exploratory – Therapists Against Conversion Therapy and Transphobia

Responses to the UKCP meeting

UKCP – The Board Removal Vote.

As many of you know, The UKCP Board held an online meeting Monday to put its case to members on how to vote in its forthcoming removal election. Over 300 UKCP members are reported to have joined this meeting.

We are listing here the headlines, as we understood them, and below this (in the longer version), quotations from the meeting and links to relevant documents.

As the vote begins we remain extremely concerned about the actions of the UKCP Board and we do not believe that their actions in withdrawing from the MoU have been adequately explained. We believe that some very serious questions remain, and in the absence of receiving answers, despite trying for months, our UKCP cohort continues to call for the removal of the Board and their subsequent replacement with a new team which will restore the UKCP to the MoU (as the current Board restated that it would not do), unless a full and transparent consultative process involving members of all kinds indicates a different course of action.

The headlines from the meeting are:

1. The UKCP Board states that their figure for triggering the vote is 2% and that that’s low by comparison with other organisations. They stated that the petition achieved this level, just, and inferred that if a higher number had been required, it wouldn’t have been reached. We’d like to respond that TACTT’s open letter stopped being promoted at the point we reached the number of signatures required and a decision was made to submit to UKCP. TACTT is confident that it could have added more signatures, perhaps significantly more, had it continued to seek them.

2. The UKCP Board states that NCPS supports them in the aim of creating a new, alternative version of the MoU. NCPS has categorically denied this and has now asked UKCP to stop saying it’s true. (Please note that communication from the UKCP to TACTT after the publication of this blog asks us to update. The UKCP is not planning to create a new version of the MoU. We are not sure what they are planning to create, except a regulatory document of some kind that involves conversion therapy. In the meeting they discussed the MoU ‘not going far enough’ and wanting to strengthen this, but it seems that what they are planning to create is not something like the MoU).

3. The UKCP Board states they had no choice but to withdraw at speed from the MoU and although they knew that this may be seen as a transphobic action, they a) didn’t have time to mitigate the process around this, and b) although they knew it could be perceived as transphobic, they didn’t consider how their action would impact members. They also feel that they are “ethically sensitive” and the right people to remain on the board. However, the Board has also said it discussed this in advance of making the decision with colleagues and some of the member colleges. Which is it? That there was time to engage with several colleges and colleagues, or that this had to be done so fast that there wasn’t time to consider the impact the decision would have?

WHY did the decision have to be so fast? Can the UKCP categorically state that they have signed no legal settlement that has compelled them to withdraw from the MoU?

4. The UKCP Board’s original stated reason for withdrawal was about ‘children’. At the meeting the main message seemed to be about ‘insurance premiums’. The Board now states that it had to withdraw the UKCP because of insurance policy premiums (and that their responsibility is to UKCP, with no mention of clients or their members). With respect to stated concerns about the care of children, the UKCP board has claimed that the MoU Secretariat refused to engage on this. There is nothing in the minutes of any UKCP trustee meeting from the last 18 months that suggests this and it has been stated in the meeting on June 17th by an attendee (presumably on the secretariat) via the Q&A panel that the minutes of the MoU meetings do not support this. Whichever way, the MoU was a guideline, rather than a legal document.

5. The UKCP Board has repeatedly said that they want to hear from LGBTQ+ (and other) voices. TACTT has been trying to engage with UKCP on this matter since November 2023, with no results whatsoever. The UKCP Board also states that it supports the Cass review, which has been widely criticised since its publication, not least by trans people whose voices were systematically excluded from it.

6. The UKCP Board stated that the removal of the trustees would destabilise the organisation and that many new developments would have to be ‘put on ice’, yet also claiming that the current Board is new. Irrespective of this seemingly contradictory rhetoric, it must be pointed out that the Board wouldn’t be replaced until new members of a trustee board (also potentially members with experience of being trustees) were in place.

In short: the narrative we have heard seems to be as follows.

They couldn’t tell members the truth, but they’ve also been transparent from the start.

They are against conversion therapy, but they support the Cass Review. This has been widely discredited by leading academics, and was created and managed by a government that explicitly and energetically attempted to destroy the rights of trans people in the UK. This government has refused to bring forward a ban of Conversion Therapy (the Minister who commissioned it celebrated the release of the final Cass report with excited claims of the defeat of the “militant gender lobby”) and the Cass report has been weaponised extensively within the political and media discourse since its release.

They believe in ‘healthy exploratory therapy’ but will not commit to a starting point of stating that trans identities are valid and are as legitimate as cisgender identities. Without this, so-called ‘exploratory therapy’ effectively becomes conversion therapy.

They want to create a new regulatory version of the MoU, but again, will not commit to the standpoint of the original MoU. They didn’t know that the MoU covered children (we ask, why would it not, and why did it take 8 years and having signed the document twice to bring this question – which could have been answered easily and quickly at any stage?) and state that children have age-specific needs. Our response to this? Of course they do, but why does this mean that a well-practised approach of supporting a child to explore their identity – trans, cisgender or anything else – is invalid?. And we point out again that the MoU does not state any particular way of working for either adults or children and young people.

Long version

1: In the interests of expediency, TACTT sent the list of signatures when we knew we had reached the number required. If the number had been higher, we would have continued to share the letter until the higher number was reached.

2: UKCP have withdrawn from the MoU2 and intend to create a regulatory document around conversion therapy. UKCP (Jon Levett, CEO) said in the meeting “We’ve got together a working group which is going to start to meet on a monthly basis to really start to get some momentum on this. So NCPS are very definitely involved, very definitely signed up to this.” Another trustee states “ [we have] form[ed] a working group led by our CEO John Levitt already we’re collaborating with a number of organisations including the British Psychoanalytic Council, the National Counselling and Psychotherapy Society and a number of others”

NCPS’s response is “Just to reassure you, the NCPS has re-joined, and is fully supportive of, the MOU as the right mechanism to ban conversion therapy, a ban which has been our consistent policy. We are not looking to create an alternative MOU […] I have raised this with UKCP and asked them to refrain from sending out these statements”

3: UKCP say that they didn’t have time to consider the potential fallout. We respect that the open letter went up the same day as the announcement. However, what this tells us is that the board just did not consider this, in advance of releasing such a huge statement. They also say in the same meeting that they DID consider that it might be seen as transphobic, but that none of them (it seems) considered the impact that might have. One cannot have it both ways.

“We didn’t have time to address the potential fallout before the petition came against us. So we have been and we are always against conversion therapy and the petition was based on incorrect information”

“To be totally transparent we considered that the withdrawal taken out of context could be experienced as transphobic and homophobic, but what we didn’t consider was the potential impact.” “We believe that as the existing board that we have the skills, the vision and the ethical sensitivity to take the forward and deliver on the charity’s strategic aims”

“We did discuss it with colleagues. We did discuss with some of the colleges, although we acknowledged we didn’t discuss with all of them”

4: From the MoU2: “conversion therapy’ is an umbrella term for a therapeutic approach, or any model or individual viewpoint that demonstrates an assumption that any sexual orientation or gender identity is inherently preferable to any other, and which attempts to bring about a change of sexual orientation or gender identity, or seeks to suppress an individual’s expression of sexual orientation or gender identity on that basis.” and “signatory organisations agree that the practice of conversion therapy, whether in relation to sexual orientation or gender identity, is unethical and potentially harmful.”

UKCP state concerns about children and not knowing that children were covered under ‘people’. What exactly *are* children, to UKCP, if not people? Jen Ayling stated: “you know, a child’s need is very different to an adult’s needs and I think that’s where there’s the need for additional guidance.” The MoU does not give guidance on HOW to work with people exploring their gender. It simply allows room for children to fully explore their identities from within a framework that believes “that neither sexual orientation nor gender identity in themselves are indicators of a mental disorder” (MoU2)

From the UKCP meeting: “Now we did an attempt to engage in dialogue but came to the point when faced with a significant increase in our insurance premium”

They suggest that “over the last few weeks we have endeavoured as a board to transparently communicate the reasoning and risk assessment process which underpinned our decision”, yet they have changed their story to being about insurance and explicitly state they couldn’t state this originally. What has legally changed that they now can?

5: From the meeting: “Any clinical guidance will be backed by robust research evidence. We’re supportive of the Cass review and it will form part of our ongoing considerations when creating new regulation and clinical guidance”. Cass has been discredited in many areas and by many voices since its publication. See Transactual the OSF Preprint paper, and Dr Ruth Pearce’s ongoing updates for just three of them.

They also state “You see what we urgently need to do is create new regulatory guidance for conversion practices that has good governance, transparency, consultation, the voice of psychotherapy and most importantly the voices of the LGBTQIA+ community”.

UKCP would not answer a question as to whether they were prepared to start any new version of an MoU from the point of view that a trans identity was as valid as a cisgender identity. They did talk about “healthy exploratory therapy”. Florence Ashley has a very useful paper on why ‘exploratory therapy’ within a framework that doesn’t accept trans (whether in adults or children) as a valid identity is conversion therapy. UKCP declined to answer to this question as well.

6: From the meeting: “The upheaval and cost implications to the charity of appointing an entirely new board would essentially make the organization non-functioning in terms of major future developments for a significant period of time. Conference planning, strategic development work and many of the other projects we’ve successfully launched would have to be put on ice.”

However they go on to list all the things they have achieved as a new board. Which seems to directly contradict their claims of destabilisation.

“There’s a lot done but not all of it will be directly visible to you. So we started to work preparing the relationship with colleges, which was a factor within the EGM core. We are managing legal claims. We relocated the offices. 17th June, I think was the D date. And estimated to save 150 K annually. We’re improving office performance. We’re guiding the NHS pathways, talking therapies pilots. We’ve reinstated the annual conference. We reinstated the ethics committee. And as many of you again will be aware, we’ve consulted on and a developing the new 3 year strategy. And I just want to say a little bit about that is that the three-year strategy and we’ve run 3 4 seminars on that already through 4 webinars on that already. And put up various polls just to gain attraction and interest. The Strategy Working Group is comprised of 2 chairs at the colleges and one vice chair of the colleges working with the board nominated board of trustees.”

UKCP is presenting a bundle of contradictions and obfuscations to its members. There is no real clarity and in removing themselves from the MoU they place their members in a very difficult position.

Ahead of UKCP’s meeting this evening

Ahead of tonight’s UKCP meeting members about the Board election with we wanted to give a loose timeline and comments on UKCP’s withdrawal from the MoU.

In short: UKCP withdrew citing concerns that the MoU applied to children. The MoU does not prescribe how we work, except that we must start from the premise that no one identity (cis or trans) is better than the other. The UKCP’s clarification letter then says more about this, but draws on irrelevant things to support its point (which is a concern about working with children). Then a letter from the UKCP’s board cites legal actions as a reason. We were aware of one legal action involving UKCP, which they settled early this year. We are aware of one other legal action which also does not specify children. However, the clarification letter now states legal actions (and resultant increase in insurance) as a significant reason. Whether children are covered under the MoU2 is irrelevant to the claims, as this disctinction would not have stopped either legal action (which began in 2022 BEFORE the re-signing of the MoU2). The long UKCP letter claims “we couldn’t directly engage with you all due to the content of some of the organisational risks”. NCPS also failed to engage with its members on this. However, when approached, NCPS were open about their reasons (financial). If UKCP was also struggling with the financial aspect, they too could have been transparent from the start. Pink Therapy, who were forced to withdraw from the MoU (for insurance reasons) were transparent about this aspect.

We argue that the insurance premiums, whilst perhaps a genuine concern, are a red herring for the real issue here, which is that the MoU SHOULD cover all people. We also argue that if it was explicit that children were not covered, UKCP would be facing the same issue of finances.

Conversion therapy kills. The view put forward by people describing themselves as “gender critical” is that trans people are at best deluded about their experiences and at worst, predatory. Gender critical therapists apply the term “exploratory therapy” to their work with trans clients and trans clients only, which in the context of gender critical views and the limited application of “exploratory therapy” means that this can only be conversion therapy by another, more palatable name. The legal cases mentioned by UKCP have BOTH been in place since before the UKCP re-signed the MoU in 2022. This would also mean that the insurance company would have been aware of these cases for over a year.

At length:

UKCP initially withdrew citing the following reasons:

“The UKCP Board of Trustees reached this decision following concerns it held regarding whether the MoU applies exclusively to adults, or if children and young people are included in its scope. UKCP has received clarification that the MoU does indeed relate to all ages. Upon investigation, it became evident that there are historical concerns held by a number of UKCP colleges that regulate psychotherapeutic work with children and young people relating to this subject, and which have yet to be addressed – hence our decision to withdraw at this time.” (UKCP update on conversion therapy (psychotherapy.org.uk))

It seems clear from this statement that the issue for the UKCP here is about conversion therapy and children.

Their clarification states:

“Children and young people require and deserve careful support, that is often different from what is required for adults.

UKCP has been concerned for some time that this is not reflected in the current MoU. The current MoU was drafted to apply to adults and was retrospectively applied to children and young people without consultation with the relevant bodies and child therapists with the specialist and regulatory knowledge of working with children and young people.” (UKCP withdrawal from MoU on conversion therapy (psychotherapy.org.uk))

UKCP has not raised concerns suggesting this is the case in the past. The current MoU has consistently been accepted as a document that would protect LGBTQ+ youth as well as adults from conversion therapy since its inception. In particular, UKCP as a signatory agreed to the BPS Document ‘Guidelines and Literature Review for Psychologists Working Therapeutically with Sexual and Gender Minority Clients’ as the basis for their work in relation to the MoU as early as 2012. The document incorporates adults, young people and children.

In 2015 the UKCP agreed to the following as part of the publication of MoUv1 under the section: ‘Roles and Responsibilities’ that:

“Training Organisations will refer to the BPS guidelines on working with gender and sexual minority clients when reviewing their curriculum on equality and diversity issues”.

Within this document Children and young people are mentioned in Part II.

At several points along the way and between 2012 to date there have been ample opportunities for UKCP to move from the inclusion of children and young people and they have not. Trustees of UKCP have attended and been a party to discussions within the MoU about inclusion of young people as ‘members of the public’ who might be impacted by conversion therapy. UKCP Trustees have always been party to the knowledge and decision making surrounding MoU1 and 2, and the spirit, aims, and wording of these documents were unanimously aimed at safeguarding LBGTQ+ youth from conversion therapy. This is well documented and witnessed by those in attendance as signatory members. UKCP Trustees have attended meetings and been part of the decision making process.

As late as 2019 the MoU2 released a position statement to the press, agreed by all members including UKCP, which states clearly that:

“… a legal ban should not divert our attention from the fact that education and professional training remain essential in order for practitioners to be able to work competently with LGBT people of all ages and to provide them with a safe and respectful environment in which they can explore who they are without judgement or fear”.

UKCP has always been part of the decision making process surrounding the MoU2, and have always been aware that conversion therapy involving LGBT members of the public of all ages is harmful. As a signatory to the MoU2 UKCP have previously agreed that an adequate description of the MoU Coalition submitted to Parliamentary members is that the Coalition ‘acts on behalf of’ children and young people as well as LGBT people of all ages’ as part of its brief to government consultations.

It is not clear what the concern actually is. UKCP says it is against conversion therapy and the MoU states that:

“’conversion therapy’ is an umbrella term for a therapeutic approach, or any model or individual viewpoint that demonstrates an assumption that any sexual orientation or gender identity is inherently preferable to any other, and which attempts to bring about a change of sexual orientation or gender identity, or seeks to suppress an individual’s expression of sexual orientation or gender identity on that basis.”

It also states:

“this position is not intended to deny, discourage or exclude those with uncertain feelings around sexuality or gender identity from seeking qualified and appropriate help.” And “Nor is it intended to stop psychological and medical professionals who work with trans and gender questioning clients from performing a clinical assessment of suitability prior to medical intervention. Nor is it intended to stop medical professionals from prescribing hormone treatments and other medications to trans patients and people experiencing gender dysphoria.

For people who are unhappy about their sexual orientation or their gender identity, there may be grounds for exploring therapeutic options to help them live more comfortably with it, reduce their distress and reach a greater degree of self-acceptance. Some people may benefit from the support of psychotherapy and counselling to help them manage unhappiness and to clarify their sense of themselves.

Clients make healthy choices when they understand themselves better. Ethical practice in these cases requires the practitioner to have adequate knowledge and understanding of gender and sexual diversity and to be free from any agenda that favours one gender identity or sexual orientation as preferable over other gender and sexual diversities. For this reason, it is essential for clinicians to acknowledge the broad spectrum of sexual orientations and gender identities and gender expressions.”

It is completely unclear as to why this wording would provide a problem when working with children and young people. As therapists we should be seeking to help all clients understand themselves better. We should be able to help clients clarify their sense of themselves.

When challenged, UKCP have not been able to answer this question. Their concerns are listed as:

“No safeguarding distinctions between adults and children and young people”.

Trying to work out if you’re trans is not a safeguarding issue, if you work from the basis that being trans is not a ‘worse’ position than being cis. It simply means that you work ethically with children to allow them to explore their identities, INCLUDING the possibility that they are trans.

Applying adult-focused legislation and guidelines to children and young people which overlooks their unique developmental requirements.

There is no adult-focused legislation in the MoU. The MoU is not a legislatory document and the guidance is to remain open

Children and young people need a unique therapeutic approach that acknowledges their developmental stage and capacity for informed consent.

Agreed. However, the MoU leaves explicit space for professionals to work in the ways in which they work ethically with children. The MoU does not prescribe an approach; it says we have to work ethically.

The family and social context of children and young people, which is a vital source of information to understand the child/young person, is not taken into account.

Again – this is not what the MoU is trying to achieve here. It does not say that professionals cannot do this.

Due to the lack of child-specific guidance, child therapists face legal risks, including the possibility of lawsuits if a child detransitions in the future.

Any therapist who works with anyone is at risk of a lawsuit. We are not infallible and will make mistakes. The MoU does not say “YOU MUST TELL A CLIENT THEY ARE TRANS” it says “accept that trans is a valid identity”. It explicitly asks us to allow clients to clarify their sense of themselves.

Policy changes in the Department for Education (DfE) and the National Health Service England (NHSE) and safeguarding implications from emerging evidence and research relating to gender incongruence has not been taken into account.

We would argue again that this is irrelevant. Whatever NHS and DfEE policy say, this does not mean that counsellors/psychotherapists cannot allow clients the space they need. To suggest this is to suggest that we are in some dystopian future where thoughts should be policed. Stopping a person from having space to fully explore their identity will not stop people from coming out as trans. It *will* potentially lead to poorer mental health outcomes when children are being pushed into one particular outcome (“not trans”)

In a lengthy email to UKCP Members on 11th June, the focus shifts from instead of leaving because of safeguarding concerns (although this is still mentioned) to UKCP being named in legal action and this being expensive. UKCP suggests they could not consult with members in advance.

This may be true. However, there is nothing in any of the minutes available online for trustee meetings in 18 months that even mentions the MoU, leaving us to wonder just how important this was, when the UKCP has been named and implicated in legal action across that entire timeframe.

However we feel about whether or not UKCP should remain in the MoU (and of course, it is TACTT’s position that they should), the UKCP has not engaged in its stated objectives – the organisation should be consulting with members. It should have a clear narrative on why it has done what it has done. It seems clear that when faced with the backlash, the focus of the UKCP’s story has slowly changed to reflect a more palatable version of the reasons why. This is unacceptable and not how a board of trustees should be acting.

Open letter to UKCP about their guidance regarding so-called ‘gender-critical’ views

We have published an open letter to UKCP in response to their recently published statement on the law regarding so-called ‘gender-critical’ views and its implications for the practice of psychotherapy and psychotherapeutic counselling.

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UPDATE: It has been 24 hours since we first shared this open letter and it has already been signed over 400 times by psychoherapists, counsellors, trainees and other therapeutic practitioners. Thank you. We are moved and warmed by this outpouring of support.We also know that, sadly, work of this nature can attract negative attention. But while we acknowledge that risk, we are choosing to continue to share and promote this letter as widely as possible because we can see that it strikes a chord with so many therapists – and clients – who support an affirmative approach to working with trans, non-binary and gender-questioning clients.

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The full letter is below. If you would like to sign it, please go to https://openletter.earth/open-letter-to-ukcp-about-their-guidance-regarding-so-called-gender-critical-views-c71ce5d6

Open letter to UKCP about their guidance regarding so-called ‘gender-critical’ views

Dear UKCP,

We are writing in response to your recently published statement on the law regarding so-called ‘gender-critical’ views and its implications for the practice of psychotherapy and psychotherapeutic counselling. We are a group of over 100 registered therapists and trainee therapists, some of whom are trans, non-binary and/or gender-expansive people and some of whom are allies. We note that trans voices are palpably absent from UKCP’s statement and hope that this letter goes some way towards correcting the balance of discourse in the psychotherapy and counselling profession, which routinely discusses trans lives without centring the voices and lived experiences of trans people themselves.

Introduction

We were concerned by the publication of UKCP’s statement, which has created confusion and fear within both the profession and trans communities. We wonder why the statement was published at this time, with no explanation of its place within or alongside the UKCP Code of Ethics and Professional Practice (2019) and the Memorandum of Understanding on Conversion Therapy (2022), of which UKCP is a signatory.

Although not all of our members are registered to practise with UKCP, many are, and our stance outlined in the above paragraph is consistent with several points in UCKP’s Code of Ethics and Professional Practice (2019), specifically:

Point 3: Respect your client’s autonomy (p.1).
Point 24: Understand the limits of your competence and stay within them in all your professional activity, referring clients to another professional when appropriate. This includes recognising that particular client groups, such as children and families, have needs which not all practitioners are equipped to address (p.3).

We believe that therapy which affirms trans, non-binary and gender-questioning clients has the power to save lives. There is overwhelming evidence that gender-affirming care can improve mental health and general wellbeing, whilst decreasing risk of suicide (Lawson et al, 2023). We advocate for an affirmative approach, in which the therapist supports the client’s right to define themselves. Affirmative therapy is exploratory in nature. However we are concerned that the term ‘exploratory therapy’ is increasingly being used to justify therapy undertaken by those with so-called ‘gender-critical’ beliefs. We believe that unless a therapist holds the view that being trans is one of many potentially favourable and healthy outcomes, they are not competent to work with gender in the therapy room. Any ‘exploratory’ approach that does not consider transness to be as good as any other state of being, and which seeks to uncover and possibly ‘fix’ the ‘reason’ for the client’s gender identity is conversion therapy.

As with any marginalised client group, therapists have the task of unlearning preconceptions or pre-decided theoretical ideas regarding a client’s identity in order to work safely and effectively. Consider, for example, the similarities with lesbian, gay or bisexual affirming practice, where therapists are asked to examine and unlearn unconscious biases about sexuality, and to refer clients on if this is not possible (point q, section 5, UKCP, no date). It should be no different for gender identity and gender-expansive experiences.

Simply put, we consider it exceedingly difficult for therapists to hold the dual position of having ‘gender-critical’ beliefs whilst offering genuinely ‘exploratory therapy’ with trans, non-binary and gender-questioning clients. We are concerned that this is not the view UKCP presents to its members and the general public with its new statement. To position therapists with ‘gender-critical’ beliefs as the main proponents of ‘exploratory therapy’ is highly misleading.

Memorandum of Understanding on Conversion Therapy

TACTT wishes to understand why UKCP has published this statement now and what purpose it is intended to achieve. We would like to remind UKCP that, as a signatory of the Memorandum of Understanding on Conversion Therapy (MoU, 2022), you are already bound to an ethical stance on working with gender diversity:

Ethical practice in these cases requires the practitioner to have adequate knowledge and understanding of gender and sexual diversity and to be free from any agenda that favours one gender identity or sexual orientation as preferable over other gender and sexual diversities. For this reason, it is essential for clinicians to acknowledge the broad spectrum of sexual orientations and gender identities and gender expressions. (MoU, 2022, p2; emphasis added)

Indeed, point 36 of the UKCP Code of Ethics and Professional Practice (2019, p.4) specifically highlights that practitioners should be familiar with the Memorandum of Understanding on Conversion Therapy (MoU) (2022). We are concerned by the stark omission of the MoU in this statement. We are also concerned to find a discrepancy in point 30 of UKCP’s own Code of Ethics and Professional Practice:

Not allow prejudice about a client’s sex, age, colour, race, disability, communication skills, sexuality, lifestyle, religious, cultural or political beliefs, social economic or immigration status to adversely affect the way you relate to them. (UKCP, 2019, p.4)

We notice that gender is not included in these protections and wonder why? As a signatory of the MoU, UKCP is committed to the protection of gender diverse people. May we remind UKCP that ‘gender reassignment’ is still a protected characteristic under the Equality Act (2010).

We request more clarity on how UKCP members should act on the information provided in the statement – is it guidance, or policy? How should this statement be observed and put into practice with clients whilst UKCP’s members abide by the UKCP Code of Ethics and Professional Practice and the Memorandum of Understanding?

An exploratory approach?

We disagree that an ‘exploratory’ psychotherapeutic approach is likely to be taken if a practitioner has sympathy with ‘gender-critical’ views (Ashley, 2023). We also find UKCP’s definition of ‘exploratory therapy’ to be unclear. It has already, in the short time since the publication of its statement, created confusion and distress for clients and the wider trans community.

Whilst case law has confirmed that ‘gender-critical’ beliefs are protected under the Equality Act 2010, the expression of such beliefs is not protected if it causes harm or distress to another. The ‘gender-critical’ belief that sex is binary and immutable translates into a belief that trans identities are not valid. We agree with the MoU (2022, p.2) that ethical practice when working with gender requires clinicians ‘to be free from any agenda that favours one gender identity […] as preferable over other gender […] diversities.’ Thus, when therapists work from the starting point that being trans is not a favourable outcome and are constantly looking for an ‘explanation’ for someone’s identity, this can easily tip into conversion practices. How can a therapist, who does not believe that a trans person is who they define themselves to be, conduct therapy ‘without any preconceptions or pre-decided theoretical framework regarding the person’s gender identity’ (UKCP statement)?

To work with gender ethically and competently, therapists must accept that being trans is a good state of being and a good outcome – one of many possible, valid outcomes, none of which is preferable to another. Furthermore, any movement towards one of many possible, valid outcomes should always be determined by the client.

While we agree that practitioners will often hold differing views on what approach is in the best interests of our clients, what is missing from this statement is any acknowledgement of what the client wants, needs or feels. Clients who are trans, non-binary and gender-questioning do not always present with ‘dysphoria’ and when they do this term means different things to different people. It is vital that we follow our clients’ lead and explore what they want to talk about. In general, therapists are not medical gatekeepers and, outside of gender services, we do not play a role in whether or not clients can or should access medical care. It is our role to support clients’ sense of agency in defining themselves. It is not our job to greenlight our clients’ gender journeys but to be with them as they figure out where they go.

Research by Hunt (2014) found that therapists’ lack of awareness and competence in working with gender can be a barrier to trans people accessing the support and space for exploration they may require from therapy. Indeed, therapists may not actually be someone their clients choose to share their gender journeys with. But the chances of this are more likely if clients feel able to bring all of themselves. Again, we emphasise that trans voices are noticeably absent from UKCP’s statement, which appears to prioritise the right of the therapist to assert an approach that ‘is in the best interest of their clients’ over the actual needs and desires of their clients.

Misleading and contradictory

We found UKCP’s statement to be misleading and contradictory in several ways. First, we are concerned that by leading with a reference to the interim Cass Review and its implications for UKCP members, and then continuing to reference medical interventions for children and young people, it replicates a hyperfocus on trans children and young people which excludes their voices whilst contributing to public hysteria. Furthermore, therapists who are not informed about the Cass Review and its specific emphasis on children and young people may, having read UKCP’s statement, now take this as direction to hold a particular stance in relation to providing psychotherapeutic support to adult clients.

Secondly, we find that overall UKCP’s statement conflates working psychotherapeutically with being directly involved in any medical care trans clients may wish to consider and access. Psychotherapists and psychotherapeutic counsellors are not medical professionals. Outside of specific Gender Identity Clinics, therapists are not involved in any decision-making about gender-affirming medical care. This is the case regardless of whether we find ourselves supporting children, young people, or adults. This continues to be the case even if a client self-defines as experiencing gender dysphoria (in whatever language they may use), has a medical diagnosis of gender dysphoria, or may be seeking a gender dysphoria diagnosis for any number of reasons.

However, thirdly, this statement unnecessarily centres the concepts of gender dysphoria and medical intervention, as though these are the only experiences of being trans in the world. It is incorrect, disrespectful, and reductionist to regard all trans, non-binary and gender-questioning clients as experiencing gender dysphoria and/or seeking gender-affirming medical intervention. Doing so dismisses the incredible diversity of what it means to be trans, non-binary or gender-expansive, and to experience oneself authentically and euphorically. This statement reads as though it has been written by people who have never worked with trans, non-binary and gender-questioning people. As per point 29 of UKCP’s Code of Ethics and Professional Practice (2019, p.4), we urge you to expand your knowledge of transness, to honour the diverse narratives of trans people, and to make space for other experiences, such as gender euphoria and trans joy.

Reductive and pathologising

We find the UKCP Chair’s use of the term ‘gender issues’ in this statement to be reductive. By placing this alongside ‘mental health conditions and emotional issues such as depression, eating disorders and relationship difficulties’, UKCP treats gender diversity as problematic and pathological and ignores the creativity, potentiality and joy that can be found in working with trans, non-binary and gender-questioning clients. The Chair further reduces working with gender to ‘questioning’, which in our experience is only ever part of a vast, kaleidoscopic landscape of what it means to work with gender in therapy. Many trans people in therapy already know what their gender is; it is living in a world which denies their existence and does violence to their bodies which causes them psychological distress and harm.

We also wish to remind UKCP that trans people may seek therapy for all the reasons anyone seeks therapy and it is important that therapists do not assume clients are only seeking support for gender identity or transition. We work with clients on family issues, sex and relationships, work, bereavement, isolation, anxiety, depression – all the things any client may bring to therapy.

The Chair’s assertion that a ‘thorough exploration’ of gender ‘can take time, and sometimes a very long time’ is highly alarming, and redolent of the potentially harmful concept of ‘watchful waiting’. It suggests that therapists have the power to decide how long a ‘thorough exploration’ should take, all the while clients are held in a place of discomfort and dis-ease. How will the therapist know when enough time has passed? What will tell them that any exploration is ‘sufficiently thorough’? Again, this argument appears to prioritise the approach of the therapist over the agency of the client. As Saketopoulou (Acast, 2022) suggests, “This seems to have more to do with the person who wants to do the watching, rather than the person that is doing the waiting.”

We believe the Chair’s reference to medical interventions has no place in guidance published by a UK psychotherapy body. As we have stated, in the UK, psychotherapists and psychotherapeutic counsellors are not medical gatekeepers; it is not our responsibility to determine ‘risk’ in seeking gender-affirming medical care. UKCP’s statement risks generating panic amongst practitioners and clients by suggesting that it is the therapist’s place to sanction a client’s access to gender-affirming care.

For UKCP therapists who are interested but inexperienced in supporting trans, non-binary and gender-questioning clients, such panic prevents them from learning and offering appropriate psychotherapeutic services. Thus, the pool of competent, safe therapists available to such clients becomes ever smaller.

Furthermore, medical intervention is not the only choice open to trans and non-binary clients, and this reductionist statement does nothing to help wider public understanding of the complexity and nuance of what it means to explore gender or to be trans in the world.

We find the Chair’s closing argument troubling. It creates further concern about UKCP’s stance on how its members should work with gender diverse clients:

Regardless of viewpoints, all professional psychotherapists and psychotherapeutic counsellors who work with gender dysphoria or gender-identity want the best for the person who is struggling and needs help. If this is always kept in mind, these vitally important conversations, however difficult, can take place in a healthy and supportive manner, allowing us to ensure our clients’ and the public’s best interest and safety remain paramount. (UKCP statement)

Can UKCP clarify why safety is a concern for the public in relation to transgender, non-binary, and gender non-conforming people seeking therapy? How will psychotherapists and counsellors know what is ‘best’ for clients? Who defines ‘best interest’? Does this mean respecting our clients’ autonomy? How will UKCP act to protect trans, non-binary and gender-questioning clients from therapists whose ‘gender-critical’ beliefs cannot be bracketed and unduly influence what they believe is in the best interest of the client?

It cannot be said with any certainty that all psychotherapists and psychotherapeutic counsellors who work with gender dysphoria or gender identity want the best for those who are struggling and need help. By definition, therapists who hold ‘gender-critical’ beliefs already disagree on what trans, non-binary and gender-questioning people define as best for themselves.

Overall, UKCP’s statement grossly misunderstands the reality of working with trans, non-binary and gender-questioning clients who seek psychotherapeutic support. There is nothing ‘difficult’ about being allied with our clients’ views on how they feel about themselves, or their expressions of identity in ways that are fulfilling and meaningful. Doing so is simply part of offering psychotherapeutic support in an ethical manner, making space for difference and diversity along the way.

Conclusion

We ask that UKCP clarifies its original guidance and responds to the questions and points we have raised throughout this letter.

We invite you to further your own education on trans experiences and centre trans voices in any future public commentary on trans lives. This can be achieved by consulting with trans and non-binary therapists, as well as practitioners who are undertaking affirmative therapy with trans, non-binary and gender-questioning clients. There are many practitioners in TACTT and beyond who would generously share their experiences in the interest of making emotional and mental wellness a human right for trans people.

Finally, we urge UKCP to reflect on how a ‘gender-critical’ therapist could reasonably, ethically, and legally be able to offer psychotherapeutic support to trans, non-binary and gender-questioning people. We see nothing but risk of harm in this approach.

We fear that if UKCP continues down this path, the council and its members will be considered by clients to be synonymous with being ‘gender-critical’. Indeed even in the short space of time since this statement was published, we are already seeing this fear shared amongst trans people. Many practitioners train for a long time to achieve UKCP membership and registration; it is disappointing that those of us who are trans-affirmative are starting to question our place in the organisation.

We invite other psychotherapists and psychotherapeutic counsellors who support this letter to sign below.

Yours sincerely,

Therapists Against Conversion Therapy and Transphobia (TACTT)

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References

Acast. (2022). ‘Exposing Transphobic Legacies, Embracing Trans Life’ with Dr Jules Gill-Peterson & Dr Avgi Saketopoulou. Couched (Podcast) 24 June. Available at: Episode 3, Season 3. iPlayer, 17 February 2023. Available at: https://couchedpodcast.org/exposing-transphobic-legacies-embracing-trans-life/

Ashley, F. (2023). ‘Interrogating Gender-Exploratory Therapy’. Perspect Psychol Sci. 18(2): 472–481. Available at: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10018052/

Bachman, C. L., & Gooch, B. (2018). LGBT in Britain: Health Report. Stonewall. https://www.stonewall.org.uk/lgbt-britain-health

Hunt, J. (2014). ‘An initial study of transgender people’s experiences of seeking and receiving counselling or psychotherapy in the UK.’ Counselling and Psychotherapy Research Journal. 14 (4): 288-296. Available at: https://onlinelibrary.wiley.com/doi/10.1080/14733145.2013.838597

Lawson, Z., Davies, S., Harmon, S., Williams, M., Billawa, S., Holmes, R., Huckridge, J., Kelly, P., MacIntyre-Harrison, J., Neill, S., Song-Chase, A., Ward, H., & Yates, M. (2023). ‘A human rights based approach to transgender and gender expansive health.’ Clinical Psychology Forum 369.

Available at: https://explore.bps.org.uk/content/bpscpf/1/369/91

Memorandum of Understanding on Conversion Therapy in the UK: Version 2 – Update March 2022. (2022). Available at: https://www.bacp.co.uk/media/14985/memorandum-of-understanding-on-conversion-therapy-in-the-uk-march-2022.pdf

UKCP. (2019). Code of Ethics and Professional Practice. Available at: https://www.psychotherapy.org.uk/media/bkjdm33f/ukcp-code-of-ethics-and-professional-practice-2019.pdf

UKCP. (no date). Guidance on the Practice of Psychological Therapies that Pathologies and/or Seek to Eliminate or Reduce Same Sex Attraction. Available at: https://www.psychotherapy.org.uk/media/hhxle33g/guidance-on-psychological-therapies-that-pathologise-and-or-seek-to-eliminate-or-reduce-same-sex-attraction.pdf