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A Bill to ban conversion therapy is currently being debated in the Northern Ireland Assembly. It shares many features of the Westminster bill but also has some significant differences. Both Bills pose a real threat to parents, teachers, and to any person or group who wants to stop a child from taking life changing steps in the belief they are the opposite sex.

The consultation on the Northern Ireland Bill closes on October 1^st 2026. You can respond here.

We will be responding citing these following key problems with the Bill and arguing for it to be dropped in its entirety.

Outline of the Bill

The Bill’s sponsor is Eoin Tennyson, deputy leader of the Alliance Party. Clause 1 of the Bill would criminalise anyone who ‘provides or carries out conversion therapy’ with the intent of ‘changing or suppressing the sexual orientation or gender identity of a victim’ and who ‘suffers physical or psychological harm as a consequence of the therapy.’  ‘Psychological harm’ includes ‘fear, alarm, and distress.’ It defines conversion therapy as ‘counselling or any form of talking therapy, coaching or instruction, a treatment or purported treatment.’

There is a carve out, Clause 4 (3) for clinicians who are registered with various professional bodies such as the GMC.

Clause 2 criminalises anyone who ‘engages in coercive conversion behaviour.’ Coercive behaviour is any behaviour which is ‘violent’ ‘threatening’ ‘controlling, regulating or monitoring’ day-to-day activities, ‘depriving or restricting’ freedom of action, and ‘making the victim feel frightened, humiliated, degraded, punished or intimidated.’ It also includes the offence of causing ‘psychological harm.’

Clause 3 covers the offence of taking a person out of NI for the purposes of conversion therapy.

An accused person could offer a defence of ‘reasonableness’ in the particular circumstances, but if found guilty, by juryless courts, could face up to two years in prison and/or an unspecified fine.

Forced teaming: adults and children, gay and trans

Like the draft Westminster Bill, no distinction is made in Tennyson’s Bill between adults and children as victims of conversion therapy. Those the Bill calls ‘victims’ could be a five-year-old boy who says he is a girl, or a depressed teenage girl with an eating disorder who wants to bind her breasts, or a sixteen-year-old boy who is ashamed of his growing homosexuality and believes he is trans, or a girl who has suffered undisclosed sexual assault, or a child with autism. Conditions and traumas such as these are all characteristics of the majority of children who present with gender-related distress. All may claim they are sure of their identity and be unwilling to listen to other views.

Many laws make a clear distinction between children, defined as under 18, and adults, in areas such as the age of consent, marriage, criminal responsibility and employment law. Children are treated differently because their cognitive abilities are still developing. But this proposed legislation does not protect children as developmental beings. It treats them as adults.

Children’s identities are fluid and subject to constant revision as they grow. Puberty is a process, starting essential cognitive and physical changes and growth. This Bill ignores this established knowledge about child development and treats what may be a passing identity as permanent. It will make conversations between children and parents and teachers much harder. In addition, if honest conversations with those who know the child best are proscribed, and if parents feel pressured to affirm, it will make it harder for a clinician to conduct traditional therapy further down the line.

It will cause serious harm to one of the groups the Bill claims it is protecting; gay and lesbian teens who are beginning to discover their sexual identities. Evidence from the Cass Review shows that same-sex attracted children are overrepresented in gender services. Troubled children who are struggling to define their sexuality are the most vulnerable to the idea that they could be trans and straight. The accounts of detransitioners show that emerging same-sex attraction is left unacknowledged if affirmation takes place before conventional therapy.

Homosexuality has been a constant expression of human sexuality for decades and no drugs or surgeries are required to be gay. The concept of gender identity is different. It only entered widespread social use around 2005.

The Bill discriminates against girls. By treating adults and children, those with same-sex orientation and those with gender-related distress as one undifferentiated group it fails to take account of girls’ needs.  There has been an unprecedented increase in the number of children, a majority of them girls, many of whom are same-sex attracted, presenting to health services with gender-related distress. Testosterone and double mastectomies are the main treatment options. It is wrong to bring in legislation which will penalise anyone asking questions about this increase before there is an investigation into the reasons behind it.

Coercive behaviour

The freedom to parent according to your values is most under threat from Clause 2 of the Bill. Ordinary parenting involves making decisions that children find restrictive such as setting boundaries on internet use, drinking, drug use, travel and spending. Parents who want to change their daughter’s belief that she is really a boy could find themselves prosecuted for coercive behaviour. A refusal to buy a binder for her could be seen as ‘controlling, regulating or monitoring’ her everyday activities, stopping her from attending a trans support group for 13-25-years-olds could be seen as ‘restricting’ her freedom of action, refusing to use male pronouns could make her feel ‘humiliated.’ There will be strong pressure to affirm their child’s belief to avoid being accused of conversion therapy.

Clause 2 (2) relating to psychological harm will impact family life. Psychological harm is not defined in the Bill except to say that it includes ‘fear, alarm and distress.’ Children in households where the parent and child argue over pronouns and name changes are likely to experience alarm or distress. Children are told by NI campaign groups, contrary to all evidence, that children ‘know’ their gender identity by the age of 7. A parent countering this misconception may indeed cause the child some distress as they try to bring their child back to a realistic understanding of themselves and their sexed bodies.

Suppression and intent

Even if a parent remains neutral and does not attempt to change their child’s identity belief, a charge of ‘suppressing’ their identity could be brought if the parent prohibits certain activities such as a boy going out dressed as a girl or buying hormones online. The draft Bill does not give any guidance as to what may be classified as suppression. Parents will not know which actions leave them open to prosecution if they try to stop their children making decisions that will have life changing consequences before they have reached adulthood. 

This Bill if enacted will allow unprecedented state interference in family life and parental choice. A parent’s duty to protect their child from harmful actions will be undermined. The ‘intent’ aspect of the Bill is subjective. A parent may believe their actions are in the child’s best long term interests, but as worded any action that the child perceives as ‘controlling’ or ‘restricting’ may be liable to prosecution for suppressing their gender identity.

Anyone can make an accusation that particular actions are coercive behaviour as outlined in the Bill; for instance an activist teacher or social worker, another parent or an affirming doctor who is opposed to parental refusal to affirm a trans identity.

An accused person will not be able to say in their defence that there was no  ‘intent’ in their actions to change or suppress a child’s gender identity. But there is a defence for those who want to affirm any gender identity. There is a specific carve-out for this at Clause 7 (1) (c). This will allow LGBT campaign groups, affirmative teachers, doctors and others to encourage transition without being accused of conversion therapy.

Definitions in the Bill

The Bill relies on terms (gender identity, suppress, psychological harm) that are contested, undefined or open to interpretation. Gender identity is not used in any legislation in the UK. The explanatory notes define ‘gender identity’ being both what the victim and the perpetrator consider it to be. This is entirely subjective and cannot be proven or disproven.

It’s possible that a refusal to endorse a genderfluid, genderqueer, neutrois, non-binary,  trigender or any other gender identity could be seen as conversion therapy.

The Bill defines asexuality as a sexual orientation. This a new legal term which is not found in any other NI legislation. Having no sexual feelings is complex, possibly the result of developmental stage, a medical condition or trauma. The attempt to have it seen as an orientation comes from activist groups, not medical research. The NHS does not record asexuality in its data sets for sexual orientation. If gender identity and asexuality are written into law this will be a back door route to gender self-ID, which is not legal in any part of the UK.

Defining psychological harm, the Bill’s explanatory notes say ‘Under this clause, psychological harm includes fear, alarm and distress.’ Without a clear definition of psychological harm parents, teachers and others who talk to children about gender distress will not know if what they say can be interpreted in this way. There are no time restrictions in the Bill, allowing the possibility that earlier conversations or family friction could be recast as conversion therapy.

Evidence of conversion practices in Northern Ireland

There is no evidence that conversion practices are taking place in Northern Ireland which requires a new law beyond those which exist to tackle verbal and physical abuse.

The Bill cites as evidence a single piece of research, A Study of Conversion Practices in Northern Ireland, by Professor Fidelma Ashe and Dr Danielle Mackle. In the explanatory memorandum prepared by the Bill’s sponsor, Eoin Tennyson, he fails to mention that the research was commissioned by Cara-Friend, HEReNI, The Rainbow Project and TransgenderNI, groups which campaign for a conversion ban. Tennyson claims the research found:

“evidence that conversion practices have been offered to LGBTQIA+ people and practiced in Northern Ireland over the last 10 years. Study participants identified conversion practices offered to or conducted on young adults and children in spiritual, health, and educational settings.”

Ashe and Mackle were only able to recruit 10 people for their research, despite the four commissioning trans rights groups calling for respondents through their social networks. The authors admitted that ‘some participants were also recruited through the researchers’ networks.’

Of the 10 who participated in the study, 6 were aged 18 or under at the time of the conversion therapy. 3 participants identified as trans, 2 of whom were aged 14 at the time of the conversion therapy. Each interview lasted only 40 minutes.

The testimony from the two trans identifying teenagers in the study is what we would expect to see given the sudden increase in trans identification around 2015. Both had psychotherapy at mental health clinics. They say that therapists tried to talk about their family backgrounds, autism and mental health but both teenagers viewed this as conversion therapy.

Despite warning that their findings cannot be generalised the authors recommended a ban on conversion therapy.

The activist context

There’s been no risk assessment of the effects of the messaging from activist organisations and how it might be received by teenagers and children with gender-related distress. Organisations in NI’s Ban Conversion Practices Coalition call only for affirmative gender health care for children with gender-related distress. The Rainbow Project has links to Anne Health a private online company which claims it has a legal way to offer puberty blockers. TRP also directs under 18s for gender affirming care at the Knowing Our Identity clinic and claims to be working with the clinic to  ‘resolve’ the issue of the ban on puberty blockers. These organisations will be exempt from any prosecution under the Tennyson Bill should it become law because it will protect those who affirm a child’s belief that they can change sex.

In the wider context groups like Trans Kids Deserve Better claim that ‘many of us die waiting for gender affirming care’ and talk of the ‘UK’s judiciary, government and media messages of genocide.’

There must be a risk assessment of possible harms caused to emotionally vulnerable and mentally unstable children if this Bill is passed. It will give governmental authority to the message that not affirming a child’s transgender identity is violence against the child and a crime.