The Partnership of Counselling and Psychotherapy Bodies, the British Psychological Society and the Association of Child Psychotherapists have opened a twelve-week consultation on two draft documents: a working definition of conversion practices, and a set of good practice principles for working with gender, sexuality and relationship diversity.
Together they will shape how every counsellor, psychotherapist and psychologist in this country is expected to work when a client brings sexuality or gender into the room. What follows is my comprehensive submission.
I have no quarrel with a profession that refuses to make gay clients straight or trans clients cisgender by decree, and I say so at the outset.
My concern is with what these drafts do to the therapeutic space itself, and above all to the deep, developmentally informed trauma work that attachment-informed EMDR is built on.
They infer a therapist’s purpose from where a client ends up. They set aside a client’s own request for the work they want. And they manage, across two documents and several thousand words, never once to say that human beings are male or female.
I have tried to write this with respect for the development team and with the fearlessness the subject needs, and I would welcome thoughts, disagreements, and indeed other submissions before the consultation closes at midday on 17 November.
For what I wish to contribute, read on. It’s quite long!
Response to the consultation on the working definition of conversion practices and the draft good practice principles for working with gender, sexuality and relationship diversity
Submitted by Mark Brayne, EMDR Europe-Accredited and EMDRIA-Approved Consultant, Director of EMDR Focus Ltd, author of Unleash Your EMDR, and developer of the attachment-informed EMDR (ai-EMDR) model. Former Reuters and BBC foreign correspondent (1973 to 2003) and Director Europe of the Dart Centre for Journalism and Trauma (2002 to 2008). More than 17,000 clinical hours as a psychotherapist and EMDR practitioner, supervisor and trainer.
Where I stand
I want to begin by saying plainly what I support. Any practitioner who sets out to make a gay client straight, or a trans client comfortable in a body they experience as wrong, because the practitioner has decided in advance which outcome is acceptable, is doing something that has no place in psychotherapy. I have no quarrel with a profession that says so, and I welcome the care the development team has taken to say that open exploration, assessment and support for autonomous decision-making are not in themselves conversion practices.
My concern is with what the drafts do in practice to the therapeutic space, and in particular to the kind of deep, trauma-focused, developmentally informed work that I practise and teach. I set that out below as directly as I can, with specific suggestions for the text.
The problem sits in the purpose test
The working definition says, rightly, that exploration is not a conversion practice. It then says, under principle 1, that the purpose of a practice should be assessed by reference to its overall character and intended outcomes rather than solely by the stated intentions of those involved, and that purpose may be evidenced by the outcomes regarding sexual orientation or gender identity that are encouraged or discouraged. Under principle 2, a predetermined outcome is one that is sought, encouraged or promoted whether or not the practitioner acknowledges it. Under principle 4, work described as exploratory may still be a conversion practice if its purpose is judged to be change or suppression.
Read together, these clauses mean that a practitioner’s purpose can be inferred after the event, by someone outside the room, from what the client went on to decide. If a client who arrived questioning their gender leaves trauma therapy no longer wishing to transition, that outcome becomes evidence of purpose. If the practitioner holds a clinical model in which early experience can shape identity, that model becomes evidence of a preferred outcome. The definition’s own glossary describes the holding of clinical beliefs as not in itself a conversion practice, but the purpose test invites exactly the inference that the glossary disclaims.
This is the chilling effect, and it is not hypothetical. I train and supervise EMDR practitioners across the UK, Europe and North America, and I know from that work how quickly a fear of complaint narrows what a practitioner is willing to explore.
The draft Bill, as the Minister acknowledged in the Commons on 25 June 2026, has already produced therapists who worry that their exploratory work might be construed as a conversion practice. A professional definition that reproduces the same open-ended purpose test, with a lower evidential threshold and no healthcare exemption, will deepen that fear rather than relieve it.
Two further features of the definition make this worse. Principle 3 says that conversion practices are shaped by stigmatising social contexts and have historically and predominantly sought conformity with heterosexual and cisgender norms. That is true as history. Placed inside a definition, though, it tells the reader which direction to look, so that a definition that is symmetrical on paper becomes asymmetrical in use.
Nobody reading principle 3 will suppose that a complaint about affirmation-only practice is what the document has in mind, and no complaints panel will treat it as such. The second feature is the treatment of sexual orientation and gender identity as a single category throughout. Sue Parker Hall has written repeatedly about this conflation, and she is right that it does real work.
A wish not to affirm a self-declared identity in a distressed adolescent is placed in the same box as the historical attempt to make gay men straight, and exploration itself, as she puts it, comes to be read as implying that the therapist prefers the client to conform to their biological sex. Once that reading is available, the therapist who explores is exposed to sanction whatever their actual intent.
What actually happens in the room
Attachment-informed EMDR works from a simple premise. Human beings become who they are through the interaction of an evolved body with the earliest relationships that shaped its nervous system. Much of what clients bring to therapy, from anxiety and depression to problems in intimacy and identity, has its roots in what happened and what did not happen in those formative years.
The work is to follow the client’s nervous system to where the trouble started, and to process what is found there. The therapist does not decide the destination but follows the client to it.
Where a client’s sexuality or gender sits within what I would call multidimensional maturity, settled in body, relationship and story, it is not my business to question it and I never would. Clients who are gay, lesbian, bisexual or trans and at ease with themselves do not need me to explore their identity, and the draft principles are right to say so.
But where a client’s presentation suggests that their experience of sexuality or gender is entangled with formative wounding, with a mother’s absence, a father’s violence, early sexual abuse, a body that was never safe, then that history belongs in the room like any other.
I cannot know in advance where the processing will lead. Sometimes a client emerges with the same identity, more securely held, and sometimes they emerge somewhere else. The point is that the outcome is theirs, and that it is not known, to either of us, at the start.
Clients who come to this kind of therapy need to know that I am prepared to go wherever their nervous system needs to take us. They sense very quickly when a therapist is speaking from protocol rather than presence, when a subject is being avoided rather than explored, when what the therapist is willing to follow is shaped by fear of complaint rather than by curiosity.
A therapy that fences off one area of a person’s history is not a neutral therapy with a small gap in it. It teaches the client that part of them is unspeakable, which for many is precisely the injury they came in with. A therapy that is not safe for the therapist cannot be safe for the client, and a therapy that is not safe is better not offered at all.
The client who asks for the work
There is a harder case than the one above, and the drafts as written close it down. A client arrives not confused but clear: she is unhappy with her attraction to women, or he with his attraction to men, or a client is unhappy with the gender identity they have arrived at, and they ask, in so many words, for help to explore where that came from and whether it might change. The initiative and the goal are theirs, and nobody has coerced them.
Principle 8 of the working definition says that a person’s request or consent does not determine whether something is a conversion practice. The glossary says that a goal identified with the individual at the outset is not a predetermined outcome, and then in the next sentence that an individual’s request for a particular outcome does not justify directing practice towards changing their sexual orientation or gender identity.
Principle 6 permits support for autonomous decisions about relationships, celibacy, transition, detransition or non-transition, but not for a wish to work on the attraction or the identity itself. The net effect is that a practitioner may help this client decide not to act on what she feels, and may help her live with it, but may not take her own stated goal as the goal of the therapy. The only outcome that her request cannot legitimately shape is the one she asked for.
I want to put this personally, because I know it from close to home. My mother was bisexual and hated the fact that she was drawn to women. She had four children.
Had she been in therapy (needless to say, not with me), I would have wanted her to be able to say to her therapist, I am unhappy with my attraction to women, I do not want it, will you help me sort that out. And I would have wanted the therapist to be free to answer yes, to take her at her word, and to go with her into the history that shaped that attraction and see where the work led.
A therapist bound by these drafts, or by a code that adopts them, would be obliged to say no, or to say yes while privately holding a different aim from hers. Either answer breaks the contract. A therapy that cannot take the client’s own goal as its starting point is not client-centred, and the BACP and UKCP frameworks both rest on respect for the client’s autonomy and self-determination as a first principle.
I am not asking for permission to promise change. In my own work the outcome of processing is never known in advance, and a therapist who guaranteed a particular result to any client would be misleading them.
What I am asking is that a client’s own aim be allowed to stand as the declared aim of the work, without the practitioner being required to disown it, and that the profession not decide on the client’s behalf which of her wishes are legitimate. A rule that says a practitioner may help a client towards any outcome except the one she has asked for is itself a predetermined outcome, imposed by the profession rather than by the practitioner, and the definition’s own logic ought to recognise it as such.
The absence of biological sex is the loophole
I write this as someone whose whole professional life has turned on how human beings come to be the way they are. In that work, bodies matter, and sexed bodies matter. Human beings gestate inside women’s bodies. Mammalian reproduction cannot work any other way.
We are shaped, from conception onwards, by our mother’s hormones, her stress responses and her nervous system, and after birth by her face, her voice and her arms. Male and female are not attributes assigned at birth by a clinician’s guess. They are embodied developmental pathways that organise attachment, desire, aggression and tenderness from the very beginning. Variation exists, and every clinician has met it, but it exists in relation to that reality rather than instead of it.
Across both draft documents, the word sex appears in only two places. One is the phrase “sex assigned at birth”, which is used to define gender identity. The other is the glossary entry on variations in sex characteristics, which describes them as innate variations in chromosomes, hormones, reproductive anatomy or sexual anatomy.
The two entries cannot both be right, since when the drafters define intersex, sex is an innate biological fact, and when they define gender identity three entries earlier, sex becomes something assigned, a social act performed on a newborn by somebody else. The documents know that sex is biological when it suits the definition and treat it as a label when it does not.
The consequence is that biological sex, the single most fundamental fact about any human being from the point of view of evolution, development and attachment, has no standing anywhere in a framework that will govern how the psychological professions work with gender and sexuality.
Identity, social context, stigma, intersecting identities and marginalisation are present on every page, while the body is absent, and with it the mother who carried and bore and fed every client who has ever sat in any of our rooms. This is not a small omission but the loophole through which the strongest form of gender-identity theory will drive a coach and horses, since a framework that names identity and never names sex has already decided which of the two is real.
The UK Supreme Court held in April 2025 that sex in the Equality Act means biological sex. The Cass Review, which the Government’s own impact assessment cites as the reference point for care of gender-questioning young people, insisted on a holistic and exploratory approach and warned against the polarisation of affirmative and exploratory camps.
A cross-professional framework that wants the trust of the whole profession needs to say plainly that human beings are male or female, with rare variations, that this is a biological reality rather than an assignment, and that a person’s sex is a legitimate and often necessary part of what a therapist attends to. Without that sentence the rest of the document will be read as taking a side, whatever the drafters intended.
A wider pattern I recognise
I want to name a pattern I have seen close up in my own community over the past year, because I think it explains why so many careful clinicians are frightened. Earlier this year a participant left the learning community I run for attachment-informed EMDR practitioners because I had said, in a discussion of development, that a body is male or female with occasional intersex variation. She did not leave because of cruelty or refusal of care, but because biology had been named.
A few days earlier I had sat through a professional training on racial trauma whose framework treated any disagreement with its premises as defensiveness, and offered a single legitimate path from fear through learning to growth.
Both episodes rest on a theoretical account of human difference and then insist that the account simply is reality. Both treat discomfort as evidence that the framework is working. Both offer safety while making it conditional on assent.
I am not a partisan in what are being called the gender wars, and I have spent forty years as a correspondent and then as a therapist watching what happens to language and to people when positions harden under pressure.
I do not agree with everything that Sue Parker Hall writes on her Substack, but on this specific point she is right: the fear now shaping the psychological professions is that ordinary exploratory therapy, the work of helping a person understand how they got to be who they are, can be reframed by others as an attempt at conversion. Her observation from supervision, that therapists can recognise trauma in a client’s presentation and yet dare not address it for fear that any attempt will be construed as a conversion practice, describes exactly the position in which these drafts would place EMDR practitioners working with formative trauma.
UKCP withdrew from the Memorandum of Understanding on Conversion Therapy in 2024 for closely related reasons, having stated in November 2023 that exploratory therapy is not conversion therapy. The concern is not a fringe one, since it sits inside one of the six PCPB partner bodies.
The consultation page describes this as a sensitive and emotive area and asks for respectful engagement. I offer this response in that spirit. Nothing here questions the dignity of any client or the good faith of the development team. What I question is whether a framework built on inferring purpose from outcome can protect either clients or clinicians.
Specific recommendations
On the working definition, I ask that principle 1 be amended so that purpose is assessed primarily by the practitioner’s stated and recorded aims and by the methods used, and that an outcome regarding sexual orientation or gender identity is never in itself treated as evidence of purpose.
I ask that principle 4 state expressly that trauma-focused work addressing formative experience, including experience that the client or practitioner believes may have shaped their sexuality or gender, is exploration and not a conversion practice provided the practitioner does not direct the client towards a particular identity outcome.
I ask that the definition state in terms what its own logic already implies, that a practice which treats affirmation of a particular identity as the only acceptable outcome is equally a predetermined outcome, and equally outside good practice.
I ask that principle 3 be moved out of the definition into an explanatory note, or balanced by an equally explicit statement that practices directing a person towards affirmation of a self-declared identity fall within the definition in the same way.
I ask that principle 8 and the glossary entry on predetermined outcomes be redrafted so that a goal freely identified by an adult client, including a wish to explore whether their attraction or identity might change, may stand as the agreed aim of the work, with the safeguard against conversion practices resting where it belongs, on coercion, pressure, undue influence and the practitioner’s own preferred outcome, rather than on the content of the client’s request.
On the good practice principles, I ask that paragraphs (2), (4) and (10), which repeatedly caution practitioners against assuming that gender or sexuality is relevant or requires exploration, be balanced by an equally clear statement that where a client’s history suggests relevance, the practitioner has a duty to follow it and should not be deterred by fear of how the work might later be characterised.
I ask that paragraph (29), on evidence, acknowledge that the evidence base on the developmental origins of gender distress in particular is contested and evolving, and that clinical judgement in this area is legitimately diverse.
On biological sex, I ask that both documents state, in the principles themselves rather than only in a glossary, that human beings are male or female with rare variations in sex characteristics, that sex is a biological reality rather than an assignment, and that a client’s sex and sexed development are legitimate and often necessary subjects of therapeutic attention alongside their gender identity.
I ask that “sex assigned at birth” be replaced throughout with “sex”, or if a qualifier is felt necessary, “biological sex” or “sex recorded at birth”, and that the glossary be made consistent with its own entry on variations in sex characteristics.
In closing
I have spent the second half of my working life sitting with people who bring what is most vulnerable, confused and unfinished in themselves. The one thing that work has taught me above all others is that clients heal when the whole of their story is allowed into the room.
The drafts under consultation, as they stand, would make one part of that story harder to bring, and would do so in the name of safety. I hope the development team will take that seriously, and I would be glad to discuss any of this further.
Mark Brayne Sheringham, Norfolk mark@braynework.com August 2026
Sources referred to
Partnership of Counselling and Psychotherapy Bodies, Consultation opens into conversion practices and GSRD guidelines, 25 August 2026. https://www.pcpb.org.uk/consultation-opens-into-conversion-practices-and-gsrd-guidelines/
PCPB, BPS and ACP, Working definition of conversion practices (for consultation), August 2026. https://www.pcpb.org.uk/wp-content/uploads/2026/08/For-consultation-Working-definition-of-conversion-practices.pdf
PCPB, BPS and ACP, Good practice principles for working with gender, sexuality and relationship diversity (for consultation), August 2026. https://www.pcpb.org.uk/wp-content/uploads/2026/08/For-consultation-GSRD-good-practice-principles.pdf
House of Commons, Draft Conversion Practices Bill, statement and debate, 25 June 2026. https://hansard.parliament.uk/commons/2026-06-25/debates/505981C1-2B0A-46E2-8FE0-ADFEA1F3743E/DraftConversionPracticesBill
Office for Equality and Opportunity, Draft Conversion Practices Bill and draft final stage impact assessment, June 2026. https://www.gov.uk/government/publications/draft-conversion-practices-bill
UK Council for Psychotherapy, statement on withdrawal from the Memorandum of Understanding on Conversion Therapy, April 2024. https://www.psychotherapy.org.uk/news/ukcp-withdrawal-from-mou-on-conversion-therapy/
Sue Parker Hall, Foundation for Academic Integrity and Responsibility (Substack): “Conversion therapy ban in the UK?”, 31 January 2026; “The psychological professions: from neutrality to political alignment”, 11 April 2026; “Speaking out about trans ideology for the Unsilenced Project”, 4 July 2026. https://fair370.substack.com/
For Women Scotland Ltd v The Scottish Ministers [2025] UKSC 16, 16 April 2025.
Cass, H., Independent Review of Gender Identity Services for Children and Young People: Final Report, April 2024.