Dear UKCP,

We are writing in response to your recently published statement on the law regarding so-called ‘gender-critical’ views and its implications for the practice of psychotherapy and psychotherapeutic counselling. We are a group of over 100 registered therapists and trainee therapists, some of whom are trans, non-binary and/or gender-expansive people and some of whom are allies. We note that trans voices are palpably absent from UKCP’s statement and hope that this letter goes some way towards correcting the balance of discourse in the psychotherapy and counselling profession, which routinely discusses trans lives without centring the voices and lived experiences of trans people themselves.

Introduction

We were concerned by the publication of UKCP’s statement, which has created confusion and fear within both the profession and trans communities. We wonder why the statement was published at this time, with no explanation of its place within or alongside the UKCP Code of Ethics and Professional Practice (2019) and the Memorandum of Understanding on Conversion Therapy (2022), of which UKCP is a signatory.

Although not all of our members are registered to practise with UKCP, many are, and our stance outlined in the above paragraph is consistent with several points in UCKP’s Code of Ethics and Professional Practice (2019), specifically:

Point 3: Respect your client’s autonomy (p.1).

Point 24: Understand the limits of your competence and stay within them in all your professional activity, referring clients to another professional when appropriate. This includes recognising that particular client groups, such as children and families, have needs which not all practitioners are equipped to address (p.3).

We believe that therapy which affirms trans, non-binary and gender-questioning clients has the power to save lives. There is overwhelming evidence that gender-affirming care can improve mental health and general wellbeing, whilst decreasing risk of suicide (Lawson et al, 2023). We advocate for an affirmative approach, in which the therapist supports the client’s right to define themselves. Affirmative therapy is exploratory in nature. However we are concerned that the term ‘exploratory therapy’ is increasingly being used to justify therapy undertaken by those with so-called ‘gender-critical’ beliefs. We believe that unless a therapist holds the view that being trans is one of many potentially favourable and healthy outcomes, they are not competent to work with gender in the therapy room. Any ‘exploratory’ approach that does not consider transness to be as good as any other state of being, and which seeks to uncover and possibly ‘fix’ the ‘reason’ for the client’s gender identity is conversion therapy.

As with any marginalised client group, therapists have the task of unlearning preconceptions or pre-decided theoretical ideas regarding a client’s identity in order to work safely and effectively. Consider, for example, the similarities with lesbian, gay or bisexual affirming practice, where therapists are asked to examine and unlearn unconscious biases about sexuality, and to refer clients on if this is not possible (point q, section 5, UKCP, no date). It should be no different for gender identity and gender-expansive experiences.

Simply put, we consider it exceedingly difficult for therapists to hold the dual position of having ‘gender-critical’ beliefs whilst offering genuinely ‘exploratory therapy’ with trans, non-binary and gender-questioning clients. We are concerned that this is not the view UKCP presents to its members and the general public with its new statement. To position therapists with ‘gender-critical’ beliefs as the main proponents of 'exploratory therapy' is highly misleading.

Memorandum of Understanding on Conversion Therapy

TACTT wishes to understand why UKCP has published this statement now and what purpose it is intended to achieve. We would like to remind UKCP that, as a signatory of the Memorandum of Understanding on Conversion Therapy (MoU, 2022), you are already bound to an ethical stance on working with gender diversity:

Ethical practice in these cases requires the practitioner to have adequate knowledge and understanding of gender and sexual diversity and to be free from any agenda that favours one gender identity or sexual orientation as preferable over other gender and sexual diversities. For this reason, it is essential for clinicians to acknowledge the broad spectrum of sexual orientations and gender identities and gender expressions. (MoU, 2022, p2; emphasis added)

Indeed, point 36 of the UKCP Code of Ethics and Professional Practice (2019, p.4) specifically highlights that practitioners should be familiar with the Memorandum of Understanding on Conversion Therapy (MoU) (2022). We are concerned by the stark omission of the MoU in this statement. We are also concerned to find a discrepancy in point 30 of UKCP’s own Code of Ethics and Professional Practice:

'Not allow prejudice about a client’s sex, age, colour, race, disability, communication skills, sexuality, lifestyle, religious, cultural or political beliefs, social economic or immigration status to adversely affect the way you relate to them.' (UKCP, 2019, p.4)

We notice that gender is not included in these protections and wonder why? As a signatory of the MoU, UKCP is committed to the protection of gender diverse people. May we remind UKCP that ‘gender reassignment’ is still a protected characteristic under the Equality Act (2010).

We request more clarity on how UKCP members should act on the information provided in the statement - is it guidance, or policy? How should this statement be observed and put into practice with clients whilst UKCP’s members abide by the UKCP Code of Ethics and Professional Practice and the Memorandum of Understanding?

An exploratory approach?

We disagree that an ‘exploratory’ psychotherapeutic approach is likely to be taken if a practitioner has sympathy with ‘gender-critical’ views (Ashley, 2023). We also find UKCP’s definition of ‘exploratory therapy’ to be unclear. It has already, in the short time since the publication of its statement, created confusion and distress for clients and the wider trans community.

Whilst case law has confirmed that ‘gender-critical’ beliefs are protected under the Equality Act 2010, the expression of such beliefs is not protected if it causes harm or distress to another. The ‘gender-critical’ belief that sex is binary and immutable translates into a belief that trans identities are not valid. We agree with the MoU (2022, p.2) that ethical practice when working with gender requires clinicians ‘to be free from any agenda that favours one gender identity […] as preferable over other gender […] diversities.’ Thus, when therapists work from the starting point that being trans is not a favourable outcome and are constantly looking for an ‘explanation’ for someone’s identity, this can easily tip into conversion practices. How can a therapist, who does not believe that a trans person is who they define themselves to be, conduct therapy ‘without any preconceptions or pre-decided theoretical framework regarding the person’s gender identity’ (UKCP statement)?

To work with gender ethically and competently, therapists must accept that being trans is a good state of being and a good outcome - one of many possible, valid outcomes, none of which is preferable to another. Furthermore, any movement towards one of many possible, valid outcomes should always be determined by the client.

While we agree that practitioners will often hold differing views on what approach is in the best interests of our clients, what is missing from this statement is any acknowledgement of what the client wants, needs or feels. Clients who are trans, non-binary and gender-questioning do not always present with ‘dysphoria’ and when they do this term means different things to different people. It is vital that we follow our clients’ lead and explore what they want to talk about. In general, therapists are not medical gatekeepers and, outside of gender services, we do not play a role in whether or not clients can or should access medical care. It is our role to support clients’ sense of agency in defining themselves. It is not our job to greenlight our clients’ gender journeys but to be with them as they figure out where they go.

Research by Hunt (2014) found that therapists’ lack of awareness and competence in working with gender can be a barrier to trans people accessing the support and space for exploration they may require from therapy. Indeed, therapists may not actually be someone their clients choose to share their gender journeys with. But the chances of this are more likely if clients feel able to bring all of themselves. Again, we emphasise that trans voices are noticeably absent from UKCP’s statement, which appears to prioritise the right of the therapist to assert an approach that ‘is in the best interest of their clients’ over the actual needs and desires of their clients.

Misleading and contradictory

We found UKCP’s statement to be misleading and contradictory in several ways. First, we are concerned that by leading with a reference to the interim Cass Review and its implications for UKCP members, and then continuing to reference medical interventions for children and young people, it replicates a hyperfocus on trans children and young people which excludes their voices whilst contributing to public hysteria. Furthermore, therapists who are not informed about the Cass Review and its specific emphasis on children and young people may, having read UKCP’s statement, now take this as direction to hold a particular stance in relation to providing psychotherapeutic support to adult clients.

Secondly, we find that overall UKCP’s statement conflates working psychotherapeutically with being directly involved in any medical care trans clients may wish to consider and access. Psychotherapists and psychotherapeutic counsellors are not medical professionals. Outside of specific Gender Identity Clinics, therapists are not involved in any decision-making about gender-affirming medical care. This is the case regardless of whether we find ourselves supporting children, young people, or adults. This continues to be the case even if a client self-defines as experiencing gender dysphoria (in whatever language they may use), has a medical diagnosis of gender dysphoria, or may be seeking a gender dysphoria diagnosis for any number of reasons.

However, thirdly, this statement unnecessarily centres the concepts of gender dysphoria and medical intervention, as though these are the only experiences of being trans in the world. It is incorrect, disrespectful, and reductionist to regard all trans, non-binary and gender-questioning clients as experiencing gender dysphoria and/or seeking gender-affirming medical intervention. Doing so dismisses the incredible diversity of what it means to be trans, non-binary or gender-expansive, and to experience oneself authentically and euphorically. This statement reads as though it has been written by people who have never worked with trans, non-binary and gender-questioning people. As per point 29 of UKCP’s Code of Ethics and Professional Practice (2019, p.4), we urge you to expand your knowledge of transness, to honour the diverse narratives of trans people, and to make space for other experiences, such as gender euphoria and trans joy.

Reductive and pathologising

We find the UKCP Chair’s use of the term ‘gender issues’ in this statement to be reductive. By placing this alongside ‘mental health conditions and emotional issues such as depression, eating disorders and relationship difficulties’, UKCP treats gender diversity as problematic and pathological and ignores the creativity, potentiality and joy that can be found in working with trans, non-binary and gender-questioning clients. The Chair further reduces working with gender to ‘questioning’, which in our experience is only ever part of a vast, kaleidoscopic landscape of what it means to work with gender in therapy. Many trans people in therapy already know what their gender is; it is living in a world which denies their existence and does violence to their bodies which causes them psychological distress and harm.

We also wish to remind UKCP that trans people may seek therapy for all the reasons anyone seeks therapy and it is important that therapists do not assume clients are only seeking support for gender identity or transition. We work with clients on family issues, sex and relationships, work, bereavement, isolation, anxiety, depression - all the things any client may bring to therapy.

The Chair’s assertion that a ‘thorough exploration’ of gender ‘can take time, and sometimes a very long time’ is highly alarming, and redolent of the potentially harmful concept of ‘watchful waiting’. It suggests that therapists have the power to decide how long a ‘thorough exploration’ should take, all the while clients are held in a place of discomfort and dis-ease. How will the therapist know when enough time has passed? What will tell them that any exploration is ‘sufficiently thorough’? Again, this argument appears to prioritise the approach of the therapist over the agency of the client. As Saketopoulou (Acast, 2022) suggests, “This seems to have more to do with the person who wants to do the watching, rather than the person that is doing the waiting.”

We believe the Chair’s reference to medical interventions has no place in guidance published by a UK psychotherapy body. As we have stated, in the UK, psychotherapists and psychotherapeutic counsellors are not medical gatekeepers; it is not our responsibility to determine ‘risk’ in seeking gender-affirming medical care. UKCP’s statement risks generating panic amongst practitioners and clients by suggesting that it is the therapist’s place to sanction a client’s access to gender-affirming care.

For UKCP therapists who are interested but inexperienced in supporting trans, non-binary and gender-questioning clients, such panic prevents them from learning and offering appropriate psychotherapeutic services. Thus, the pool of competent, safe therapists available to such clients becomes ever smaller.

Furthermore, medical intervention is not the only choice open to trans and non-binary clients, and this reductionist statement does nothing to help wider public understanding of the complexity and nuance of what it means to explore gender or to be trans in the world.

We find the Chair’s closing argument troubling. It creates further concern about UKCP’s stance on how its members should work with gender diverse clients:

Regardless of viewpoints, all professional psychotherapists and psychotherapeutic counsellors who work with gender dysphoria or gender-identity want the best for the person who is struggling and needs help. If this is always kept in mind, these vitally important conversations, however difficult, can take place in a healthy and supportive manner, allowing us to ensure our clients’ and the public’s best interest and safety remain paramount. (UKCP statement)

Can UKCP clarify why safety is a concern for the public in relation to transgender, non-binary, and gender non-conforming people seeking therapy? How will psychotherapists and counsellors know what is ‘best’ for clients? Who defines ‘best interest’? Does this mean respecting our clients’ autonomy? How will UKCP act to protect trans, non-binary and gender-questioning clients from therapists whose ‘gender-critical’ beliefs cannot be bracketed and unduly influence what they believe is in the best interest of the client?

It cannot be said with any certainty that all psychotherapists and psychotherapeutic counsellors who work with gender dysphoria or gender identity want the best for those who are struggling and need help. By definition, therapists who hold ‘gender-critical’ beliefs already disagree on what trans, non-binary and gender-questioning people define as best for themselves.

Overall, UKCP’s statement grossly misunderstands the reality of working with trans, non-binary and gender-questioning clients who seek psychotherapeutic support. There is nothing ‘difficult’ about being allied with our clients’ views on how they feel about themselves, or their expressions of identity in ways that are fulfilling and meaningful. Doing so is simply part of offering psychotherapeutic support in an ethical manner, making space for difference and diversity along the way.

Conclusion

We ask that UKCP clarifies its original guidance and responds to the questions and points we have raised throughout this letter.

We invite you to further your own education on trans experiences and centre trans voices in any future public commentary on trans lives. This can be achieved by consulting with trans and non-binary therapists, as well as practitioners who are undertaking affirmative therapy with trans, non-binary and gender-questioning clients. There are many practitioners in TACTT and beyond who would generously share their experiences in the interest of making emotional and mental wellness a human right for trans people.

Finally, we urge UKCP to reflect on how a ‘gender-critical’ therapist could reasonably, ethically, and legally be able to offer psychotherapeutic support to trans, non-binary and gender-questioning people. We see nothing but risk of harm in this approach.

We fear that if UKCP continues down this path, the council and its members will be considered by clients to be synonymous with being 'gender-critical'. Indeed even in the short space of time since this statement was published, we are already seeing this fear shared amongst trans people. Many practitioners train for a long time to achieve UKCP membership and registration; it is disappointing that those of us who are trans-affirmative are starting to question our place in the organisation.

We invite other psychotherapists and psychotherapeutic counsellors who support this letter to sign below.

Yours sincerely,

Therapists Against Conversion Therapy and Transphobia (TACTT)

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References

Acast. (2022). ‘Exposing Transphobic Legacies, Embracing Trans Life.’ Couched (Podcast) 24 June. Available at: Episode 3, Season 3. iPlayer, 17 February 2023. Available at: couchedpodcast.org/exposing-transphobic-legacies-e...

Ashley, F. (2023). ‘Interrogating Gender-Exploratory Therapy’. Perspect Psychol Sci. 18(2): 472–481. Available at: ncbi.nlm.nih.gov/pmc/articles/PMC10018052/...

Bachman, C. L., & Gooch, B. (2018). LGBT in Britain: Health Report. Stonewall. https://www.stonewall.org.uk/lgbt-britain-health

Hunt, J. (2014). ‘An initial study of transgender people's experiences of seeking and receiving counselling or psychotherapy in the UK.’ Counselling and Psychotherapy Research Journal. 14 (4): 288-296. Available at: onlinelibrary.wiley.com/doi/10.1080/14733145.2013....

Lawson, Z., Davies, S., Harmon, S., Williams, M., Billawa, S., Holmes, R., Huckridge, J., Kelly, P., MacIntyre-Harrison, J., Neill, S., Song-Chase, A., Ward, H., & Yates, M. (2023). ‘A human rights based approach to transgender and gender expansive health.’ Clinical Psychology Forum 369.

Available at: https://explore.bps.org.uk/content/bpscpf/1/369/91

Memorandum of Understanding on Conversion Therapy in the UK: Version 2 - Update March 2022. (2022). Available at: bacp.co.uk/media/14985/memorandum-of-understanding...

UKCP. (2019). Code of Ethics and Professional Practice. Available at: psychotherapy.org.uk/media/bkjdm33f/ukcp-code-of-e...

UKCP. (no date). Guidance on the Practice of Psychological Therapies that Pathologies and/or Seek to Eliminate or Reduce Same Sex Attraction. Available at: psychotherapy.org.uk/media/hhxle33g/guidance-on-ps...