Written evidence submitted by Mr Antonio Zappulla [GRA 1705]




About the Respondents

Claire Harvey MBE brings years of public sector, regulatory, corporate and third sector leadership experience, and an impressive record of impact and achievement through positive disruption and culture change. A Paralympian, former Prison Governor who managed a resettlement prison, and former Ministry of Justice Lead for Equality and Diversity, she is also the former Head of Corporate Responsibility and Culture at the FSA (the predecessor to the FCA as the UK’s financial regulator). Claire is also the former Head of Inclusive Leadership at KPMG. Her passion is the future of work; working with both schools, universities and corporate workplaces, I hope to ensure that young people are ready to be great leaders of the future in organisations that have positive cultures.

Krishna Omkar is a corporate lawyer based in London, acting for public and private companies in complex and high value cross-border mergers and acquisitions, private equity, capital markets, and restructuring and insolvency matters. Krishna is named in Legal 500, received an Asian Achievers Award in 2019, and the inaugural Rising Star Award at the British Legal Awards in 2019. Krishna is a recognised thought leader in the field of Diversity and Inclusion, and was also part of a team of lawyers who worked on the successful decriminalisation of same sex relations in India in 2018. He as also named Stonewall’s Role Model of the Year in 2018. Krishna has twice, in 2019 and 2020, spoken at the World Economic Forum in Davos on the topics of Diversity and Inclusive Capitalism. In 2019, he was invited by the UN Under Secretary General for Human Rights to host the UN’s public-private sector consultation on LGBTQI+ Rights in Berlin.


Section 1

  1. Will the Government’s proposed changes meet its aim of making the process “kinder and more straight forward”?
  1. Should a fee for obtaining a Gender Recognition Certificate be removed or retained? Are there other financial burdens on applicants that could be removed or retained?
  1. Should the requirement for a diagnosis of gender dysphoria be removed?
  1. Should there be changes to the requirement for individuals to have lived in their acquired gender for at least two years?
  1. What is your view of the statutory declaration and should any changes have been made to it?
  1. Does the spousal consent provision in the Act need reforming? If so, how? If it needs reforming or removal, is anything else needed to protect any rights of the spouse or civil partner?
  1. Should the age limit at which people can apply for a Gender Recognition Certificate (GRC) be lowered?
  1. What impact will these proposed changes have on those people applying for a Gender Recognition Certificate, and on trans people more generally?
  1. What else should the Government have included in its proposals, if anything?
  1. Does the Scottish Government’s proposed Bill offer a more suitable alternative to reforming the Gender Recognition Act 2004? 

Section 2

  1. Why is the number of people applying for GRCs so low compared to the number of people identifying as transgender?
  1. Are there challenges in the way the Gender Recognition Act 2004 and the Equality Act 2010 interact? For example, in terms of the different language and terminology used across both pieces of legislation.
  1. Are the provisions in the Equality Act for the provision of single-sex and separate-sex spaces and facilities in some circumstances clear and useable for service providers and service users? If not, is reform or further guidance needed?
  1. What issues do trans people have in accessing support services, including health and social care services, domestic violence and sexual violence services?
  1. Are legal reforms needed to better support the rights of gender-fluid and non-binary people? If so, how?

November 2020





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