Should the Gender Recognition Act be repealed?

[SingleSexSpacesInSchools]

Basically, it's a lie and the government should not be in the business of falsifying official documents.

But on top of that:

• It reduces trust
• it perverts stats and analysis
• it reduces protections based upon sex
• People start to think sex really is changeable, or worse, just a piece of paper, when it's not, it's binary and immutable
• All sorts of issues in the NHS with sex based healthcare

The EHRC guidance ties itself in knots trying to deal with the fact we don't reliably record sex, the most basic of information.

A humane society can treat people with courtesy without falsifying reality. Trans people should not be treated differently to others, they should have every right to an existence free from abuse. But these legal fictions are no good for anyone.

You cannot become female at the stroke of a pen.

So it seems your take is just because so few of those crimes lead to a conviction it does matter that it didn’t pass?

I am just talking stats. if only 5% of offences lead to a conviction, not allowing those criminals rather than the ones who did not get caught, to not have a GRC is perfomative

also insane. If people have the right to a GRC, they have the right to a GRC and criminal behaviour or otherwise should not matter. Like voting.

I stand by the GRA being repealed in all forms and replaced with other, better legislation.

I have to disagree. Sex offenders can use the GRC loophole to escape their previous charges. I think it’s perfectly reasonable to close down that loophole

I'll reword myself. Nobody should have a GRC, ever, for any reason. But if you're going to let people have them, if the law says they have that right, then everyone should be able to, and there should no no loop holes

Not letting convicted people have one makes the entire thing make even less sense.

I suppose that if they have a GRC and their crime was a sexual offence against a woman, it might be an idea not to put them into the women's estate, even so.

And I think that was the object of the amendment: if they can't have a GRC when they have been convicted of having committed a sexual offence against a woman, then they can't be (or at least ought not to be) put into a prison cell shared with a woman.

Men without GRCs were put in women's prisons. I think there more more men without GRCs in womens prisons then men with GRCs

Yes, I forgot to put the word "muddleheaded" in there somewhere.

I think what they wanted was some sort of "sex offenders against women ought not to be put in women's prisons" ruling, and they had the mistaken impression that a man had to have a GRC in place for them to be put in the women's estate. Or something. There was so much bullshit going on that them getting it wrong might even make sense of a sort.

I can actually remember when it was a shock and totally counter intuitive that a man who had committed a violent crime could be moved into a women's prison, the reason given being that the poor little fellow was afraid he might be hurt by the nasty men he would otherwise have been imprisoned with. It was some time this century that the first one happened, possibly 2014 or 2015?

The UK has been putting men in women's prisons because they claim to be women since the 1980's. Part of the history:

Queer Theory and the Transition from Sex to Gender in English Prisons
Michael Biggs
Journal of Controversial Ideas 2022, 2(1), 2; doi:10.35995/jci02010002.

"In England, by the 1980s, males who had previously undergone genital surgery could be placed in a women’s prison. Gloria Greaves was convicted of living off immoral earnings and sentenced to eighteen months in HMP (Her Majesty’s Prison) Holloway, a women’s prison, even though only a man could commit that specific crime. 30 Such cases were so rare they could be left to the discretion of prison officials. The first public statement of policy came in 1994. The Director General of the Prison Service told Parliament that ‘the principal criteria is [sic] the most obvious physical characteristics of the person concerned and their ability to integrate with other inmates. A male-to-female transsexual who has undergone surgery and hormone treatment would therefore be more appropriately allocated to a female establishment’. 31 The nature of this surgery was not specified, and so it is not clear whether orchidectomy would have sufficed, or whether vaginoplasty was also required. There was no corresponding exception for female-to-male transsexuals, who would always be placed in the women’s estate. 32

The Director General’s statement was a response to activism that emerged in the early 1990s. Press for Change was founded by Stephen Whittle and others to campaign ‘for the legal rights of transsexuals’. 33 The Parliamentary Forum on Transsexualism was created by Lynne Jones, a Labour MP. The main point of leverage was the European Court of Human Rights, to which transsexuals brought a series of cases (e.g., Rachel Horsham and the person known as ‘I’, both cases registered in 1994) demanding the right to change legal sex. Prisons were only a minor element in these cases, but perhaps the Conservative government hoped that explicit codification of prison policy would bolster its argument that transsexuals were not unfairly treated. Press for Change and the Parliamentary Forum seized the opportunity to craft a policy document for the Home Office. Its author was More, the leading British proponent of queer theory who co-edited the newsletter Radical Deviance: A Journal of Transgendered Politics . This exuberant magazine propagated novel ideas from France and the United States: ‘once upon a time TSs needed to learn and create medical jargon to progress our culture, now that TS and TG politics has come of age, we need to talk of hegemonies, Queer, and Post-Modernism’. 34

When Butler visited London, she gave an interview to the magazine. 35 Despite such radical theoretical commitments, More’s proposals for prison were modest. The document suggested that prisoners who identified as transsexual should be kept in the prison’s hospital unit, and after clinical diagnosis should be moved to a specialist unit which ‘could be attached to a women’s prison’. 36 This fell short of the demand made by Jones, to ‘house pre-operative transsexuals in the gaols of their new gender if they have had two or more years of hormone therapy’. 37

Labour’s accession to power in 1997 created a more favourable climate for transsexual activists—or transgender activists, as they began to prefer. 38 The Home Office commissioned research on prisons from Whittle, who had become law lecturer at Manchester Metropolitan University. 39 Whittle had also taken up queer theory, perhaps due to More’s influence; they edited a book together. 40 For Whittle, who had come out as a lesbian before identifying as transsexual in the 1970s, the new ideas promised emancipation from feminist traditions that viewed transsexuals as either predatory or deluded. ‘No solution could be offered to this impasse until Judith Butler made her huge contribution to Queer theory by compressing all gender into performativity.’ 41 Whittle eventually recommended that all prisoners ‘post-transition but prior to completion of all desired surgical procedures’ must be ‘housed in facility of appropriate gender role’. 42 This proposal, however, was ignored by the government. The official Interdepartmental Working Group on Transsexual People emphasized ‘problems in placing a [‘pre-operative’] male-to-female transsexual person in a female establishment, where she may not be accepted by other prisoners, many of whom may have suffered violent or sexual abuse from men’. 43

The exception for transsexuals who had previously undergone genital surgery applied to very few, of course. Besides Greaves, Stephanie Lloyd spent three months in HMP Askham Grange, a women’s open prison, for selling transgender-themed adult videos; 44 another transsexual was sentenced to eight years in HMP Holloway for blackmail. 45 These were not violent crimes. Crucially, prisoners were not eligible for genital surgery. By the late 1990s, at least one male was pursuing legal action on this point. John Pilley had been sentenced (in 1981) to life for kidnapping a woman at knifepoint. In prison he took the name Jane Anne and was prescribed cross-sex hormones. Pilley then argued that it was unfair for the service to deny genital surgery—which would enable transfer to a women’s prison. 46 Pilley prevailed in 1999, after a legal decision in another domain. Three patients launched a judicial review against their local health authority for refusing to fund genital surgery. They won the case in the High Court in 1998. The prison service was already committed to providing healthcare equivalent to that provided by the National Health Service (NHS), and therefore it could no longer refuse to provide genital surgery. 47 Pilley thus underwent surgery and was eventually transferred to HMP Holloway. A Liberal Democrat MP from the Parliamentary Forum on Transsexualism, Alex Carlile, declared this to be an ‘important step towards giving transsexuals proper civil liberties’. 48 There was apparently no concern for the impact on the civil liberties of female prisoners.

The 1999 decision enabled prisoners serving lengthy sentences to transfer to women’s prisons. For the NHS to approve genital surgery, the patient on cross-sex hormones would have to pass the ‘real life’ test, to ‘live and work in their female role for two years’. According to the consultant psychiatrist Russell Reid, who advised inmates, this test ‘is very difficult, though not impossible for them to fulfil’. 49 One candidate who passed the test was Douglas Wakefield, sentenced to life (in 1974) for beating and stabbing his uncle to death. In prison he strangled and beat to death another inmate, and attempted to kill a warden. To experience life as a woman, Wakefield took the name Tai, decorated the prison cell with lace curtains and flowers, and wore earrings. Genital surgery subsequently enabled Wakefield to relocate to a women’s prison, HMP New Hall. 50

3. Legal Sex

Press for Change’s crowning success was the Gender Recognition Act of 2004, which enabled anyone to apply to be recognized legally as the opposite sex. A medical diagnosis was needed to obtain a gender recognition certificate and thereby an amended birth certificate, but endocrinological or surgical intervention was not required. It was the first law in the world to divorce legal sex from the physical body. As Whittle declared, ‘the Gender Recognition Act is performative (see Butler 1990), in that as a form of speech-act, what it “does” is make gender into sex in law’.51 When the bill was debated, a Minister told the House of Commons that prisoners ‘can apply and … will be subject to prison arrangements for their new acquired gender’.52 Press for Change therefore argued, quite logically, that male prisoners who obtained a gender recognition certificate should be transferred to a women’s prison.53 The prison service, however, ignored the new Act, and continued to use the criterion of genital surgery.

Change in policy came about, as in 1999, as the unintended consequences of a decision taken outside the prison system. Mark Jones had served a sentence for manslaughter, for strangling his boyfriend. A few days after release from prison, Jones attempted to rape a woman who worked in a shop selling transgender accoutrements. (The shop was owned by Stephanie Lloyd, mentioned above as an early transsexual prisoner.) Jones, now using the name Karen, was sentenced to life imprisonment. In prison, Jones was given cross-sex hormones and laser hair removal, and obtained a gender recognition certificate. But the NHS Gender Identity Clinic would not approve genital surgery, on the grounds that Jones could not pass the ‘real life’ test in a men’s prison. This was a policy reversal, of course, because at least twelve male prisoners had undergone genital surgery while in the men’s estate. 54 And the Clinic would soon approve a female prisoner’s phalloplasty while the prisoner remained in a women’s prison. 55 One wonders if the reversal in policy reflected embarrassment that the first prisoner to be approved for genital surgery, Pilley, subsequently renounced his feminine identity and required a phalloplasty in order to return to a men’s prison. 56 Whatever the reason behind the reversal, it placed Jones in a double bind: ‘They will not consider me as a female until I have my penis removed ... Yet they resist moving me to the female estate which would enable the surgery to be arranged’. 57

Jones contacted Whittle who helped orchestrate a judicial review, held in 2009. 58 The judge, David Elvin QC, viewed the case through the lens of Article 8 of the European Convention on Human Rights: ‘Everyone has the right to respect for his private and family life, his home and his correspondence’. The landmark 2002 decision by the European Court of Human Rights—which precipitated the Gender Recognition Act—had interpreted this article as creating a right to change legal sex. Elvin noted that the Act required Jones to be treated as a woman ‘for all purposes’. 59 Because the prison service had provided insufficient justification to retain Jones in the men’s estate, Elvin ordered Jones to be transferred to a women’s prison. The argument that Jones would be hard to manage in the women’s estate was dismissed on the grounds that Jones would pose still greater difficulties if thwarted, due to what the consultant forensic psychologist described as a personality with ‘narcissistic, compulsive, aggressive, violent and sadistic elements’. 60

The rights of the women who would share facilities with such a person were ignored. James Barrett, lead psychiatrist at the Gender Identity Clinic, had concern only for the welfare of Jones: ‘There will probably always be a small number of prisoners who will choose to make an issue of the matter because they are the sort of women who enjoy conflict. If this patient is able to cope with protracted close proximity [with] women of that sort I would judge her able to cope with the less prolonged, more avoidable, travails of the civilian world’. 61 Attempting to rape a woman did not detract from the claim to be ‘a woman trapped inside a man’s body’, because Jones’ legal team had appealed against the length of the second sentence by using gender dysphoria to justify the crime. 62 Apparently it was ‘more inspired by feelings of frustration and jealousy than sexual desire’. 63 After the verdict, Jones was transferred to HMP Holloway.

As a result of this judgment, in 2011 the prison service drafted the first official regulations for The Care and Management of Transsexual Prisoners . The criterion for placement shifted from genital surgery to legal sex. ‘A male to female transsexual person with a gender recognition certificate may be refused location in the female estate only on security grounds’. 64 Such a person was thus treated identically to a woman, as exceptionally dangerous females are held in special units within men’s prisons. Even without legal certification, a transsexual who was ‘sufficiently advanced in the gender reassignment process’ could request to transfer to the estate of the other sex and was promised a case conference. 65 In the following years, incidentally, NHS clinicians became more reluctant to approve genital surgery for prisoners. At a clinical meeting in 2014, Barrett and others agreed that time in prison—even in the women’s estate—‘would not often constitute proper lived experience’ as required for surgery. 66 But this no longer mattered. As the Prisons and Probation Ombudsman later declared, ‘a person’s gender is a legal rather than an anatomical question’. The Ombudsman took up the case of a prisoner held in the women’s estate, due to the possession of a gender recognition certificate, who wished to transfer to an open prison. This request had been refused on the grounds that a prisoner with penis and testicles was not suited for this establishment as its showers were communal and accommodation was unsupervised during the night, and many of its female inmates had experienced sexual abuse. The Ombudsman supported the prisoner. ‘She has a GRC and is therefore a woman, under UK law’. 67

The shift from genital surgery to legal sex in the 1990s and 2000s was most immediately caused by unintended interactions between the health system and the legal system. The changes were brought about piecemeal by judges and psychiatrists; if their actions were informed by theory, it was the liberal individualism of human rights. Queer theory was nevertheless crucial for shaping the Gender Recognition Act, which one of its authors—Whittle—viewed as the implementation of Butler’s ideas. The Act legislated dramaturgical performativity, because it required someone to have ‘lived in the acquired gender’ for two years as a precondition for changing legal sex. This mysterious phrase was not specified, nor did advocates like Whittle explicate its meaning. Presumably it originated in the real-life test required for surgery by the Gender Identity Clinic, which also spanned two years. According to Barrett, success ‘is achieved if the patient is treated by most others as if they are of the assumed sex’.68 In Goffman’s terms, an individual maintains face insofar as other participants in an encounter act to support it, regardless of their actual beliefs.69"

(That is not the end of the story - link to full article)
https://journalofcontroversialideas.org/article/2/1/183/htm#fn030-Controversial_Ideas-2-2

What Biggs calls "legal sex" is now "certificated sex" as per the Supreme Court judgement in the case of For Women Scotland vs The Scottish Ministers, April 2025.
https://supremecourt.uk/cases/uksc-2024-0042#judgment-details

For Women Scotland's case against the (vile, misogynistic) Scottish Prison Service for continuing to incarcerate men, often violent sex offenders, with women:

https://forwomen.scot/category/prisons/

I think perhaps the operative words are "previously undergone genital surgery"; I don't think it was expected in the 1980s that intact males with meat and two veg between their legs ought to be put into women's prisons just because they said "waah, but I'm a girlie" (or had had surgery to give them massive boobs even though they were still starting fights in pubs and breaking random men's faces in their spare time, something women so often do....)

Yes, that was the thin end of the wedge. The thinking being that they cannot inconveniently rape and impregnate a woman prisoner = "no risk".

Further poll and discussion, trying to address all issues including the phrase "woman for all practical purposes" case law problem.

https://www.mumsnet.com/talk/womens_rights/5536395-should-the-uk-have-a-simple-clear-legal-definition-of-sex-male-and-female

Yes, that definitely is the case in Scotland.
And of course a castrated man can still sexually assault someone

@POWNewcastleEastWallsend Press for Change and the Parliamentary Forum seized the opportunity to craft a policy document for the Home Office. Its author was More, the leading British proponent of queer theory who co-edited the newsletter Radical Deviance: A Journal of Transgendered Politics .

Oooh would you look at that. 'Deviance' being used by a queer theorist to describe transgender politics. Wonder if that would be fun for Sex Matters to use when they defend against GLP, for using the word 'deviant'?

@SingleSexSpacesInSchools Hi, I saw this exchange on X and thought it might be of interest re this discussion. It's between Clare Page and Mr Menno where Clare details her view that Sex Matters' approach is unhelpful and why the GRA must go. I found it very interesting.

Apologies I haven't read all of the thread, so sorry if this has already been covered!

https://x.com/NoSecretLessons/status/2060824461184475473

I wonder if campaigning for repeal would be outside Sex Matters Charitable Objectives as an organisation?

https://sex-matters.org/sex-matters-charity/

I understand the arguments on both sides. I just don't know why those who want to repeal the GRA/ remove the PC of GR don't get on with organising to do that, instead of criticising the organisations that are taking a different approach. I'm guessing they don't have the skills, or the numbers (meant respectfully).

I don't disagree with you, but the words 'A campaign to repeal the GRA/remove the PC of GR' conjure up images of smashed windows, smoke bombs, arson attacks, accusations of toxicity and 'literal genocide', punched TERFs, threats of rape with added details, and even death threats.

In the current climate where the tiny % of transpeople can rely on a large number of parliamentarians to prioritise their rights privileges over the rights of women, it's going to take a lot of courage to campaign to repeal the GRA, with so much stacked against us.

And I can already imagine the celebs queuing up to denounce any such campaign as cruel, fascist and hate-fuelled, and how they stand with their trans etc etc brothers and sisters...

'Courage calls to courage' and all that, but I confess that I would not have the courage to take on such a widely supported movement that has shown it is not beyond using aggression and even violence against anyone who resists it.

I hope there are braver women/people than me out there who have the courage and the resources to take it on.

I think the issue has always been that because of the wording of the EA and false training by Stonewall etc., this lead to the incorrect application of the law that those with a GRC ie a "legal woman" had the same status in relation to the protected characteristic of sex as a biological woman ie an actual female.

Thanks to the Supreme Court ruling this has been clarified for those who chose not to recognise that a "legal woman" was never and should never have had the status of a biological woman.

But now of course, all those who think they are right even though the law has said they are wrong are trying to say the law shouldn't be implemented.

As always it is quite likely that those who are "legal women" and even those who "identify" as one, are not the same as the crazed, aggressive over the top campaigners, the TRAs, who have given trns rights the justifiable tag of being anti woman.

Best to remember that part of the Supreme Court ruling was that due to how some chose to interpret the law meant was that Sex was the only protected characteristic being discriminated against by another one. So on that basis alone the Court was saying the Stonewall "law" was and still is wrong.

Effectively, and even the Judge admitted it, that the clarification that sex is biological has meant that a GRC has very little value.

So rather than suggest it is those who are pointing out how the anti woman TRAs are still discriminating against women, you should tell them to stop presuming they dont have to obey the law, stop harassing and intimidating women and OBEY THE LAW.

I think most women wouldn't have any problem if there are men who want to cross dress or be feminine.

It is the relentless need of these men to try and enforce women to accept their purely personal life styles as somehow "real" and in doing so undermine women's sex based rights that is the problem.

As usual the problem is male aggression and entitlement and the never ending demand that women obey what they as men demand them to do.

I don't disagree with you, but the words 'A campaign to repeal the GRA/remove the PC of GR' conjure up images of smashed windows, smoke bombs, arson attacks, accusations of toxicity and 'literal genocide', punched TERFs, threats of rape with added details, and even death threats.

Sure, so if folk don't have the courage to do it themselves (and I don't blame them), then why are they criticising SM for not doing it?

So rather than suggest it is those who are pointing out how the anti woman TRAs are still discriminating against women, you should tell them to stop presuming they dont have to obey the law, stop harassing and intimidating women and OBEY THE LAW.
I'm sorry, I don't understand what you mean nor what it has to do with the article and my post.

How would repealing the GRA work for people that already have a new birth certificate?

I asked for help from Perplexity AI with this question - IANAL and welcome comments on this suggestion.

Note: Perplexity's answer does not deal with the issue that some official documents currently used as "identity documents", such as Passports and Driving Licences, can be issued with a falsified sex marker without the need for a GRC.

Query to Perplexity:

There have been suggestions that the Gender Recognition Act 2004 should be repealed.

However, several thousand people have already been issued with Gender Recognition Certificates. Their names have been entered into the Gender Recognition Register, the Register of Births has been annotated and they have been issued with new Birth Certificates with an opposite-sex marker.

Some people have detransitioned and wish to have their GRCs revoked with the original Birth Register record being recognised and reissue of their original Birth Certificate.

1. Suggest appropriate legislative changes to enable: the revocation of GRCs; relevant changes to the Birth Register; re-issuing of original Birth Certificates; revocation and reissuing of any identity documents based on GRC "Certificated Sex".
2. Consider whether any additional legislation would be required to deal with cases where an individual continued to use a revoked GRC, Birth Certificate or identity documents based on "Certificated Sex".

Perplexity replied:

A workable reform would be to create a statutory revocation and reversion scheme inside the Gender Recognition Act 2004, coupled with consequential amendments to the Births and Deaths Registration legislation and the main identity-document statutes. The core idea should be that revocation restores the legal position prospectively, while preserving the evidential integrity of historic records by marking, not deleting, the earlier GRC-based entries
https://www.gov.uk/correct-birth-registration]

GRC revocation scheme

The GRA should be amended to insert a new power allowing a person to apply for revocation of a full GRC, and allowing revocation on objective grounds where the certificate is no longer wanted or was issued in error. The statute should specify who may apply, what evidence is needed, whether the applicant must make a formal declaration, and whether there should be a cooling-off period or inquiry period before revocation takes effect.
https://www.legislation.gov.uk/ukpga/2004/7/section/9]

A useful model would be to define revocation as ending the legal effect of section 9 prospectively, rather than “undoing” all consequences retrospectively. That avoids destabilising past acts done while the certificate was valid, while still allowing the person’s legal sex to revert for future purposes. The legislation should also provide for the Gender Recognition Panel or Registrar General to notify the General Register Office and relevant identity-document authorities automatically once revocation is final.
https://www.gov.uk/apply-gender-recognition-certificate]

Birth register changes

The Births and Deaths Registration Act 1953 and the associated registration rules should be amended to allow the original birth entry to be re-annotated to reflect the revocation of the GRC and to restore the original sex entry on the register for future certified copies. The current law already contemplates margin notes and corrected particulars in some circumstances, and new amendments could expressly authorise a “reversion note” that records both the existence and later revocation of the GRC.
https://www.gov.uk/correct-birth-registration]

There are two policy choices here. One is to keep the existing amended entry as the historical record and add a margin note showing that the certificate was revoked and the original entry reactivated. The other is to require a formal reversion re-registration, with the original birth particulars reinstated and the GRC-based version archived. I would prefer the first, because it preserves auditability and avoids implying that the GRC-based entry never existed.
https://www.gov.uk/order-copy-birth-death-marriage-certificate]

Reissued birth certificates

The legislation should expressly empower the Registrar General to issue a replacement full birth certificate showing the original registered sex, on production of a revocation certificate. That replacement certificate should be treated as the operative certificate for civil purposes, but it should not erase the fact that a GRC had previously been issued and later revoked.
https://www.gov.uk/apply-gender-recognition-certificate]

To reduce confusion, the statute should distinguish between:

• the register itself;
• historical certified copies issued while the GRC was in force; and
• replacement certificates issued after revocation.

A short-form administrative rule should also require the GRO to retain the prior indexed entry and cross-reference it, so that future searches disclose the existence of the revocation trail without exposing unnecessary personal data.
https://www.gov.uk/order-copy-birth-death-marriage-certificate]

Identity documents

The main identity-document regimes should be amended so that a revoked GRC can no longer be used as evidence for a renewed passport, driving licence, NHS record marker, pensions record, or other official document based on “certificated sex.” For passports, the Passport Office would need express authority to cancel or withdraw a passport issued on the basis of a GRC and to require a fresh application supported by the updated birth certificate or other current evidence.
https://www.gov.uk/changing-passport-information/gender]

For driving licences, DVLA rules would need parallel provisions allowing correction of the sex marker and, where necessary, replacement of a licence if it was issued on the basis of a now-revoked certificate. Similar amendment powers would be needed across the identity-document framework so that each issuing authority has a clear legal basis to revoke and reissue documents without relying on ad hoc policy.
https://www.gov.uk/reapply-licence-revoked]

Use after revocation

Yes, additional legislation would be needed to deal with continued use of a revoked GRC, a reissued birth certificate, or identity documents issued on the basis of certificated sex. The cleanest approach would be to create a specific offence of knowingly or recklessly using, presenting, or relying on a revoked certificate or a document superseded by revocation for a legal advantage, official transaction, or to induce another person to act.
https://www.legislation.gov.uk/ukpga/2004/7/section/9]

That offence should be narrowly drafted to avoid criminalising innocent possession or accidental reliance by third parties. It should also include a civil/administrative invalidity rule stating that a revoked GRC, and any document superseded by it, is not valid evidence of legal sex from the effective date of revocation, except for acts done before revocation took effect.
https://www.gov.uk/changing-passport-information/gender]

Drafting approach

A coherent bill would probably need:

• a new GRA Part on revocation and reversion.
• amendments to registration law for re-annotation and replacement certificates.
• consequential amendments to passport, driving licence, NHS and pensions legislation.
• information-sharing provisions between the GRO and document issuers.
• offences for fraudulent or knowing use of revoked documents.
• transitional provisions preserving past legal acts and third-party reliance. https://www.gov.uk/correct-birth-registration]

One important drafting point is that the law should speak in terms of legal status and evidential documents, not “erasing” historical records. That gives you administrable rules, protects registry integrity, and reduces knock-on litigation over what was lawful before revocation.
https://www.legislation.gov.uk/ukpga/2004/7/section/9]

That sounds like a right faf so it will probably never happen

Looks pretty straightforward to me. All that would be lacking is political will.

I don’t know, it sees pretty complicated. How would repealing the GRA and reverting documents comply with the Goodwin judgment?