For the attention of the members of the PCPB

As psychological professionals and stakeholder organisations committed to justice and anti-oppressive practice, we, the undersigned, are raising our concerns about the process by which the draft conversion therapy guidance [pcpb.org.uk/consultation-opens-into-conversion-pra...] has been reached, its contents, and how the current consultation is being undertaken.

-Lack of clarity and understanding of specific cultural contexts will put trans+ people at risk.

-Canvassing public opinion on such a sensitive and misunderstood topic is inflammatory.

-From start to finish, the production of these guidelines seems to have wilfully avoided existing expertise and evidence.

-Instead, the process appears to have included those who wish to continue practicing conversion therapy as co-creators of the guidance.

-The guidance backs concerning loopholes around healthcare exemptions in the conversion therapy ban that experts in this field are attempting to close.

-It does not draw on best practices informed by expert voices, but rather on desired practices shaped by political and lobbying interests.

-It is now opening the door to those interests decimating an already weak document further.

-It does not make reference to or build upon similar best practice guidance from other countries, e.g. the Netherlands.

Although this impacts all LGBTQA+ people, the current “culture wars” context means there is a political element to how the trans+ community has been treated in this process. In addition, much of what we say here is mirrored in the experience of asexual people, who face similar risks of being subjected to conversion practices in the guise of healthcare.

We note that putting something out to public consultation at a time of rising ill-will towards trans+ people, fomented by populist vested interests, will ensure that responses that seek to erase trans+ voices will outweigh the voices of trans+ therapists and trans+ clients, and this, therefore, is not a justice-informed process, nor an ethical one. We note also there is no way in the feedback document to demonstrate clinical or lived experience that might allow the feedback to be sifted or weighed.

Trans+ people have been damaged in the UK by repeated public consultations, which have increasingly been used to push back on appropriate support and accommodations, in a climate of misinformation and trans+ erasure. These successive public consultations appear to have been used in a strategic manner to push back on rights and freedoms and whip up and entrench misinformation campaigns.

The political ideology that seeks to undermine the robust evidence base for trans+ experiences is alive in the document in phrases such as “Research evidence relevant to some areas of GSRD practice may be evolving, limited, conflicting or contested”. Trans+ existence is often being misrepresented as new and under-researched. This does not reflect the 100 years of academia into trans+ healthcare and experiences, nor the World Health Organisation’s 2019 declaration [1] that we now have enough established evidence to conclude that trans+ experiences are genuine and not a sign of mental illness, nor the robust evidence base GSRD affirmative therapists practice from [2] or the sound academic lineage of their (much misrepresented) work.

We are concerned to learn that the PCPB failed to respond to a 2025 proposal from a member of the original steering group formed to develop these guidelines asking the PCPB to accept the World Health Organisation’s 2019 declaration as an underpinning for this work. This person, we understand, was subsequently excluded from the process despite considerable relevant clinical and research experience. Their rejected proposal and other concerns raised can be read at [docs.google.com/document/d/1uZnQAM39145q-S48KHOmkc...].

We are concerned about the opacity of this process and the lack of involvement from many clinical experts and relevant organisations in the field. In particular, the exclusion of those involved with the Memorandum of Understanding on Conversion Therapy (MoU) [3], who have been working tirelessly to bring about the conversion therapy ban, is of great concern to us, as these are the people who know this subject area best.

We do not believe the people who created this guidance were better placed than existing experts in the field and established academia to produce this document. We are concerned that the PCPB positioned itself as an authority in this when they are not well placed to understand the clinical concerns of the populations in question and lack proximity to their context.

We are concerned about the profound lack of clarity in the guidance, that it is not rooted in the evidence base and strives to be “neutral”. We remind you what many have said about neutrality in the face of oppression. Our concern is that affirmative practice has not been specifically mentioned or understood in the document, leaving the door open for bad actors to claim affirmative therapy is itself a conversion practice. Affirmative therapy [4] is a well established and researched, inherently exploratory approach that seeks to counterbalance cultural transphobia, homophobia, etc. with positivity towards LGBTQA+ identities in general. It does not seek to push clients towards or away from any identity.

The document does not address the many concerns [5] voiced by legitimate organisations regarding the exclusion of healthcare practices from the UK government’s conversion practices ban. In fact, the guidance wording allows the possibility of enabling conversion therapy in healthcare settings, in particular endorsing the idea of providing therapy as an alternative to healthcare for some trans+ people, for example trans+ children and adolescents, using the language of “assessment” and “exploration”. There is no evidence supporting this approach, in fact research commissioned following the UK Government's 2016 Transgender Equality Inquiry [6] found current healthcare processes, including prolonged waits, extended psychological assessments and barriers to healthcare for specific demographics of trans people contributed to iatrogenic harm [7]. Something should not be in a clinical best practice document just because it is politically expedient or currently practised. Nor can an assessment where the clinician holds power over patient outcome ever be freely exploratory in nature. Currently, trans+ healthcare assessments have inherently predetermined outcomes in which some demographics of trans+ people will be denied the right to their first-person authority [8].

The provision of psychological support to trans+ people on the waiting list for healthcare has become a de facto form of conversion therapy, in that it is being provided instead of the various avenues necessary to reduce the waiting list, and the wait, sometimes up to a decade in length, has become politically desirable, even though it is costing trans+ lives [9].

Finally, the wording in the document when it comes to children and adolescents is at its most opaque, and the document shies away from stating the clear benefits of respecting trans+ children and adolescents’ self-stated identities, even if they evolve and change. There is an overall conflation in the document between the choices a trans+ child/adolescent might be able to make and the facts of their trans+ experience. It is clinically well established that trans+ children and adolescents experience being assigned into a social gender category by society differently than cisgender children and adolescents do. We understand what clinical best practice [10] looks like with regard to trans+ children and adolescents; good psychological outcomes follow from allowing their identities to emerge without coercion in any direction and offering them support and social accommodation. We disagree that this fundamental respect for children and adolescents’ experiences and stated identities should be age dependent or arbitrated by therapists. We know that for most trans adults, awareness of trans+ identity begins in childhood [11] and generally takes time to be vocalised. Trans+ children and adolescents, as with adults, are a diverse group and it must not be assumed what interventions they will need or should have.

Given that the UK Government’s recent school guidance refuses to acknowledge trans+ children and adolescents and only refers to those “gender questioning”, even when they might have been stable in their social transitions [12] for multiple years, and given that, against all global clinical best practice, UK trans+ children and adolescents are being prescribed therapy as an alternative to being allowed to be themselves, it would seem that the guidance document is treading a line of being swayed by political pressures, however harmful, rather than truly offering best practice guidance based on up-to-date knowledge from those with clinical and academic expertise in this area.

As with all clients of all identities, trans children, adolescents and adults deserve a therapeutic relationship of trust and respect, where therapists are mindful of issues of power and autonomy, are practicing within their competence and have a deeply embedded understanding of transness from having immersed themselves in diverse client contexts through CPD and reflection, and truly listened to the lived experience of diverse trans+ people.

To conclude, we reject this document and the process that led to it, although we do encourage people to still give individual feedback. Nevertheless we demand from PCPB that a more robust process is engaged in, led by those with excellent clinical and research experience of the populations most affected, as well as centring people of lived experience and not allowing their oppression to be a matter of debate by those who lack experience and understanding.

References

[1] World Health Organisation (2019) Moving one step closer to better health and rights for transgender people. (who.int/europe/news/item/17-05-2019-moving-one-ste....)

[2] Neves, S. (2023) The big issue: Are you GSRD competent? Therapy Today. (bacp.co.uk/bacp-journals/therapy-today/2023/june/t....)

[3] BACP (2026) Memorandum of understanding on conversion therapy in the UK. (bacp.co.uk/about-us/advancing-the-profession/influ....)

[4 ] Hope, S. (2021) What is Affirmative Therapy? (sam-hope.co.uk/wp-content/uploads/2021/10/affirmat....)

[5] Transactual (2026) Bill to ban conversion practices reads like an instruction manual for abuse. (transactual.org.uk/blog/2026/06/25/bill-to-ban-con....)

[6] House of Commons Women and Equalities Committee (2016) Transgender Equality: First report of the session 2015-16. (publications.parliament.uk/pa/cm201516/cmselect/cm....)

[7] Holti, R Callahan, E., Fletcher, J., Hope S., Moller, N., Vincent, B., and Walley P., (2023). Improving the Integration of Care for Trans Adults, Final Report. Health and Social Care Delivery Research. (journalslibrary.nihr.ac.uk/hsdr/EWTA4502#/abstract....)

[8] Bettcher, T. (2024) Trans identities and first-person authority. (taliamaebettcher.com/publications/trans-identities....)

[9] Good Law Project (2026) Trans people are dying of suicide more than the general UK population, data shows. (goodlawproject.org/trans-people-are-dying-of-suici....)

[10] de Vries, A. L. C., Steensma, T. D., Kreukels, B. P. C., van de Grift, T. C., van Mello, N. M., & Hannema, S. E. (2026). The Dutch approach for transgender adolescents; past, present and future perspectives. European Journal of Developmental Psychology, 1–23. (https://doi.org/10.1080/17405629.2026.2615311)..)

[11] Turban J, Dolotina B, Freitag T (2023) Age of Realization and Disclosure of Gender Identity Among Transgender Adults. Journal of Adolescent Health, 72, 852-859. (https://doi.org/10.1016/j.jadohealth.2023.01.023)..)

[12] Cool2BTrans (2026) Trans kids are no longer safe in UK schools. (youtube.com/watch?v=2oQKPYs4k58.%C2%A0).....)

Further reading

Florence Ashley, Neeki Parsa, Til Kus, Lee Leveille, Ky Schevers & G. Nic Rider (2025) Gatekeeping gender-affirming care is detrimental to detrans people, International Journal of Transgender Health, 26:1, 235-252, DOI: 10.1080/15532739.2025.2462582 (florenceashley.com/uploads/1/2/4/4/124439164/ashle....)

McDermott,E.,Schaub,J.,Stander,W.J.,Reid,B.,Taylor,A.B., Eden,T., M., Hobaica,S., Kofke, L., Jarre, B.A., Suredini, K., & Nath, R. (2024) United Kingdom Report on the Mental Health of LGBTQ+ Young People. West Hollywood, California: The Trevor Project. (thetrevorproject.org/survey-international/uk/2024/....)

Schofield, K., Dunnett, A., & Gabriel, L. (2024). Let me be me: Investigating transgender clients' experiences of their therapeutic relationship with their counsellor. Counselling and Psychotherapy Research, 24, 582–590. (https://doi.org/10.1002/capr.12692)..)

The Trevor Project (2023) It’s Still Happening: A Report on Practitioners of So-Called Conversion "Therapy” in the U.S. (storage.googleapis.com/trevor-web-public/2023/12/F...)

Trans Youth Trajectories (2026) It Is False to Say That Medical Transitions Worsen Young People’s Mental Health (trajectoiresjeunestrans.fr/en/news/it-is-false-to-...) 

Turban J L, Beckwith N, Reisner S L and Keuroghlian A S (2020). Association between recalled exposure to gender identity conversion efforts and psychological distress and suicide attempts among transgender adults. Jama Psychiatry, 77(1), 68-76. (pmc.ncbi.nlm.nih.gov/articles/PMC6739904/).....)