Policy paper

Draft equality impact assessment

Updated 27 August 2026

This was published under the 2024 to 2026 Starmer Labour government

Applies to England and Wales

Assessment of the impacts on Equality Act 2010 protected characteristics of the draft Conversion Practices Bill

This document records the analysis undertaken by the Office for Equality and Opportunity (OEO), and provided to ministers, to enable ministers to fulfil the requirements placed on them by the Public Sector Equality Duty (PSED) as set out in section 149 of the Equality Act 2010 (the 2010 Act). The PSED requires the minister to have due regard to the need to:

• eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the 2010 Act
• advance equality of opportunity between people who share a protected characteristic and those who do not
• foster good relations between people who share a protected characteristic and those who do not

Policy outline 

This is an initial PSED assessment to be considered by ministers alongside the draft Conversion Practices Bill, to be published for pre-legislative scrutiny. It will be updated as further decisions are made in relation to the draft bill. 

What the government is seeking to achieve 

The government’s position is that conversion practices are abuse. Such practices have no place in society and must be stopped. There is growing evidence on the harm associated with conversion practices, including long lasting damage to those who go through it.^{[footnote 1]}

The intention is to bring forward a new criminal offence banning conversion practices, which acts as an effective deterrent, while also targeting the narrow gap in the existing legislative framework which allows for certain abusive acts to continue.   

This will be supported by an additional criminal offence of encouraging or assisting a conversion practice on a UK national/resident outside of the UK, civil law interventions in the form of Conversion Practice Protection Orders to protect those at risk of harm, as well as a criminal offence of breaching a Conversion Practice Protection Order. 

OEO recognises the complexity of this legislation, and is balancing the need for measures to protect individuals, while ensuring measures are targeted and proportionate. Our draft Conversion Practices Bill is aimed at preventing a very specific form of abuse, which exposes people to significant physical or emotional harm, while attempting to change their sexual orientation or gender identity.

The draft bill will only criminalise abusive, harmful acts which are intended to change a person’s sexual orientation or transgender identity. The offence is designed to enable people to live in accordance with their religious or ideological beliefs and to respect those offering legitimate support or guidance to those exploring their sexual orientation or gender identity. We have also built in safeguards to protect the provision of healthcare.

There will be a clear threshold for offences, to ensure we only capture abusive acts. To be captured cases must meet all 3 of the following criteria:

Intend to change a person’s sexual orientation or transgender identity

Suppression would not be covered. This not only allows people to seek support to live in line with their religious or ideological beliefs but also ensures more innocuous acts are not criminalised.

Amount to abusive conduct

What this abuse looks like will depend on the facts of the case, allowing the courts to recognise the range of behaviours which can amount to a conversion practice. The bill will draw closely on existing areas of the criminal law framework, such as coercive and controlling behaviour, sexual and physical violence, and psychological abuse.  

Cause serious harm, alarm or distress on the person resulting from the abusive conduct

In line with other criminal offences, of actual bodily harm and controlling or coercive behaviour, there must be evidence of harm for an act to be criminalised. 

We have designed the legislation to be symmetrical, which means it covers practices where the attempts aim to change a person from or to LGBT+. 

The draft bill will cover anyone with a sexual orientation within the definition of the Equality Act 2010 (attracted to opposite sex, same sex or both sexes), as well as those who are attracted to none of these groups (asexual people). It will also cover those within the meaning of transgender identity under the Sentencing Act 2020, which itself relies on the definition of gender reassignment under the Equality Act 2010, with additional clarification that our draft bill also provides protections for those who identify as neither male or female, or not solely male or female.  

This assessment of equality impacts relates to the primary legislation changes that the proposed draft bill will make, if enacted, namely to:

• make a new offence of conducting an abusive criminal conversion practice
• bring forward an offence of encouraging or assisting a conversion practice on a UK national/resident outside of the UK
• introduce Conversion Practices Protection Orders and an offence of breaching an order

Headline legislative changes

A new criminal offence targeting conduct that is designed to change another person’s sexual orientation and/or transgender identity, that is abusive, and that causes serious harm, alarm or distress to the victim. 

A new criminal offence of encouraging or assisting a conversion practice on a UK national/resident outside of the UK.

Corporate liability provisions which ensure that prosecutions can be brought against relevant officers of an incorporated or unincorporated body. The legislative ban will therefore act as a deterrent for incorporated and unincorporated organisations offering conversion practice. 

Conversion Practices Protection Orders (CPPO) are civil law orders. They protect individuals at risk of undergoing conversion practices, on application by:

• the individual concerned
• the police
• a local authority
• another party with knowledge of the individual and their situation, if permitted by the court

A CPPO can protect someone without application if the courts consider it appropriate. These would enable a court to impose any requirement it considers necessary to protect someone at risk, which could include a passport being removed from the person in need of protection so they are not taken abroad to undergo conversion practices. Breach of an order would constitute a criminal offence. 

Other policy areas

While this draft bill will not provide explicit changes directly in the following areas, we have factored these into our overall policy approach and so have also considered what the equality considerations are. 

Proceeds of Crime Act 2002

This Act will apply to the new offence and will remove the opportunity to benefit financially from criminal conversion practices.

Charities

A person found guilty of the new offence will be more likely to be disqualified from working as a senior leader in a charity.

Charities found to be carrying out the new offence will be required to cease carrying out the practice, and where no charitable purpose for public benefit is found, the status may be removed from the organisation. 

Online safety

The Online Safety Act 2023 requires in-scope companies to take action to understand and manage harms resulting from illegal content. Once conversion practices are criminalised, content promoting or related to such practices will therefore be prohibited.

Analysis

Data used in this assessment

To better understand the nature of this issue, the government commissioned an assessment of the evidence base, published in October 2021, alongside the public consultation on banning conversion practices.

The evidence base on conversion practices, while relatively limited, has been growing for over 20 years. It is dominated by international studies, mainly from North America, and has historically focused on conversion practices for sexual orientation. While the evidence for gender identity conversion practices is much newer, an increasing number of UK and international studies are now documenting and measuring these practices (Jowett and others 2021). 

Prevalence

There are challenges to measuring the prevalence of conversion practices, largely due to its hidden and complex nature. Incidents of conversion practices are not currently captured in any official statistics or through administrative data sources. Part of the reason for this is that it is not the responsibility of any agency or body to do so. For this reason, people reporting their experience of conversion practices in a survey is likely to be the only source of quantifying its prevalence (see GEO 2021a, Jowett and others 2021). Consequently, existing estimates heavily rely on self-selected samples, and the analytical limitations associated with this. 

The government’s National LGBT Survey (2018) 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 100k LGBT+ respondents, it relied on a self-selecting sample. It is therefore not an accurate measure of prevalence, as the sample may not be representative of the LGBT+ population.^{[footnote 2]} 

Since the National LGBT Survey survey, 4 further studies have been published which have attempted to measure lifetime and, on one occasion, annual prevalence (Stonewall 2021, Galop 2022a, Galop 2022b, Stonewall 2025). Across these sources, estimates of LGBT+ people in Great Britain (England, Scotland and Wales) or the UK who have experienced these practices in their lifetime range from 2% to 30%. Significant methodological variations and differing definitions mean these figures are not directly comparable. More recent data, using more representative survey approaches, consistently suggests that measures of prevalence may be higher than initially reported in the National LGBT Survey.

Of these data sources, only the 2024 survey by Opinium, commissioned by Stonewall, provides a recent annual self-report measure of UK conversion practices from a nationally representative LGBT+ sample (Stonewall 2025).^{[footnote 3]} This suggests that approximately 11% of the LGBT+ population experienced specific types of conversion practices in the previous 12 months (each of 8 actions listed had been experienced by between 2% and 5% of respondents). While this data has limitations^{[footnote 4]}, in the absence of better alternative sources, it represents the best evidence available and has been used to develop an estimation of the prevalence of conversion practices as covered by the bill. 

Harms associated with conversion practices

Recent research, including robust evidence reviews and analysis of large-scale data, shows that conversion practices aimed at changing sexual orientation or gender identity are associated with a wide range of self-reported harms among study populations across mental, physical, and economic domains. These include the following:

Mental health and psychological harm including:

• suicidal thoughts and/or suicide attempts (for example, Tran and others 2024, Mammadli and others 2024, Anderson and others 2023, Campbell and Rodgers 2022, Forsythe and others 2022, Przeworski and others 2021, Turban and others 2020, Blosnich and others 2020, Green and others 2020, Turban and others 2020)
• depression (for example, Tran and others 2024, Anderson and others 2023, Forsythe and others 2022, Przeworski and others 2021)
• substance use (for example, Anderson and others 2023, Forsythe and others 2022)
• post-traumatic stress disorder (for example, Tran and others 2024)
• anxiety (for example, Tran and others 2024, Anderson and others 2023)

Wider psychosocial and relational consequences – robust systematic reviews report that conversion practice severely affects survivors’ lives, leading to family dysfunction, social isolation and loss of essential social support networks. It has also been reported to negatively affect civic participation, the ability to study and work, integration of faith or religion with sexuality and/or gender identity, and can lead to heightened sexual risk taking (for example, see Anderson and others 2023, Glassgold 2023, Przeworski and others 2021).

Physical health – one study found that experiencing conversion practices is associated with adverse cardiovascular health indicators among sexual and gender minority young adults assigned male at birth, including elevated blood pressure, increased systemic inflammation, and higher odds of hypertension (Gibb and others 2025).

Economic impact – an economic analysis in the US estimated the cost of conversion practices at over $650 million a year, with the associated harms creating an economic burden of $9.23 billion (Forsythe and others 2022).

Because experimental or prospective clinical trials are ethically impossible in this field, there is no direct causal evidence tracking these outcomes over time. Instead, the literature relies on strong, consistent correlational data across diverse studies. There is no casual evidence directly measuring the outcomes or impact of conversion practices.

Wider evidence on conversion practices

A 2021 review of evidence^{[footnote 5]} relating to conversion practices for sexual orientation showed that:

• there is no robust evidence that conversion practices can change sexual orientation
• conversion practices tended to be delivered by faith groups and in health settings
• there is consistent evidence of self-reported harms (such as negative mental health effects like depression and suicidality)^{[footnote 6]}
• people’s motivations for seeking conversion practices tended to be associated with conflict about sexual orientation

Studies^{[footnote 7]} looking specifically at conversion practices attempting to change an individual to or from being transgender show that:

• there is no robust evidence that conversion practices can change gender identity
• the types of practices used tend to be similar to those for conversion practices for sexual orientation
• there is some robust evidence of self-reported harms (such as negative mental health effects like depression and suicidality)
• there is indicative evidence that transgender respondents were similarly or more likely to be offered and receive conversion practices, than non-transgender respondents

Limitations 

The main limitations with the evidence base relating to conversion practice include the following.

Evidence on conversion practices is limited due to the hidden nature of these practices. 

There is little representative data on the prevalence of conversion practices in the UK. The 2024 survey by Opinium, commissioned by Stonewall, provides a recent annual self-report measure of UK conversion practices from a nationally representative LGBT+ sample. The National LGBT Survey 2017 and the consultation are both self-selected samples, and may not be representative of any wider population.

The evidence base as a whole is limited by clear methodological challenges in undertaking research on the population(s) of interest. There is a lack of studies which are longitudinal. More robust research designs, such as randomised control trials (used to assess the effectiveness of health interventions) are not possible in this area. Evidence of harm has been identified using interviews and surveys in which participants have reflected on their previous experiences and impact. 

Most studies related to the impacts of conversion practices outside of the UK. 

The evidence base is mainly but not exclusively based on conversion practices focused on sexual orientation rather than gender identity. 

Impacts on protected characteristics

This assessment firstly considers the protected characteristics on which the policy will have the most significant impacts, namely sexual orientation and gender reassignment given evidence indicating the majority of conversion practices are committed against LGBT+ individuals. Consideration of other protected characteristics follows in alphabetical order.

Sexual orientation

Evidence

Stonewall/Opinium Survey 2024

Among lesbian and gay respondents, 9% reported that they had undergone conversion practices at some point in their lifetime, with 2% of them saying they had in the last year. 

Among bisexual respondents, 21% of bisexual men who responded to the survey reported that they had undergone conversion practices at some point in their lifetime, with 4% of them saying they had in the last year. 7% of bisexual women who responded to the survey reported that they had undergone conversion practices at some point in their lifetime, with 1% of them saying they had in the last year. 

National LGBT Survey 2017

For non-transgender respondents who had undergone conversion practices, asexual respondents were more likely to have undergone or been offered it (10%) while bisexual respondents were the least likely to have undergone or been offered it (5%).

Among all transgender respondents to the 2017 survey there was less variation by sexual orientation. Gay, lesbian and queer^{[footnote 8]} respondents were most likely to say that they had undergone or been offered conversion practices (both 14%), followed by pansexual and asexual respondents (both 13%) and then heterosexual, bisexual and ‘other’ respondents (all 12%). 12% of respondents also said they didn’t know their sexual orientation, and a further 12% preferred not to say. 

Previous government’s consultation 

By contrast, the previous government’s public conversion practices consultation, just over a half (51%) of consultation respondents who had experienced conversion practices were gay or lesbian (of these, 67% were male and 28% were female, the remainder did not say), 19% were heterosexual, 15% were bisexual, and 10% had an ‘other sexual orientation’

The consultation also found that of those who had undergone conversion practices, 68% said they were aimed at changing their sexual orientation with 12% aimed at changing both (their sexual orientation and whether they were transgender). 

Other evidence 

There is good evidence that LGB and trans adults have higher prevalence of poor mental health and low wellbeing when compared to heterosexual people (for example, Semlyen and others 2016^{[footnote 9]}, Kneale and others 2020^{[footnote 10]}).

Eliminate unlawful discrimination, harassment and victimisation

The intention is that the new offence will eliminate abusive, unlawful discrimination, harassment, victimisation and any other conduct prohibited by the Equality Act 2010 and, ultimately, serious harms caused by conversion practices, which are disproportionately experienced by LGBT+ individuals. Evidence suggests that conversion practices are associated with psychological harm.^{[footnote 11]} Conversion practices result in unfavourable treatment of LGBT+ individuals that is not justified and the objective of the draft bill is to end abusive conversion practices.

As practices that attempt to change someone’s sexual orientation predominantly impact those of a minority sexual orientation (lesbian, gay, and bisexual) or those who are not attracted to the same sex, the opposite sex, or to both (asexual), this may contribute to an overall atmosphere of hostility towards people who are not heterosexual. The proposed criminal offence reflects the government’s intention to be clear that these practices are ineffective and harmful. By being symmetrical in nature, the proposed offence makes clear that no particular sexual orientation is preferable to another, and that no sexual orientation enjoys more or less protection under the offence than another. 

As the Equality Act defines sexual orientation as an orientation toward persons of the same, opposite, or both sexes, it is our assessment that those who are pansexual (whose sexual orientation is not defined by binary sex alone) would only enjoy partial protection under said definition. 

As such wording has been included in the draft bill that enables those without a sexual orientation to be included under the scope of the offence without changing the definition of sexual orientation in the Equality Act. The draft bill is also framed in terms that refer to practices that  cause a person ‘to have or not to have’ a sexual orientation. As a ‘sexual orientation’ for these purposes means being attracted to the same sex, the opposite sex or both sexes, this framing extends to protection to those who are not attracted to the same sex, the opposite sex or both sex, meaning to asexual people. Our evidence base makes clear that asexual people experience conversion practices at a higher rate than gay, lesbian and bisexual people. 

Conversion practices are not currently a recognised or specific offence and there is a narrow gap in the existing legal framework. A bespoke criminal offence would help to eliminate these practices, including through a deterrent effect. This would be supplemented by the civil law protection order scheme to protect individuals at demonstrable risk and/or new criminal offence of encouraging or assisting a conversion practice outside of the UK. Overall, outlawing conversion practice is likely to have a positive impact. 

Advance equality of opportunity between people who share this protected characteristic and those who do not

There is robust evidence of higher levels of prevalence of poor mental health among people who identify as LGB+ compared with those who do not.^{[footnote 12]} LGBT+ individuals are already the cohort most targeted with conversion practices. A higher prevalence of poor mental health may make this cohort particularly vulnerable to conversion practices. 

Using the existing legislative definition of sexual orientation (Equality Act 2010), and implementing symmetrical drafting will ensure that protections apply to LGB and asexual individuals as well as heterosexuals. Banning conversion practices in this way will help advance equality between people who are LGB+ (including asexuals) and are not (heterosexual), the former of which are disproportionately subjected to these practices. 

Foster good relations between people who share this protected characteristic and those who do not

The draft bill may increase understanding about discriminatory attitudes that exist, the potential techniques used, risks of violence or coercion, and the support available to those who are at risk or who have undergone conversion practices.

The creation of a clear definition of conversion practices in law, and the threshold of the offence will empower safeguarding professionals to better understand and identify conversion practices and intervene during or prior to such acts occurring. This will not only reduce harm, but generate awareness of this form of abuse beyond the immediate LGBT+ community and across wider society.

In addition, these interventions which may increase societal awareness that these practices still take place in the UK. 

We therefore think that the draft bill has potential to have a positive impact on relations between groups of different sexual orientations. This should be further supported by the symmetrical nature of the draft bill which means that everyone benefits from equal protection regardless of their sexual orientation. 

Gender reassignment

^{[footnote 13]}

Evidence

Stonewall/Opinium Survey 2024

Among transgender respondents, 33% reported that they had undergone conversion practices at some point in their lifetime, with 9% of them saying they had in the last year. 

One in 4 (25%) of transwomen who responded to the survey reported that they had undergone conversion practices at some point in their lifetime, with 5% of them saying they had in the last year. 

Almost 2 in 5 (38%) of transmen who responded to the survey reported that they had undergone conversion practices at some point in their lifetime, with 12% of them saying they had in the last year. 

Over 1 in 4 (27%) of non-binary who responded to the survey reported that they had undergone conversion practices at some point in their lifetime, with 9% of them saying they had in the last year

National LGBT Survey 2017 

Over 2 in 5 (44%) survey respondents who had experienced conversion practices reported they were a man, while 29% of respondents reported that they were a woman. Another 7% reported that they were a ‘trans woman’, with 5% reporting that they were a ‘trans man’ and 11% reporting that they were non-binary. Another 4% were responses from people who could not be classified as either non-transgender or transgender (for example, those who did not provide details of their gender identity or selected ‘prefer not to say’, for example).

Previous government’s consultation 

By contrast, data from the consultation found that non-transgender LGB+ respondents were more likely to report experiencing conversion practices than transgender people (73% and 24% respectively). The difference in the findings between the 2017 survey and the consultation is likely to be explained by the sample compositions. The majority of conversion practices reported in the latter were aimed at changing an individual’s sexual orientation rather than whether they were transgender (68% and 13%.) 12% were aimed at changing both.

Other evidence

Evidence suggests that trans^{[footnote 14]} people’s mental health is worse than that of non-trans people.^{[footnote 15]} A 2018 study found that 46% of transgender people thought about taking their life compared to 1 in 20 in the general population.^{[footnote 16]} Trans people also experience greater mental health problems, lower self-esteem, greater body dissatisfaction, and greater interpersonal problems than non-trans people (see also Bouman and others 2016^{[footnote 17]}, Saunders and others 2021^{[footnote 18]}).

Eliminate unlawful discrimination, harassment and victimisation

The draft bill makes clear that transgender identity is defined as an individual who is undergoing, is proposing to undergo or has undergone a process of gender reassignment, is transexual, or identifies as neither male or female or not solely male or female.

This definition encompasses the existing language used in the Sentencing Act 2020, as taken from the Equality Act 2010. It provides clarity that individuals who are non-binary are within the scope of the draft bill. This ensures protection aligns with the evidence base, which shows that trans and non-binary people experience high rates of conversion practices (realised or offered), without effecting a change to the definition of gender reassignment within the Equality Act 2010. 

As with conversion practices aimed at sexual orientation, practices aimed at changing someone’s transgender or non-binary identity result in unfavourable treatment, which is not justified. A bespoke legal framework would help to eliminate these practices, including through a deterrent effect supplemented by the civil law protection order scheme to protect individuals at demonstrable risk and/or new criminal offence of encouraging or assisting a conversion practice outside of the UK. Overall, outlawing conversion practice is likely to have a positive impact. 

Advance equality of opportunity between people who share this protected characteristic and those who do not

There is a higher reported prevalence of poor mental health among people who identify as transgender and non-binary compared with those who do not. This may make transgender and non-binary people particularly vulnerable to attempts to offer or undergo conversion practices. The draft bill’s provisions should particularly benefit this group. 

Foster good relations between people who share this protected characteristic and those who do not

The draft bill accounts for the current social and cultural climate in which public debate, particularly on or around transgender identity, is often contentious and polarised. The government is aiming to demonstrate that transgender and non-binary people must be protected from conversion practices while allowing all people the right to express their views or beliefs on these identities, as long as this expression does not constitute an abusive conversion practice as defined under the draft bill or constitute another offence.

This draft bill may increase understanding by or from people who do not identify as LGBT+  about the impact of conversion practices on people who are transgender or non-binary, and the support available to those who are at risk or who have undergone conversion practices. 

It is vital that all health care professionals can provide legitimate services in assisting those who are exploring their transgender identity and/or supporting those who wish to alleviate gender incongruence or dysphoria. 

On that basis, the draft bill will ensure legitimate care can continue by outlining that actions in the course of providing any healthcare service are out of scope, as long as they do not fall below the standards reasonably expected. This approach ensures genuine clinical mistakes in a complex area are not criminalised and mitigates against the chilling effect. 

Overall, this ensures that transgender individuals can access support, while also acknowledging concerns of some non-transgender individuals. Aside from mitigating any potential chilling effect, this approach aims to alleviate tensions as much as is possible between transgender and some non-transgender individuals in relation to any opposing views on what constitutes best practice in the transgender healthcare space.

Age

Evidence

Stonewall/Opinium Survey 2024

This survey indicated that people aged 18 to 34 years old are most likely to undergo conversion practices. This rate decreases as people age.

Among respondents aged 18 to 24, 17% reported that they had undergone conversion practices at some point in their lifetime, with 5% of them saying they had in the last year. 

Among respondents aged 25 to 34, 17% reported that they had undergone conversion practices at some point in their lifetime, with 3% of them saying they had in the last year. 

Among respondents aged 35 to 44, 9% reported that they had undergone conversion practices at some point in their lifetime, with 2% of them saying they had in the last year. 

Among respondents aged 45 to 54, 6% reported that they had undergone conversion practices at some point in their lifetime, with 1% of them saying they had in the last year. 

Only 6 respondents over the age of 55 in this survey had undergone conversion practices in their lifetime. 

National LGBT Survey 2017

The 2017 survey indicated that respondents aged 16 to 17 years were more likely to report that they were offered conversion practices than respondents from any other age group.^{[footnote 19]} 

Around 2 in 5 respondents who had experienced conversion practices were younger than 25 years:

• 18 to 24 years (30%)
• 16 to 17 years (9%)

Around half of all respondents were from the following age-groups: 

• 25 to 34 years (21%)
• 35 to 44 years (15%)
• 45 to 54 years (14%)

Smaller proportions were from older age-groups:

• 55 to 64 years (7%)
• 65 years and above (4%)

Younger people are over-represented in the National LGBT Survey 2017 dataset compared to the national population statistics at the time (GEO 2021).

Previous government’s consultation 

In response to the previous government’s consultation, the majority of people who reported they had experienced conversion practices were aged between 11 to 34 years at the time (83%). 

Just over a third (34%) of consultation respondents said their most recent experience was between the age of 18 to 24 years, followed by 25 to 34 years (18%), 11 to 15 years (16%), and then 16 to 17 years (15%). 4% of respondents said they had their most recent experience of conversion practices when they were under 10 years old.

The consultation also found that 2% of 16 to 17 year olds said they had received it (a similar proportion to the 2017 Survey). The consultation also found that:

• 39% of respondents experienced conversion practices from 2000 to February 2022
• 40% had their most recent experience between 1980 and 1999
• 17% between 1960 and 1979
• the remaining 3% between 1940 and 1959^{[footnote 20]} 

This suggests that conversion practices are a live issue.

Eliminate unlawful discrimination, harassment and victimisation

Children are generally more vulnerable to conversion practices than adults. People aged under 18 may not have the capacity to understand the potential for conversion practices to cause harm. Adults generally have a greater capacity to protect themselves, and are more likely to understand which acts might have long lasting negative impacts. 

Children are often dependent on others, and subsequently more susceptible to imbalanced power dynamics. They may be more exposed to societal pressures due to being reliant on wider community and extended family members.  

Overall this could lead to children finding it more difficult to seek help when they do face potential harm. 16% of respondents to the previous government’s consultation said their most recent conversion practice experience had been carried out by a ‘Parent, guardian or other family member’. 

The government acknowledges that the draft bill must protect children, simultaneously  upholding parental freedoms, and the right to raise one’s child in line with parental beliefs/values. 

The draft bill makes clear that an offence occurs only if an act intends to change a person’s sexual orientation and/or transgender identity, the act is abusive, and the act results in serious harm to the individual. This threshold balances the need to protect people from serious harm, while ensuring that families can continue to live by their religious beliefs, their values, or other ideological tenets. 

In defining conversion practices in law, and in making clear the nature of the offence, minors and vulnerable adults will benefit from greater protection under existing safeguarding frameworks that enable and empower interventions when the evidence of abuse, or the risk of abuse, is clear. People – including social workers, police and teachers – will be better equipped to identify and intervene on instances of potential conversion practices in line with their professional standards and requirements. 

This approach takes into account the clear need to protect children while upholding parental rights and overall ensuring the bill is compatible with the European Convention on Human Rights’ Article 8 – private and family life, and Article 9 – freedom of thought, conscience and religion).

Protection Orders and the offence of encouraging or assisting an abusive conversion practice performed outside England and Wales will protect young people who might be vulnerable to these practices from those who intend to make them undergo conversion practices at home or abroad. 17% of respondents to the previous government’s consultation who said they had experienced conversion practices said their most recent conversion practice experience had taken place ‘Outside the UK’. 

Where it is appropriate, a court might even make an order stipulating that someone who is under 18 has their passport removed to ensure they cannot be taken abroad, or that their guardian/parents’ travel documentation is seized, if the minor’s details are contained within. CPPOs will also protect those who are aged 18 and over, in setting out specific conditions within the order – for example, ‘the respondent’ remains a set distance from the victim. The proposed model for protection orders balances the need for protection and addresses the risk that CPPOs could be used disingenuously in a family setting such as in the context of family breakdown or custody disputes. The new criminal offence of encouraging or assisting a conversion practice outside of the UK will also provide a deterrent from children being taken abroad to undergo a conversion practice.

A bespoke legal framework would help to deter perpetrators and eliminate these practices, supplemented by the proposed protection order scheme and/or new criminal offence of encouraging or assisting a conversion practice outside of the UK, the victims support service and other ancillary policy measures – the overall package of measures will enhance the protection of those who are under 18. For all the reasons above, we consider the draft bill will help eliminate unlawful discrimination against people on the basis of their sexual orientation or transgender identity, which our evidence indicates younger persons report in significant numbers.

Advance equality of opportunity between people who share this protected characteristic and those who do not

Evidence suggests that younger people (16 to 24) are the most likely to report being LGBT in comparison to older age groups. The 2021 Census reported that more than 1 in 14 (6.9%) of 16 to 24 year olds identified as LGB+, with 1% of the same group being ‘being trans’.^{[footnote 21]} A criminal offence on conversion practices may serve to protect this age group more, while signalling to people of all ages that conversion practices are unlawful, thus reducing prejudice against LGBT+ individuals across the spectrum of age. We consider the draft bill could have a positive impact in advancing equality of opportunity between younger people with the protected characteristics of sexual orientation and/or gender reassignment and those who do not. 

Foster good relations between people who share this protected characteristic and those who do not

The interventions are designed to equally provide protection for people of all ages (which may help to mitigate a perception that only a certain age group is vulnerable to being victims of conversion practices). As the new core offence treats minors and adults equally, this will ensure that one group is not given preferential treatment over another which may foster positive relations for those across the spectrum of age.

Disability

Evidence 

In response to the previous government’s consultation, 47% of people who said they had experienced conversion practices, also said they had a physical or mental health condition or illness, lasting or expected to last 12 months or more (53% said they did not). Disability was overrepresented in the consultation with 32% reporting having a disability, in comparison to 2021 Census data where the proportion of disabled people was 17.8%.^{[footnote 22]}

No similar analysis was carried out for the National LGBT Survey 2017.

Eliminate unlawful discrimination, harassment and victimisation

It is possible that someone who is disabled, particularly someone with a learning disability, may be more vulnerable to coercion than someone without a disability, and therefore at greater risk of undergoing conversion practices.

The proposed legislation is clear that no one should be coerced or can consent to abusive conversion practices. This blanket approach means that special protections to criminalise the coercion of those individuals captured, under section 2 (1) of the Mental Capacity Act, are not required. As such, we consider the draft bill will help to eliminate unlawful, indirect discrimination against disabled persons.

Advance equality of opportunity between people who share this protected characteristic and those who do not

Individuals who are discriminated against because they are LGBT+ may experience poorer mental health and may be more likely to ‘consent’ to conversion practices. In addition if an individual is disabled and LGBT+, and dependent on assistance from someone who is trying to subject them to a conversion practice, they may be more vulnerable to these acts.

Draft bill provisions protect all individuals equally and do not allow for consent, this mitigates against a loophole where a perpetrator claims that someone vulnerable consented to the act. Equal treatment of individuals with this protected characteristic ensures that safeguards are comprehensive. 

Foster good relations between people who share this protected characteristic and those who do not

Given the government is not allowing for consent due to the abusive nature of the acts, this rationale should raise awareness of the harm conversion practices can cause. Provisions protect all individuals in this space equally, and as provisions do not allow for consent, this mitigates against a loophole where a perpetrator claims that someone vulnerable consented to the act. Equal treatment of individuals with this protected characteristic ensures that safeguards are comprehensive. 

Pregnancy and maternity

It is possible that pregnancy or recent birth may make someone more vulnerable to pressures, beliefs or societal expectations about their sexual orientation or gender identity but we do not have evidence currently available on this. Beyond this, we have not identified any impact on how this policy will eliminate unlawful discrimination, harassment and victimisation to pregnancy and maternity.

Race

Evidence

National LGBT Survey 2017

Our understanding of the overall volumes or prevalence of conversion practices for people of different ethnic groups and/or nationality is limited, however the National LGBT Survey 2017 found that a broad range of ethnic groups said they experienced conversion practices, albeit at different levels. 

The majority (82%) of survey respondents who had experienced conversion practices belonged to the white ethnic group, followed by mixed or multiple ethnic groups (6%), the Asian or Asian British group (5%), the black, black British, Caribbean or African group (4%), and other ethnic group (3%). 

Previous government’s public consultation 

The majority (85%) of the previous government’s consultation respondents who had experienced conversion practices belonged to the white ethnic group, followed by mixed or multiple ethnic groups, and the Asian or Asian British group (both 3%), the black, black British, Caribbean or African group and other ethnic group (both 2%).

Eliminate unlawful discrimination, harassment and victimisation

Evidence above suggests that conversion practices occur across a broad range of ethnic groups. We believe our draft bill will act as a key deterrent for stopping criminal conversion practices regardless of individuals’ race, ethnicity or nationality. In addition, this would be supplemented by the proposed protection order scheme, and the new criminal offence of encouraging or assisting a conversion practice outside England and Wales.

Reflections of stakeholders engaged throughout policy development, also indicate that acts happen across a wide spectrum of ethnic groups and often due to varying but widely held cultural and community beliefs. Interventions will therefore impact and likely benefit all ethnic groups. Measures will send a clear sign across all ethnic groups that the idea that being LGBT+ is something to be ‘fixed’ is misplaced and unacceptable. However it will not prohibit the holding or expression of beliefs and opinions on LGBT+ people. 

Advance equality of opportunity between people who share this protected characteristic and those who do not

In some areas there is higher prevalence within specific ethnicities. For example, within the 2017 survey, non-transgender LGB+ Black/African/Caribbean/Black British (13%) and Asian/Asian British (14%) respondents, and respondents belonging to an ‘Other’ ethnic group (15%), for example, were much more likely than White (7%) respondents to have undergone or been offered conversion practices. However, this may be due to more respondents who were white responding to the survey than other ethnic groups. 

This data suggests that some ethnic groups may be at higher risk of undergoing conversion practices. The draft bill measures will work as an important deterrent in these demographics, aim to reduce the incidence of conversion practices across different ethnic groups and advance protections and equality of opportunity for those who statistically appear to be at higher risk.

Foster good relations between people who share this protected characteristic and those who do not 

Cross-cutting themes identified by the previous government’s consultation external analysis report included concerns from some respondents about prejudice in statutory services, particularly the Police, on the basis of being LGBT+ and race/ethnicity. 

Mitigations envisaged include guidance for all relevant services and appropriate training emphasising that conversion practices need to be addressed adequately for everyone. 

Given higher self-reporting of conversion practices by people of some ethnicities, there is a risk that conversion practices are viewed as an issue only affecting some groups. To make clear that conversion practices can happen across different ethnic groups, mitigations will include reflecting appropriate diversity in government communications. 

Religion or belief

Evidence

National LGBT Survey 2017

Just over half (51%) of survey respondents who had experienced conversion practices said that they had conversion practices conducted by faith organisations. 

Nearly half (47%) of survey respondents who had experienced conversion practices had ‘no religion’, and just under a third (30%) were Christian. The next most common single faith/ religious group was Muslim (5%). Respondents were also Buddhist, Jewish, and Pagan (all 2%), and Hindu, Atheist, Agnostic, and Spiritualist (all 1%). A small number of respondents were Humanist, Sikh, and Wiccan (under 1%).^{[footnote 23]}

Previous government’s public consultation 

Similarly, headline findings from the previous government’s consultation response highlighted respondents were most likely to report that faith organisations had conducted conversion practices (68%). Spiritual, religious, or faith-based activities were the most common form of conversion practices reported in the consultation (65% of respondents), nearly twice as many as purported ‘psychoanalytic therapies’ (33%) and ‘cognitive-behavioural therapy’ (30%).  

The consultation had different findings to the survey with Christian respondents more likely than respondents from all other religion/ belief groups to have undergone conversion practices: (47% compared to the next highest group, which was 36% ‘No Religion’).

Eliminate unlawful discrimination, harassment and victimisation

The need to create legislation that protects people from abusive conversion practices has been considered alongside the need to protect freedom of speech, beliefs and religion. This is a known concern and has been expressed by consultation respondents and stakeholders.  

Expressing the teachings of any religion and/or expressing an ideological belief or general opinion, will not constitute a conversion practice. 

The focus of the draft bill is on change acts rather than acts which aim to suppress an individual’s sexual orientation or transgender identity. This will reduce the risk of unjustified interference with individuals’ rights under the European Convention on Human Rights, in particular religious freedoms and respect for private and family life. However, acts designed to change a person’s sexual orientation to a state of not having a sexual orientation would be captured. Likewise, acts seeking to cause a transgender individual or non-transgender individual not to have that identity, would also constitute a change act and be within the scope of the new offence.

In addition to only targeting change acts, the draft bill has clear thresholds which need to be reached for a conversion practice to be considered criminal: such practice must also be abusive, and result in serious harm to the individual. These thresholds mean that  the expression of opinion, belief or ideology are highly unlikely to be within the scope of the new criminal offence. Likewise, acts that merely cause offence or discomfort will not be captured. This preserves freedom of religion, expression and speech, while protecting those at risk of abuse. 

This approach means that religious congregants, leaders and counsellors will be able to express their views freely and offer support to those who are exploring their sexual orientation or gender identity. The draft bill is also not intended to inhibit a person’s ability to manage or suppress their own gender identity or sexual orientation to live a life that aligns with their personal beliefs, for example through choosing celibacy. 

While some religious parties are concerned about a ban, many faith groups are clear that they do not endorse or support conversion practices. The government’s approach balances concerns around religious freedoms with the need to protect individuals from abusive acts, acknowledging that conversion practices often take place in a religious setting.

Anecdotal evidence suggests that some victims have been encouraged to undergo conversion practices with their family/ religious communities outside of the UK. The new criminal offence of encouraging or assisting conversion practices outside of the UK and the introduction of CPPOs will help to protect against people who are at risk of this. 

For all these reasons, we consider the draft bill will have a positive impact in fulfilling the PSED aim of eliminating unlawful discrimination and that any interference with a person’s right to freedom of religion or belief will be proportionate, in pursuit of a legitimate aim.

Advance equality of opportunity between people who share this protected characteristic and those who do not

The proposals will benefit all people who are offered, at risk of, or experience conversion practice regardless of faith or belief. The proposals will provide the same legislative interventions against those who commit an offence regardless of their religion or beliefs. 

Foster good relations between people who share this protected characteristic and those who do not

In terms of religious faiths or beliefs, the different forms of support available to people who have experienced conversion practices may foster good relations between people of different faiths or beliefs, or none. Anyone who has been offered or undergone conversion practices within a faith setting, including practices they have consented to, will be offered support should they require it on the same basis of others who have experienced conversion practice techniques in non-faith settings. 

Conversion practices are sometimes associated with religious practice, therefore, any increased discussion in the public domain about conversion practices may see a rise in assumptions that those who hold religious beliefs are complicit. 

It is possible that some may feel that their right to hold or practise their religion and beliefs has been restricted, potentially leading to an increase in tension and a perception of opposing sides. We will address this in documents accompanying the draft bill and further consider ways to mitigate this, including through ongoing stakeholder engagement.    

Our assessment is that the focus on change acts only and not suppressive acts – with a robust threshold clarifying that innocuous acts will not be captured – for example, personal prayer, expression of opinion or religious doctrine – this approach not only strikes the right balance but can provide reassurances to concerned stakeholders. This could help foster better relationships between those affected by conversion practices, making clear the difference between expressing religious belief and attempts to change an individual, thus allowing for greater clarity and frankness of discussion.

Sex

Evidence

The policies and legislative actions outlined will protect people from undergoing conversion practices whatever their sex.

National LGBT Survey 2017

Evidence from the 2017 survey found that a higher proportion of men had undergone or been offered conversion practices than women. 60% of survey respondents who had experienced conversion therapy were male, and 40% were female. No data is available on the sex assigned at birth of transgender respondents.

Previous government’s public consultation 

Similarly, a higher proportion of the previous government’s consultation respondents who said they had experienced conversion practices were male (54%) compared to female (35%). 

Eliminate unlawful discrimination, harassment and victimisation

A ban will protect individuals from attempts to change their sexual orientation or transgender identity regardless of their sex. 

Data and evidence above shows a slightly higher proportion of men have undergone or been offered conversion therapies, and may therefore see a higher benefit from a ban than women. However, men are also overrepresented in studies of conversion therapy, including the 2017 National LGBT Survey. 

Advance equality of opportunity between people who share this protected characteristic and those who do not

The nature of the legislation will be symmetrical and target any practice which aims to change someone’s sexual orientation or transgender identity, regardless of their sex. 

The government-funded Victim Support Service is available to people regardless of sex and therefore benefits everyone. 

Foster good relations between people who share this protected characteristic and those who do not

The symmetrical nature of the legislation ensures that everyone, regardless of their sexual orientation, sex or transgender identity, will be protected from conversion practices. The aim of the ban is to protect everyone from the abusive practices and prevent others from changing a person’s innate identity.

These symmetrical protections may help foster improved relations between: 

• those who are concerned with protecting sex-based rights and/or who may be concerned about conversion practices that are targeted at cisgender/non-transgender people or individuals who may have reversed their gender identity transition
• those who are more focused on advocating for improved protections and rights for transgender people

Decision making 

We do not consider that any negative impacts on equality are disproportionate and we have considered appropriately the need to eliminate unlawful discrimination, advance equality of opportunity and foster good relations.

The policies outlined will have a beneficial impact on practices that might have an adverse effect, including practices that may amount to prohibited conduct, on the basis of age, gender reassignment, religion or belief and sexual orientation. These policies are expected to advance equality of opportunity on the basis of:

• age
• disability
• gender reassignment
• pregnancy and maternity
• race
• religion or belief
• sex and sexual orientation 

It is possible that restrictions on certain practices that amount to conversion practices that occur within a faith setting, or are motivated by faith, will affect people with a particular religion or belief. While the interventions proposed are not designed to limit people practising their religion, some people within those religious groups may feel that these prohibitions mean they cannot practise or express their faith in all the ways that they would choose. 

These restrictions are intended to protect people from the potential significant harm that could result from conversion practices, and are not intended to change or prohibit specific beliefs, or to restrict certain practices because they are conducted by those with a specific religion or belief. We think the restrictions on practices outlined are justified by the need to protect citizens from harm, whatever their religion or belief may be.  

These policies have the potential to foster good relations on the basis of gender reassignment, religion or belief, sex, and sexual orientation, and in particular for people to learn and gain support on the basis of their shared experiences. The scope of the offence is a live part of public discourse, which is characterised by tension between:

• those who are concerned that legislation could inadvertently impact legitimate clinical support especially for young people
• those who across a range of ideological views on gender identity (themselves confirmed as protected under the Equality Act’s provisions on belief and focusing on biological sex as immutable and the importance of sex-based rights)
• those advocating for greater legal recognition for transgender identities and rights

The draft bill will need careful and considered communications and engagement with interested parties on all sides, including in Parliament through the pre-legislative scrutiny process, to mitigate the risk of this tension increasing.  

Monitoring and evaluation

This Equality Impact Assessment will be kept under review and considered further to reflect policy and legislative development including in due course in response to recommendations from the joint committee for PLS.

1. Jowett, A, Brady G, Goodman S, Pillinger C and Bradley L (2021) Conversion Therapy: An evidence assessment and qualitative study. Government Equalities Office. Government Equalities Office (2021b) An assessment of the evidence on conversion therapy for sexual orientation and gender identity. Government Equalities Office. American Psychological Association (2009). Report of the American Psychological Association Task: Force on Appropriate Therapeutic Responses to Sexual Orientation. APA. The conclusions of these reports are based predominantly on non-UK studies looking at mainly but not exclusively sexual orientation-only conversion practices. ↩

2. Other limitations associated with the 2017 National LGBT Survey include: no clear definition of ‘conversion therapy’, and no attempt to distinguish between those who experienced conversion practices directed at changing sexual orientation and/or whether it was directed at changing transgender identity. ↩

3. Stonewall (2024) New survey findings reveal alarming scale of conversion practices in Great Britain. Opinium (2024) Stonewall Press Tables.  ↩

4. Limitations include that the survey did not contain a clear definition of ‘conversion practices’. It asked individuals to select all actions they had experienced in response to the question, ‘Have you experienced any of the following with the aim to change/alter your sexuality or gender identity?’ Some actions would not fall within our proposed legislation definition. Our estimation has been developed from actions covered by the proposed legislation, accounting for potential overlap in the number of people who have experienced different types of conversion practices. ↩

5. Jowett and others 2021, GEO 2021. ↩

6. See also, American Psychological Association (2009). Ryan, C., Toomey, R.B., Diaz, R.M., and Russell, S.T. (2020) Parent-Initiated Sexual Orientation Change Efforts With LGBT Adolescents: Implications for Young Adult Mental Health and Adjustment. Journal of Homosexuality. 67(2), 159–173.. Green, A.E., Price-Feeney, M., Dorison, S.H., and Pick, C.J. (2020) Self-Reported Conversion Efforts and Suicidality Among US LGBTQ Youths and Young Adults. American Journal of Public Health. 101(8), 1221-1227. Higbee, M., Wright, E.R., and Roemerman, B.A. (2020) Conversion Therapy in the Southern United States: Prevalence and Experiences of the Survivors. Journal of Homosexuality. 69(4), 612-631. The conclusions of these reports are based predominantly on non-UK studies looking at mainly but not exclusively sexual orientation-only conversion practices.   ↩

7. Jowett and others 2021, GEO 2021. ↩

8. ‘Queer’ was a self-identified term that some respondents used to describe their sexual orientation in the 2017 survey. ↩

9. Semlyen J, King M, Varney J, Hagger-Johnson G. Sexual orientation and symptoms of common mental disorder or low wellbeing: combined meta-analysis of 12 UK population health surveys (2016) BMC Psychiatry. 2016 Mar 24, 16:67.. ↩

10. Kneale D, Thomas J, French R (2020) Inequalities in Health and Care Among Lesbian, Gay, and Bisexual People Aged 50 and Older in the United Kingdom: A Systematic Review and Meta-analysis of Sources of Individual Participant Data. J Gerontol B Psychol Sci Soc Sci. 2020 Sep 14;75(8):1758-1771. ↩

11. Jowett and others 2021, Ryan and others 2020, Green and others 2020, Higbee and others 2020. The conclusions of these reports are based predominantly on non-UK studies looking at mainly but not exclusively sexual orientation-only conversion practices. ↩

12. NHS Digital (2021) Health and health-related behaviours of Lesbian, Gay and Bisexual adults.  ↩

13. Gender Reassignment’ is a broadly defined term in the Equality Act 2010 and protects individuals who are proposing, planning to, or are in the process of transitioning, whether that be a social and/or medical process. ↩

14. While the current government uses the term LGBT+, the previous government and some external organisations used or use LGBT. To accurately reflect the source material when this occurs the term LGBT will appear rather than LGBT+. ↩

15. Hudson-Sharp, N. and Metcalf, H. (2015) Inequality among lesbian, gay bisexual and transgender groups in the UK: a review of evidence. National GP Patient Survey (2019) ↩

16. Bachmann CL and Gooch B (2018) LGBT in Britain – Health report. Stonewall.  ↩

17. Bouman, W.P  and others (2016) Predictors of psychological well-being among treatment seeking transgender individuals. Sexual and Relationship Therapy, 31 (3), pp. 359-375. ↩

18. Saunders CL, Berner A, Lund J, and others (2021) Demographic characteristics, long-term health conditions and healthcare experiences of 6333 trans and non-binary adults in England: nationally representative evidence from the 2021 GP Patient Survey. BMJ Open 2023;13:e068099. doi: 10.1136/bmjopen-2022-068099. ↩

19. Government Equalities Office (2018) National LGBT Survey: Research report.    ↩

20. To estimate when conversion practices took place, the youngest age that respondents could have had their most recent experience was subtracted from the oldest age they are now. This provided the maximum number of years ago respondents could have had their most recent experience, which was then subtracted from 2021 (the first year of the consultation), giving the earliest date that respondents could have had their most recent experience. ↩

21. Census (2021) Sexual orientation, England and Wales: Census 2021. Census (2021). Gender identity, England and Wales: Census 2021.  ↩

22. Census (2021) Disability, England and Wales: Census 2021.  ↩

23. Some religion/ belief categories in the National LGBT Survey have been created from responses to a free-text ‘other’ option when respondents’ religion was not listed. ↩