hesitant about going into the toilets?” [By “girl”, it means the adult man.] 

The worksheet for school children asks: 

“Can you say why the person went into the ladies’ toilets and not the mens’ toilets? How did the women behave towards her? How did that make her feel?”

The guidance was only withdrawn after a 14-year-old girl brought a legal claim.

In 2021 the CPS published guidance for prosecutors on same-sex sexual violence and sexual violence involving a trans complainant or suspect/defendant, in which it said that the idea that “trans women” are men who want to deceive straight men into having sex “is part of a wider transphobic myth that trans women are ‘dangerous’”.

It also says: 

“It is not uncommon for men who identify as heterosexual who engage in sexual activity with a trans woman to feel disgusted with themselves, and they may then react with violence towards the trans woman or to accuse her of rape. Gay men who have sex with trans men can also become violent and aggressive, and sexual violence can occur as a result.”

In 2022, when the CPS appointed Sophie Cook as its “speak out champion”, concerns were raised that he had a history of derogatory statements towards gender-critical women. 

In 2022 the CPS updated its legal guidance on domestic abuse. It gave “withholding money for transitioning” and “refusing to use their preferred name or pronoun” as examples of domestic abuse against transgender individuals. 

In 2024 these two statements were dropped in an update of the guidance, after the think-tank Policy Exchange pointed out that they do not constitute criminal offences. Instead the guidance now says that it might be a crime to refuse to use a family member’s preferred name “with the intention of causing emotional or psychological distress, particularly where the victim has obtained a recognised Gender Recognition Certificate”.

Of course a gender-recognition certificate does not direct how family members think and talk about a person.

Despite the documented instances of crimes with transgender perpetrators (including a disproportionate number of sexual offences), the experiences of “trans widows” and children of transitioners, which can include domestic abuse, and the fact that transgender perpetrators of homicide outnumber transgender victims, the CPS does not have any guidance that recognises clearly that “trans women” are men and “trans men” are women, and that transgender individuals may be perpetrators of crime.

There is increasing attention on non-contact deviant sexual behaviour as a risk factor for offending. But when recast as an expression of gender identity it may be overlooked or even celebrated, and those concerned by it cast as “transphobic”.

In 2022 Lionel Idan, CPS Hate Crimes Lead, told Pink News about gaining a sympathetic understanding of the behaviour of a man stealing women’s underwear:

“I remember one of my early experiences, it must have been 2006, I met with the chair of my local transgender advocacy group. She really made me think about the way we do things in a different light. She said, ‘Lionel, back when I was younger, I couldn’t walk into a shop and buy women’s lingerie. And so I used to have to steal items off of clotheslines’ … I said, ‘Of course, I’d have prosecuted you.’ And she said, ‘There you go. Now, you know the context. I had to steal, not because I’m a thief, but because I couldn’t buy what I needed for my identity.’ … That was one of the moments where I realised, in the job I do, that to better understand lived experience is absolutely crucial.”

The frightening experience of a woman whose underwear was stolen off the line did not seem to trouble Idan.

Sex by deception

Individuals who lie about their sex online or in person in order to encourage another into a sexual act are disregarding consent, whether their victims are male or female, gay, straight or bisexual.

That the CPS can’t or won’t see this from the victim’s point of view is the result of 20 years of training itself to forget what it once knew about sexual fetish and deviant behaviour, to view “gender identity” as equivalent to sex, and to view gender-critical (that is, truthful) speech as a hateful act.

The post The CPS: keeping sex secret appeared first on Sex Matters.

At the heart of the case is a straightforward question: can the CPS lawfully tell prosecutors that a person’s “gender identity” may be legally relevant when deciding whether deception invalidates consent to sex? Sex Matters says the answer is No.

The case will be heard on 8th and 9th July 2026 at the Royal Courts of Justice. We are represented by Sarah Vine KC and Chris Knight KC. 

How we got here

This hearing is the culmination of more than four years of engagement with the CPS about whether its guidance is an accurate statement of the criminal law. 

In May 2021 the CPS published guidance called “Deception as to Gender” as a section in its Rape and Sexual Offences Prosecution Guidance (under Chapter 10: consent). It sought to explain how prosecutors should apply section 74 of the Sexual Offences Act 2003 in cases where someone alleges that their consent to sexual activity was obtained through deception about a partner’s sex.

The CPS had been a member of the Stonewall Champions scheme and it updated the guidance following a “preconsultation with interested groups” that included the Government Equalities Office, LGBT charity Galop, Mermaids, Gendered Intelligence, LGBT Consortium, LGBT Foundation, Scottish Trans Alliance and Stonewall, along with organisations concerned with violence against women. 

The updated draft guidance it published in 2022 confused biological sex and gender identity and presented them as parallel concepts. The section entitled “Evidential considerations” advised that a suspect’s trans identity, if genuine, should be treated as evidence that a deception as to sex was not deliberate, and that trans suspects had no duty to disclose “gender history” (by which it meant their sex). 

Sex Matters and the Gay Men’s Network both raised concerns, arguing that the guidance did not accurately reflect the law. 

In December 2024, the CPS published a revised version, which was now called “Deception as to Sex”. Although some wording had changed, the central problem remained: prosecutors were repeatedly directed to consider “sex and/or gender identity” as though the two concepts were legally interchangeable. The guidance suggested that the suspect’s rights to privacy protected by Article 8 ECHR, the Equality Act 2010 or the Gender Recognition Act 2004 might trump the right of the complainant to understand what she or he is consenting to in an act of a sexual nature.

In February 2025, Sex Matters sent a formal pre-action letter explaining why we believed this guidance was unlawful.

The CPS asked for additional time to respond. Over the following months, we exchanged extensive correspondence. It accepted that some amendments were needed and proposed a number of changes to the guidance. But it refused to abandon its core position that “gender identity” could be relevant to the legal test for consent.

Following the Supreme Court’s judgment the CPS amended the guidance again, inserting the word “biological” before “sex” at numerous points. This didn’t help; while sex is by definition biological, adding that word in this way tends to suggest there is another relevant kind of sex that isn’t biological (or that “biological sex” and “gender identity” are two parallel characteristics).  The most recent version of the guidance was updated in June 2026.

What does the law say?

The Sexual Offences Act 2003 sets out the offences requiring the prosecution to prove absence of consent. They are rape, assault by penetration, sexual assault and causing a person to engage in sexual activity. In relation to these offences, a person (A) is guilty of an offence if she or he acts intentionally, and (B) does not consent to the act, and (A) does not reasonably believe that B consents.

English law recognises that some forms of deception can invalidate consent to sexual activity. But not every lie between sexual partners is a criminal offence.

The Court of Appeal has made clear that the deception must be “so closely connected to the performance of the sexual act” that it is capable of negating consent. That is the legal test established in R v Lawrence [2020]. Cases involving deception about fertility, HIV status or other wider circumstances have generally failed that test. Cases involving deception about the nature of the sexual act itself, such as secretly removing a condom or pretending a sexual act is a medical procedure, may satisfy it.

The key precedent on deception related to sex is R v McNally, in which the Court of Appeal held that deception about whether a person is male or female could invalidate consent. (Sarah Vine KC discussed the legal concepts with Michael Foran on his podcast in 2024).

Sex Matters argues that the CPS guidance is unlawful as it treats gender identity as though it were equivalent to sex. We say that a person’s gender identity (whether they identify as a transwoman, transman, masc, femme, non-binary, gender fluid or anything else) is not part of the performance of the sexual act and therefore cannot satisfy the Lawrence test. As the Supreme Court recognised in For Women Scotland: 

“People are not sexually oriented towards those in possession of a certificate.”

The CPS disagrees and says that the matter should be left to a jury in an appropriate case.

The hearing on 8th and 9th July 2026 will therefore focus on a fundamental point of principle: is gender identity legally relevant to deception under section 74 of the Sexual Offences Act 2003?

Why the guidance matters

Crown Prosecutors are expected to follow CPS guidance when making charging decisions. Police officers, defence lawyers and victim-support organisations also rely on it. Guidance issued by the Crown Prosecution Service should explain what the law is, not what groups such as Stonewall, Galop and Gendered Intelligence would like it to be. 

Muddled guidance could have real and damaging consequences: genuine offences may not be prosecuted or people may face prosecution on the basis of an incorrect understanding of the law.

The guidance is also likely to influence sex education and guidance produced by other organisations for young people, and for those who identify as transgender. Young people who are experimenting with sexual relationships for the first time and who may believe that “you are who you say you are” are particularly at risk of misunderstanding the importance of sex to the validity of consent, and of becoming either victims or perpetrators. 

Our case includes a witness statement from Dennis Kavanagh of the Gay Men’s Network, who says that deception as to sex is a growing issue for male homosexual victims: 

“The practice of trans identifying females concealing their sex, colloquially known as ‘stealthing’, is a known issue in homosexual male spaces.“ 

He points at the guidance issued by ClincQ, Cruising: a trans guy’s guide to the gay sex scene, which encourages this – “Some guys [trans-identifying women] might not tell their sex partners.”

Kavanagh points out in his witness statement that deception as to sex has been identified by some trans-supporting lobby groups and charities as a target for reform with the ultimate aim of removing the right of the victim to obtain information about the sex of their potential partner prior to sexual contact. For example, Stonewall’s publication A vision for change: Acceptance without exception for trans people included as a goal:

“Judicial clarity of ‘sex by deception’ cases to define the legal position on what constitutes sex by deception based on gender, and to ensure trans people’s privacy is protected.” 

The CPS itself, as the principal authority responsible for prosecutions, should be unequivocal, precise and clear as to the centrality of biological sex to sexual orientation and therefore to consent to sexual activity, just as the law itself is clear on this point. 

Sex Matters is asking the court to quash the guidance, or to remove those parts of it that misstate the law.

The post We’re taking the CPS to court over sex by deception appeared first on Sex Matters.

When the government unveiled its draft bill to criminalise so-called “conversion practices” on 25th June, ministers and officials said they had evidence of a serious problem.

For proof, equalities minister Olivia Bailey pointed to a newly published report by LGBT charity Galop. It was described as containing “hundreds of case studies” demonstrating widespread abuse taking place across Britain today. The Cabinet Office claimed to have evidence of tens of thousands of people being victimised. But dig into the numbers and the picture changes dramatically.

Following the evidence

Galop’s report Still not illegal: Evidence of modern-day conversion practices from Galop’s frontline services analyses case notes the charity collected between 2022 and 2025. It is presented as “some of the strongest evidence yet” that conversion practices are widespread. 

Researchers examined records from around 13,500 Galop clients over three years. From those they identified:

• 371 potential cases of conversion practice 
• 195 cases with sufficient detail for analysis
• just 132 recent cases
• only 29 cases that came through any of Galop’s helplines.

Only 51 clients approached Galop seeking help specifically because of alleged conversion practices. Most were already receiving support for issues such as domestic abuse, “honour”-based abuse, forced marriage, sexual violence, homelessness or asylum issues. That hardly suggests an epidemic requiring the creation of new criminal offences.

Meanwhile the Cabinet Office is citing a debunked Stonewall survey that claims tens of thousands of people are undergoing exorcism every year.

The Ban Conversion Therapy coalition of campaigning organisations has more members than the number of “case studies” of conversion therapy reported by Galop in Still not illegal.

The £360,000 helpline

The government presents the Galop report as if the charity is an independent observer. It fails to mention that Galop was paid £360,000 over three years to operate the government’s National Conversion Therapy Helpline.

When the service was commissioned, officials expected as many as 10,000–15,000 callers every year. Instead, the evidence presented in the report strongly suggests that only a handful of conversion-therapy reports were ever received.

Taxpayers deserve to know whether this spending represented value for money before ministers commit even more public funding.

What was reported to the helpline?

The cases in Galop’s report vary widely and are extremely short on detail. A few involve genuinely horrific crimes:

• rape
• sexual assault
• physical violence
• forced marriage
• kidnapping
• coercive control
• false imprisonment.

These are appalling, but they are already criminal offences. No new ban is required for them to be prosecuted.

Many other examples are far less serious, including interfamilial tension that is no doubt distressing but should not be criminalised. Some involve parents of the individuals in the case studies:

• insisting homosexuality is “just a phase”
• refusing to use preferred names or pronouns
• encouraging a child to marry
• praying for them
• taking them to church or a mosque
• arguing about sexuality or gender identity.

Others involve family estrangement, emotional pressure or religious disagreement. These situations may be painful, and in some circumstances may be abusive. But that does not mean entirely new criminal offences should be created.

There is not a single example of the historical practices involving electric shocks or aversion techniques that most people understand by “conversion therapy”. 

A solution looking for a problem

Galop joined the Ban Conversion Therapy coalition before the Government Equalities Office (GEO) opened bidding to run the national helpline with criteria that, in effect, required applicants to be already operating a similar service. It ended up being the sole bidder for a contract that seemed tailor-made for it. And now ministers are using research it produced, alongside research from Stonewall, to seek to justify both new criminal legislation and continued funding for the helpline that didn’t ring.

That creates at the least the appearance of circularity. Campaigners claim a serious problem exists. The GEO funds an organisation linked to that campaign to investigate it. The organisation writes a report supporting the campaign objectives. The government cites that report as independent evidence for new legislation and further funding. 

This is not robust evidence-based policymaking. 

Victims of domestic abuse, “honour”-based violence, forced marriage, assault and sexual violence deserve protection. But those protections already exist in law.

The question is not whether abuse should be punished. It is whether creating a new category of crime called “conversion practices” adds anything useful for victims or prosecutors, or simply creates a distraction from using existing safeguarding powers and domestic-abuse legislation to tackle real crimes with worryingly low conviction rates. 

The impact assessment for the proposed new law contains a calculation based on a Stonewall survey that came up with a widely debunked estimate of 10% of LGBT people having undergone exorcism to change their gender identity or sexual orientation. Based on this survey, the government estimates that around 80,000 people undergo conversion practices in the UK each year.

Parliament should now ask some simple questions:

• How many genuine cases of conversion therapy did the £360,000 helpline receive?
• How many resulted in police investigations?
• Which harms are not already covered by existing criminal law?
• Why does the government believe a new offence is necessary?
• Why is the government relying on a widely criticised Stonewall opinion survey as its main source of evidence?

Some fantastical estimates from Stonewall plus a few brief accounts of family conflict and religious disagreement along with a handful of more serious incidents that already fall under existing laws from Galop hardly constitute the strong case for new criminal legislation that ministers suggest. Evidence should drive policy, not the other way around. 

The post The £360,000 helpline that didn’t ring appeared first on Sex Matters.

While there are improvements on previous drafts of this law, it remains an attempt to shift “Stonewall Law” – now slowly being driven out of workplaces and services – into homes and classrooms.

It puts parents, therapists, teachers and partners at risk of being subjected to investigation if they do not affirm that someone is “male” or “female “ (or both, or neither) based on their personal declaration rather than their biology. 

Although it offers an exception for medical professionals as long as they do not “act in a way that falls far below the standards reasonably expected of a person in their position”, others are at risk of being subjected to investigation if they do not support a person’s transition. 

It also hands the power of private prosecution to organisations like the Good Law Project and Nancy Kelley’s Trans Solidarity Alliance.

What does the bill do? 

The bill defines “conversion practice” as any conduct with the intention of causing the individual to have or not have (or to believe that they have or do not have) a particular sexual orientation or transgender identity. The question of whether conduct amounts to an abuse is a question of fact “to be determined by reference to all the circumstances of the case”.

The government’s argument is that “abuse should never be legal”, but in practice this bill hands off the detail for determining what is or isn’t abuse to the courts. 

We fear that this open-ended and subjective definition will lead to parents, teachers, therapists, youth workers, pastoral leaders and others being investigated by the police and possibly submitted to the Crown Prosecution Service for assessment and prosecution, and also being vulnerable to private prosecution. 

The offence of carrying out an abusive conversion practice on an individual is defined in terms of causing “serious harm” to the individual’s physical or mental health, or “serious alarm or distress to the individual which has a substantial adverse effect on their usual day-to-day activities”. This could potentially mean a wife telling her husband to stop wearing her clothes, parents telling a child they will not pay for puberty blockers or cross-sex hormones, or a school insisting on referring to all children accurately as girls or boys, in line with its safeguarding responsibilities. 

Making Equality Act compliance a criminal offence? 

The crime may be tried as a summary offence at a magistrates’ court, which can hand down a 12-month prison sentence, or by the Crown Court, leading to imprisonment of up to five years. Corporate bodies such as companies can also be tried for “failing to take all reasonable steps to prevent the commission of the offence”.

This is likely to have a significant chilling effect on individuals expressing gender-critical beliefs and applying sex-based rules at work. 

A brief history: from historic abuses to strategic campaigning

Historically, what the public understands as conversion therapy refers to abhorrent, systemic attempts in the 1950s and 1960s to “cure” homosexual individuals using barbaric aversion techniques such as electric shocks or nausea-inducing drugs. These historic practices have long since died out – and are completely illegal under existing UK criminal laws.

When we reviewed 10 years of annual reports from major LGBT organisations up to 2019 we found that “conversion therapy” was barely mentioned as an active concern: it was widely seen as a historical relic. The sudden pivot occurred around 2020 following the loss of the debate over gender self-identification via the Gender Recognition Act. Lobby groups strategically co-opted the universal moral outrage against historic gay conversion methods and lifted the terminology wholesale to apply it to an entirely different phenomenon: “gender identity”. 

The evidence vacuum: pulling apart the numbers

Proponents of the ban routinely lean on three heavily compromised data sources to assert that there is an ongoing “epidemic” requiring a new criminal law. When subjected to scrutiny, the evidence is not there:

• 2017 National LGBT survey: this self-selected online survey is frequently cited because 2% of respondents claimed to have undergone conversion therapy. However, the survey bundled spiritual counselling and ordinary conversations into the same definition as serious criminal abuses like corrective rape. Crucially, the survey showed that reporting was higher among older age groups, confirming that traditional conversion efforts are a historic, rather than contemporary, UK issue.
• 2023 Galop report: This was based on a survey claiming that 43% of trans-identifying people had faced conversion practices. Yet the qualitative data in fact shows that 56% of those accounts described ordinary interpersonal family friction or peer disagreements (such as a friend telling a teenager they are transitioning “for attention”). While emotionally distressing, family arguments should not be the business of the criminal justice system.
• 2025 Stonewall/Opinium poll: This push poll claimed that 30% of trans-identifying people in the UK had been subjected to an exorcism in the past five years. It also featured a bizarre generational skew whereby the youngest respondents reported drastically higher rates of physical violence than the older generations who actually lived through the persecution of the 20th century. It represents a narrative capture that broadens the definition of “harm” so widely that it pathologises everyday parental guidance and clinical scepticism.

Today’s announcement came with another report from Galop which analysed the case notes of 195 detailed cases of GALOP clients. Most of these relate to family relationships which they identify as “emotional and psychological abuse” such as: 

“Dad makes frequent comments that ‘[Client] is not trans’ and that he is a woman. […] [Client] disclosed his parents want to take him to counselling to ‘convince him he is a female’.“

Like the previous Galop study, it includes a small number of crimes such as sexual assault alongside a much larger number of family disagreements. There is nothing in the study about what proportion of these cases were judged to be crimes by Galop, and what the outcomes were if they were reported to the police. 

What happens next?

Ministers have opted for the slow track: the draft bill will be sent for pre-legislative scrutiny by a joint committee. This gives parliamentarians, clinicians, parents and teachers a vital window to influence what happens next. 

The post Draft Conversion Practices Bill threatens parents with jail time appeared first on Sex Matters.

But the report had limitations, most seriously – as we said in our initial commentary – its failure to tackle the school-to-clinic pipeline and its endorsement of a trial of puberty blockers to provide the evidence base it recognised was lacking. The puberty-blocker trial was one recommendation of 32 in the report, and the only outright bad one. There was no detail on how such a trial might be designed; many experts thought it would never happen because ethical approval was simply not possible. 

And yet Baroness Cass has thrown her considerable prestige and authority behind plans, now far advanced, to carry out such a trial. Here is why we think she is wrong.

School-to-clinic pipeline

While Baroness Cass was carrying out her review, we raised the problem of the promotion of trans ideology and widespread acceptance of “social transition” in schools, meaning children were being treated as if they had changed sex in school rules and policies. Many parents say that it was in school that their child first picked up the idea that they might be trans, and it had become commonplace for schools to transition children behind their parents’ backs. The Cass Review acknowledged the role of social contagion in trans identification, and suggested that social transition might be unwise. But it showed no understanding of the pernicious way that doctors’ recommendations of social transition had been converted into a “doctor’s orders” edict to schools, which then extended to children being supported to socially transition in school without any doctor’s involvement. 

The review also failed to grapple with the fact that what an individual child wants is not a matter for them alone. Even if, hypothetically, puberty blockers and social transition are “right” for a particular child, this cannot be accommodated in schools without unacceptably infringing on the rights of other children. This means social transition supported by puberty blockers and the promise of cross-sex hormones cannot ethically be offered to a child as a viable and coherent package.

Schools exist to educate children while keeping them safe, not to provide complex and risky psychosocial treatments. A gender-confused child’s classmates are not there to validate the child’s professed identity by accepting the falsehood that he or she has changed sex. Doctors have no right to propose to their patients that this should happen, even if that is what those patients want.

The missing evidence base

As originally envisaged, the review was supposed to include evidence gleaned from following up the children who had previously been prescribed puberty blockers by the NHS, thought to be around 2,000 of those seen at the Tavistock. This “data-linkage study” would not have been definitive on outcomes because the control group (children seen but not treated) would not be statistically comparable with those who received the drugs. But it would have provided excellent data on safety, revealed whether the children were still distressed, probably provided useful information on desistance and detransition, and in general been the most meaningful data on outcomes from medicalising gender distress beyond a year or two anywhere in the world.

But the adult gender clinics refused to cooperate with the Cass review, and refused to hand over their data. In the end the review was published without that information. The data-linkage study is still nowhere to be seen. And yet in December 2024 the secretary of state for health, Wes Streeting, announced that NHS England was commissioning a new trial of puberty blockers. And in November 2025 news broke that the trial had received ethical approval. 

If the data-linkage study had concluded by now, it would have established the existence or otherwise of some of the most immediate harms thought to be caused by puberty blockers, in particular whether they raise the risks of early-onset osteoporosis, which is so rare among people in their teens or 20s that even a couple of cases would send a strong signal about treatment safety. It would also help establish whether puberty blockers are helpful in reducing suicides, which are also, thankfully, extremely rare at that age. By now we would have data on chronic and acute health problems, emergency admissions, diagnoses, prescriptions and eligibility for incapacity benefit for adults who had received puberty blockers as children, which would give a clear picture of whether or not they are thriving. 

In short, we would know a lot more about whether the treatment pathway that starts with puberty blockers and almost always continues to cross-sex hormones creates serious risks to physical health, and whether those who travel this path are unusually unhealthy in early adulthood. If the answer to either of these questions was Yes, any further use of these drugs would be indefensible.

Baroness Cass has repeatedly criticised the adult gender clinics for refusing to cooperate. She knows that puberty blockers are not a standalone treatment: her report said so. She knows they hugely increase the risk of future, irreversible medical intervention – that they do not, in the words chosen by journalist Hannah Barnes for the title of her whistleblowing book about the Tavistock, offer children “time to think”. Before the advent of puberty blockers most gender confusion resolved in childhood; afterwards, most persisted. Puberty blockers are an almost inevitable precursor to giving oestrogen to boys and testosterone to girls. Any fair assessment of their benefits, risks and harms therefore has to include those of cross-sex hormones. She also knows that the previous trial at the Tavistock clinic opened the door for routine prescribing before its results were published, and that those results belatedly showed no benefit for children’s mental health. 

The planned trial will compare answers to a questionnaire about wellbeing between children who receive puberty blockers at the start of the trial, and children who are required to wait a year. That can provide no useful information about medium- or long-term risks. It is likely to create an artificial difference between the trial’s two groups, since participants may well believe false claims by the trans lobby that puberty blockers are “life-saving”. Those who receive the treatment straight away are likely to be elated; those forced to wait devastated.

Recently, Baroness Cass has defended the trial as a harm-reduction measure. Children denied puberty blockers on the NHS, she says, may turn instead to online providers who do not monitor their wellbeing and may be selling less safe alternatives. But the trial has not been designed to test harm reduction. And no data is being collected to find out whether or not overall harm is in fact being reduced.

Despite all this, instead of putting her considerable authority and prestige behind the push for the data-linkage study, which would give useful information without exposing any more children to a treatment regarded as so risky that neither the NHS nor private health providers can lawfully prescribe it, Baroness Cass instead supports a new trial. That the new trial is so poorly designed that it cannot possibly provide a meaningful contribution to the evidence base her review said was lacking makes this even more inexplicable. 

Reckoning with the Supreme Court

In April 2025, a few months after plans for the new trial were announced, the Supreme Court ruled in the case of For Women Scotland (FWS) that in the Equality Act, sex means sex. Two weeks after that judgment was handed down, Sex Matters, together with LGB Alliance, Transgender Trend and Genspect, wrote to Sir James Mackey, then the chief executive of NHS England, and the health secretary. 

In that letter we spelled out the implications of the ruling for the care of gender-distressed children:

“Children under the care of all gender services, both NHS and private, must now be told that they will never be able to access spaces or services for the opposite sex, no matter what legal or medical steps they take now or in the future. Such children will, throughout their lives, need to use either the spaces and services designated for their own sex or an alternative provided for both sexes (mixed-sex or single-user) if available.

…

“We have always argued that it was unethical and a breach of human-rights principles to treat young people’s mental distress with major, unproven physical interventions with known harms (including to their adult sexual function and fertility), and to promise them that they could intrude on other people’s privacy, safety and dignity as well as put their own safeguarding at risk by using spaces for the opposite sex. 

“Now that the Supreme Court has ruled out the use of opposite-sex spaces, no promise can be made that medical treatment will enable a person to fit in or go unnoticed while using opposite-sex facilities. The use of these drugs on children too young to understand this is ethically untenable.”

This year Keeping children safe in education, statutory safeguarding guidance for schools, has been updated to take account of the judgment. Schools have been expressly warned that by law they must record every child’s sex accurately, and must not ever allow any child to use toilets (or changing-rooms where they exist) for the other sex. Even if a school considers using preferred pronouns for trans-identifying children, or allowing them to wear the opposite sex’s uniform (we think both these policies are indefensible on safeguarding grounds), it is now beyond doubt that schools cannot lawfully pretend any child is the opposite sex.

As we also said in that letter, this undercuts the entire rationale for treatment with puberty blockers:

“The drugs are intended to block gender-distressed children’s natural puberty so that if they persist in cross-sex identification and progress to cross-sex hormones and perhaps surgery, they will “pass” better as the opposite sex. But passing as the opposite sex ceases to be a desirable goal to present to children when they will never be permitted to use spaces or services for the opposite sex, and may in future be restricted in employment in roles such as police officer or nurse which can involve intimate contact with others in situations where sex matters for those others’ human rights. Instead it becomes a major, permanent social problem for those young people, since their future lives and freedoms will be seriously curtailed by being legally barred from using the other sex’s spaces while appearing anomalous in those for their own sex.”

Not only are puberty blockers a treatment based on a false premise, but they cannot ethically be offered to any child. Quite apart from the health risks, no child (or parent on their behalf) can consent to destroying their future ability to live normally in society as an adult. 

As we wrote when news broke last year that the trial had received ethical approval:

“The Department of Health, NHS England, the National Institute for Health and Care Research and the Research Ethics Committee which approved this study have allowed it to go ahead by ignoring the conflict with the Equality Act and feeding the unrealistic hopes of children who are not old enough to understand or consider these constraints on their desires.

“Recruiting children into a study that is based on a mis-selling of rights and which forecloses their chances for adult sexual function and fertility is unconscionable.”

That a clinician and parliamentarian of Baroness Cass’s stature continues to press for this trial risks undermining all the good work she has done.

The post Baroness Cass is wrong about the puberty-blocker trial appeared first on Sex Matters.