In the following article Peter Jenkins discusses the recent Guidance issued by the British Association for Counselling and Psychotherapy on gender, sexuality and relationship diversity (GSRD), identifying some factual errors and shedding light on its core ideological priorities. He also examines the role of a recently formed cross-therapy meta organisation, the Partnership of Counselling and Psychotherapy Bodies. The PCPB now wields enormous power in terms of shaping UK policy on therapy regulation, despite its lack of a recognisable public face, or visible means of support. The PCPB’s current consultation reveals an unshakeable allegiance to the counterfactual narratives of gender identity and the overriding need to ban ‘conversion practices’.
Introduction
The British Association for Counselling and Psychotherapy (BACP) is the largest professional therapy association in the UK, with around 80,000 members. Since its emergence in the 1980’s, the BACP has acted as a key reference point across the wider UK therapy professions, particularly in terms of its influential Ethical Framework (2018). However, its leading role has been under increasing strain since pivoting towards its Equality, Diversity and Inclusion strategy, which prioritises social justice as its core mission.
BACP has increasingly come to rely on its guidance on Gender, Sex and Relationship Diversity (GSRD) as a means of shifting its membership by degrees towards the kinds of ‘cultural competence’ now expected of all its members. The GSRD Guidance sets out the new moral relativism necessary for competent practice. It also provides a means of tracking BACP’s growing movement away from its former espousal of therapeutic excellence and its current tilt towards activist allyship. These not-so-subtle shifts, combined with the more obvious changes in the GSRD Guidance, thus give us some useful clues as to how far and how fast the BACP is likely to go in its new ‘shape-shifting’ presentation of self as an activist political lobby.
Sue Parker-Hall (2026) has expressed her own profound sense of unease as a therapist concerning the new Guidance, describing it as ‘an imposition’, ‘a singular conceptual framework’, which is likely to ‘create anxiety for many therapists, regardless of their beliefs or values’. This critique will instead focus more specifically on the political meaning of the guidance, in its attempt to construct a powerful counter-factual narrative, built around the crucial twin themes of biology and the law.
The rise of counter-factual narratives
Counter-factual narratives seem to be growing in popularity and influence. Apple TV hosts two such series, The Man in the High Castle, and For All Mankind, based on this kind of fantasy premise. A counter-factual narrative fleshes out a drama based on resolutely ignoring a critical well-established fact – in the first case, the crushing defeat of the Axis powers in World War 2, in the second, US success in putting the first humans on the moon. Gender identity ideology closely imitates these examples. Gender identity ideology seeks to erase and misrepresent biological science, by promoting the myth that medical transition from one sex to another is in any way achievable. However, supporting this trans political stance places BACP in direct conflict with established consensual scientific reality. Hence BACP’s need to constantly revise and update its GSRD Guidance, in order to keep its members on the straight and narrow. It also potentially places BACP in direct conflict with UK law, via its highly selective interpretation of the Supreme Court ruling of 2025 on the key role of sex in applying the Equality Act 2010.
Maintaining a counter-factual narrative can produce enormous strains within any organisation. It requires that the leaders exercise close control over publications, continuing professional development, public policy statements and the internal disciplining of its members, in order to limit free debate and prevent the growth of opposition and dissent within its own ranks. The GSRD Guidance plays a key defensive role in this process, needing frequent updating as a public-facing shield to reassure nervous regulatory bodies of the BACP’s good intentions. The GSRD Guidance will also play a key part in the wider continuing capture and restructuring of the UK therapy industry. This process has taken shape in the form of the Partnership of Counselling and Psychotherapy Bodies, discussed in more detail later in this article.
BACP’s GSRD Guidance
The current issue of the GSRD Guidance is produced by Jack Lynch and Jeanine Connor, with previous versions having been written by Meg John Barker (BACP, 2023). Barker’s version of the Guidance recommended using an affirmative approach for bisexual identities (36), kink (41), nonmonogamy (50) and sex work (56), solely on the basis of assumed expert opinion. The change in authorship from Barker is perhaps significant, by indicating the need to bring the Guidance more emphatically back in-house. (Jeanine Connor is Editor of the BACP Divisional Journal, Children, Young People and Families, and a strong advocate of trans allyship (Jenkins, 2025)). Perhaps reflecting Connor’s own specialist interests in work with children, the GSRD stresses that it is “intended for use with adults (aged 18+)…specifically designed for adult-focused work” (2026: 6). This step may only bring temporary reassurance, given that the incoming Ethical Framework is now firmly in step with Queer Theory. It no longer recognises the absolutely fundamental ethical distinction between therapy with children and therapy with adults (BACP, 2025a).
The GSRD Guidance seems to me to be evasive, error-strewn and unreliable as any kind of professional reference point for therapists trying to grapple with good therapeutic practice in this area. It is based on a queasy form of moral relativism, asserting that “Everyone’s experience of their own gender, sexuality and relationships is valid and should be respected” (2026: 7). This stance then potentially opens the door to practitioners shutting down their therapeutic responses to ethically questionable client behaviours, which are explored later in this piece.
Asexuality and the MOU
Sometimes the Guidance is simply factually incorrect: hence “BACP is a signatory of the Memorandum of Understanding (MoU) on conversion therapy in the UK, which makes it clear that conversion practices in relation to gender identity and sexual orientation (including asexuality) are unethical, potentially harmful and are not supported by evidence” (2026: 8). This is clearly not correct, as the MOU makes no mention at all of ‘asexuality’ (BACP, 2024).
At other points, the Guidance just sows more confusion on the same point, stating that “The Equality Act 2010 does not include specific reference to asexuality in its definition of ‘sexual orientation’ and it is therefore unclear as to whether an asexual individual would be protected under section 12 on the basis of them being asexual” (2026: 40). Not referring to asexuality in legislation does not mean that there is any lack of legal clarity at all here – this is just wishful thinking on Lynch’s part.
In fact, the opposite case is true. Far from it being unclear, the position has been clarified in a definitive Parliamentary statement made by Kemi Badenoch MP on 10th February, 2021. “Sexual orientation is defined under the Act as a person’s orientation towards persons of the same sex, the opposite sex or of either sex. We have no plans to amend the Act and are not aware of any significant evidence of discrimination against people because of their asexuality” (UK Parliament, 2021). So, also incorrect…
Selective obedience to the law
Overall, the Guidance plays a key part in the BACP’s much wider political project: namely, to diminish the importance of sex as a key reference point in law and therapy practice; and to displace lesbian, gay and bisexual issues, by adopting a narrow, dominant focus on trans-identifying persons. So we read that “…some clients will sit at complex intersections, including migration status, race, gender, sexuality, and class” (2026: 13), contributing yet again to the relentless process of erasing sex as a category of legal and therapeutic value to clients or therapists.
The updated Guidance is breathtaking in its silent removal of the former 400 word section covering therapy issues relating to lesbians, gays and bisexuals, from the previous Barker version (2023: 39-40). This apparently casual erasure is, however, completely consistent with the new BACP pivot towards prioritising trans concerns. This is also clearly evident in the BACP’s response to the UK Supreme Court judgement on the key significance of sex in interpreting and applying the Equality Act 2010, restated for good measure in this Guidance:
“BACP aims to be a fully inclusive membership body and charity, for all transgender (trans), non-binary and gender questioning (TNBGQ) people. BACP is ‘committed to serving TNBGQ communities, considering lived experience and developing improved services, guidance and resources’ (BACP, 2025b) (quoted in: 2026: 8).
Or, as a recent Times Leader wryly commented on the parallel stance of some UK councils in rejecting the legal authority of the UK’s highest court, “…selective obedience to the law: these gestures should be the preserve of student union narcissists, not adults…” (Times, 2026).
Selective attention to biological science
The Guidance also offers potentially misleading summaries of crucial issues regarding the biological nature of sex. According to Lynch, “biological sex is more complex than simply whether a person has XX or XY chromosomes” (2026: 15). Well, actually, it really isn’t any more complex than this. The standard scientific view still holds true that “Females possess two X chromosomes, while males possess one X and one Y”; “Sex is thus dependent on whether an egg receives, at fertilisation, either an X or a Y chromosome from the sperm” (Hilton and Wright, 2024: 23).
Lynch also quotes the heavily contested data that “about 1.7% of the population worldwide has an intersex variation” (2026: 17). Leaving aside for just a moment the view that the term ‘intersex’ is itself now deemed “clinically inaccurate and stigmatising” (Hilton and Wright, 2024: 25), the original estimate of 1.7% of the population as ‘intersexual’ derives from a study by Fausto Sterling in 2000. “This loose definition of DSDs captures a large number of people with no biological ambiguity of sex…The frequency of 1.7 percent was revised to 0.4 percent by Hull and Fausto Sterling (2003) after identifying numerous flaws in the original study like failing to account for the sex-specific nature of many DSDs” (Hilton and Wright, 2024: 26). But Lynch still goes for the marginally higher figure, with no hint of acknowledging the author’s later downward revision of their original estimate.
GSRD as minimising the rights of women
BACP’s trans policy pivot has produced some concerning developments, including its own CPD event in 2022 on ‘Queering the therapy space’. This focused on “Understanding the specific role Terfism plays at the heart of British media…” (Jenkins, 2022). According to the All Party Parliamentary Group on Hate Crime (APPGHC) the term ‘trans exclusionary radical feminist’ (or TERF) [is] a term of abuse (2019: 25), a fact seemingly lost, or of little apparent interest, to BACP.
Warming to his chosen themes, Lynch suggests that consensual non-monogamy can include open relationships, polyamory and swinging (2026: 53). Apart from a scrupulous concern about using the correct language in the rush to appear non-judgemental, there seems to be little if any space here for standard therapeutic curiousity. Do past and enduring patterns of attachment or abuse play any role at all here? Is consent (or even the oxymoron of ‘consensual non-consent’) really all it seems here? These are questions worth considering, given recent press reports of substantial numbers of women being coerced into ‘consenting’ to swinging, i.e. sex with strangers, by their partners (BBC News, 2026). Even non-therapists are now beginning to ask the crucial question: “can abuse be shielded behind the language of sexual preferences and proclivities?” (Klingler, 2026). A little less moral relativism and a tad more therapeutic curiousity might well be advisable here, whatever the benign and value-neutral scenarios offered up the GSRD Guidance. Or is there just a consistently steady thread at work here, within the wider GSRD project as a whole, of constantly minimising the importance of women’s rights and experiences?
The wider PCPB project for therapy
If the GSRD Guidance represents an attempt to re-centre BACP members practice, then there are the recent moves by the Partnership of Counselling and Psychotherapy Bodies (PCPB) to inscribe these changes onto a national canvas. The PCPB includes all major therapy bodies, such as the Association of Christian Counsellors, British Association for Counselling and Psychotherapy, British Psychoanalytic Council, Human Givens Institute, National Counselling and Psychotherapy Society and the United Kingdom Council for Psychotherapy. The PCPB has just completed an ambitious national restructuring of employment criteria for UK therapists, in the form of the SCOPED framework. It is now turning its attention to complementing a draft criminal law ban on alleged conversion practices in England and Wales, by consulting on a joint policy which will also outlaw alleged conversion as unethical therapy practice.
Conversion therapy, or conversion practices, as they are termed in the new Draft Bill and in the PCPB consultation, come with their own chequered history. Aversive therapy was originally practised on the margins of the National Health Service against gay and lesbian patients, but largely disappeared from the mid-1970’s onwards. Most therapy associations signed the Memorandum of Understanding on Conversion Therapy (MOU) in 2015, opposing conversion on the grounds of sexual orientation. This was followed by the much more controversial and less-evidenced inclusion of conversion on the grounds of gender identity within the MoU in 2017 (Charlesworth, nd). Whereas sexual orientation is a well-established behaviour, part of the broad spectrum of human sexuality, gender identity is simply a concept, a part of a wider belief system, which can be identified as a key component of gender identity ideology.
Gender identity is defined by the World Professional Association for Transgender Health as “an internal identification and experience” (Coleman et al, 2022: S31). There are no set criteria for defining gender identity, nor any settled agreement on the number of potential gender identities which might or might not exist. The perception and attribution of gender identity are entirely self-defined. Conversion therapy or conversion practices (the terms are almost indistinguishable) rely on a perception, e.g. by a client in therapy, that the therapist is attempting to change or ‘suppress’ this self-defined quality, or experience (Jenkins,2024). Of course, therapists who hold gender critical or sex-realist beliefs might not choose to affirm a client’s belief in their own chosen gender identity. They are nevertheless protected by a wide tranche of case law, following the Forstater case at Appeal Court level, and by the provisions of the Equality Act 2010.
Minimising legal rights of gender critical therapists
The PCPB will have none of this. It has produced two documents for consultation, namely the Working definition of conversion practices (PCPB, 2026a) and the Good practice principles for working with gender, sexuality and relationship diversity (GSRD) (PCPB, 2026b). These documents seem designed to closely complement the Draft Conversion Practices Bill 2026. This law will criminalise conversion practices in England and Wales, albeit with a (possibly notional) protective exception for therapists. If the Bill succeeds in outlawing conversion practices in wider society, then the PCPB joint policy will finally succeed in implementing the MOU. This will ensure that therapists are prohibited from practising alleged conversion in their work with clients.
Yet the PCPB seems to operate in a parallel and somewhat counter-factual universe all of its own making. Research evidence for the prevalence of conversion is largely absent and is certainly heavily contested. This fact is reluctantly admitted by the Office for Equality and Opportunity’s crucial Impact Assessment (2026). Conversion therapy can be construed as simply an absence of affirmation, rather than a deliberate attempt to ‘convert’, a term charged with obsolete religious nuances. Gender identity ideology relies heavily on painting an emotively charged narrative of oppression, thus requiring exceptional levels of legal protection for trans-identifying persons.
The PCPB’s definition of conversion practices includes alarmingly subjective measures, including its “purpose, content and context” (2026a: 1). The PCPB appears to see existing legal protection for gender critical beliefs as being completely immaterial. Presumably their skilled investigators will be able to divine a therapist’s “preferred predetermined outcome” even more efficiently than the Witchfinder Generals of old could sniff out hidden signs of witchcraft, or the House of UnAmerican Activities could detect the very faintest traces of communist sympathies during the McCarthy era in the US? Once again, we see that therapist rights to free speech are considered to be incompatible with the PCPB’s pressing need to stamp out what is, in effect, a persistent urban myth, the chimera of ‘conversion practices’ or ‘conversion therapy’.
Conclusion
The updated BACP GSRD Guidance denotes a continuing policy shift towards prioritising trans issues, at the expense of the profession’s well-established concern for the rights of gay, lesbian and women clients. However, the problem in maintaining a counter-factual narrative, i.e. one lacking any basis in reality, is the constant need to keep generalising it, as more and more cracks inevitably develop. Thus a counter-factual approach to biology is now extended to embrace the law. It does this by minimising the real significance of both the Supreme Court ruling of 2024, and of the widening case law supporting the free speech rights of gender critical therapists.
If anything, the therapy associations are now further ramping up the odds with the current PCPB consultation. This is a purely token consultation, a plebiscite about nonsense. The consultation’s declared focus is on an alleged practice (conversion) with very little empirical evidence to its name, which is alleged to target something else with no empirical evidence at all (gender identity). As George Orwell, no fan himself of counter-factual narratives, ruefully concluded, “a widespread illusion, capable of influencing public behaviour, is itself an important fact” (1941/2020: 6). So we certainly seem to be living through an age of illusion at present. And, of course, it would be a final irony indeed if the PCPB consultation, despite all its supposed concerns about conversion therapists on this specific point, was itself carefully geared to producing its very own “preferred predetermined outcome”.
Non-electronic references
Hilton, E. and Wright, C. (2024) “Two sexes”, pp. 16-34, In A. Sullivan and S. Todd (Eds) Sex and gender: A contemporary reader. London: Routledge.
Orwell, G. (1941/2020) Fascism and democracy. Penguin.
By Peter Jenkins, counsellor, supervisor, trainer and researcher in the UK. He has been a member of both the BACP Professional Conduct Committee and the UKCP Ethics Committee. He has published a number of books on legal aspects of therapy, including Professional Practice in Counselling and Psychotherapy: Ethics and the Law (Sage, 2017).
Peter is also a member of Thoughtful Therapists. His critique of the Memorandum of Understanding on Conversion Therapy was described as ‘instrumental’ in persuading the UKCP Board of the case for leaving the MOU in 2024.
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