lemkininstitute.com
Statement on the Anti-Trans and Anti-Intersex EHRC Code of Practice in the United Kingdom
June 20, 2026
The Lemkin Institute for Genocide Prevention and Human Security condemns the Equality and Human Rights Commission’s (EHRC) updated Code of Practice for services, public functions, and a...
![Dear Keir and Bridget,
Reject the EHRC’s Code of Practice
| am writing to echo the letter written by the Interim Women and Equalities lead of the
Parliamentary Green Party, Sian Berry, to raise serious concerns over proposed guidance
from the Equality and Human Rights Commission, which is not fit for purpose and will
harm trans people living in the UK.
The Code of Practice for services, public functions, and associations is the culmination
of years of well-funded campaigns to drive a minority group out of British public life. It
sets out a system of segregation where trans people are excluded from services and
spaces that reflect their gender, and in some cases also excluded from services and
spaces that reflect their sex assigned at birth. Where unisex facilities exist, trans people
will be forced into them. Where they do not exist, trans people will be left with nowhere
to go.
Your own Equalities Impact Assessment [1] on the code admits there will be a significant
impact on those with the protected characteristic of gender reassignment - from forcing
trans people to out themselves by using disabled toilets to putting trans women at
greater risk of sexual violence by making them use men’s services.
The Code of Practice is both cruel and confusing. Inconsistencies between the Code of
Practice and its Equalities Impact Assessment, the Gender Recognition Act and the
European Convention on Human Rights will leave organisations and service providers at
risk of litigation from all sides. Frontline staff in spaces like cafes, gyms, and offices will
be forced to police gender, whilst the costs of creating self-contained gender neutral
facilities are estimated by your advisors as reaching £600m, which the government is
providing no funding to cover [2]. | am pleased to see associations, like the Women’s
Institute and Girlguiding, given a potential route to serving trans and cisgender women,
but this does not counteract the pain caused by the majority of the guidance.](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:kcuezkvhtpdlk3vurzkavnye/bafkreifbpmwimf2fd4ugbudos4c4cxw3st6m7ccxwf4642ftfynkfvfa6a)
![By enacting this guidance, trans people will simply be scapegoated. Research by
Translucent found there was just one complaint to English Unitary Authorities in 2025
concerning trans women’s use of single-sex spaces, such as toilets and changing rooms
[3]. By refusing to act, your government is once again playing politics with trans people’s
lives, rather than tackling real problems, like the soaring cost of living, rising inequality
and the ongoing climate crisis.
Trans people of all ages and backgrounds exist in communities across the country - and
always have. They have every right to thrive just as their cisgender friends, family
members,and colleagues do. When Labour brought in the Gender Recognition Act in
2004 it promised trans people they could live their lives with peace, privacy, and dignity.
Now you are breaking that promise.
| believe there is a real risk of trans people being essentially segregated from public
spaces. | urge you to withdraw the code and take legislative action to create an
equalities framework that protects trans people’s safety, dignity and humanity.
Yours sincerely,
Hannah
1 Equality impact assessment. EHRC, May 2026.
https://www.gov.uk/government/publications/equality-act-2010-draft-code-of-practice-for-services-public-
functions-and-associations-2026/equality-impact-assessment
2 Final stage impact assessment, 9. Minimising administrative and compliance costs for preferred option. EHRC,
May 2026. https://www. gov.uk/government/publications/equality-act-2010-draft-code-of-practice-for-services-
public-functions-and-associations-2026/final-stage-impact-assessment#minimising-administrative-and-
compliance-costs-for-preferred-option
3 Trans Women and Single-Sex Spaces: 2026 UK Council FOI Report. Translucent. June 2026.
https://translucent.org.uk/trans-women-and-single-sex-s} < -Uk- il-foi-report/](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:kcuezkvhtpdlk3vurzkavnye/bafkreid2r4kksa456muv7cku6qyokipfwh7bwcpf7tnhzseymjuy3y5zbi)
