TL;DR: The UK government has finally published its draft bill to ban conversion practices, but the legislation has been met with mass criticism due to loopholes that effectively make it an “instruction manual for abuse”
After years of promises, delays and U-turns, the government has finally published its draft bill on banning conversion practices. Although it has been welcomed as a historic and long overdue step in the fight against abhorrent anti-LGBTQIA+ abuse, broad and vague loopholes have raised serious concerns that it is a ban in name only and queer people will continue to face risk and suffer harm.
Conversion practices, also known as so-called ‘conversion therapy’, consist of pseudoscientific “treatments, practices or services that seek to change or suppress a person's sexual orientation, gender identity or gender expression, based on the assumption that any sexual orientation, gender identity or gender expression is inherently preferable to any other” – Ban Conversion Practices
Previous research has shown as many as 1 in 5 LGBTQIA+ people in the UK have experience with conversion practices, with trans and non-binary people facing the highest rates of abuse – Galop
The 20-page draft Conversion Practices Bill, which applies to England and Wales, was laid before Parliament on Thursday.
It was announced to the LGBTQIA+ community with a joint collaboration post on social media by the Ban Conversion Practices Coalition, Stonewall, Gendered Intelligence and Galop.
Following its publication, two significant loopholes – a healthcare exemption and the use of symmetrical language – were pointed out by organisations, activists and wider members of the queer community directly in the post’s comments and on other platforms.
Many have expressed fear these loopholes could be exploited by conversion practitioners and anti-queer political actors to continue to perpetuate harm.
After putting these concerns to the organisations, QueerAF was told by Saba Ali – the chair of the Ban Conversion Practices Coalition – that they have seen the comments, hear the concerns being raised and are taking them seriously.
“This has been eight years in the making, eight years of broken promises, and none of us know for certain what the political landscape holds,” Ali said via email. “So personally, I am glad it has been published. But I say that knowing full well that publication is not the finish line, it is where the hard work truly begins.”
What does all this mean though? Let's explore in-depth.
What does the draft bill say?
Titled as the Conversion Practices Act 2026, the draft legislation creates new criminal offences, sets the threshold for criminal conduct, allows courts to issue Conversion Practice Protection Orders to people who are deemed at risk, and outlines the legal punishment for carrying out conversion practices.
The two new offences described in the bill are, firstly, carrying out conversion practices on an individual and, secondly, encouraging or assisting conversion practices outside of England and Wales.
In the context of these offences, the draft legislation sets the threshold for conversion practices as any conduct that aims to change someone’s sexual orientation or transgender identity through abusive acts that seriously harm the victim – Office for Equality and Opportunity
If a person is found to have conducted conversion practices, under the proposed ban they will face an unlimited fine, a five-year prison sentence, or both.
Presenting the bill in the House of Commons on Thursday afternoon, Equalities Minister Olivia Bailey described the bill as “comprehensive”, having “no loopholes” and being that which “fills gaps in our criminal law” and provides both victims and authorities “a clear definition with which to identify, tackle and prevent this abuse” – Hansard
What are the loopholes?
Despite Bailey’s claim the draft bill has no loopholes, the exact opposite is the case.
Healthcare exemption
Firstly, the proposed ban has an explicit exemption for “legitimate” healthcare.
In the document, their definition of what constitutes “legitimate” services includes “all forms of health care services provided for individuals, whether relating to physical or mental health” and “procedures that are similar to forms of medical or surgical care but are not provided in connection with a medical condition”. In the bill’s explanatory notes, this definition is confirmed to have the same meaning as in section 135 of the Health and Care Act 2022 where the provision will include “people working in all public and private, regulated and non-regulated sectors”.
This is concerning as there are a number of health and social care professions in the UK that are not subject to any statutory regulation, such as the fact anyone can legally practice and call themselves a ‘therapist’ without legal registration – Professional Standards Authority
It is not just unscrupulous providers that concern has been raised about, as there are fears institutionalised anti-trans conversion practices could be legitimised in healthcare settings under the language of the bill. One need only look at the sweeping ban on puberty blockers or direction schools have been given to teach that gender identity is "highly contested" in relationships, sex and health education (RSHE) to get a sense of this.
Indeed, although 25 major health, counselling and psychotherapy organisations in the UK share a memorandum of understanding on conversion therapy, the results of the government’s own National LGBT Survey found that groups described as ‘Healthcare provider or medical professional’ were the second most prolific (28.7%) at having carried out conversion practices on respondents, with ‘Faith organisation or group’ being the most common (50.4%).
Dr Hilary Cass, author of the controversial and much-critiqued Cass Review, is cited in the government’s press release on the ban’s announcement as saying the bill’s exemption allows healthcare professionals to be able to do their job “without fear of litigation”.
By contrast, Good Law Project founder Jolyon Maugham said because the definition of healthcare is very broad in the bill, the exemption could see a situation where a “crank providing "mental health" services is providing "health care services" and so isn't engaging in "conversion practices"”. In a lengthy statement, TransActual also criticised this, saying the bill “paves the way for a cottage industry of conversion abusers posing as therapists and healthcare practitioners”.
QueerAF put such concerns about the healthcare exemption to the government’s Equalities Office. A spokesperson said: “Medical and therapeutic bodies view legitimate gender identity healthcare as never aimed at causing someone to have or not have a particular transgender identity; the intention is to support and assist that person as they explore their gender identity.”
Symmetrical language
Secondly, the draft bill contains symmetrical language wherein it sets out that conversion practices are conducted with the intention of “causing the individual (i) to have or not to have, (ii) to believe that they have or do not have” a sexual orientation or transgender identity.
As noted by legal researcher Jess O’Thomson, the section is perhaps “mirrored for neatness of construction” and also as a means of protecting people on the asexual spectrum from conversion practices.
However, concern has arisen that if the letter of the law treats conduct that intends to make an individual believe that they have, or do not have, a sexual orientation or transgender identity in equal measure it may result in professionals offering gender-affirming care liable to complaint.
Again, putting this to the government’s Equalities Office, a spokesperson said: “Although evidence clearly shows that LGBT+ people are most commonly at risk from conversion practices, our draft legislation aims to protect anyone subjected to this abuse. Our draft Bill will also cover situations where a perpetrator undertakes conversion practices on someone they perceive to be LGBT+ when that person is not.”
Eight years of legislative snakes and ladders
Theresa May was the first prime minister of the United Kingdom to back a ban on conversion practices but was not the last, in what has been a legislative journey of snakes and ladders.
Since 2018, May’s Conservative successors Boris Johnson, Liz Truss, Rishi Sunak, and Labour’s Keir Starmer have all committed to outlawing abhorrent conversion practices, with the pledge appearing in the speeches given at the State Opening of Parliament in 2021, 2022, 2024 and 2026.
Despite this, Johnson’s government did try to ditch progress on securing a ban, only to reverse that decision but not make it trans-inclusive. After backlash from the public and politicians alike, the government U-turned once more and announced it was committed to legislating a full, trans-inclusive ban – Sophie Perry
Between 2018 and 2026, conversion practices have been outlawed in 11 nations and dozens more states in differing countries – Equaldex
Britain as a whole remains one of the few Western European nations not to have a ban already in place, which is a fact reflected by its falling position in ILGA Europe’s annual ranking of European nations’ LGBTQIA+ rights.
In fact, Spain – which this year topped the ILGA ranking – this week also announced a ban on conversion practices alongside a raft of other steps to better protect LGBTQ+ citizens – La Moncloa
Despite the development of legislation starting and stalling during those eight years, the groups carrying out conversion practices – who could continue operating outside the bounds of the law – increased their efforts to sustain such practices in the UK.
Last year, in July 2025, it was revealed in research by Amnesty International that organisations promoting conversion practices in the UK had increased their spending by 165% between 2019 and 2023, with these those groups shelling out an estimated £2 million in the years after a ban was announced – QueerAF
Analysis: A ban in name, but not much else
Eight years and five prime ministers later, we have one draft bill – but no full, trans-inclusive ban.
As a journalist, I know well that first drafts are rarely the final word – and that is perhaps the main comfort we can take at the moment.
In their statement, TransActual criticised the government as having “introduced so many loopholes that it has practically written an instruction manual on how to get away with conversion abuse” – easy to see why.
Effectively, if you can label yourself as providing a healthcare service you are off the legislative hook.
At best these loopholes are naive oversights that through a rigorous scrutiny process could be be kicked to the curb. At worst, they are a dangerous indication of this government’s true commitments to protecting vulnerable LGBTQIA+ people from harm.
As much as this bill could open the door to charlatans selling anti-queer snake oil under the guise of healthcare, it could also serve to further legitimise the anti-LGBTQIA+ policy decisions of governments to come.
We need a full, trans-inclusive ban and, more than ever, we must be vigilant in holding our elected leaders to account.
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