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.

Quite! I am baffled as to how these people managed to use the toilets/facilities corresponding to their sex for their whole lives up until their "transition" but then this apparently suddenly becomes unthinkable.

Personally I do not think that gender neutral facilities will appease many trans identifying males. Some of them seem absolutely determined to use women's facilities as validation for their delusion and to prove that their rights are more important.

It’s all so daft. It costs so much money to change toilets. Very few businesses are going to scrap a working set of single sex toilet cubicles (with all the associated plumbing and electrics in a washroom) that conform to building regulations, and then create individual rooms with a toilet, sink, mirror, ventilation, VAD alarm and dryer etc in each. Each of these rooms have to lead off onto a main circulation space too. How’s that work practically?

What has happened in the past is people have stuck a unisex pictogram on the door of the ladies and gents. They can just change the pictogram back.

More inclusive to spend any money creating an accessible toilet room, that caters for more needs.

@tallyoh I have been looking at health and safety in toilet compartments for a few years now. I respectfully disagree with ‘But public loos are not a hit I would be dying on’. It is something to get worked up about as toilet design does make a difference to outcomes - including if someone gets rescued in time when, for instance, 11% of cardiac arrests happen in toilets. Lots of people collapse in toilets each year.
On a personal note, I was very relieved to be passed more toilet roll under the partition when I had my miscarriage in the ladies cubicle.

@tallyoh Polling shows that most people prefer single-sex changing areas and toilets. They also want trans-identified people to use the facilities for their sex or an alternative. These preferences are present across all age-groups and political affiliations.

https://sex-matters.org/posts/single-sex-services/new-poll-shows-most-people-prefer-single-sex-toilets-and-changing-rooms/

Re: hidden cameras, the BBC have recently brought out a documentary all about it -

https://www.bbc.co.uk/mediacentre/2026/hunting-the-spycammers

Given that hidden spy cameras is an actual category on porn sites, I'm always surprised at the naiveity of 'I'm as gender critical as they come, honest!!' posters who declare that they don't have an issue with mixed sex toilets and don't seem to have even considered that if safeguards are removed and toilets are solely mixed sex, predators will take advantage of the fact.

"A woman in a pub on a Friday night will have to use the same toilet facilities as men"

It's not that unusual to find women in the gents in pubs or clubs on Friday Saturday ( if the nebs queue is shorter)...

When I first read that Sex Matters polling, I was actually surprised that a large percentage of people don't even want an alternative changing area or toilet to be provided. It's almost as if Jo/Joe Public are getting a bit fed-up of all the demands from boundary-crossing males.

Thank you. The sinks were in the cubicles so within the rules. The point I was thinking about making was that there needs to be a sign to alert people that these are unisex provision. My most generous interpretation of my man pissing with the door open was that this what he would do in the men’s and some signage may have made him stop and think before 2 female teens came upon him.

there is also a fancy bar near me with cubicles (floor to ceiling) and shared sinks. So that must be against the rules. Whenever I go there there are started and confused people of both sexes assuming they have made a mistake and often men standing outside and debating if they want to go in, looking akward. This really works for no one.

It's legal to have groups which are trans inclusive by specifying more than one protected class. So, the Girl Guides or Women's Institute could be for women and transgender people.

Likewise, under the new guidance you can exclude trans men from women-only spaces, but you can also include them.

@Plasticchesse Whenever I go there there are started and confused people of both sexes assuming they have made a mistake and often men standing outside and debating if they want to go in, looking akward.

I think that we sometimes underestimate how many men really do not want to be put in an awkward position wrt toilets. Some of them genuinely respect women and girls, others are maybe just worried about being accused of something inappropriate. Either way, they don't like it.

And yet the new guidance will mean an increase in mixed-sex provision. It's terrible for transgender people and bad for gender critical people.

It is not at all clear that it is legal.
Even the linked document from the church group says: It is likely also to be lawful to provide a service only for people of more than one particular protected characteristic.
Note the word 'likely'
Personally I think it is unlikely, but it needs to be tested in court.

What is more to the point, I believe it should be legal to have single-sex (trans excluded) clubs and societies.

I'm not sure that is true. I think most large establishments will just keep their existing facilities and add in a couple of single occupancy 'gender neutral/unisex' facilities - which will be single rooms with integral basins. And this is already what most small establishments have - and as such they are already compliant - and just require appropriate labelling. The same for changing rooms.

Yes, I’ve been asked more than once when I come out if there are other women in there or if the coast is clear.

but eroding single sex spaces will soon knock that out of them.

I agree that mixed-sex provision is worse for everyone. But why do you say it will be 'terrible' for transgender people? Surely a transwoman would rather use a mixed-sex toilet than a men's toilet?
Genuine question.

You keep saying that, but I am not convinced. There may be an increase in certain areas, I have noticed it in a couple of bus and train stations for example, but I don't think that it will be the wholescale remodelling of the landscape that you imagine. It is a matter of money and space and throughput and document T, in England anyway. Separate-sex areas enable faster throughput because the sinks are separate to the toilets, for example.

No. It’s a cubicle. Stalls are for animals like horses.

I meant the EHRC guidance as a whole is terrible for transgender people, not specifically the mixed sex provision. The code even suggests that trans men might have nowhere to pee at all.

Girl Guiding could become a mixed sex organisation...

-If they dropped their use of the single sex exemption for Associations with more than 25 members

• if they changed their charitable aims and objectives
• if they dropped the 'for girls' deal
• and crucially, if the members themselves wanted to. There's been polling over the years which consistently shows that girls and parents want it to continue as a single sex organisation. The foot stamping of a few activists wearing their promise badges upside down in protest 🙄 doesn't change that.

No it doesn't. Transmen can only be excluded from female services if an alternative is provided. See FWS judgment for further details

Any small provider with and handful of separate individual loos will switch to unisex, per the EHRC head's guidance in her Channel 4 interview.

The only thing the EHRC says about not providing single sex loos is it "could be direct or indirect sex discrimination against women who use the service " without specifying any examples or circumstances under which would be the case. It's an absolute car crash. A recent high court decision suggests that as long as there is some single-sex provision, it's find to provide other "mixed-sexed" loos based on gender rather than "biological sex."

Lockable, individual unisex cubicles with urinals are the gold standard.

The one thing I hope we can agree on is that the guidance is vague and unhelpful and leaves service providers with no clear guidance.

The previous situation where places like museums and universities could (and did) put signs up telling women to welcome anyone who identified as female into the ladies wasn't great either. It is entirely due to that sort of overreach that the law was clarified. Especially as so many trans women have no intention of blending in. I see plenty of men with eg boobs and long hair and a pornstar dress plus doc martens and a beard saying they are women and getting in.

No. The guidance is clear. It is the spin being put on it by transactivists that is trying to muddy the waters.

@Mouldemort Lockable, individual unisex cubicles with urinals are the gold standard.

If you are going to keep stating this without addressing the points that other posters have made then you are not really moving the conversation along, are you?

The design still doesn’t sound great - it sounds like there’s an outer door leading to a blind corridor mixed sex room with rooms off? The Home Office had a similar problem when they converted a traditional washroom with cubicles into ‘gender neutral’ toilets behind a door. Unisex or universal toilets should directly lead off onto a thoroughfare. It seems men remember to close the door then.