The Puberty Blockers Ban: What does the law actually say?
A review of the legislation restricting access to puberty blockers for trans young people.
Legislation: The Medicines (Gonadotrophin-Releasing Hormone Analogues) (Restrictions on Private Sales and Supplies) Order 20241
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
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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