A 90-day public consultation opened on 9 March 2026 with a proposal that could permanently reshape gender-affirming care for trans young people in England. NHS England has published a draft Clinical Commissioning Policy Proposition that would remove access to masculinising and feminising hormones for every new patient under 18 seeking care through the NHS Children and Young People’s Gender Service. If adopted, this policy would leave trans young people in England with no medical pathway to physical transition until they reach adulthood. I have read the full policy document carefully, and in this review I want to walk you through what it actually says, where the evidence really stands, and what you can do before the consultation closes on 7 June 2026.

🔴 Complete removal of access to new hormone prescriptions for all under-18s, with no clinical pathway offered as an alternative.

🔴 Evidence reviews used a PICO framework so narrow that most of the international research base was excluded before quality assessment began.

🔴 Policy is underpinned by the post-Cass 2024 restrictions; the Cass Review is methodologically discredited and not accepted by international clinical bodies.

🔴 No acknowledgement of the substantial evidence that withholding gender-affirming care causes psychological harm to trans young people.

🔴 No fixed policy review date; revision depends only on NHS England receiving information that indicates a review is needed.

🔴 Existing patients aged 16 and 17 must engage in a formal discussion framed around ‘limited evidence’ and ‘potential adverse outcomes’ as a condition of continuing their current treatment.

🟠 Young people aged 16 and 17 already on treatment can continue, but the continuation process is conditional and the language used may be distressing.

🟠 The 90-day consultation allows for public response, though how responses will be weighted against conclusions already reached by the policy working group is not explained.

🟠 Psychosocial support is noted as the primary approach for young people in the service, but no detail is given about what is available or current waiting times.

🟢 A public consultation exists, providing a formal opportunity for trans young people, families, clinicians, and advocates to submit evidence and views.

🟢 Young people currently on NHS treatment are not immediately removed from their prescriptions.

🟢 The policy uses the current ICD-11 classification, which places gender incongruence under conditions related to sexual health, not mental disorders.

Key: 🔴 Restrictive 🟠 Limited or conditional 🟢 Supportive

What This Policy Actually Proposes

NHS England’s draft proposition states clearly that feminising and masculinising (MAF) hormones are not recommended as a routine commissioning treatment option for children and young people under 18. The policy would supersede the current arrangements, which were themselves only introduced in 2024 in immediate response to the Cass Review, and which already restrict hormone prescribing to those aged 16 and 17 with persistent gender dysphoria, requiring national Multi-Disciplinary Team (MDT) endorsement for every single referral.

This new proposal goes considerably further. It would close access entirely to new prescriptions, regardless of a young person’s clinical presentation, the views of their treating clinician, or any individual assessment of their needs. The phrase used in the commissioning position is worth reading carefully: ‘Feminising and masculinising medicines are not available as a routine commissioning treatment option for treatment of children and young people under 18 years who have gender incongruence.’

There is a transition arrangement for young people who are already receiving treatment. Those aged 16 and 17 who have an existing NHS prescription may continue, but only if their lead clinician, the young person themselves, and their parent or guardian all agree in writing that continuation is in their best interests. This written agreement must follow a formal discussion about what the policy describes as the limited evidence about safety, benefits and risks, and a discussion about potential adverse outcomes. The framing of that requirement matters, and I will return to it.

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How the Evidence Was Reviewed

The policy rests on two independent evidence reviews, commissioned by NHS England and conducted by Solutions for Public Health in 2026. Both reviews used a PICO framework, which stands for Population, Intervention, Comparator, and Outcomes. This is a standard methodological tool in evidence-based medicine, and it is a reasonable approach when the criteria are set appropriately.

The concern here is that the PICO criteria were drawn very narrowly. Looking at the volume of papers excluded at the title and abstract screening stage alone gives a sense of how much of the international evidence base was set aside before any quality assessment took place. The reviews categorised the evidence across ten subcategories covering different combinations of medication, gender identity, and transition goal. In eight of those ten categories, the conclusion was that no evidence was returned within the PICO criteria. In the remaining two categories, covering oestrogen or testosterone for binary transition in adolescents, the conclusion was weak evidence of benefit.

It is important to be precise about what that means. An absence of evidence within a narrow methodological framework is not the same as evidence that the treatment is ineffective or unsafe. The global clinical consensus from the World Professional Association for Transgender Health (WPATH), the Endocrine Society, the American Academy of Pediatrics, and numerous other professional bodies continues to support gender-affirming hormones for adolescents as clinically appropriate care, based on decades of research and clinical experience. The evidence exists. The question is whether the framework used in these reviews was designed to find it.

The policy also cites the Cass Review, published in 2024, as the basis for the immediate interim restrictions that preceded this proposal. The Cass Review has been the subject of sustained and serious international scrutiny. A systematic re-analysis of its methodology and conclusions identified significant concerns about how the evidence was interpreted and which research was included. International clinical organisations have formally declined to adopt its recommendations. The Cass Review cannot be treated as a reliable or neutral foundation for a policy of this significance, and this review reflects that position clearly.

The Traffic Light Assessment in Detail

The table above provides an at-a-glance overview. Here is more detail on each area.

Under the red category, the most fundamental concern is that the policy removes access to treatment for all new patients under 18, without offering any alternative clinical pathway. A trans young person presenting to the NHS gender service who would previously have been considered for hormones now has no route to that care within the NHS. There is no individualised assessment process that could lead to a different outcome, no bridging arrangement, and no indication of when or whether that might change.

The evidence review methodology is a further serious concern. The PICO criteria were specific to the point of exclusivity, and the resulting evidence base does not reflect the full body of international research. The Taylor et al (2024) systematic review, which is cited in the policy’s own references, identified evidence of benefit in adolescents undergoing binary transition with oestrogen or testosterone. That finding is technically acknowledged in Category B of the evidence summary, but the overall policy conclusion does not reflect its significance.

The requirement for existing patients to engage in a formal discussion framed around limited evidence and potential adverse outcomes before they can continue their current prescription is also a red-category concern. These young people are already in clinical care. They and their families have made informed decisions with their treating clinicians. Imposing this requirement as a condition of continuation risks causing real psychological harm and may undermine the therapeutic relationship.

Under the amber category, the continuation arrangement for existing patients is a partial protection, but it comes with conditions that may not be easy to navigate. The 90-day consultation is a meaningful mechanism, but the fact that a policy working group has already reached its conclusions and that the policy has been published in draft form means the bar for reversal is high, and the process for weighing public responses against prior work is not explained.

The green category reflects some genuinely positive elements. The consultation exists, and that matters greatly. Existing patients are protected from immediate removal of their treatment. The policy’s use of the ICD-11 classification, which correctly categorises gender incongruence as a condition of sexual health rather than a mental disorder, is a small but important acknowledgement.

What Concerns Me Most

Reading this policy carefully, the thing that concerns me most is not what it says but what it does not say. There is a substantial and growing body of evidence on what happens to trans young people when access to gender-affirming care is delayed or denied. The research on mental health outcomes, including depression, anxiety, self-harm, and suicide risk, is not ambiguous. That evidence is not referenced anywhere in this policy document. The Equality and Health Inequalities Impact Assessment, published alongside the policy for consultation, needs to address this directly and in detail. I would urge everyone responding to the consultation to raise this as a priority.

I am also concerned about the young people who fall between the current policy and this new proposal: the 16 or 17-year-old who presents to the gender service now, who is not yet on treatment, who has been working towards a referral for hormones, and who will simply lose that possibility. They may seek private care if their family can afford it. They may access hormones through online sources without clinical oversight. This policy does not protect those young people. It removes their protection.

The absence of a fixed review date is troubling too. The policy states that it will be reviewed when information is received which indicates that the policy requires revision. That is not a commitment to review. It is a condition that may never be met if the standard of evidence required to trigger a review is set at the same level as the standard used to justify the original decision.

How to Respond to the Consultation

NHS England is asking three specific questions in this consultation, and each one offers a genuine opportunity to put important evidence on the record.

The first question asks whether all of the relevant evidence has been taken into account. This is where you can raise the limitations of the PICO framework, the exclusion of international research, the evidence from WPATH, the Endocrine Society, and others, and the findings of studies excluded at the screening stage.

The second question asks whether the Equality and Health Inequalities Impact Assessment reflects the potential impact of the proposed changes. This is where the evidence on psychological harm, suicide risk, and documented outcomes of care denial needs to be raised clearly and directly.

The third question asks whether there are any other issues NHS England should consider. This is open ground. You can speak to individual experience, to clinical practice, and to the situation of young people who will lose access with no alternative pathway.

The consultation closes on 7 June 2026. Please respond if you can, and please share this article with everyone who cares about the health and wellbeing of trans young people. Every response matters, and every voice needs to be heard.

Respond to the consultation here: NHS England MAF Hormones Consultation

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If this policy review has been helpful, please share it with anyone who needs to see it. Every response to this consultation matters, and every person who shares this article helps to ensure that the voices of trans young people and their families are heard by those making this decision.

Dr Helen Webberley | Gender Specialist and Medical Educator

www.helenwebberley.com

Please feel free to share your thoughts in the comments or as a Note, Article or Restack, or keep the conversation going on other platforms.

Resources and Links

• Dr Webberley Responds: Why the Cass Review Still Matters, And Why We Must Look Again

• Respond to the NHS England consultation (closes 7 June 2026)

• NHS England Public Consultation Guide

• Draft Policy Proposition (PDF)

• Draft Equality and Health Inequalities Impact Assessment (PDF)

• Evidence Reviews

• Consultation overview page

Type: UK Statutory Instrument (No. 1319)

Applies to: England, Wales, Scotland and Northern Ireland

Made: 11th December 2024

In force: 1st January 2025

Review due: By 1st October 2027

Link: legislation.gov.uk

At a glance

🔴 Under-18s, new patients: Cannot access puberty blockers privately for gender dysphoria or gender incongruence

🟠 Under-18s, existing patients: Can continue if they started treatment before June 2024 (August 2024 in Northern Ireland)

🟢 Adults (18+): Can still access puberty blockers privately for any purpose

🟢 NHS prescriptions: Unaffected by this Order (but NHS England has separately stopped prescribing)

🟢 Other uses: Under-18s can still access puberty blockers privately for conditions other than gender dysphoria

🔴 Overseas prescribers: Cannot prescribe for under-18s even for non-gender purposes

Key: 🟢 Permitted 🟠 Limited or conditional 🔴 Prohibited or restricted

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Summary

This Order makes it illegal to sell or supply puberty blockers (GnRH analogues) to under-18s when prescribed privately for the purpose of treating gender dysphoria or gender incongruence, unless the young person was already receiving treatment before the ban came into effect. Adults are unaffected. NHS prescriptions are technically unaffected by this Order, though NHS England has separately stopped prescribing puberty blockers for gender dysphoria. The Order applies UK-wide and must be reviewed by October 2027.

This is the permanent version of emergency legislation first introduced in May 2024. It effectively closes the private healthcare route that families had been using while NHS waiting lists stretched to years.

The detail

What does the Order prohibit?

What the legislation says: “The sale or supply of a GnRH analogue is prohibited” (Article 4), subject to specific exceptions.

GnRH analogues covered include buserelin, gonadorelin, goserelin, leuprorelin acetate, nafarelin and triptorelin.

What this means: The default position is that these medicines cannot be sold or supplied at all. Everything else in the Order is about carving out exceptions to this blanket ban.

Can adults still access puberty blockers?

What the legislation says: The prohibition does not apply to private prescriptions where “on the day the prescription was issued, the patient in respect of whom it was issued was aged 18 or over” (Article 6).

What this means: Yes. If you are 18 or over, you can still access puberty blockers through private prescription for any purpose, including gender-affirming care. There are some administrative requirements around age verification, but no substantive restrictions.

Can under-18s access puberty blockers for non-gender purposes?

What the legislation says: The prohibition does not apply where “the purpose for which the private prescription was issued is a purpose other than treatment for the purpose of puberty suppression in respect of gender dysphoria, gender incongruence or a combination of both” (Article 7).

What this means: Yes, but only from UK-registered prescribers. Under-18s can still be prescribed puberty blockers privately for other conditions, such as precocious puberty or certain cancers. The prescriber must be a UK-registered practitioner.

Can under-18s access puberty blockers for gender dysphoria?

What the legislation says: For under-18s where the purpose is “treatment for the purpose of puberty suppression in respect of gender dysphoria, gender incongruence or a combination of both”, the prohibition applies unless the young person “started a course of treatment with a GnRH analogue” before June 2024 (Article 8).

What this means: No, unless they were already on treatment. New patients under 18 cannot access puberty blockers privately for gender dysphoria, regardless of parental consent, clinical need, or any other factor.

What counts as having “started treatment”?

What the legislation says: “A person is treated as having started a course of treatment with a GnRH analogue if... that person was issued with a NHS prescription or a private prescription for a GnRH analogue, whether or not the prescription has been dispensed or the prescribed GnRH analogue has been taken by that person” (Article 8(6)).

The relevant dates are: before 3rd June 2024 (England, Wales and Scotland) or before 27th August 2024 (Northern Ireland).

What this means: If a young person had a prescription issued before the relevant date, they can continue, even if they had not yet started taking the medication. Having a prescription is enough; they do not need to have actually commenced treatment.

Can overseas doctors prescribe for UK patients?

What the legislation says: For under-18s, the prescription must be issued by an “approved UK prescriber”, defined as someone who is “an appropriate practitioner in relation to any prescription only medicine by virtue of regulation 214(3)(a), (c), (d) or (e) of the 2012 Regulations” (Article 2).

What this means: No. For patients under 18, only UK-registered prescribers can issue valid prescriptions. This applies even when the purpose is not gender-related. Prescriptions from doctors registered outside the UK cannot be dispensed for under-18s.

What about NHS prescriptions?

What the legislation says: “Article 4 does not apply to a sale or supply in pursuance of a NHS prescription” (Article 5).

What this means: This Order does not restrict NHS prescribing. However, NHS England has separately stopped prescribing puberty blockers for gender dysphoria in under-18s, except as part of a research trial. So while the legal route exists, the practical route is closed.

What about clinical trials?

What the legislation says: Supply “does not include supply for the purposes of a clinical trial that has been authorised by the licensing authority” (Article 3).

What this means: Puberty blockers can still be supplied as part of authorised clinical trials. This is the route NHS England has indicated it will use going forward.

When will this be reviewed?

What the legislation says: The Ministers must “carry out a review” and “publish a report setting out the conclusions of the first review” before 1st October 2027 (Article 9).

The review must “assess the extent to which those objectives are achieved” and “assess whether those objectives remain appropriate.”

What this means: The Order must be formally reviewed within roughly two and a half years. After that, reviews must occur at least every four years. Whether this leads to any change will depend on the political context at the time.

What’s missing from this legislation

Evidence base: The Order was made because it “appear[ed] to them to be necessary... in the interests of safety”, but the evidence base for this conclusion remains contested. The Cass Review, which informed this decision, has been criticised by international medical bodies and its methodology questioned.

Consideration of harms from denial of treatment: The Order focuses on potential harms from treatment but does not address potential harms from denying treatment, including impacts on mental health, educational outcomes, and the effects of undergoing unwanted puberty.

Proportionality: The Order applies a blanket ban rather than allowing individual clinical assessment. There is no exception for young people with clear clinical need, supportive families, and access to appropriate clinical oversight.

International context: While the UK has moved to restrict access, other countries including the United States (in most states), Spain, and several other European nations continue to provide puberty blockers as part of evidence-based care.

Overall assessment

This legislation effectively ends private access to puberty blockers for new patients under 18 seeking treatment for gender dysphoria. Combined with NHS England’s separate decision to stop prescribing outside research settings, it closes both main routes to treatment for trans young people in the UK.

The grandfather clause for existing patients provides some continuity, but creates a two-tier system where access depends on when you happened to present, not clinical need. Young people who have not yet started treatment, including those on years-long waiting lists, are now locked out entirely.

For families seeking to support their trans children, the options have narrowed dramatically. The only remaining legal routes are: NHS clinical trials (extremely limited places), waiting until the young person turns 18, or seeking treatment abroad (which this Order does not prevent, though it prevents UK pharmacies dispensing the resulting prescriptions).

The review due by October 2027 offers a potential opportunity for change, but this will depend entirely on the political and clinical landscape at that time.

Questions this raises

If you are affected by this legislation, consider:

1. Was the young person prescribed puberty blockers before June 2024? If so, they can continue.

2. Is the young person now 18 or over? If so, they can access treatment privately.

3. Is there a clinical trial accepting participants? Places are extremely limited.

4. Is treatment abroad an option? The legislation does not prevent this, though UK pharmacies cannot dispense the prescription.

5. What support is available while waiting? Mental health support, social transition support, and family support may help in the interim.

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Policy Review

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Further Reading

Browse all policy reviews - https://www.helenwebberley.com/s/policy-review

Type: GP practice Location: Cumbria, England

Policy reviewed: Gender Dysphoria Policy (Clinical Guidance Document)

Policy date: Current (references 2013 NHS England guidance; mentions 2021 review)

Status: Current

Link: HAVERTHWAITE SURGERY: Clinical Guidance Document - Gender Dysphoria Policy

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At a glance

🟢 Name and title: Staff must use patient’s preferred name and title at all times

🟢 Pronouns: Staff should ask and use correct pronouns

🟢 Medical records: Can be changed without GRC or updated birth certificate

🟢 Referrals: Direct to Gender Identity Clinic; no mental health assessment or CCG approval required

🟢 Confidentiality: Strong protections; references GMC guidance and GRA Section 22

🟢 Screening: Thoughtful approach based on organs present, with safeguards against falling out of recall systems

🟠 Non-binary inclusion: Not explicitly addressed

🟠 Language: Some dated terminology

Key: 🟢 Supportive 🟠 Limited or conditional 🟡 Restrictive or denied

Summary

This is a practical, largely supportive policy focused on ensuring trans patients receive appropriate care. The policy is operationally detailed, covering everything from how to process a gender marker change to ensuring patients don’t fall out of screening programmes. It explicitly requires all staff to use patients’ preferred names, titles and pronouns. Referrals to Gender Identity Clinics can be made directly without requiring a mental health assessment or CCG approval first. The policy’s strength lies in its administrative thoroughness, though it could be strengthened with explicit recognition of non-binary patients.

The detail

Names and pronouns

Will my name and pronouns be respected?

What the policy says: “It is imperative that patients who are transitioning or have transitioned are addressed in the correct manner. All staff at Haverthwaite Surgery are to use the patient’s preferred name and title at all times.”

On pronouns: “Where doubt exists, staff should ask the patient ‘How do you prefer to be addressed?’ and, if necessary, ‘What pronoun do you use?’”

What this means: Yes. The policy is clear that staff must use your preferred name and title, and should proactively ask about pronouns if unsure. This is framed as imperative, not optional.

Medical records

Can I change the gender marker on my medical records?

What the policy says: “A patient’s request to change the sex that is indicated on their medical records will be accepted. The patient does not need to have been issued with a Gender Recognition Certificate or have an updated birth certificate for their records to be amended.”

“Trans patients have a legal right to change their name and gender on their healthcare records. Patients may request to change gender on their patient record at any time and do not need to have undergone any form of gender reassignment treatment to support this request.”

What this means: Yes, without barriers. You don’t need a GRC, updated birth certificate, or any medical treatment to change your records. The policy correctly recognises this as a legal right.

Referrals

Can I be referred to a Gender Identity Clinic?

What the policy says: “All GPs in England can refer those patients who request treatment for gender dysphoria directly to a GIC. There is no requirement for a GP to first refer the patient for a mental health assessment, nor do GPs need to request prior approval from their Clinical Commissioning Group (CCG).”

What this means: Referrals should be straightforward. The policy explicitly states that no prior mental health assessment is needed and no CCG approval is required. This reflects correct understanding of the pathway.

Confidentiality

Is my trans status kept confidential?

What the policy says: The policy quotes GMC guidance: “It is unlawful to disclose a patient’s gender history without their consent. When communicating with other health professionals, gender history need not be revealed unless it is directly relevant to the condition or its likely treatment.”

It references Section 22 of the Gender Recognition Act 2004 and notes that when records are changed, “any information relating to the patient’s previous identity should not be included in the new record.”

What this means: Strong protections. The policy recognises both GMC guidance and legal requirements around confidentiality. When you change your records, your previous identity should not carry forward into your new record.

Screening

Will I still receive appropriate health screening?

What the policy says: “It is considered reasonable and pertinent to screen for the organs present, not the gender.”

The policy provides detailed guidance on ensuring trans patients don’t fall out of automated screening systems when their NHS number changes, including: explaining which screening may be affected, working with patients to ensure screening happens, placing reminders on records, and advising patients to keep track of when screening is due.

What this means: The approach is medically sensible and patient-centred. The policy recognises the real risk that changing gender markers could cause patients to miss important screening, and sets out a clear process to prevent this.

Administrative process

What happens when I request a gender marker change?

What the policy says: The policy sets out a detailed process: the patient provides a statutory declaration, the practice notifies PCSE, a new NHS number is issued, and a new medical record is created with all previous medical information transferred but without information relating to previous identity.

The policy notes this should be completed within five working days to ensure no interruption to care.

What this means: The process is well-documented and includes safeguards for continuity of care. The five-day target shows commitment to not leaving patients in limbo.

What’s missing

Non-binary inclusion: The policy doesn’t explicitly address non-binary patients. The administrative guidance notes that only “M” or “F” should be selected as sex category, not “I” (indeterminate). While this reflects current NHS systems limitations, the policy could acknowledge non-binary identities and explain how patients who don’t identify as male or female will be supported.

Patient-led language: While practically supportive, the policy is written from a clinical rather than patient perspective. Terms like “gender dysphoria” and “transsexual” appear throughout. The definition of “transsexual” as someone who “feels that they belong to the opposite sex” is dated.

Psychiatric framing: The policy notes that “some patients may have psychiatric comorbidities” and may require “formal psychiatric intervention.” While acknowledging mental health needs is reasonable, the framing could inadvertently pathologise trans patients.

What’s notable about this policy

• Explicit requirement to use preferred name, title and pronouns

• Clear statement that no GRC, birth certificate, or medical treatment is required to change records

• Direct referral pathway to GICs without gatekeeping

• Strong confidentiality protections referencing both GMC guidance and the GRA

• Detailed, practical screening guidance that prioritises continuity of care

• References to RCGP guidelines and intercollegiate good practice guidelines

• Named data controller for confidentiality queries

Overall assessment

This is a solid operational policy that should result in respectful, appropriate care for most trans patients. Its strength is in the practical detail: it tells staff exactly what to do, references the correct guidance, and has clear processes for common situations. The explicit requirement to use preferred names, titles and pronouns is welcome, as is the clear statement that no GRC or medical treatment is needed to change records.

The policy could be improved by explicitly recognising non-binary patients, updating some dated language, and framing the content more from a patient perspective. But in terms of what it commits to do, this policy should work well in practice.

For trans patients registered at this practice, or considering registering: this policy suggests you should be treated with respect and have your administrative needs handled appropriately. The screening guidance in particular shows thoughtful consideration of how to ensure trans patients don’t fall through gaps in the system.

Questions to ask any GP practice

Based on this policy, here’s what to look for elsewhere:

1. Will they use my preferred name, title and pronouns?

2. Do I need a GRC or medical treatment to change my records?

3. Will they refer me directly to a GIC without requiring a mental health assessment first?

4. How do they ensure I won’t fall out of screening programmes?

5. Who is responsible for handling confidentiality queries?

6. Is non-binary identity explicitly recognised?

Have a policy you’d like reviewed?

If your GP practice, hospital, or healthcare provider has a trans patient policy you’d like me to review, send it to me.

Browse all policy reviews

Most GP surgeries and healthcare providers don’t have a specific policy on trans patients. Those that do vary enormously in quality. Some are genuinely supportive. Others pay lip service to inclusion while creating unnecessary barriers. Many fall somewhere in between, leaving individual staff to make it up as they go along.

This checklist is designed to help you understand what your healthcare provider’s approach actually means for you. These are the questions that matter, and the answers you should look for.

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Names and pronouns

Will staff use my affirmed name?

Look for clear statements that your preferred name will be used in all interactions: at reception, during appointments, on appointment letters, and when calling you from the waiting room. Ask whether this happens automatically or whether you need to make a special request each time.

Will my correct pronouns be used?

Look for explicit commitments that staff will use your correct pronouns. Ask whether there’s guidance for staff on how to ask patients about pronouns, and what happens if a member of staff repeatedly misgenders you.

What if I haven’t legally changed my name?

You have the right to be known by your chosen name regardless of whether you’ve changed it by deed poll or statutory declaration. Ask whether your affirmed name can be used in day-to-day interactions even if your legal name remains on official records.

Medical records

Can I change the name on my medical records?

You have a legal right to change your name on healthcare records. Ask what documentation is required. Some providers accept a simple written request; others ask for a statutory declaration. A provider should not require a Gender Recognition Certificate or proof of medical treatment.

Can I change the gender marker on my records?

This should be possible without a GRC or any medical treatment. Ask what the process is and how long it takes. Be aware that changing your gender marker triggers a new NHS number, which has implications for continuity of care.

What happens to my old records?

When you change gender marker, your medical history needs to be transferred to a new record. Ask how this is handled, whether any information will be lost, and whether your previous identity will be visible to staff who don’t need to know.

Who can see my trans status on my records?

Ask what flags or alerts are placed on your record and who can see them. Your trans status should only be visible to clinicians where it’s directly relevant to your care.

Confidentiality

Is my trans status kept confidential?

The GMC is clear: disclosing a patient’s gender history without consent is unlawful. Ask how the provider ensures confidentiality, and what happens if a breach occurs.

Who is told if I’m trans?

Ask under what circumstances your trans status would be shared with other healthcare professionals, and whether you would be consulted first. It should only be disclosed where directly relevant to your care.

What about referral letters and external communications?

Ask whether your trans status is routinely included in referral letters or communications with other services. It often isn’t relevant and shouldn’t be disclosed automatically.

Referrals and treatment

Can my GP refer me to a Gender Identity Clinic?

GPs in England can refer directly to a GIC without prior mental health assessment and without CCG approval. Ask whether your GP understands this pathway and is willing to make the referral. A good provider will make this straightforward.

What support is available while I wait for a GIC appointment?

Waiting times for GICs are measured in years. Ask what support your GP can provide in the meantime, whether that’s mental health support, bridging prescriptions, or simply regular check-ins.

Will my GP work with private providers or shared care arrangements?

Many trans patients access private care due to NHS waiting times. Ask whether your GP is willing to engage in shared care arrangements, including prescribing and monitoring. Some are; some refuse. It’s important to know where your provider stands.

What about non-binary patients?

Ask whether the provider recognises non-binary identities and what practical support is available. Non-binary patients often fall through gaps in systems designed around a binary model.

Screening and ongoing care

Will I receive appropriate screening?

Screening should be based on the organs and tissues you have, not the gender marker on your records. Ask how the provider ensures you receive appropriate invitations for cervical screening, breast screening, prostate checks, or any other relevant tests.

What if I fall out of automated screening systems?

Changing your NHS number can cause you to drop out of automated recall systems. Ask how the provider will ensure you continue to receive screening invitations. A good provider will have a process for this, including reminders on your record and clear communication with you about what screening you need.

Will I be outed by screening processes?

If you’re a trans man having cervical screening, or a trans woman needing prostate checks, the paperwork may not match your presentation. Ask how this is handled sensitively, whether your trans status will be disclosed to labs, and how results will be communicated to you.

Staff training and culture

Have staff received training on trans inclusion?

Ask whether clinical and administrative staff have received specific training on supporting trans patients. Training should cover language, pronouns, record systems, and clinical needs.

Is there a named person responsible for trans patient support?

Some providers designate a staff member to support trans patients and ensure policies are followed. Ask whether this exists and who it is.

What happens if something goes wrong?

Ask what the complaints process is if you experience discrimination, misgendering, or breaches of confidentiality. Is this taken seriously? What would happen?

Policy and legal understanding

Does the provider have a written policy on trans patients?

Ask for a copy. If they don’t have one, ask how decisions are made and what guidance staff follow.

Does the provider understand the legal framework?

Trans patients are protected under the Equality Act 2010 (gender reassignment is a protected characteristic). If you have a GRC, additional protections apply under the Gender Recognition Act 2004. Ask whether staff understand these obligations.

When was any policy last reviewed?

Healthcare guidance evolves. A policy written years ago may be out of date. Ask when it was last reviewed and whether it reflects current best practice.

What excellent looks like

• Trans patients welcomed and affirmed without barriers

• Affirmed name and pronouns used immediately and consistently by all staff

• Clear, simple process for updating records without excessive documentation

• Strong confidentiality protections with staff trained to uphold them

• Direct referral to GIC without gatekeeping or unnecessary steps

• Willingness to engage in shared care with private providers

• Robust process for ensuring appropriate screening continues after record changes

• Staff trained and confident in supporting trans patients

• Non-binary identities recognised with practical support available

• Named person responsible for trans patient experience

• Policy developed with trans patients and regularly reviewed

What good looks like

• Trans patients included in equality policy

• Process for updating name and pronouns

• Willingness to refer to GIC

• Confidentiality taken seriously

• Some awareness of screening issues

• Staff open to learning

• Complaints process in place

Red flags

• No mention of trans patients in any policy

• Excessive documentation required to change name or gender marker

• Refusal to refer to GIC or insistence on mental health assessment first

• Refusal to engage with private providers or shared care

• Trans status routinely disclosed without clear clinical need

• No process for ensuring screening continues after record changes

• Staff unfamiliar with the law or dismissive of legal obligations

• “Case by case” approach with no clarity on what that means

• Reception staff untrained and using wrong names or pronouns

• History of trans patients leaving or being made to feel unwelcome

• Complaints about discrimination not taken seriously

Use this list

Print it out. Take it to your GP surgery. Ask for written answers. You have the right to know how you’ll be treated.

If a provider can’t or won’t answer these questions clearly, that tells you something.

Healthcare policy reviews

I’m reviewing individual healthcare provider policies against this checklist and publishing the results. If you’d like me to review your GP surgery or healthcare provider’s policy, send it to me.

Browse policy reviews

Type: NHS mental health and learning disability trust

Location: Sheffield, England

Policy reviewed: Affirming Gender Identity in the Workplace

Policy date: February 2024 (Version 4)

Status: Current (review date September 2026)

Link: Policy: Affirming Gender Identity in the Workplace

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At a glance

🟢 Name: Staff can change preferred name immediately; full name change supported with documentation

🟢 Pronouns: Encouraged and supported; can be included on name badges

🟢 Facilities: Not explicitly addressed but policy is affirmative throughout

🟢 Uniform: Not explicitly addressed but policy supports living in role

🟢 Bullying protection: Discrimination, harassment and victimisation will be “challenged and acted on”

🟢 Confidentiality: Strong protections; criminal offence to disclose GRC status without consent

🟢 Non-binary inclusion: Explicitly includes non-binary and gender fluid staff

🟢 Medical appointments: Treated like any other medical appointments

🟢 Transition support: Detailed process with planning meetings, memorandum of understanding, named support

🟢 Recruitment: DBS sensitive applications route explained; no requirement to disclose trans status

Key: 🟢 Supportive 🟠 Limited or conditional 🔴 Restrictive or denied

Summary

This is a genuinely supportive workplace policy. It’s been through four versions since 2012, updated in 2024 to explicitly include non-binary and gender fluid staff following case law developments. The policy centres the employee throughout, with transition support described as led by the person transitioning. There’s a detailed procedure with planning meetings, checklists, and practical guidance on everything from email changes to pensions. The language is respectful, the legal framework is clearly understood, and the policy has been developed with input from trans people.

The detail

Names and pronouns

Will my name and pronouns be respected?

What the policy says: “We will encourage and support employees, volunteers and applicants to use their preferred pronouns.”

“We will encourage and support employees and volunteers to include pronouns if they wish on name badges and other forms of identification.”

On names: Staff can change their “preferred name” on ESR (Electronic Staff Record) immediately without documentation. A full legal name change requires supporting documentation such as a statutory declaration.

What this means: Yes. The trust actively encourages pronoun use and supports name changes. You don’t need to wait for legal documents to be known by your correct name day-to-day.

Confidentiality

Who will know I’m trans?

What the policy says: “Members of staff might gain information about a person’s gender history in the course of their work. This information must be kept confidential.”

“If this information needs to be passed on then the specific permission of the person it relates to must be obtained.”

“If the person has a Gender Recognition Certificate and this information is passed on without gaining the persons permission, the person passing the information on will be committing an offence.”

Records must be stored securely: “Hard copies of any old documents that cannot be altered, or replaced, must be stored securely in sealed envelopes, marked strictly confidential, and kept separately from the files of other employees.”

What this means: Strong protections. You control who knows. The policy explicitly acknowledges the criminal offence under the Gender Recognition Act for disclosing GRC status. Old records are kept separately and securely.

Non-binary and gender fluid staff

Are non-binary identities recognised?

What the policy says: “Case law has confirmed that protection extends to people who are gender fluid or non-binary.”

“It is our intention that all staff, volunteers, applicants... whose gender identity is non-binary or gender fluid will experience respect and dignity.”

The policy explicitly covers “staff whose gender identity is non-binary or gender fluid” throughout, not just those undergoing gender reassignment.

What this means: Yes. The 2024 update specifically expanded the policy to include non-binary and gender fluid staff, following the Taylor v Jaguar Land Rover tribunal ruling.

Transition support

What support is available if I’m transitioning?

What the policy says: The policy includes a detailed procedure with:

• Initial meeting to agree who’s involved and provide policy information

• Planning meetings to agree timescales, communication, and adjustments

• Progress meetings throughout

• A “memorandum of understanding” signed by employee and manager

• Practical checklists covering ESR, email, ID badges, payroll, pensions, professional registration

• Option to seek informal support from Rainbow Staff Network or peer support at Porterbrook service

“It is important that service managers include the person in all aspects of planning and take the lead from the person undertaking the transition process.”

What this means: Comprehensive, structured support led by you. The policy provides a clear framework while emphasising that it “may be modified to meet individual needs.” You’re not left to figure things out alone.

Medical appointments and time off

Can I take time off for transition-related appointments?

What the policy says: “If a person requires time off for an operation or medical appointment, they must be provided with time off from work under the organisations policies as they would apply to anyone else absent from work due to an operation or medical appointment.”

“Staff must not be treated less favourably because they are undergoing gender reassignment.”

What this means: Transition-related medical appointments and surgery are treated like any other medical need. No special hoops to jump through.

Bullying, harassment and discrimination

Am I protected from transphobic treatment?

What the policy says: “Discrimination, harassment or victimisation of employees, Bank Workers, volunteers, people undertaking activities in the workplace as Experts By Experience and job applicants that is associated with gender reassignment being non-binary or gender fluid will be challenged and acted on through relevant organisation policies.”

“Staff are legally protected from discrimination on the grounds of gender reassignment being non-binary or gender fluid irrespective of informing their employer of their status.”

“Any inappropriate release of information resulting in the member of staff being identified against their stated wish, whether internally or externally, may be regarded as gross misconduct.”

What this means: Clear protection. The policy explicitly covers discrimination, harassment and victimisation. Outing someone without consent could be gross misconduct.

Recruitment

Do I have to disclose my trans status when applying?

What the policy says: “Employment recruitment procedures and practice will include provisions for ensuring that people are not discriminated against in the recruitment process.”

“SHSC staff do not need information about a member of staff’s gender history they must not ask about this during DBS checking.”

The policy includes detailed guidance on the DBS sensitive applications route for trans applicants.

What this means: No, you don’t have to disclose. Staff are explicitly told not to ask. The policy provides practical information about protecting your privacy during DBS checks.

Occupational requirements

Could I be excluded from a role for being trans?

What the policy says: “It is our organisational policy to assume that any role advertised by our organisation will not have an occupational requirement around gender but any exception to this that may arise must be agreed by the Director of People to confirm this is to pursue a legitimate aim, this may include taking legal advice.”

What this means: The default is that no role excludes trans people. Any exception would need sign-off at director level with legal advice. This is a high bar, as it should be.

What’s notable about this policy

• Version 4, updated February 2024, showing ongoing commitment to improvement

• Explicitly includes non-binary and gender fluid staff following case law

• Developed with input from Experts by Experience at the Porterbrook service

• Detailed practical appendices covering everything from ESR to pensions

• Named contact person (Head of Equality and Inclusion)

• Rainbow Staff Network and peer support available

• Training available through Rainbow Badge package

• Clear understanding of legal framework including GRA protections

• Transition process led by the employee, not imposed on them

Overall assessment

This is what a supportive NHS employer policy looks like. It’s comprehensive, regularly updated, legally informed, and centres the trans employee throughout. The detailed appendices show this isn’t just warm words; there’s practical guidance for making it work.

The policy has evolved since 2012, with each version responding to legal developments and feedback. The 2024 update explicitly including non-binary and gender fluid staff shows an employer keeping pace with case law.

For trans people considering working for this trust, or already employed there, this policy suggests you’ll be supported. Of course, policies are only as good as their implementation, but this is a strong foundation.

For other NHS trusts: this is what good looks like.

Questions to ask any employer

Based on this policy, here’s what to look for elsewhere:

1. Does the policy explicitly include non-binary and gender fluid staff?

2. Is there a named person responsible for support?

3. Is there a detailed transition procedure, or just general statements?

4. Does the policy understand the legal protections (Equality Act, GRA)?

5. Is confidentiality taken seriously, with secure storage of records?

6. Has the policy been developed with trans people?

7. When was it last updated?

Have a policy you’d like reviewed?

If your employer has a policy you’d like me to review, send it to me.

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Recent employment tribunals have shown what can go wrong. These cases reveal a pattern: trans staff facing hostility, exclusion, and unwanted media attention.

Most employers have equality and inclusion policies. But policies vary enormously, and the gap between what’s written and what’s practiced can be vast. This checklist helps you cut through the jargon and understand what your employer’s policy actually means for you.

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Names and pronouns

Will my affirmed name be used at work?

Look for clear statements that your chosen name will be used in all workplace contexts: email, ID badges, rotas, internal systems, and by colleagues. Ask how quickly this can happen and whether it depends on a deed poll or legal name change.

Will colleagues and managers use my correct pronouns?

Look for explicit commitments that staff will use correct pronouns. Ask what happens if someone refuses or repeatedly misgenders you. Is that treated as a conduct issue?

What if someone claims a religious or philosophical objection?

Some colleagues may claim their beliefs prevent them from using your name or pronouns. Recent case law has found such beliefs protected, but that doesn’t give anyone the right to harass you. Ask how your employer balances competing rights, and whether your dignity is protected.

Facilities

Can I use the toilets and changing rooms matching my gender?

Look for clear statements that trans staff can use facilities appropriate to their gender. Be wary of policies that require you to use “gender neutral” facilities unless you choose to. Ask whether this is a right or something you need to request.

What if a colleague objects to sharing facilities with me?

This has been central to several tribunal cases. Ask how your employer handles objections. A good policy will make clear that discomfort is not grounds for excluding you. The person with the objection should be offered alternatives, not you.

Dress code and uniform

Can I wear clothing and uniform consistent with my gender?

Look for explicit inclusion of trans staff in dress code policies. Ask whether you need permission or whether you can simply dress appropriately for your gender from day one.

What about during transition?

If you’re transitioning at work, ask whether there’s flexibility during the process. Some employers offer a phased approach if that’s what you want, but it should be your choice, not a requirement.

Workplace support

Is there a policy specifically on supporting trans employees?

Some employers have dedicated trans inclusion policies. Others include trans staff within broader equality policies. Ask whether there’s specific guidance and whether it’s been developed with trans people.

Is there a named person or team I can go to for support?

Ask whether there’s someone with responsibility for supporting trans staff, whether HR, an equality lead, or a staff network. Ask whether they’ve had training.

Will I have a transition plan if I want one?

If you’re transitioning at work, a good employer will offer to work with you on a plan covering timing, communication, facilities, and support. This should be led by you, not imposed on you.

What support is there for non-binary staff?

Non-binary people often fall through the gaps. Ask whether your employer recognises non-binary identities and what practical support is available, including pronouns, titles (Mx), and facilities.

Time off and medical appointments

Can I take time off for medical appointments related to my transition?

Ask whether transition-related appointments are treated like any other medical appointments. Look for policies that don’t require excessive disclosure about the nature of appointments.

What about surgery and recovery time?

If you’re having surgery, ask how this is handled. It should be treated like any other medical leave.

Confidentiality

Who will know I’m trans?

You have a right to privacy. Ask who needs to know, who will be told, and whether you control that information. Under the Gender Recognition Act 2004, if you have a GRC, it’s a criminal offence for someone who acquired the information in an official capacity to disclose it without your consent.

What’s recorded on my personnel file?

Ask what information is held, who can access it, and whether your trans status or previous name is visible to people who don’t need to know.

What happens if I’m outed without my consent?

Ask what your employer would do if someone disclosed your trans status without permission. Is that treated as a serious matter?

Bullying, harassment, and discrimination

Does the policy explicitly protect trans staff?

Look for explicit mention of gender reassignment as a protected characteristic. Ask whether transphobic harassment is named and defined.

What’s the process for reporting incidents?

Ask how you report harassment or discrimination, who handles complaints, and what timescales apply. Ask whether you can report informally first if you prefer.

What happens to the perpetrator?

Ask what sanctions are available and whether transphobic harassment is treated as a disciplinary matter. Look at what’s happened in practice, not just what’s written.

What if the harassment comes from management?

This is common. Ask whether there’s a route to escalate concerns if your manager is the problem. Ask whether you can go to HR, a union, or an external body.

What if colleagues organise against me?

In some cases, groups of staff have coordinated hostility towards trans colleagues. Ask whether your employer recognises this as a form of harassment and how they would respond.

Recruitment and promotion

Is the recruitment process inclusive?

Ask whether application forms include appropriate gender options, whether deadlines accommodate name changes, and whether interview panels have had equality training.

Do I have to disclose my trans status when applying?

Generally, no. Ask what information is requested and at what stage. You should not have to out yourself to get a job.

What about DBS checks?

If your role requires a DBS check, your previous name may appear. Ask how this is handled and whether the sensitive applications process is used to protect your privacy.

Legal protections

Does my employer understand the law?

Under the Equality Act 2010, gender reassignment is a protected characteristic. You’re protected from the moment you propose to transition, whether or not you’ve had medical treatment or changed your documents. Ask whether your employer’s policy reflects this.

What about the Gender Recognition Act?

If you have a GRC, additional protections apply. Ask whether your employer understands these and has processes to protect your confidentiality.

What good looks like

Excellent:

• Trans staff welcomed and affirmed without barriers

• Clear policy developed with trans people

• Named support person with training

• Immediate use of correct name and pronouns

• Full access to facilities matching your gender

• Harassment treated as serious misconduct

• Confidentiality protected

• Transition support led by you, not HR

• Non-binary identities recognised

• Track record of supporting trans staff in practice

Good:

• Trans staff included in equality policy

• Process for updating name and pronouns

• Access to appropriate facilities

• Harassment policy covers gender reassignment

• Some support available

• Willingness to learn

Red flags:

• No mention of trans staff in policies

• “Gender critical” beliefs treated as equal to your dignity

• Facilities access described as “case by case” or requiring approval

• No clear process for handling harassment

• History of trans staff leaving or being pushed out

• HR seems unfamiliar with the law

• Policy says the right things but practice tells a different story

• Colleagues known to be hostile with no consequences

• You’re expected to educate your employer

Use this list

Print it out. Take it to HR. Raise it with your union. You have the right to know how you’ll be treated.

If an employer can’t or won’t answer these questions clearly, that tells you something.

Workplace policy reviews

I’m reviewing individual employer policies against this checklist and publishing the results. If you’d like me to review your employer’s policy, send it to me.

Browse policy reviews

Type: Independent school

Location: Queensland, Australia

Policy reviewed: Supporting Students Diverse in Gender Policy

Policy date: Current (references 2017 guidelines)

Status: Current

Link: GENDER DIVERSITY POLICY - SUPPORTING STUDENTS DIVERSE IN GENDER

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At a glance

🟢 Bathroom access: Student choice; can use facilities of affirmed gender or unisex options

🟢 Changing rooms: Negotiated with student; goal is to maximise integration and minimise stigma

🟢 Sports and PE: Participate with affirmed gender where possible; flexibility for swimming

🟢 Name: Student chooses; staff asked to use chosen name on reports, certificates, day-to-day records

🟢 Pronouns: Staff asked to use correct pronouns when requested by student

🟢 Uniform: Students wear uniform of their choosing consistent with gender identity

🟢 Bullying protection: Complaints taken “very seriously” with “immediate attention”

🟢 Overnight trips: Sleep in accommodation appropriate to gender identity; alternatives if preferred

🟢 Privacy: Gender identity is private; consent required to disclose; no obligation to notify school

🟢 Parental involvement: Parents are “key contributors” but cannot override anti-discrimination law

Key: 🟢 Supportive 🟠 Limited or conditional 🔴 Restrictive or denied

Summary

This is what a genuinely inclusive school policy looks like. Hillbrook’s policy centres the student throughout, with decisions described as “student led”. Trans students can use bathrooms and changing rooms of their affirmed gender, wear the uniform of their choice, be called by their name and pronouns, and sleep in appropriate accommodation on trips. There is no “watchful waiting”, no requirement for diagnosis, and no barriers to support. The policy explicitly states there is “no medical or mental health diagnosis or treatment threshold that students must meet in order to have their gender identity respected and recognised.”

The detail

Privacy and confidentiality

Will they tell parents or others that my child is trans?

What the policy says: “A person’s gender identity is private and consent must be given by the student to disclose or share information.”

“Information about a student’s transgender status, legal name or gender assigned at birth constitutes confidential medical information. Legal advice must be obtained before sharing without consent.”

“Students are under no obligation to notify the school or community if they identify as gender diverse.”

What this means: Your child controls who knows. The school treats trans status as confidential medical information. They cannot share it without consent, and must seek legal advice before doing so. Your child doesn’t even have to tell the school if they don’t want to.

Bathrooms and changing rooms

Will my child be allowed to use the facilities of their affirmed gender?

What the policy says: “The use of toilets and changing rooms by students will be negotiated with each individual student... with the goal being to maximize social integration, minimize stigmatization and ensure safety and comfort.”

“Students may use the unisex bathroom and change rooms available around the school, or the student may use the facilities of their affirmed gender.”

What this means: Your child chooses. They can use facilities matching their gender identity, or unisex facilities if they prefer. The goal is integration and reducing stigma, not separation.

Sports and PE

Will my child be able to play sports with their affirmed gender?

What the policy says: “Wherever possible, when teams are segregated by gender, students should be enabled to participate in the activity which corresponds to their gender identity if this is what they request.”

For students over 12, “restrictions on participation in sport may be imposed if the restriction is reasonable, having regard to the stamina, strength or physical requirements of the sport.”

If a student is on puberty blockers, “this should be taken into consideration when considering if a restriction is required.”

“Swimming can be problematic... Flexibility may be required in either the swimming costume or participation in swimming.”

What this means: The default is inclusion with affirmed gender. Restrictions are possible for older students in some sports, but must be “reasonable” and consider individual circumstances including any medical treatment. The policy shows awareness that swimming may need particular flexibility.

Name and pronouns

Will my child be supported in their affirmed name and pronouns?

What the policy says: “Respecting a young person’s request to change name and pronoun is an essential part of validating and supporting their identity.”

“Students may refer to themselves by a name of their choosing. School staff are asked to use the name, personal pronouns and preferred gender when requested by the student.”

“Academic reports, certificates, awards and day-to-day school records/notes may use the student’s preferred name.”

What this means: Yes, fully. Your child’s chosen name and pronouns should be used. This can extend to reports and certificates, not just day-to-day use.

Uniform

Can my child wear the uniform of their affirmed gender?

What the policy says: “All students have the right to dress in a manner consistent with their gender identity and expression. Students are therefore permitted to wear the uniform of their choosing.”

What this means: Yes. Your child chooses which uniform to wear. No application process, no case-by-case consideration, just a clear right.

Bullying

Is my child protected against transphobic bullying?

What the policy says: “Any complaint alleging discrimination, harassment and bullying based on a student’s actual or perceived gender identity, and expression, will be taken very seriously. The incident of discrimination will be given immediate attention and appropriate action will be taken.”

What this means: Yes, explicitly. Complaints are taken seriously and acted on immediately.

School trips and overnight stays

Will my child be included and accommodated on residential trips?

What the policy says: “Whenever possible, students should be able to sleep in tents appropriate to their gender identity. Some transgender young people may not feel comfortable doing this and in such cases alternative sleeping arrangements will be made.”

Students consult with staff about “sleeping arrangements, toilets and change areas. Decisions will be made that best suit to help the student feel safe and comfortable.”

What this means: Your child sleeps with their affirmed gender where possible. If they’d prefer something different, that’s accommodated too. The focus is on what helps the student feel safe and comfortable.

Parental involvement

Will I be involved in decisions?

What the policy says: “Whenever possible, parents will be key contributors to the formulation of a plan for helping their child be supported to learn free from discrimination at school.”

However: “concerns regarding the views of the person’s parents or other members of the school community do not provide exemptions from the legal requirement to neither directly or indirectly discriminate.”

What this means: Parents are involved and valued, but parental objection cannot override the child’s right to be free from discrimination. Queensland law protects the child.

The school’s approach

What principles underpin this policy?

What the policy says: “Each student will have a unique process for transitioning and the school will work collaboratively with students and their families to ensure a plan specific to each student’s needs. This will ensure that it is a student led process.”

“There is no medical or mental health diagnosis or treatment threshold that students must meet in order to have their gender identity respected and recognised.”

What this means: The process is led by the student, not imposed on them. No gatekeeping, no diagnosis required, no waiting period. The school works with your child to create a plan that fits their needs.

What’s notable about this policy

• Student-led throughout

• No diagnosis or medical threshold required

• Grounded in Queensland and Australian anti-discrimination law

• Includes Aboriginal and Torres Strait Islander terminology (BrotherBoy, SisterGirl)

• References Australian Standards of Care and Treatment Guidelines

• Explicitly states parental objection cannot override anti-discrimination law

• Comprehensive glossary of terms showing genuine understanding

• Links support for the whole community including parents and siblings

Overall assessment

This is an exemplary policy. It centres the student, removes barriers, and is grounded in rights and law. It shows what’s possible when a school genuinely commits to inclusion rather than managing trans children as a problem.

For parents in England reading this: policies like this exist. The restrictions you’re facing are not inevitable. They’re choices.

Questions to ask a school

If you’re looking for a school with a genuinely supportive approach, this policy shows what to look for:

1. Is the process student-led?

2. Is there a diagnosis or medical requirement?

3. Can my child use facilities of their affirmed gender?

4. What does the policy say about parental objection?

5. Is the policy grounded in anti-discrimination law?

Have a policy you’d like reviewed?

If your child’s school has a policy you’d like me to review, send it to me.

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Published by: Children, Young People, Education and Skills (CYPES), Government of Jersey

Date: August 2021

Status: Current

Link: Available via Hautlieu School website

Note: This is Jersey (Channel Islands) guidance, not England. Jersey has its own government and laws, including the Discrimination (Jersey) Law 2013 which explicitly protects transgender people.

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At a glance

🟢 Bathroom access: Child chooses which toilets to use; single stall available if preferred

🟢 Changing rooms: Child should ideally choose; alternative arrangements discussed with pupil

🟢 Sports and PE: Minimise segregation; child chooses which group to join; inclusion prioritised

🟢 Name: Child has right to be called by chosen name; school should adopt it

🟢 Pronouns: Correct pronouns should be adopted by school community

🟢 Uniform: Schools should enable trans children to dress according to their gender identity

🟢 Bullying protection: Transphobic behaviour must be challenged at all levels

🟢 Overnight trips: Trans child should sleep in room appropriate to their gender identity

🟢 Privacy: Child has right to keep trans status private; staff must not disclose without permission

🟠 Parental involvement: Views listened to and respected, but child’s confidentiality protected

Key: 🟢 Supportive 🟠 Limited or conditional 🔴 Restrictive or denied

Summary

This guidance is strikingly different from what schools in England are being told. It is explicitly supportive, frames trans children as “enriching the school community”, and prioritises the child’s voice and wellbeing throughout. Trans children can use toilets and changing rooms matching their gender identity, wear uniform of their choice, be called by their name and pronouns, and sleep in appropriate accommodation on trips. The guidance is grounded in children’s rights (UNCRC) and Jersey’s anti-discrimination law. It reads as what supportive school guidance should look like.

The detail

Privacy and confidentiality

Will they tell parents or others that my child is trans?

What the guidance says: “A child or adult has the right to keep private their trans* status at school.”

“Staff should not disclose information concerning a child’s trans* status to others, including parents, carers and other members of the school community unless legally required to do so or because the child has asked the school to do so.”

“Confidential information should not be shared with the parents or carers without the child’s permission, unless there are safeguarding reasons not to do so.”

What this means: Your child controls who knows. Staff cannot out your child to other parents, other pupils, or even to you without your child’s permission (unless there’s a safeguarding concern). This is the opposite of the England approach.

Bathrooms and changing rooms

Will my child be allowed to use the facilities of their affirmed gender?

What the guidance says: On toilets: “Children in transition must be allowed to choose which toilets they wish to use.”

On changing rooms: “Ideally a child should be able to choose which changing room they wish to use.” If not, staff should “discuss the most appropriate arrangement with the individual pupil to develop a plan which best meets their needs.”

“Ideally, all toilets within schools would be single stalled toilets available to all children.”

What this means: Your child chooses. If they want extra privacy, that’s available too, but it’s their choice, not imposed on them. The guidance explicitly says trans children “must be allowed to choose”.

Sports and PE

Will my child be able to play sports with their affirmed gender?

What the guidance says: “Schools should try to minimise segregation wherever possible during physical education. If segregation is a requirement, then the child should be allowed to choose which group they wish to join.”

“Trans* children should be permitted to participate in competitions and sports days in a manner that corresponds to their gender identity.”

The guidance acknowledges that at secondary level “staff may need to use their discretion” for competitive events, but frames the question as whether “exclusion of the trans* student from the sporting event will be detrimental to the trans* student’s development”.

What this means: The default is inclusion. Your child chooses which group to join. For competitions, the focus is on avoiding harm to the trans child, not on abstract debates about fairness. Exclusion is the exception, not the rule.

Name and pronouns

Will my child be supported in their affirmed name and pronouns?

What the guidance says: “An individual has the right to be called by a name of their choice and therefore the pronoun that reflects their chosen gender identity should be adopted by the school community.”

“Staff must be careful to use the correct pronoun when referring to a trans* child or adult.”

What this means: Yes, fully. Your child’s name and pronouns should be used by everyone. No “case-by-case” delays, no “watchful waiting”, no right for staff to refuse.

Uniform

Can my child wear the uniform of their affirmed gender?

What the guidance says: “Schools should enable trans* children to dress according to their chosen gender identity.”

“Allowing a trans* child to dress in clothes which make them feel comfortable and associated with their gender identity will enable them to become empowered.”

What this means: Yes. The guidance recognises this is often “one of the first steps” and frames it positively as empowering.

Bullying

Is my child protected against transphobic bullying?

What the guidance says: “Ensure transphobic behaviour is challenged and dealt with at all levels, including abuse, bullying (name-calling, derogatory jokes, graffiti, unacceptable and unwanted behaviour, intrusive questions) and harassment.”

The guidance also notes that signs of a struggling trans child (poor performance, truanting, self-harm) are “not caused by the child being trans* but by society’s attitude towards transgender people”.

What this means: Yes, and the guidance goes further by naming specific examples of transphobic behaviour and explicitly locating the problem in society’s attitudes, not in the child.

School trips and overnight stays

Will my child be included and accommodated on residential trips?

What the guidance says: “A trans* child should be able to sleep in a room appropriate to their gender identity. If a trans* child is uncomfortable with this, alternative arrangements must be provided.”

What this means: Your child sleeps with their affirmed gender. If they want something different, that’s their choice. Compare this to England, where trans children must sleep with their birth sex or alone.

Parental involvement

Will I be involved in decisions?

What the guidance says: “The views of children, parents and carers must be listened to and respected.”

But also: “Confidential information should not be shared with the parents or carers without the child’s permission, unless there are safeguarding reasons not to do so.”

What this means: Your views matter, but your child’s privacy is protected. If your child hasn’t told you, the school won’t out them. This respects both parental involvement and the child’s autonomy.

The guidance’s approach

What principles underpin this guidance?

What the guidance says: “Trans* children should be viewed as enriching the school community and providing an opportunity for all pupils to challenge gender stereotypes and norms.”

“No child should be made to feel that they are causing problems or owe something to the schools for being treated with the equality they deserve and are legally entitled to.”

The guidance is framed around the UN Convention on the Rights of the Child and Jersey’s Discrimination Law.

What this means: This guidance starts from a fundamentally different place. Trans children are welcomed, not managed. Their presence is an opportunity, not a problem. The language throughout is affirming and rights-based.

What’s notable about this guidance

• Written in 2021, before the current political climate around trans children intensified

• Grounded in children’s rights (UNCRC) and anti-discrimination law

• Uses respectful language throughout (”trans*” with asterisk to include non-binary identities)

• Links to supportive organisations (Mermaids, Gendered Intelligence, Liberate Jersey)

• Explicitly names the cause of trans children’s distress as society’s attitudes, not their identity

• No “watchful waiting”, no “contested belief”, no barriers to support

Overall assessment

This is what supportive guidance looks like. It centres the child, protects their privacy, enables them to live as themselves at school, and frames their presence as positive. It’s grounded in rights and law, not fear and caution.

Jersey is not England. It has its own government, its own laws, and apparently its own approach to trans children. Parents in Jersey can expect something very different from parents in England.

For parents in England reading this: this shows another way is possible. The restrictions in the draft English guidance are policy choices, not inevitabilities.

Questions to ask a Jersey school

1. Are you following this CYPES guidance?

2. What training have staff received on supporting trans pupils?

3. How do you handle confidentiality if my child isn’t out to everyone?

4. What support is available if my child experiences transphobic bullying?

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If your child’s school has a policy you’d like me to review, send it to me.

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Type: Independent co-educational day and boarding school

Age range: 3–18

Location: Berwick-upon-Tweed, Northumberland

Policy reviewed: Transgender and Transitioning Guidance

Policy date: May 2024

Policy status: Under review (listed as such on school website)

Link: Longridge Towers School: Transgender and Transitioning Guidance

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At a glance

🔴 Bathroom access: No access to affirmed gender facilities; single-occupancy alternative only

🔴 Changing rooms: No access to affirmed gender facilities; single-occupancy alternative only

🔴 Sports and PE: Restricted for contact sports; “no exception” for safety concerns

🟠 Name: Accommodated “where possible” with parental involvement

🔴 Pronouns: Case-by-case; primary children unlikely; school “reserves the right to decline”

🟠 Uniform: Case-by-case consideration

🟢 Bullying protection: Explicitly includes gender identity

🔴 Overnight trips: Must share with birth sex or have separate room

🟠 Privacy: Won’t share with other parents, but may inform school community

🔴 Parental involvement: Required for under-16s; parents informed “as a matter of priority”

🔴 Language: Uses “trans” but also “biological sex” throughout; references “contested belief”

Key: 🟢 Supportive 🟠 Limited or conditional 🔴 Restrictive or denied

Summary

This policy follows the government’s draft guidance closely, adopting its language, its framing, and its restrictions. It takes a “watchful waiting” approach, requires parental involvement for most decisions, and explicitly prohibits access to bathrooms, changing rooms, and sleeping arrangements matching a child’s affirmed gender. The policy states the school takes a “neutral stance” on transgender issues, but in practice the stance is restrictive. Trans children at this school will face significant barriers to being recognised and supported.

The detail

Privacy and confidentiality

Will they tell other parents or students that my child is trans?

What the policy says: “Confidential information about trans pupils will not be shared with other parents and any queries or questions from other parents will be considered carefully before responding.”

However: “If and where any change has been agreed, the School will communicate this to other pupils and staff where it is necessary and proportionate to do so.”

What this means: The school won’t proactively out your child to other parents. But if your child socially transitions in any way, the school may tell staff and pupils. You may have limited control over how and when this happens.

Bathrooms and changing rooms

Will my child be allowed to use the facilities of their affirmed gender?

What the policy says: “The School must comply with minimum standards, including that separate toilets for boys and girls aged 8 years and over are to be provided. Biological boys must not be allowed to go into the girls’ toilets (and vice versa) in order to protect all children.”

“Schools must not allow a child, aged 11 years or older, to change or wash in front of a child of the opposite biological sex, nor should they be subject to a child of the opposite biological sex changing or washing in front of them.”

If a child does not want to use facilities matching their birth sex, the school “will consider whether an alternative toilet facility is available”.

What this means: This is a blanket ban. A trans girl cannot use the girls’ toilets or changing rooms. A trans boy cannot use the boys’. The only option is a single-occupancy alternative, if one exists. The policy frames this as “protecting all children”, placing trans children outside that protection.

Sports and PE

Will my child be able to play sports in the team of their affirmed gender?

What the policy says: “For all sports where physical differences between the sexes threaten the safety of children, the School will adopt clear rules which mandate separate-sex participation. There can be no exception to this.”

“It would not be safe for a biological boy to participate in certain sports as part of a teenage girls’ team.”

What this means: Trans girls are banned from girls’ teams in contact sports, with “no exception”. The policy specifically names trans girls (”biological boys”) as the risk. Trans boys wanting to play on boys’ teams may face barriers based on “safety” and “fairness” assessments.

Name and pronouns

Will my child be supported in their affirmed name and pronouns?

What the policy says:

On names: The school will “seek to accommodate a preferred name change where possible” after discussion with the pupil and parents. The legal name remains on the admissions register.

On pronouns: “Unless there are exceptional circumstances, primary school aged children will not have different pronouns to their sex-based pronouns used about them. The School will make decisions in this regard on a case-by-case basis, and reserves the right to decline such a request.”

What this means: Names are more likely to be accommodated than pronouns. For pronouns, primary-age children are effectively refused. Older children face a “case-by-case” process where the school can still say no. The school explicitly reserves the right to decline. Even if agreed, staff are not compelled to use correct pronouns.

Uniform

Can my child wear the uniform of their affirmed gender?

What the policy says: “If a transgender pupil has difficulty complying with the School’s uniform policy, they should raise this with a member of the pastoral staff, in order that the School can consider these concerns on a case-by-case basis.”

What this means: There’s no automatic right to wear the uniform of your affirmed gender. It’s another request to be considered, with no guarantee of approval.

Bullying

Is my child protected against transphobic bullying?

What the policy says: “The School does not tolerate bullying of any form and deals with any instances under its Anti-bullying and Cyber-bullying Policy. This includes bullying for reasons related to pupil’s sex or gender identity.”

What this means: This is the clearest positive in the policy. Transphobic bullying is explicitly covered. However, the policy doesn’t define what transphobic bullying includes, and given that staff can refuse to use correct pronouns, the line between policy and bullying may be blurred.

School trips and overnight stays

Will my child be included and accommodated on residential trips?

What the policy says: “To meet our safeguarding obligations as set out in Keeping Children Safe in Education (KCSIE) no child will be allowed to share a room with a child of the opposite biological sex.”

The school will take a “case-by-case approach” weighing up “the wishes, welfare, age, development, and privacy needs of the trans pupil and any other pupils”.

What this means: A trans girl must share with boys or have a separate room. A trans boy must share with girls or have a separate room. The “case-by-case” consideration is about whether alternatives are available, not whether your child can be with their affirmed gender.

Parental involvement

Will I be involved in decisions?

What the policy says: “For pupils under the age of 16, the parents/carers of trans pupils will be informed and involved unless there are specific safeguarding reasons for not doing this.”

“The School will endeavour to work in close partnership with parents and carers of trans pupils, favouring open dialogue between all parties.”

What this means: Yes. Parents are central to this policy. For under-16s, you will be informed unless there’s a safeguarding reason not to. The threshold for not informing parents is high. A child who is not out at home has limited protection.

The school’s process

What approach does the school take when a child comes out or requests support?

What the policy says: The school follows a “Watchful Waiting” approach: “We will wait for a period whilst considering a request, to ensure it is a sustained and properly thought through request from the child.”

Staff “will not unilaterally adopt any changes, including using a new name or new pronouns, unless or until this has been agreed by the School in accordance with the proper procedures and, in the vast majority of cases, parental consent”.

Factors considered include: safeguarding obligations, view of parents, age of the child, any clinical information, “the context of the request”, and “the impact on other pupils and the school community”.

What this means: The default is delay. Individual teachers cannot support your child until the school formally agrees. The process is weighted towards caution, parental control, and the comfort of other pupils. Your child’s own certainty about their identity is treated as something to be tested rather than trusted.

What’s missing from this policy?

• How long “watchful waiting” lasts

• What happens if parents and child disagree

• What “exceptional circumstances” would allow pronouns for primary children

• Any timescale for decisions

• Staff training requirements

• Named staff member responsible for trans pupils

• Any route of appeal if requests are refused

• Recognition that delay itself can cause harm

Overall assessment

This policy follows the government’s draft guidance closely, sometimes word for word. It frames trans identities as “contested”, adopts “watchful waiting” as its approach, and places significant barriers in front of any form of social transition.

The positives are limited: bullying protection explicitly includes gender identity, names may be accommodated, and the school says it won’t share information with other parents. But these are outweighed by blanket bans on bathroom and changing room access, significant restrictions on pronouns, and a process designed to slow everything down.

It’s worth noting that both this policy and the government guidance it follows reference the Cass Review, which has been widely criticised for its methodology and conclusions. The government guidance itself remains in draft form, over two years after consultation closed, and is long overdue for review.

For parents of trans children considering this school, or already enrolled, this policy suggests your child will face significant challenges being recognised and supported. The school’s stated “neutral stance” is not neutral in practice.

Questions to ask this school

1. How long does “watchful waiting” last, and what happens during that period?

2. What would count as “exceptional circumstances” for a primary-age child to have their pronouns respected?

3. Where is your single-occupancy toilet, and will using it effectively out my child?

4. What training have staff received on supporting trans pupils?

5. What happens if I give consent but the school still declines a request?

6. Has any pupil at this school had their pronouns respected? Their uniform changed?

7. When will this policy be reviewed, and will the review consider the delays to government guidance?

Policy Review

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Further Reading

• This review is based on my checklist of questions for parents. Read it here

• Browse all policy reviews

• This policy follows the government’s draft guidance closely. Read my review of that guidance here.

Many schools now have a policy on trans pupils. But policies vary enormously, and the language can be vague or hard to interpret. Some schools are supportive. Others follow restrictive government interim guidance to the letter. Many fall somewhere in between, making decisions “case by case” without telling you what that actually means.

This checklist is designed to help you cut through the jargon. These are the questions that matter, and the answers you should look for.

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Privacy and confidentiality

Will the school tell other parents that my child is trans?

Look for clear statements that your child’s trans status is confidential and won’t be shared with other families. Be wary of vague wording about informing the “school community” if your child socially transitions. This could mean other parents find out without your control.

Will the school tell other students?

Same principle. Your child should be able to decide who knows and when. If the school says it will communicate changes to staff and pupils, ask exactly what that means and whether you and your child have input.

Who within the school will know?

Some staff will need to know for safeguarding or practical reasons. But it should be limited and purposeful, not gossip in the staffroom. Ask who has access to this information and why.

How is information about my child stored?

Your child’s trans status is sensitive personal data. Ask how it’s recorded, where it’s kept, and who can see it.

What if my child is out at school but not at home, or vice versa?

This is where policies often get complicated. Some schools now say they will inform parents if a child requests social transition, unless there are safeguarding concerns. Ask what “safeguarding concerns” means in practice, and who decides.

Names and pronouns

Will my child’s affirmed name be used at school?

Many schools will accommodate a preferred name for day-to-day use. But ask whether it will appear on registers, report cards, library cards, email addresses, and internal systems, or only their legal name.

Will staff use my child’s correct pronouns?

This is where many policies are restrictive. Some schools say pronouns are decided “case by case” or that primary-age children are unlikely to have different pronouns. Ask what the criteria are, who decides, and how long the process takes.

What happens if a member of staff refuses?

Some policies say staff cannot be “compelled” to use different pronouns. Others say mistakes will be treated with understanding. Ask what happens if a staff member consistently refuses. Is that acceptable to the school?

What about external exams?

Exam boards have their own rules. Ask whether your child can be entered under their affirmed name, and what the school will do to facilitate this.

What name will appear on references and records when my child leaves?

This matters for the future. Ask whether your child’s affirmed name can be used on references for sixth form, college, university, or employers.

Toilets and changing rooms

Will my child be allowed to use the toilets that match their affirmed gender?

Some schools now explicitly prohibit this, following draft government guidance. They may offer a single-occupancy alternative instead. Ask whether this exists, where it is, and whether using it will effectively out your child.

Will my child be allowed to use the changing rooms that match their affirmed gender?

The same restrictions usually apply here. Ask what alternatives are offered and whether they’re dignified, private, and convenient, or an afterthought.

Will using alternative facilities single my child out?

A single-occupancy toilet in the medical room on the other side of the building isn’t a real solution. Ask where the facilities are, whether your child will need to explain why they’re using them, and whether other students use them too.

Sports and PE

Will my child be able to participate in PE with students of their affirmed gender?

Many policies restrict this, particularly for contact sports and particularly after puberty. Ask which sports are affected and what the school’s reasoning is.

Will my child be able to join sports teams that match their affirmed gender?

Competitive sport is often more restricted than PE lessons. Ask about specific sports your child is interested in.

What if my child can’t participate with their affirmed gender?

Ask what alternatives are offered. Will they be forced to participate with their birth sex? Can they opt out? Will this affect their PE grade or school reports?

Does the school follow guidance from sports governing bodies?

Some sports have their own rules on trans participation. Ask whether the school applies these and how.

Uniform

Can my child wear the uniform that matches their affirmed gender?

Some schools allow this readily. Others require a formal process or say it will be considered “case by case.” Ask what the process is and how long it takes.

Does the school have a gender-neutral uniform option?

Some schools have moved to a single uniform for all pupils. This sidesteps the issue entirely. Ask whether this is available.

Bullying and safety

Is my child explicitly protected against transphobic bullying?

Look for policies that specifically mention gender identity, not just generic anti-bullying statements. Ask how transphobic bullying is defined.

How does the school respond to transphobic incidents?

Ask about the process for reporting, investigating, and resolving incidents. What sanctions are used? How is your child supported?

Does the school record and monitor transphobic bullying?

Schools should track incidents to identify patterns. Ask whether this data is collected and reviewed.

What proactive steps does the school take?

Responding to bullying after it happens isn’t enough. Ask what the school does to prevent it, through education, culture, staff training, and visible inclusion.

Is there a staff member my child can go to?

Ask whether there’s a designated person responsible for supporting trans pupils, or whether staff have received training on trans inclusion.

School trips and overnight stays

How will sleeping arrangements be handled?

Most policies say children must share with their birth sex, or be given a separate room. Ask what the options are and whether your child will be singled out.

How will toilets and washing facilities be managed on trips?

Ask what’s available at the venue and how the school will ensure your child can use facilities safely and privately.

Will external providers be told about my child’s trans status?

Activity centres, hotels, and other providers may be informed. Ask whether this happens, whether you’ll be consulted, and how your child’s privacy will be protected.

Curriculum and classroom

Is trans identity included in the curriculum?

Look for inclusion in PSHE, RSE, or elsewhere. Ask whether this is factual and respectful, or whether trans identities are presented as “contested.”

How does the school handle transphobic views in class?

Students or staff may express negative views about trans people. Ask how the school responds and whether your child will be expected to defend their own existence in classroom discussions.

Records and administration

What name and sex will appear on official school records?

Schools are legally required to record a pupil’s legal name and sex. But ask whether your child’s affirmed name can be used elsewhere in school systems.

What about when my child leaves?

Ask what name will appear on references, exam certificates, and any records passed to future schools, colleges, or employers.

Decision-making and process

What happens when a child comes out or requests support?

Ask the school to walk you through their process. Who is involved? How long does it take? What factors do they consider?

Will my child’s wishes be central to decisions?

Some policies emphasise listening to the child. Others focus on parental consent and professional caution. Ask how your child’s voice is weighted.

Does the school use “watchful waiting”?

This phrase appears in government guidance and many school policies. Ask what it means in practice. How long does it last, what are they waiting for, and what happens during that period?

Does the school require a diagnosis or external referral?

Some schools won’t act without input from CAMHS or a gender clinic. Given current waiting times, this could mean years of delay. Ask whether the school can support your child without external sign-off.

What if the school says no?

Ask whether there’s an appeals process, and what happens if you disagree with a decision.

Policy and legal standing

Does the school have a written policy on trans pupils?

Ask for a copy. If they don’t have one, ask how decisions are made.

What guidance does the policy follow?

Many schools reference the draft government guidance from December 2023, which has not yet been finalised. Ask whether the school is aware of this and whether the policy will be reviewed when final guidance is published.

When was the policy last reviewed?

Policies written several years ago may be out of date. Ask when the next review is scheduled.

Has the school taken legal advice?

Schools have duties under the Equality Act to avoid discrimination on grounds of both sex and gender reassignment. These can be in tension. Ask how the school balances them and whether they’ve sought legal advice.

What excellent looks like

• Your child is welcomed and affirmed without question

• Affirmed name and pronouns used immediately and consistently by all staff

• Full access to toilets, changing rooms, and facilities matching your child’s affirmed gender

• Full participation in sports teams matching your child’s affirmed gender

• Uniform of your child’s choice without needing to request an exception

• Sleeping arrangements on trips match your child’s affirmed gender

• Trans identities included positively in the curriculum, not as “contested”

• Visible LGBTQ+ inclusion across school culture, not just policy

• Staff trained and confident in supporting trans pupils

• Your child’s voice is central to all decisions, with support to express their needs

• No “watchful waiting” or delays: support begins when your child asks for it

• Other parents are never informed of your child’s trans status

• Language is respectful and current: “trans pupils” rather than clinical or outdated terms

What good looks like

• Clear confidentiality protections

• Affirmed names used across school systems

• Pronouns respected without excessive barriers

• Alternatives to gendered facilities that are dignified and don’t out your child

• Explicit anti-bullying protection mentioning gender identity

• Staff training on trans inclusion

• A named person responsible for supporting trans pupils

• Your child’s voice genuinely considered in decisions

• Flexibility rather than blanket restrictions

• Language that recognises your child for who they are

Red flags

• Repeated emphasis on “biological sex” with no acknowledgement of gender identity

• Blanket bans on bathroom or changing room access

• Blanket bans on sports participation

• “Watchful waiting” with no clarity on what that means or how long it lasts

• Parental consent required with no consideration of the child’s own wishes

• No mention of bullying protection related to gender identity

• Policy described as “under review” indefinitely

• Language that frames trans identities as “contested” or a “belief”

• Clinical or dehumanising language: “gender reassignment”, “transgender pupil”, “the transgender”, “transgendered”

• Avoidance of the word “trans” entirely, replaced with “gender questioning” throughout

• No named staff member or clear process for support

• External diagnosis or referral required before any support is given

Use this list

Print it out this post (cmd-P or ctrl-P). Take it to meetings. Email it to the school and ask for written answers. You have the right to know how your child will be treated.

If a school can’t or won’t answer these questions clearly, that tells you something.

School policy reviews

I’m reviewing individual school policies against this checklist and publishing the results. If you’d like me to review your child’s school, send me their policy.

Browse school policy reviews

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At a glance

🔴 Bathroom access: No access to affirmed gender facilities; single-occupancy alternative only

🔴 Changing rooms: No access to affirmed gender facilities; single-occupancy alternative only

🔴 Sports and PE: Restricted where safety or fairness is a factor; no exceptions for safety

🟠 Name: Can be changed informally with parental consent and school agreement

🔴 Pronouns: Primary children: no. Older children: expected to be refused in almost all cases

🟠 Uniform: Case-by-case; schools not expected to change policies to accommodate

🟠 Bullying protection: Bullying “must not be tolerated” but limited detail

🔴 Overnight trips: Must share with birth sex or have separate room

🔴 Privacy: Parents must be informed in almost all cases

🔴 Parental involvement: Required in “the vast majority of cases”

🔴 Language: Avoids “transgender”; frames gender identity as “contested belief”

Key: 🟢 Supportive 🟠 Limited or conditional 🔴 Restrictive or denied

Summary

This draft guidance takes a restrictive approach throughout. It frames gender identity as a “contested belief”, avoids using the word “transgender” to describe children, and makes clear there is “no general duty” for schools to support social transition. Parents must be involved in almost all cases, pronouns should rarely if ever be changed, and access to toilets, changing rooms, sports, and sleeping arrangements matching a child’s affirmed gender is effectively prohibited. The guidance emphasises “watchful waiting” and caution, drawing on the Cass Review’s interim findings that social transition is “not a neutral act”.

The detail

Privacy and confidentiality

Will the school tell parents?

What the guidance says: “Where a child requests action from a school or college in relation to any degree of social transition, schools and colleges should engage parents as a matter of priority.” The only exception is “the exceptionally rare circumstances where involving parents would constitute a significant risk of harm to the child.”

If a child simply discloses they are questioning their gender but makes no request for change, “teachers can listen respectfully about a child’s feelings without automatically alerting parents, but, for safeguarding reasons, cannot promise confidentiality.”

What this means: If your child asks for anything at all, you will almost certainly be told. Schools are instructed to inform parents as the default. The threshold for not informing parents is set extremely high: “significant risk of harm”. A child who is not out at home and does not want their parents to know has very little protection under this guidance.

Bathrooms and changing rooms

Will my child be allowed to use the facilities of their affirmed gender?

What the guidance says: “Schools must always protect single-sex spaces with regard to toilets, showers and changing rooms... Responding to a request to support any degree of social transition must not include allowing access to these spaces.”

“Boys must not be allowed to go into the girls’ toilets (and vice versa) in order to protect all children, particularly girls.”

If a child does not want to use facilities matching their birth sex, schools “may wish to consider whether they can provide or offer the use of an alternative toilet facility” which “should be secured from the inside and for use by one child at a time”.

What this means: This is a blanket prohibition. A trans girl cannot use the girls’ toilets. A trans boy cannot use the boys’ toilets. The only option is a single-occupancy alternative, if one exists. The guidance frames this as protecting “all children, particularly girls”, making clear that trans girls are categorised as boys for these purposes.

Sports and PE

Will my child be able to play sports in the team of their affirmed gender?

What the guidance says: “For all sports where physical differences between the sexes threatens the safety of children, schools and colleges should adopt clear rules which mandate separate-sex participation. There can be no exception to this.”

“It would not be safe for a biological boy to participate in certain sports as part of a teenage girls’ team.”

For non-competitive sport, schools should still “prioritise safety” and consider “how safe it would be to allow mixed-sex participation” and “how fair it would be”.

What this means: Trans girls are prohibited from girls’ teams in any sport where safety is considered a factor, with “no exception”. Trans boys may request to play on boys’ teams but this is subject to the school’s assessment of safety and fairness. The guidance applies primarily to older children; “early primary age children” may take “a more relaxed approach”.

Name and pronouns

Will my child be supported in their affirmed name and pronouns?

What the guidance says:

On names: Schools “may allow pupils to change their informal (’known as’) name if they believe it is in the best interests of the child to do so” after “having fully consulted with the child’s parents”. The legal name must remain on the admissions register.

On pronouns: “Primary school aged children should not have different pronouns to their sex-based pronouns used about them.”

For older children: “schools should only agree to a change of pronouns if they are confident that the benefit to the individual child outweighs the impact on the school community. It is expected that there will be very few occasions in which a school or college will be able to agree to a change of pronouns.”

Even when agreed: “no teacher or pupil should be compelled to use these preferred pronouns”.

What this means: Names are possible with parental consent and school agreement. Pronouns are effectively refused for primary-age children and expected to be refused for most older children too. Even when pronouns are agreed, staff and pupils can refuse to use them. The guidance explicitly protects the right to misgender.

Uniform

Can my child wear the uniform of their affirmed gender?

What the guidance says: “A child who is gender questioning should, in general, be held to the same uniform standards as other children of their sex at their school and schools may set clear rules to this effect.”

Schools with flexibility or unisex options may be able to accommodate a request more easily. But “schools would not be expected to develop new uniform policies as a result” of a request.

What this means: If the school already has flexible or unisex uniform, there may be room for accommodation. If not, the default is that your child wears the uniform for their birth sex, and the school is under no obligation to change that.

Bullying

Is my child protected against transphobic bullying?

What the guidance says: “Schools and colleges should be respectful and tolerant places where bullying is never tolerated.”

“In all cases, bullying of any child must not be tolerated. No child should be sanctioned for honest mistakes when adapting to a new way of interacting with another pupil.”

What this means: The guidance says bullying must not be tolerated, but provides little detail on what constitutes transphobic bullying or how schools should address it. The phrase “honest mistakes” suggests that misgendering will generally be treated leniently. There is no specific mention of transphobic bullying as a category.

School trips and overnight stays

Will my child be included and accommodated on residential trips?

What the guidance says: “No child should be allowed to share a room with a child of the opposite sex.”

If a child “does not wish to share a room with another child of the same sex”, schools may seek “alternative arrangements” such as “a suitable separate room”.

What this means: Your child must share with their birth sex or have a separate room. A trans girl cannot share with other girls. The alternative is isolation. This applies to dormitories, tents, and shared rooms.

Parental involvement

Will I be involved in decisions?

What the guidance says: “Parents should not be excluded from decisions taken by a school or college relating to requests for a child to ‘socially transition’.”

“We would expect parental consent to be required in the vast majority of cases.”

What this means: Yes. This guidance places parents firmly in control. Schools are told to engage parents “as a matter of priority” and to require parental consent for most decisions. The child’s own wishes are a factor but not determinative.

The school’s process

What approach does the guidance recommend?

What the guidance says: Schools should “allow for watchful waiting: Wait for a period of time before considering a request, to ensure it is a sustained and properly thought through decision.”

Schools should consider: safeguarding obligations, the view of parents, the age of the child, any clinical information, the “seriousness and context” of the request (including whether the child has been “influenced by peers or social media”), the long- and short-term impact, and the impact on other pupils.

Staff “should not unilaterally adopt any changes, including using a new name or new pronouns, unless or until this has been agreed by the school or college in accordance with the proper procedures”.

What this means: The default is delay and caution. Schools are told to question whether the child has been influenced by external factors. Individual teachers are prohibited from supporting a child until the school has formally agreed. The process is designed to slow things down and raise the threshold for any accommodation.

What’s missing from this guidance?

• Any acknowledgement that trans children exist and may benefit from support

• Any timescale for “watchful waiting”

• Any recognition of the child’s own expertise in their identity

• Specific guidance on transphobic bullying

• Staff training requirements

• Any mention of external support organisations

• Guidance on what happens when parents and child disagree

• Any route of appeal if a request is refused

• Recognition that delay and denial can themselves cause harm

A note on timing

This guidance was published as a draft in December 2023. The consultation closed in March 2024. As of January 2026, it has still not been finalised.

Schools have been left in limbo, many adopting the draft as if it were final, while others wait for clarity. The reasons for the delay have not been explained. Meanwhile, trans children are living with the consequences of guidance that was never meant to be permanent.

Overall assessment

This guidance is restrictive by design. It frames trans identities as a “contested belief”, avoids the word “transgender”, and sets out a process intended to make social transition difficult to achieve. Access to facilities, sports, and sleeping arrangements matching a child’s affirmed gender is effectively prohibited. Pronouns are expected to be refused in almost all cases. Parents are given control, and children’s wishes are treated with suspicion.

The guidance draws heavily on the Cass Review’s interim findings to justify its cautious approach. However, the Cass Review has faced significant criticism from clinicians, researchers, and medical bodies internationally for its methodology and conclusions. Many of the studies it dismissed as “low quality” used the same methods accepted in other areas of medicine. Whether you find the Cass Review persuasive or not, it’s worth noting that this guidance treats its conclusions as settled fact when they remain contested.

For parents of trans children, this guidance represents a significant barrier. Schools that follow it closely will be unlikely to affirm your child in any meaningful way. The language of “watchful waiting” and “safeguarding” is used to justify inaction and delay.

It is also worth noting that this guidance remains in draft form. It has not been finalised. Schools are not legally required to follow it, and some may choose not to. But many schools are already adopting its approach, either in anticipation of final publication or because it aligns with their existing views.

Questions to ask a school using this guidance

1. How long does your “watchful waiting” period last, and what happens during it?

2. What would it take for you to agree to use my child’s pronouns?

3. Where is your single-occupancy toilet, and will using it out my child?

4. What training have staff received on supporting trans pupils?

5. What happens if I give consent but the school still refuses a request?

6. How do you define and respond to transphobic bullying?

7. What support will my child receive while waiting for decisions to be made?

Have a policy you’d like reviewed?

If your child’s school has a trans policy you’d like me to review, send it to me.

The checklist

This review is based on my checklist of questions every parent of a trans child should ask their school. Read the full checklist here: [link to anchor post]

This series breaks down policies into plain English. Each review answers the questions that actually matter and gives you a clear picture of what to expect.

Use the lists below to find the policy you’re looking for, or browse them all in the Policy Reviews section.

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Government guidance

The official guidance that shapes how schools, workplaces, and public bodies approach trans inclusion.

• Gender Questioning Children (DfE draft, December 2023) — The government’s draft guidance for schools in England. Restrictive throughout. [Read review]

• The Puberty Blockers Ban (SI 2024/1319) — UK-wide legislation, January 2025. Prohibits private sale of puberty blockers to under-18s for gender dysphoria. Existing patients protected. Adults unaffected. Review due October 2027. [Read review] 🔴🔴🟠

Schools

What do individual schools actually say in their trans policies? These reviews are for parents, carers, and young people.

Checklist - what to expect from your schools policy.

• Longridge Towers School — Independent school, Northumberland. Follows government draft guidance closely. [Read review] 🔴🔴🟠

• Jersey Transgender Guidance for Schools — Government of Jersey, 2021. Supportive throughout. [Read review] 🟢🟢🟢

• Hillbrook School — Independent school, Queensland, Australia. Exemplary. Student-led, no barriers, grounded in law. [Read review] 🟢🟢🟢

Colleges and universities

Policies for further and higher education. These reviews are for students, parents, and staff.

• Coming soon

Workplaces

Employer policies on trans inclusion. These reviews are for employees, job seekers, and HR professionals.

Checklist - what to expect from your workplace policy.

• Sheffield Health and Social Care NHS Trust — NHS trust, Sheffield. Comprehensive and supportive. Includes non-binary staff, detailed transition support, strong confidentiality. [Read review] 🟢🟢🟢

Healthcare

Checklist - what to expect from your healthcare policy.

NHS trusts, GP practices, and private providers. How do they approach trans patients?

• Haverthwaite Surgery — GP practice, Cumbria, England. Practical and supportive. Clear on names, pronouns, records and referrals. Strong on screening continuity. [Read review] 🟢🟢🟠

Other organisations

Sports bodies, membership organisations, charities, and more.

• Coming soon

How these reviews work

Each review follows the same format:

• At a glance — Traffic light summary of key areas

• The detail — What the policy says and what it actually means

• What’s missing — Gaps and silences in the policy

• Overall assessment — The big picture

• Questions to ask — What to raise with the organisation directly

Reviews are based on my checklist of questions every trans person (or their parent, or their employer) should be asking. Read the checklists here:

• For parents of trans children: [link to anchor post]

• For trans employees: coming soon

• For trans students: coming soon

Request a review

Is there a policy you’d like me to review? Send it to me and I’ll add it to the list.