Analysis of Gender Recognition Certificate application process: FOI release

Information request and response under the Freedom of Information (Scotland) Act 2002

Information requested

With reference to recent comments made last month by the First Minister:

" the first year of this Parliament, we will introduce the gender recognition reform bill...It will make the existing process of gender recognition less degrading, intrusive and traumatic."

Nicola Sturgeon MSP, Scottish Parliament, Official Report, 7 September 2021

Please provide details of all qualitative and quantitative analyses undertaken and/or commissioned by the Scottish Government regarding the experiences of those applying for a Gender Recognition Certificate to support this statement. Please provide details of the methodology used in all analyses.”


The Scottish Government has carried out two public consultations, the first on the principles of gender recognition reform, and the second on a draft Bill. Two independent analyses were commissioned which provided both a qualitative and quantitative analyses of consultation responses, which included responses from those with experience of applying for gender recognition. For example - 

Paragraph 6 of the analysis report of responses to the first consultation states:

“Respondents sometimes related personal experiences of the difficulties they had encountered when applying for a Gender Recognition Certificate (GRC) or suggested that, although they had lived in their acquired gender for many years, they had not applied for a certificate because of the costs, the intrusive nature of the process, or the difficulties in providing the evidence required.”

paragraphs 2.9 – 2.10 of the analysis report of responses to the second consultation state:

“There were also particular concerns about the GRP – both in terms of the inappropriateness of a panel-based system and the actual experiences of those whose cases have gone to the Panel. The latter included reports that this experience had been intimidating and/or humiliating. The administrative burden, including in relation to compiling a document-based body of proof, was described as time consuming and onerous. It was also seen as disadvantaging those trans people who may not have access to key documentation, for example because they are homeless or fleeing domestic abuse.

Both through their own stories and more generally, respondents who supported change spoke of the detrimental impact the current approach is having on trans peoples’ health, wellbeing and life chances. Respondents spoke of their own, sometimes lengthy and difficult, experiences of going through the current system, or of their reluctance to apply for a GRC because of concerns or anxiety about the process. There were particular references to the impact on mental health and also to self-harm and risk of suicide. It was suggested that a more straightforward process, with a focus on trust and validation, could have a transformative effect on the mental health and wellbeing of individuals and the wider trans community.”

In addition, you may find it helpful to note that the consultation refers to the Women and Equalities Select Committee’s transgender equality inquiry at the UK Parliament which reported in 2016 having heard evidence from witnesses, including about the experiences of those applying for gender recognition. It also refers to UK Government’s National LGBT survey which published a report in 2018, including about the experiences of those applying for gender recognition.

Further information about the methodologies can be found at the links provided.

The Cabinet Secretaries who have had responsibility for gender recognition reform have also heard from trans people and representative organisations at meetings and through correspondence.

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