Written evidence submitted by Ms S Cummings [GRA1748]

Will the Governments proposed changes meet its aim of making the process kinder and more straight forward?


The current process makes it clear to applicants that changing your legal gender is a serious decision that has lifelong consequences. Experts should be involved to guide and assess applicants. It shouldn't be as easy as buying a T.V. Licence, and its a one off expense.

Its no more difficult than applying for PIP as a disabled person. The Govt. needs to treat everyone with the same respect and kindness.


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?


The fee should be retained. Its already means tested.

Lots of people have to pay fees to get a letter from their GP.  Women have to pay fees to get letters about their children's health for school, even if they are on a low income. Either remove fees for everyone that needs the service or charge everyone the same.


Should the requirement for a diagnosis of gender dysphoria be removed?


A formal diagnosis should be retained.

More people say they identify as trans than apply for a GRC and you accept that you don't understand why that is. The pressures for people to conform need to be understood before you make the process easy and free, because this is going to have real life consequences for vulnerable people.


Should there be changes to the requirement for individuals to have lived in their acquired gender for at least two years?


As transitioning involves a lifelong commitment that affects both the person making the change and other people they interact with, it doesn't seem onerous. Its asking people to do the thing they say they want to do anyway.


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?


The rights of the spouse and children need to be protected.

The transitioning partner is asking for a change to the marriage contract. Its a change in the meaning of a 'contract' if one party can demand it is changed retroactively.


Its unfair to offer the spouse anything other than an easy and straightforwards exit clause that reduces the risk of coercion. The couple should divorce automatically, and if they both agree can enter into a civil partnership after the transitioning party obtains their GRC.


Should the age limit at which people can apply for a Gender Recognition Certificate (GRC) be lowered?


No. children should not be able to make such a life altering choice any more than they should be able to get a tattoo.


What else should the Government have included in its proposals, if anything?


An explanation of how single sex spaces and services will be ring fenced as long as people can change their legal sex markers.

Why is the number of people applying for GRCs so low compared to the number of people identifying as transgender?


There is immense social pressure on people to conform so more people say they 'identify' as trans than are transsexual or transgender.

The number of women being reported for a 'hate incident', sacked, or threatened with violence for speaking up for their existing legal rights makes other women afraid to say anything that is perceived as contrary.

Its easier and safer for women to say they identify as trans than to say they are lesbian.


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.


Sex and gender are not interchangeable terms. The correct terminology needs to be used across all Govt. websites and legislation.

Women have specific sex based needs and rights which men don't need, however they identify. 

Peoples sexual orientation is based on sex, not gender or gender markers.

Medical staff should be told a persons sex, otherwise they risk making an incorrect diagnosis and giving the wrong treatment.


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?


Yes they are unclear, and they are now also impossible to enforce. Even in cases where an organisation can use the exceptions, men without a GRC can enter or apply for a job because its considered discriminatory to 'harass' them by asking.

Many women's services are underfunded and oversubscribed, and are afraid to be single sex because of the risk of being sued,. They can't afford for funds to be tied up and to deny the service to all the women who need them.


Women need and have the right to single sex services. They shouldn't have to ask or be places in the position of giving consent for them to be made mixed sex.



November 2020