NHS England Proposes to Remove Hormones for Trans Young People: A Clinical Policy Review
The draft Clinical Commissioning Policy would end new prescriptions for under-18s in England. Here’s what the policy says, what the evidence shows, and how you can respond before 7 June 2026.
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.
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
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
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Please can you explain the reason for and the benefits of gender incongruence being classed as a sexual health condition rather than a mental health condition? Thank you 🙏
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