LangCleg - the government responded to the trans equality report here.
In response to recommendation 22 (recommendation 12 in the response for some reason but identical wording) they said -
We agree with the principle of this recommendation, that those who sought and have completed a gender transition - and who have secured a Gender Recognition Certificate - should be afforded the full legal and social status of their acquired gender.
The Government welcomes the good practice highlighted to the Committee, for example, by providers of services to domestic abuse survivors that include transgender women as far as possible. We will continue to encourage service providers to share good practice within their sectors. To support service providers in treating transgender customers appropriately and lawfully we recently published Providing Services for transgender customers: a guide4. This new guidance, produced in partnership with Gendered Intelligence, sets out guidance and good practice examples to help ensure transgender people are welcomed, included and valued as customers, clients, users or members, and to ensure that they are treated fairly and appropriately. The guide explicitly addresses the sensitive issue of separate and single-sex services, making it explicitly clear that the exception can only be used in exceptional circumstances and where there is no less discriminatory way of providing the service. It also notes that it is very unlikely that any exceptions will apply in ordinary ‘high street’ service provision situations. The Equality Advisory and Support Service, funded by the Government Equalities Office, can provide advice in those cases where service users feel they may nonetheless have suffered discrimination.
In addition, recently published guidance, The recruitment and retention of transgender staff – guidance for employers5, produced in conjunction with Inclusive Employers, states clearly that: “very careful consideration should be given before applying a genuine occupational requirement. Such restrictions are rare and, if wrongly applied, unlawful.” The EHRC provides advice for employers on the use of genuine occupational requirements (GORs) in the relevant section of the Employment Statutory Code of Practice6. We understand the concerns being raised by some transgender people about the provisions. The Government is keen to ensure that that law in this area operates fairly and is not abused, therefore we are keen to receive further representations and evidence on the availability and use of the exceptions in the Equality Act 2010 from all affected parties to take into account for future policy discussions.
So they are keen to hear more from all affected parties about the implementation of the exceptions in the EA.
Technically, the exceptions can be used even where a transwoman has a GRC but increasingly services are not using them at all and are also acting as if self-ID is a done deal.
Because of this there are very few situations where a GRC makes a jot of difference, the notable one being prisons. As such this legislation massively disproportionately affects the most vulnerable women who have no choice to remove themselves from the situation.
It's an easy, virtue-signalling youth-vote-winner which will make fuck all difference to the vast majority of trans people but will screw over women prisoners mostly.
I think the bigger, longer term battle is reforming the EA to strengthen the sex based exceptions and make them more useable, and to reaffirm sex as a protected characteristic more generally (e.g. by making misogyny a hate crime). And ensuring guidance respects this as well. Who decided for example that 'very careful consideration should be given before applying a genuine occupational requirement. Such restrictions are rare ...'? What was that based on?