The Charity Commission asks that you try to contact the charity directly before you raise a complaint, and include any response you get (if any), so I've written to them now in their Contact form. www.gires.org.uk/contact-us/
Sent them this:
"I am gender nonconforming and autistic, and was deeply concerned to read your response to the NHS Standard Contract. (drive.google.com/file/d/0B7n9HajupVrLSzdzVEhvaEVhZmRBNzVXMkMxdlZlZlV4SGFv/view?usp=sharing)
In particular, section 1.5 Autistic spectrum:
"It seems unlikely that the Finnish would have twice as many ASD as the UK in the gender variant population, but that is not a reason for believing the UK figure is an underestimate. Anecdotally, young people who have been successfully treated, are often described as having no residual ASD. The symptoms have disappeared once the dysphoria has been treated. That is obviously not always the case, but it is something that long-term follow-up should address."
Anecdotes have no place in rigorous medical science. Autism has already been proven to be a congenital, lifelong condition, and we autistics and autism researchers have worked for decades to debunk misinformation around any number of "autism cures".
There is a very long and ugly history of invasive treatments being misapplied to autistics as an attempt to "cure" us, or to sterilise us to ensure our genetic condition is not passed on. A pathway of GnRH agonists (puberty blockers) followed by cross-sex hormones now does both: claims to "successfully treat" autism and also damages future fertility.
Section 1.2 Persistence/Desistence of your own document states: "It is not always possible to know whether gender non-conforming behaviours in a child are actually a reflection of gender dysphoria, or whether they are related to some other possible outcome, such as being gay, lesbian or bisexual." To that, I would add "such as being autistic". Autistics do not easily absorb gendered social norms, and we can be very sensitive to uncomfortable clothing and hairstyles: an autistic girl ripping off a scratchy lacy dress, or an autistic boy distressed at having the barber in his personal space, may just be expressing a preference for comfort and not any gendered implications. We don't fit in with our peer group in childhood and sometimes get on better with opposite sex playmates. Our poor motor skills are easily interpreted as graceless and masculine in girls and non-sporty and feminine in boys.
This all goes doubly for non-verbal autistic children whose efforts at communication may be easily misinterpreted by their parents or guardians, and for autistic children with neurotypical (non-autistic) parents who may not understand autism well and look for any promise of a "treatment" for the autism rather than supporting their child to learn ways to manage and get the most out of it.
I am encouraged by the statement "Since there appears to be a raised incidence of ASD in this field, clinicians with this specialism should be part of the team." I agree entirely. However, the following sentence "ASD should not be an excuse for delaying treatment for gender dysphoria" implies that it is indeed an "excuse" rather than a desire to "first do no harm" and ensure dysphoria is the correct diagnosis and not simply an expression of autistic traits or other possible outcomes such as those listed in Section 1.2.
As it stands, the recommendations are open to abuse by unethical medical staff who promote an interventionist and eugenicist approach on the autistic community. Please revise these, in order to have the best outcome for both the trans community and the autistic community.
I look forward to your response."
I'll see what they say. I'm not holding out much hope, given that a lot of their document talks about gender nonconformity as if it's pathological in itself, and it even mentions it might just mean the kid's a future lesbian, gay man or bisexual, but doesn't see it as a problem to transition them anyway. So if they don't care about the rest of the LGBT they're not likely to care about autistics. Still, I'll be interested to see if I get a response.