Is this what a sane but pro-Trans response to the EHRC Guidance looks like?

[RareGoalsVerge]

I thought this was worth sharing as a potentially welcome, rational response to the EHRC guidelines. It's not perfectly in line with what we as feminists want, but it is way better than the toddler-tantrum responses I have seen elsewhere:
https://transfiguredmission.uk/wp-content/uploads/2026/06/faqs-for-churches-following-ehrc.pdf

It is clearly written from the point of view of wanting to be as inclusive as possible, within the scope of the law as it stands.
You cannot expect or require trans people to use the ‘wrong’ toilet, therefore you will need sufficient mixed sex / all gender toilets. You must be careful not to simply repurpose the disabled toilet as this could amount to unlawful disability discrimination.

If you have single rooms / cubicles with a lockable floor-to-ceiling door the simplest way to cater fairly to everyone is to make them all unisex – or most of them if you have lots. If you currently only have two – one labelled M and one F - you must do this.

This seems rational to me. The document goes on to highlight that for the most part, everything that reasonably can be unisex/open to all should be - and describes that things which should be legitimately single sex might include

• whether women are likely to be in a state of undress
• whether there will be limited ability for women to leave or to choose an alternative service
• whether the service is provided a result of, or connected with, male violence against women
• whether the physical differences between men and women are relevant to the experience of the service and put women at a particular disadvantage

Most single-sex church groups would not be ‘necessary’ under this analysis. You cannot require trans people to attend the group that corresponds to their ‘birth sex’

There's plenty not to like - I wish they didn't refer to things that are legitimately single sex as being for cis women - obviously cis is inappropriate for large numbers of women who have just been getting on with their lives for a many decades just existing as best they can under a patriarchy without the luxury or priviledge of the leisure to work out if they have a gender identity, and also many things in the above bullet-pointed list would be very much appropriate for people who are female but identify with a masculine or non-binary identity, so a better document would highlight benefits to female people of all gender identities rather than using cis. In the toilets section the authors clearly know, by implication, that gender neutral toilets are only legitimate if they are fully enclosed with floor-to-ceiling walls and doors, but fail to explicitly mention this or to draw attention to the well-known health and wellbeing detriments that arise when people are taken ill in such facilities. And the fact that they signpost to the Good Law Project at the end is disappointing.

But despite all this I thing its a welcome example of how reasonable organisations of good intention might do their best to find a reasonable way forward within the law, rather than just trying to ignore the law and carry on prioritising male people's wishes over female people's needs.

Thank you! Does that include where all the cubicles are completely self contained with sink etc?

Keeptoiletssafe says it best, but until she gets here:

1. Toilet gaps save lives. When you are ill, you go to a toilet. That is a common place for someone to need emergency help, and you can't know that if they're locked behind a floor to ceiling door.
2. Women vastly prefer being able to wash their hands away from men if they're on their period.
3. Urinals are great for men. They are quicker and cleaner than a seated loo. Having no cubicle doors is more hygienic as there are fewer touch points - he walks in, wees, washes hands, leaves.

It is a system that works. Men who identify as trans can still use a urinal, or a cubicle in the men's. They are not being discriminated against, they have the same provision as all other men.

As for changing rooms, it is just so obvious that they must be single sex, that it's not even worth entertaining any alternative

The worst seat-piss I’ve encountered have been a couple of occasions when I foolishly used a cubicle in the women’s loos just vacated by a boy evidently young enough that his mum didn’t want him going alone into the gents (in naice NT sort of places) but old enough (they looked about 10 to me) she trusted him to use a separate cubicle to her. I shudder to think what mixed sex primary school loos must be like.

You might not have an issue with unisex facilities during the day, and in a workplace in which people know each other, but can you imagine being a lone woman in a mixed sex facility in the night time economy when there are several men in there with you?

I am in hospital today so typical there’s so many toilet threads. Happy to report the ladies is the standard regulated cubicle inside a separate sex washroom. Good floor-door and floor-partition gappage of 15cm. Well ventilated and clean. Space above the door and partitions. Two hooks at correct height. Bonus for obscure glazed window in washroom for natural light and ventilation! No smells. I was in there on my own and I know that because the cubicle doors were ajar. All thought out and within regulations.

This is a screenshot of building regs highlighted in document T.
You have to make sure women and men are provided for first. Then add unisex.

This is the document if the screenshot didn’t come out well
https://assets.publishing.service.gov.uk/media/6901feb971b575684c3cf7c4/ADT_2024_rev16Jun25.pdf
“The Building Regulations can be contravened by not following the correct procedures or not meeting the technical performance requirements. If the building owner or those responsible for the works contravene the Building Regulations, the local authority may prosecute them in the magistrates’ court.”

You may see in Approved Document T that it does not mention door gaps! I have it confirmed they can be there in single sex designs C and D they are just not mentioned. In a lot of the text you can see it’s implied but HSE said they were trying to keep the document manageable and short for general readership. Which is why my campaign started to show the importance. I want to get the advantages stated in them and put as an option in the cross section diagrams. This is the document most people will look at. I have spoken to the Health and Safety Executive and the Building Safety Regulator who confirmed the dimensions in British Standards BS6465 are correct.

British Standards BS6465 has 4 parts that cost ££££ and go in to a lot of technical detail including calculations for men v women’s toilets, positioning of hooks, circulation space, widths, heights etc. It’s many pages long. I have parts of it. That’s where my ‘ventilation, cleaning, prevention of misuse and supervision’ comes from when I talk about the advantages of not having fully enclosed toilet compartments. Approved Document T is based on BS6465.

This is why I roll my eyes when people think they know better. A lot of people have spent a lot of time over decades refining all of these documents, based on the biological needs of men and women. Nothing makes sense in these documents if ‘women’ doesn’t mean biological women and ‘men’ doesn’t mean biological men.

A unisex facility needs to be positioned to lead out onto a thoroughfare for safety reasons. Like the accessible does.

I think this proposal is a load of nonsense. How can a woman feel safe if all loos are mixed-sex? A woman in a pub on a Friday night will have to use the same toilet facilities as men. What happens if there is only woman wanting to use the loos and the only other people waiting in there are a group of men who've had a few pints?

This proposal also contradicts the idea that transwomen are too scared to use the same toilets as other men. If they can use the same toilets as men with mixed-sex facilities then surely they can use the same toilets as other men in single-sex male toilet facilities.

And the Equality Act and accompanying EHRC guidance are not just about toilets. What about changing rooms and hospital wards and rape crisis centres?

But TW don't want a plethora of options. It's not about access to the toilets. It's about access to the women who use the toilets.

Stonewall has had income of close to £100million over the last 10 years. That could have financed a LOT of toilets, if that was what TW wanted.

I despair of the reading comprehension shown by most responders on this thread.

This is an advice sheet specifically for churches @BunnyBunbunbun - the situation for pubs on a Friday night is not relevant.

I was not asking, in my OP, whether this document was fully compliant with all the requirements of gender critical women. I pointed out several flaws myseld in the OP which hasn't stopped some people from replying criticising the same flaws as if they were contributing something new to the discussion.

The document does not call for all facilities to be unisex. It calls for all venues to make unisex provision and gives an example of how this might be achieved. It points out that for other things not to do with toilets, that if there are reasonable grounds for them to be actually single sex then they should be, and gives points for providers to consider for when there are good grounds.

The guidance that comes into force today makes no statements on the decisions of individuals who are using facilities. It is about explaining to providers what they have to provide.

My question was about whether this document makes a welcome change from all the other responses to the EHRC which I have seen which amount to "ignore the guidance, they can't make us obey the law if we don't want to".

I have a strong dislike for unisex facilities. In single-sex spaces, I only had to manage occasional messes caused by some women and children. However, in unisex facilities, I have to contend with male use on top. The unisex cubicles at M&S are consistently unpleasant. Each time I visit, I find the toilet seat soiled with urine. As women, we often have to clean it up before we can use the facility ourselves or help our children. It feels like we are acting as free cleaners, and I'm sure M&S appreciates this setup.

Yes, I think this document is a very welcome change. The "just ignore the EHRC" approach we usually see is a total legal dead end for organisations. It leaves churches exposed to massive liability because defiance isn't a real legal strategy.

What makes this document refreshing is that it actually engages with the reality of compliance. It accepts that providers need clear, actionable rules on what they must build and manage. By decoupling provider obligations from individual cubicle policing, it actually offers a practical framework instead of just screaming into the void. It’s flawed, as you rightly noted, but it’s a much more mature response than the usual blanket defiance.

So what if it's a set of proposals for churches @RareGoalsVerge ? That's barely mentioned in the OP. Is it not possible to expand the discussion to the principle of single-/mixed-sex facilities in general, as most posters appear to be doing anyway?

What this proposal boils down to - in relation to toilets, the document covers other things too, e.g. church women's groups or men's groups - is that both single-sex and mixed-sex loos should be provided if possible. If a church (or any service provider) has floor-to-ceiling doors on their loos then the toilets provided should be unisex. The preference of the authors of the proposal seems to be to go for unisex facilities. That opens up a can of worms, as discussed above. As for having both single-sex and mixed-sex facilities, this is not possible in all circumstances or for all spaces (how would it work for hospital wards, for example, or in sporting competitions?).

In any case, this isn't a "sane" response that is trying to compromise. They are being forced to come up with this "advice" because they now have to comply with the law. This isn't even their own proposal - it's lifted from the EHRC guidance (see section 13.120 onwards and section 13.140). Am I meant to feel grateful that some people have finally realised that the law needs to be complied with and can't simply be ignored? They are still prioritising the part of the law that allows service providers not to provide single-sex facilities.

This is basically what my workplace has done for our semi-public meeting rooms.

All the other toilets have remained the same single sex as before, but the meeting rooms have a little vestibule before the meeting room with most having two single room toilets (the others have disabled toilets) all having sinks and everything within. Since the vast majority of the people who use the meeting rooms are women, we've had situation where women are waiting for one toilet while the other went unused. They've all been turned into unisex toilets with single sex toilets down the hall.

And having regularly checked the rooms and toilets after their use (cleaning staff cannot go in until they've been checked that all private documents have been removed, and yes people leave random stuff in the toilets so yes, I checked what was the male toilet), I've not seen much difference in how they're left when they were single sex vs being unisex.

Toilet gaps save lives. When you are ill, you go to a toilet. That is a common place for someone to need emergency help, and you can't know that if they're locked behind a floor to ceiling door.

Emergency cords and buttons are far, far safer than just expecting someone to come by and see you in a gap under the door.

A lot of public toilets are put in the most out of the way leftover space, and I've more than once been made very aware that if I had another fall while I was in the toilets, that it could be ages until I was found by anyone.

Not in any way blaming OP(!) but seriously this is a / the church writing a whole document that at no point acknowledges women might have rights.

Yes of course guidance is need to help churches, facilities comply with the law, but throughout no acknowledgement anywhere about why women need single sex services.

That is what the guidance is about as much as pandering to the tiny minority (under the law around 10,000 people as non binary, gender fluid people are not part of this). Not surprising given who they have consulted.

Just so disturbing that even a church can not acknowledge that what is happening now is rectifying the terrible abuse and loss of women' rights that has been happening.

I just got angrier and angrier reading it as it was all about trans rights nothing about women's rights.

All the groups listed at the end are all about trans rights.

Not even one reference to a women's rights groups that they could consult to ensure that women's rights aren't abused.

Sorry OP to be so negative, but what are we are women reduced to that we have to think this is the best we can expect.

No it isn't. It is legal for them to use gender neutral facilities and imo they should wherever possible be provided with them.

Plenty of women won't sit on a public toilet seat and send up leaving pee on it by hovering above it for fear of catching germs from it.

I do agree with you that more men then women leave pee on the seat and crap on the toilet bowl.

The document suggests that if toilets have floor to ceiling walls and doors, churches can just relabel them unisex. But I dont think that's correct. I think theres more to unisex then lack of gaps in doors and walls.

Its a case of the church trying to be kind, but still ignoring regulations.

There’s a lot to unpack there.

So presumably you think all toilets should be for both sexes and private and have alarms in them, even if, as you say, they are usually in far away places.

Emergency cords and buttons are far, far safer than just expecting someone to come by and see you in a gap under the door.

Assuming you remain conscious and mobile long enough to pull the cord. (And it's not been tied up.) A significant number of people don't.

The law is clear,womens single sex spaces/services are for females and must not include any males (not the nice ones,the nasty ones or the ones who believe themselves women) because then they would not be single sex.
As for the floor to ceiling cubicle option being best,i would disagree,my neice was pushed into cubicle and raped ,a mixed sex ante room clearly poses risk.

I think many people don't imagine the realiity of a toilet block in which there are multiple cubicles and a shared access area, all behind a closed door, when they imagine a unisex facility.

Having said that the mixed sex facilities ( which has shared wash-basins) at the Manchester Aviva Studios lead out onto a busy public thoroughfare, in the way you describe; and to be honest that was not a pleasant experience either. Who wants everyone, the general public, to be able to see into the toilet area?

Agree. Reasons people need assistance in toilets (off the top of my head of the many accounts I can remember): cardiac arrest, overdose, seizure, feeling sick after being spiked, hypo, choking to death on restaurant food (don’t go to the toilet out of embarrassment if you are choking), endometriosis, miscarriage, giving birth, birth, stroke, brain haemorrhage, fainting and hitting head, heart attack, sexual assault, rape, electrocution.

Yes they don’t conform to Approved Document T.

Oh what a tangled web we now have to weave because some people back in the day didn't say "no, don't be stupid, we're not doing that" to a man!

Think of all the unnecessary conversations we wouldn't now be having.

In reference to the OP's question, I think the document reads like a "how to look like we're obeying the law and how to look like we're compromising, while still denying women their rightful place in society, because what we really want is to focus on what men want." In other words, it's activist BS.

From the document:

You must provide toilets for everyone. Toilets that are separated by sex will generally be considered to be for use by those whose sex recorded at birth matches the sign on the door.
"Toilets that are separated by sex will generally be considered to be" - um, no. They are required to be used only by those whose sex recorded at birth matches the sign on the door, and everyone knows what that is, and that never changes.

You cannot expect or require trans people to use the ‘wrong’ toilet, therefore you will need sufficient mixed sex / all gender toilets.
I think you can, actually, if you do not have space for another, mixed-sex toilet.

You must be careful not to simply re- purpose the disabled toilet as this could amount to unlawful disability discrimination.

At least they allow for the fact that disabled people exist. I wonder if they know that some of them will be women?

If you have single rooms / cubicles with a lockable floor-to-ceiling door the simplest way to cater fairly to everyone is to make them all unisex – or most of them if you have lots.
I'm not sure this is strictly legal. There are other legal and regulatory considerations here.

If you currently only have two – one labelled M and one F - you must do this [make them both unisex].
I don't think this is correct.

The guidance specifically states that is unlikely to be practical or appropriate to challenge people using ordinary toilet facilities. This is not only to prevent harassment of trans people but also cis people who may be judged not to be ‘feminine’ or ‘masculine’ enough.

"This is not only to prevent harassment of trans people but also cis people who may be judged not to be ‘feminine’ or ‘masculine’ enough." Of course you, as a service provider, are expected to care whoever uses your toilets. Otherwise, you could be breaking the law. And it's not about "cis" people looking "feminine" or "masculine" enough. This is BS.

Many organisations and venues who feel strongly about trans inclusion are signposting that they are happy for people to use whichever toilet feels right to them. This is not without legal risk, particularly if there gender critical people in your congregation, or if someone posts about it on social media, but it may make trans people feel safer.

Or, maybe this is not without legal risk, because it's against the law? No, actually, it's because a "gender critical" person might complain, or say something online.