Why we oppose the Conversion Practices Bill

CAN-SG has serious concerns about the draft Conversion Practices Bill.

A parliamentary committee is scrutinising the Bill, and it wants to hear from people the bill would affect. The deadline for submissions is 16th November 2026 at 5pm. Sex Matters has a useful guide for submitting evidence.

Our concern is that the Bill is so widely drafted that it risks bringing ordinary, non-abusive parenting, counselling and professional practice within its scope.

Under the Bill, a conversion practice is any conduct intended to change a person’s sexual orientation or transgender identity, or their belief that they have one. An offence is committed if the abuse causes serious harm, or alarm and distress that affects day-to-day activity. The maximum sentence is five years in prison.

In summary, the Bill:

is very broadly drafted, covering “any conduct” by anyone towards an individual
does not define abuse, leaving that to the courts
makes no distinction between adults and children. It applies adult coercive control concepts to the relationship between parents and children, ignoring the fact that good parenting may include exercising control
sets a low threshold for harm: “alarm or distress” with a substantial adverse effect on usual day-to-day activities is enough
requires no intention to cause harm and no pattern of behaviour, so a single conversation, refusal or rebuke could be enough
has no exception for parents and only a narrow one for healthcare professionals
has no defence of reasonableness. A parent acting reasonably, or people following the law or regulations such as the Equality Act, workplace regulations or schools’ statutory safeguarding guidance, could not use these as defences
embeds contested terms like “transgender identity” in law, biasing it against those who do not believe in that concept
defines “transgender” to include any possible gender identity. According to the Bill: “The circumstances in which an individual has a transgender identity include (but are not limited to) where (a) the individual is undergoing, is proposing to undergo or has undergone a process of gender reassignment, (b) the individual is transsexual, or (c) the individual identifies as neither male nor female or as not solely male or female.”
undermines human rights including freedom of speech, belief and religion, the right to privacy and family life, the right to a fair trial, and the right to know what crime you are at risk of committing (see the Gay Men’s Network report for further analysis of human rights implications).

The Sex Matters briefing, Who will be criminalised?, sets out situations in which ordinary people could face investigation and potential prosecution if the Bill becomes law, or be made subject to a “conversion practice protection order”.

As Helen Joyce of Sex Matters said in her recent substack article:

The main effect of the new law would probably be a chilling effect, as people changed their behaviour in order to avoid being caught in this extraordinarily widely cast net. For trans-identifying children this will be a slow-motion disaster. Their parents are the only people who stand between them and ideas that a t best seriously interrupt their normal psychological and social development and at worst put them on the path to irreversible physical harm and lifelong medicalisation. It’s already extraordinarily difficult for parents to counter the myriad influences pushing susceptible children towards trans identification. The threat of criminal prosecution will be the final element making it pretty much impossible.

Government assurances

In an article in The Independent on Sunday on 18th October, Bridget Phillipson, Minister for Women and Equalities, wrote that the draft Bill “will not impinge on” people’s freedom of expression, religious practice or decisions about how to parent, because “the legal bar set is high”.

Other officials have repeated those assurances, and the draft impact assessment says: “The government is committed to developing legislation that avoids any ‘chilling effect’ on legitimate clinical practice, and does not risk unintended consequences on the ability of parents, teachers, counsellors and healthcare practitioners to have open, exploratory, and even challenging, conversations with those exploring their sexual orientation or gender. The government has drafted a targeted and proportionate draft bill, which fills the legal gaps while remaining tight in definitions and scope.”

These statements are not reassuring. The draft Bill is not targeted and proportionate; it is not tight in definitions and scope; and its proponents have failed to identify the legal gaps they want to close.

Challenging conversations, by their nature, can cause alarm or distress. Nothing in the draft Bill protects normal parenting, which may include boundary setting, restrictions and disagreements. The Bill draws on “coercive control” law, but that does not apply to the parent–child relationship. As Helen Joyce of Sex Matters said when giving evidence to the Bill committee: “If my husband takes my phone away from me because he doesn’t want me contacting people, that’s coercive control. If I do that to my child, that may be responsible parenting.”

For the same reason, the Bill will not provide “clarity and confidence” (as the impact assessment claims) to those in safeguarding roles such as teachers. It remains unclear what would count as an offence, and how teachers and others should handle clashes with guidance such as Keeping Children Safe in Education (KCSIE). Would telling a child they can’t use the bathroom of the opposite sex count as intending to cause the child to believe they were not transgender?

No evidence of a gap in the law

Most people understandably oppose conversion practices because they are thinking of abusive practices like aversion therapy. These, and other cruel, violent or coercive practices, are already illegal, and the government has provided no evidence of abusive practices that are not. Surveys indicate that some people are subjected to forced marriage, coercion, child cruelty, false imprisonment, exorcisms, threats of violence or actual violence. What victims need is support, including support to bring charges, not new legislation.

The Bill’s drafters admit in the draft impact assessment that they have no good data on the nature or prevalence of abusive conversion practices in the UK. They blame methodological challenges and the alleged hidden nature of conversion practice, and claim that more robust research designs, such as randomised controlled trials, have not been possible.

But randomised controlled trials are for clinical interventions, not epidemiological studies. There are robust study designs they could have used, but did not. UK research, including research commissioned by the government, is characterised by sources of bias such as unrepresentative samples, self-reporting based on recall, no clear definition of conversion practices, no data on when they occurred, and a failure to distinguish between abusive and non-abusive practices.

The government’s National LGBT Survey (2018) done in 2017 found that 2% of respondents said they had undergone conversion practices and a further 5% said they were offered them. Although this survey was very large, with over 100,000 LGBT+ respondents, it relied on a self-selecting sample. It was therefore not an accurate measure of prevalence, as the sample may not be representative of the LGBT+ population. Other problems with the survey included no clear definition of ‘conversion therapy’, so we don’t know what the respondents were describing or whether the practices were abusive, and no indication of when the practices happened, so some could have been many years ago. A larger number of transgender people said they had experienced conversion therapy, but as non-affirmation was considered conversion those numbers could have included people not being able to access affirmative medical treatments.

The Jowett et al (2021) study commissioned by the UK government found no evidence of the prevalence, nature and effects of conversion practices in the UK, with only one study on sexual orientation based on interviews with psychiatrists and one case study from 1997 on a transgender patient. Subsequent attempts to gather better data have failed. The 2026 Galop study, unveiled when the draft Bill was announced, was hailed as providing hundreds of cases the Bill would cover. There were not hundreds, and most of the cases described appear to already be illegal, as this Sex Matters critique explains.

Further attempts at assessing the prevalence and nature of abusive conversion practices have failed. The Opinium/Stonewall 2026 survey on which the draft impact assessment based its estimate that there were 75-93,000 conversion practices a year is demonstrably ridiculous as explained by mathematician Dr John Armstrong, and should not be the basis of legislation.

“According to research commissioned by Stonewall, clerics are conducting one LGBTQ+ exorcism for every two religious wedding ceremonies they perform.” wrote Dr Armstrong.

One of the aims of the Bill is to reduce the incidence of mental ill-health allegedly caused by the abusive conversion practices they anticipate the legislation will prevent: “This is due to the preventions of harms understood to be associated with conversion practices, such as suicide ideation, depression and anxiety, decreased self-esteem and increased self-hatred, self-blame for treatment failure, substance abuse and risky sexual behaviour.” according to the draft impact assessment. Yet all the research they cite shows association only, and there could be multiple reasons for those associations.

While the Bill drafters admit that association is not causation that does not stop them claiming a causative relationship and on that basis making a series of implausible assumptions that the legislation would prevent between 28,486 and 35,268 cases of depression each year in England and Wales. The research literature on prevention of depression does not suggest that criminal legislation is an effective means to achieve that. Depression is understood to be complex and multifactorial and to require a multifactorial approach to prevention.

Not only that, but the Bill drafters monetise those assumptions to give an estimate of financial benefit. Their original estimate was of a benefit worth over £3 billion over 10 years. That figure was obviously so ludicrous that they applied an arbitrary 75% reduction for “optimism bias” to arrive at their figure of £783.3 million 10 year benefit. Their highly implausible figures were clearly the result of the fundamentally flawed Opinium/Stonewall survey greatly overestimating cases of conversion practices and the erroneous assumptions that evidence of association is evidence of causation so that eliminating conversion practices would prevent depression. They should have ditched the estimates and admitted they just don’t know, instead of making overblown claims. It is certainly no way to justify new criminal legislation.

LGB organisations are angry that their history of being subjected to abusive practices is being used to promote a Bill that could harm young people with a nascent same-sex attraction. With its poor definitions and no statutory defences, they see the Bill as ideological overreach rather than a carefully targeted response to a clearly defined problem. As the Gay Men’s Network report said:

We assert that gay people are better served by existing criminal law, which has higher maximum sentences, than by the poorly defined main offence proposed by the Bill. We believe the Bill is not about protecting gay people. It is about striking a blow in a culture war.

Polling commissioned by The Christian Institute and conducted by Whitestone Insight shows that public support for a “conversion therapy” ban almost completely disappears once people are told what it could mean for parents and religious leaders. While 57% of Labour voters initially support extending the law, this falls to just 4% when asked if they would still support it if certain scenarios could lead to a police investigation or criminal charges.

Chilling effect on health care providers

The Bill’s drafters say they want to avoid a “chilling effect” on legitimate health care providers. The Bill has an apparent carve-out for health practitioners (clause 1(3)), probably because of the warnings in the Cass Review:

Clinical staff must not feel that discharging their clinical and professional responsibility may expose them to the risk of legal challenge, and strong safeguards must be built into any potential legislation on conversion practices to guard against this eventuality. This will be of paramount importance in building (as opposed to diminishing) the confidence of clinicians working in this area. Any ambiguity could serve to further disadvantage these children and young people rather than support them. (Cass Review page 202 para 17.22)

We don’t believe the health carve-out is strong enough to prevent the chilling effect Dr Cass warned about. It is not a true exemption but another element the prosecution must prove: that the individual’s actions fell “far below the standard reasonably expected of a person in their position.” That standard is not defined, so it will be up to the courts. The carve-out also covers only care given to the individual, and may not extend to training, supervision, research, or conversations with colleagues or parents.

This could affect, for example, GPs, psychiatrists or therapists talking to affirming parents and advising them of the risks of social or medical transition, or advising them to wait until the young person is older as they may not persist in their transgender identity. This could be interpreted as intending to change the child or young person’s belief that they are transgender.

Only a full exemption for health care will prevent a chilling effect.

The chilling effect operates long before anything gets to court. The mere threat is enough, because no one wants to be the test case. Transgender advocacy organisations and academics have repeatedly said that failing to provide affirmative medical care is an abusive conversion practice, and have falsely asserted that this has serious consequences for mental health.

Examples where non affirmation and non medicalisation is equated with conversion. Several were cited in the Bill’s draft impact assessment (DIA)

For example, Royal College of Psychiatrists Position Statement (2018) “[Conversion therapies] may include barriers to gender-affirming medical and psychological treatments”;

Salway (2021) includes as conversion practices “so-called psychotherapeutic attempts to discourage or delay the adoption of gender identities not assigned at birth…”;

Kinitz (2021) conversion practices include “intentional delay of gender non-affirming care to a transgender (trans) or non-binary person”;

Jowett (2021), a key paper cited by the draft impact assessment suggests non-affirmation is conversion therapy: “the grey literature suggests that other forms of conversion therapy may be more specific to transgender people. For instance, there have been reports of people sharing lists online of therapists for parents of transgender children seeking non-affirming therapists.”

Anderson (2023), said conversion therapy “also extends to less overt practices such as prohibiting or unnecessarily delaying gender-affirming health care”

Bettergarcia (2018), cited by Jowett (2021) said: “when the therapist is not affirming of a client’s possible transgender identity” this “provides empirical evidence for the negative effects that conversion therapy efforts…can have on the therapeutic relationship.”

Many clinicians we know have already been accused of conversion practices, and some referred to their regulator, merely for using an exploratory therapeutic approach rather than a gender-affirming one that puts a child or young person on a medical transition pathway. Dr Az Hakeem describes this in the article linked below. Even though the GMC dismissed the case, he gave up practising in this area. As he said: “why take the risk?”

Advocates of medical transition have reported clinicians to regulators. If the Bill becomes law, there is every chance they will test it to its limits, including through private prosecutions. We already know of attempts to find clients willing to complain about their therapist. For example, this post by a journalist on Reddit tried to get information from clients of Dr Anna Hutchinson and Anastassis Spiliadis.

Many clinicians already avoid this area of work, and should the Bill become law many more will. In the Criminalising Conversations qualitative study of therapists, about half said they would quit. Those who remain may practise defensively, avoiding challenging or questioning what may underlie a child or young person’s adoption of a trans identity. This would limit the range of therapists and therapeutic options available to gender-questioning children and young people. We’ve heard from Canada and Australia that since the bans there it is almost impossible to find a “non-affirming” therapist, i.e. one who will not put a child on the medical pathway.

The Bill’s low harm threshold could easily be reached in therapy. . As Peter Jenkins of Thoughtful Therapists said in a personal communication:

For trans activists and their allies to argue that therapy can cause distress is rather like saying that food causes eating. Therapy is about distress, and is a place where distress is likely to be experienced. Therapists do not seek to cause clients to become distressed, but if an issue is important, it will inevitably have strong (often buried) emotions attached to it. In exploring the issue, eg the client’s feelings about their sexed body, then it is likely the client will experience and express distress. This is neither harmful nor gratuitous on the therapist’s part. The difficulty arises because trans activists and their allies wrongly associate experiencing distress, which is a normal part of human life, with undergoing harm. Distress is not necessarily harm. A client’s persistent avoidance of core distress is likely to be harmful over time. Experiencing distress in a safe environment as part of a safe therapeutic process is likely to be healing in the longer term. Avoidance of distress may become pathological in the long term.

Organisations

The Bill is so widely drawn that it could include organisations like CAN-SG. Clause 5, “Offences by bodies corporate and unincorporated bodies”, applies if a “person who is, or is purporting to act as, a relevant officer of the body authorises or permits, participates in, or fails to take all reasonable steps to prevent the commission of the offence, that person also commits the offence.”

It may seem unlikely that an organisation that does not carry out conversion practices, and has no members who do, could be caught up in this legislation. But the truth is we just don’t know, and finding out could be very painful.

We worry we could be targets of vexatious prosecution. CAN-SG has been accused of being pro conversion practices because we questioned the safety, evidence base and ethics of the affirmative medical model and supported exploratory therapeutic approaches (incidentally, what the Cass Review recommended). This led to attempts to get our 2024 conference “First Do No Harm” shut down. Several GPs wrote to the chair of the Royal College of General Practitioners demanding they withdraw permission for it to be held in the RCGP conference centre. The conference went ahead but was heavily protested.

Then in July Amnesty listed CAN-SG as a conversion practices organisation in its (now withdrawn) report A growing threat. The anti-rights movement in the UK.

This makes it clear that no evidence whatsoever is needed to accuse an organisation of conversion practices, and that some are keen to do so. Private prosecutions require no legal standing (no personal impact has to be shown), do not need for the consent of the Crown Prosecution Service, and carry no financial risk for the claimant. Even if a prosecution ultimately failed, defending ourselves would be expensive, time-consuming and stressful. As with other attempts at cancellation, even failed ones, “the process is the punishment”, and it could lead an organisation to close down because the risk is just not worth it.

We believe that the case for legislating for gender identity conversion practices beyond existing criminal law has not been made: the evidence offered does not establish that abusive practices occur which current law doesn’t already cover. Against that thin case, the bill’s wide scope, imprecise definitions and its treatment of gender identity create foreseeable harms for families, professionals and the young people it is meant to protect.

The government should abandon this Bill and instead explore non-legislative options as suggested in Option 2 in the draft impact assessment. This would help gather good quality evidence on whether and to what extent abusive conversion practices that are not already illegal are taking place, and also provide support for anyone who has experienced abusive treatment.

Its important that as many people as possible from all walks of life, be they parent, clinician, teacher or anyone else who may be affected by the legislation submit written evidence to the pre-legislative scrutiny committee. The deadline for submissions is 16th November 2026 at 5pm. See Sex Matters guide for submitting evidence.

Resources and further information

Websites

See the Sex Matters campaign website for a summary of the main problems with the Bill, advice on how to submit evidence to the committee, interviews and podcasts, and a report of the first evidence session to the pre-legislative scrutiny committee where Helen Joyce of Sex Matters, Dennis Kavanagh of Gay Men’s Network and Dermot Kehoe of LGB Alliance gave evidence.

The Transgender Trend website includes information on potential impact on schools and social services – see also Sarah Phillimore briefing below.

Briefings and reports

Not what it says on the tin: Report on the draft conversion practices bill 2026 Akua Reindorf KC and Baroness Kishwer Falkner

Gay Men’s Network legal analysis of the draft Bill

In this briefing Family Law barrister Sarah Phillimore explains the potential impact on families, child protection and local authorities

Criminalising conversations. Report by Matilda Gosling on potential impact of the Bill on therapists

Interviews, webinars and podcasts

Filia webinar – The conversion practices Bill: everything you need to know, with Stephanie Davies-Arai, Sarah Vine KC, Dr Louise Irvine, chaired by Sonia Sodha

Sarah Vine KC analyses the bill on Double Jeopardy podcast

Psychotherapists Sue and Marcus Evans talk about the CP Bill

Parent of detransitioner warns agains trans law “We would have been jailed”