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Conversion therapy consultation: LWD guidance

LWD guidance for conversion therapy consultation responses


Firstly, and most importantly, if you haven’t already done so, e-mail your MP as soon as possible using Sex Matters’ pro forma, to urge them to press pause on this consultation. THIS IS URGENT – don’t delay!

Answering the consultation

You can download the consultation document, with numbered paragraphs, here.

To answer the consultation, go here.  Please do submit a response, however brief, by the closing date/time of 23.45 on Friday 10 December.

A.  Question Zero

Before the numbered questions, respondents are asked: “Do you agree or disagree that the Government should intervene to end conversion therapy in principle?”

This is the place to make objections to the whole way this consultation is framed.  Naomi Cunningham’s talk to Middle Temple has clear thoughts about the need for evidence of harm and a convincing case that the harm is amenable to legislation before creating law.  The lack of a good evidence base concerning the existence of, and harm related to, current conversion therapy practices can be included here.  Sex Matters have published an excellent analysis of the poor quality of the research used (pdf downloads from here).

In relation to sexual orientation, there is little, if anything, that can be banned that isn’t covered under existing criminal legislation.

The Cass Review (‘Independent review of gender identity services for children and young people’) is underway and will report some time next year.  It seems very muddled to try to legislate on ‘conversion therapy’ before that Report, as it may impact on some aspects, concerning talking therapies.

B.  Main Questions

The most important questions to answer are Question 2 and Question 4.  If you have time and energy for more, please also answer Question 16 – and of course, any other questions you are up for responding to.

Question 2 The Government considers that delivering talking conversion therapy with the intention of changing a person’s sexual orientation or changing them from being transgender or to being transgender either to someone who is under 18, or to someone who is 18 or over and who has not consented or lacks the capacity to do so should be considered a criminal offence. The consultation document describes proposals to introduce new criminal law that will capture this. How far do you agree or disagree with this?

Paragraph 37 refers to it being ‘legitimate’ to provide talking therapy to those who are ‘questioning’.  It is well known that those – children, adolescents and adults – who present to gender clinics insist that they are absolutely certain of their ‘gender identity’, even when they have clear mental health problems, histories of trauma, etc that detransitioners and desisters have explained were the real reasons behind their seeking transition (as a perceived way out of psychological pain).  It is precisely because of those mental health issues that it is so essential that those presenting with gender dysphoria, an intention to ‘transition’ etc should engage with neutral, exploratory counselling or psychotherapy before making any potentially irreversible decisions.  This is an issue that is likely to be addressed by the Cass Review Report, making it particularly important that no legislation is initiated until after that is published.

You will have noted that the question itself refers to ‘being transgender’ as if this were something that is as real as ‘being tall’.  It is crucial that the notion of it being some innate characteristic is not allowed to pass unchallenged.

Thoughtful Therapists outline the issues comprehensively – the Executive Summary may be particularly helpful in answering this question.

Maya Forstater discusses some of the issues in this article.

Question 4 Do you think that these proposals miss anything? If yes, can you tell us what you think we have missed?

The proposals entirely fail to provide definitions for the key terms being used: ‘gender identity’, ‘transgender’, ‘being transgender’.  There is no external reference point for these terms, which are entirely subjective assumed identities.  This is unscientific, and the lack of clarity will make for poor legislation.  It is also most concerning that these terms will be enshrined in legislation  without precise understandings of what is meant.

Question 16 There is a duty on public authorities to consider or think about how their policies or decisions affect people who are protected under the Equality Act 2010. Do you have any evidence of the equalities impacts of any proposals set out in the consultation?

Making it harder for counselling and psychotherapy to be provided for young people is likely to have serious impacts most particularly for girls, especially given the known ‘social contagion’ issues.  If no discussion of a claimed transgender identity is permitted, the likelihood of rapidly spreading ROGD (rapid onset gender dysphoria), as has been documented by Lisa Littman and others, is strong.  This would be an equalities impact on the protected characteristic of sex.

There is also considerable evidence (particularly, but not solely, from desisters and detransitioners) of peer and social pressure on young lesbians and gay males to ‘transition’, and it is only through exploratory psychotherapy that it is possible to ensure that there is no serious impact of an effective ban on talking therapies on those with the protected characteristic of sexual orientation.

FOR MORE INFORMATION and help in answering ALL the questions, take a look at Transgender Trend’s excellent guide here.


Thank you for your help in the effort to prevent the ‘affirmation only’ approach becoming the only approach for those claiming a transgender identity.  This is especially important for children and adolescents, whose lives would be changed forever by hormonal medication and later surgery. 


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