Draft Conversion Practices Bill – safeguarding young lesbians

Dear Members of the Joint Committee,

Re: Draft Conversion Practices Bill – safeguarding young lesbians

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We are writing on behalf of The Fantastic Lesbians to raise serious concerns about the potential impact of the Draft Conversion Practices Bill on young lesbians.

We strongly support protection from genuine abuse intended to force a person to change their sexual orientation. Lesbians have a particular historical interest in ensuring that nobody is coerced, shamed or pressured into heterosexuality.

However, we are concerned that legislation intended to prevent conversion practices could, unless very carefully drafted, have the unintended effect of making it more difficult for vulnerable young people—particularly girls—to explore whether distress about their sex or gender is connected to their emerging sexual orientation.

Young lesbians require particular safeguarding

Adolescence is a period in which sexual orientation is developing and becoming understood. Some young lesbians may experience considerable distress before accepting that they are same-sex attracted, particularly if they are gender non-conforming or uncomfortable with the expectations placed upon girls.

It is therefore essential that gender non-conformity or distress about developing as a young woman is not automatically interpreted as evidence of a transgender identity.

There is substantial research demonstrating an association between childhood gender non-conformity and later homosexuality.

A prospective population study by Steensma et al. (2013) found childhood gender variance was significantly associated with homosexuality in adulthood for both males and females, while not being significantly associated with gender discomfort in adulthood. (PubMed)

A large UK longitudinal study using the Avon Longitudinal Study of Parents and Children (ALSPAC) similarly found that gender-typed behaviour in early childhood predicted sexual orientation in adolescence. (PubMed) A later ALSPAC study found childhood gender non-conformity predicted lesbian/gay sexual orientation at ages 15, 21 and 23. (PubMed)

More recently, a prospective cohort followed into adulthood found childhood and adolescent gender-role non-conformity was associated with diverse sexual identity and same-sex behaviour. (PubMed)

These findings do not mean that every gender-non-conforming child will grow up to be homosexual. They do mean that gender non-conformity in childhood cannot safely be treated as evidence that a child is transgender.

Sexual orientation and transgender identity must not be conflated

Sexual orientation concerns whom a person is attracted to. Transgender identity concerns a person’s relationship with their sex or gender identity.

They are different concepts and should remain clearly distinguished in legislation, clinical practice and safeguarding.

We are particularly concerned about young lesbians who have not yet understood or accepted their sexual orientation being wrongly identified as transgender when their rejection of conventional femininity, discomfort with puberty, attraction to other girls or distress about becoming adult women may form part of their development as lesbians.

A legislative framework must not inadvertently reinforce this conflation.

Medical intervention and the principle of “first, do no harm”

The consequences of getting this distinction wrong can be profound.

Puberty suppression is a medical intervention with physical consequences, and progression from puberty blockers to cross-sex hormones has historically been very high in treated cohorts. Cross-sex hormones can produce significant and potentially irreversible changes and may have long-term implications for fertility, sexual function, bone and cardiovascular health.

These concerns are particularly important given the weakness of the evidence base identified following the Cass Review. NHS England has subsequently stated that the evidence supporting cross-sex hormones for children and young people is “very limited and weak”, and in March 2026 paused new NHS prescriptions for under-18s while its policy is reconsidered. (NHS England)

A young person who begins medical intervention may therefore make decisions with consequences extending far beyond adolescence.

The fundamental medical principle of “first, do no harm” should inform both treatment and legislation affecting vulnerable children.

The danger of preventing exploratory therapy

We are also concerned about the language surrounding “conversion therapy”.

There is an enormous difference between attempting to force a homosexual person to become heterosexual—which we unequivocally oppose—and allowing a distressed adolescent to explore, without a predetermined outcome, questions concerning sex, sexuality, puberty, relationships and identity.

A young girl saying “I think I am a boy” should be able to discuss why she feels that way.

She should be able to consider whether she dislikes the physical changes of puberty, whether she is frightened by sexual attention from males, whether she rejects stereotypical expectations of femininity, whether she is attracted to girls, or whether other psychological or social factors are contributing to her distress.

That exploration should not be characterised as conversion.

Indeed, preventing such exploration risks creating precisely the problem that conversion-practice legislation is supposed to prevent: imposing an interpretation of a young person’s identity before she has had the opportunity to understand herself.

The Government itself has recognised this concern. When introducing the Draft Bill, the Minister acknowledged therapists’ concerns about exploratory work with young people and stated that the legislation should not create a chilling effect on healthcare. (Hansard)

We believe that protection must be explicit rather than dependent upon reassurance given during parliamentary debate.

Our request to the Committee

We therefore ask the Joint Committee to ensure that the legislation:

1. Clearly distinguishes sexual orientation from transgender identity, rather than treating them as interchangeable aspects of a single phenomenon.
2. Explicitly protects open-ended, neutral and exploratory therapy, particularly for children and adolescents experiencing distress about sex or gender.
3. Ensures that therapists, clinicians and parents remain free to explore whether a child’s gender distress may be connected with emerging homosexuality or bisexuality, gender non-conformity, puberty, trauma, autism, mental health or other relevant factors, without fear that doing so will constitute an unlawful conversion practice.
4. Gives particular consideration to the safeguarding of young lesbians and other gender-non-conforming girls, including the possibility that some may initially understand their distress through the language of gender identity before recognising their sexual orientation.
5. Applies the principle of “first, do no harm”, ensuring that legislation does not discourage careful assessment, differential diagnosis, therapeutic exploration or appropriate clinical caution.

The Draft Bill is intended to protect lesbian and gay people from attempts to change their sexual orientation. It would be a profound unintended consequence if the same legislation made it harder for a young lesbian to discover and accept that she is a lesbian.

Young people deserve protection from abuse. They also deserve time, careful assessment and a genuinely neutral therapeutic space in which no conclusion about their eventual identity is predetermined.

We urge the Committee to ensure that the final legislation protects both.

Yours faithfully,
The Fantastic Lesbians