All BBC content is covered by guidance on sex and gender which was published in December 2023 (by Deputy News CEO Jonathan Munro), so it falls within the parameters of the Review. It is positioned as both a fact-check and a style guide. We will critique it line by line.

Some history: in November 2013 the BBC News Style Guide was rewritten to install self-identification of sex. The wording was very similar to the wording used today - ‘use the pronouns that the person prefers’. This rewrite happened aer high level meetings with transgender activists: specifically, a group called All About Trans, which was seed-funded by the BBC and Channel 4.

No group of ‘sex realist’ campaigners was consulted. There were three meetings with executives which All About Trans described (apparently mistakenly) as ‘Editorial Policy’ staff: and crucially, in August, a meeting with the then Online News Editor, in whose remit the Style Guide fell.

Since that rewrite, the guidance on sex and gender has been tweaked a number of times, most of them aer 2018. But self-identification has never been removed, and certainly not replaced with an injunction to accuracy.

Self-identification is not the law in the UK, it’s not required by IPSO and it’s not required by OFCOM. It is a political editorial choice made by the BBC.

Line by line critique: Guidance in bold, followed by our comments. The numbering is our own.

1. This note is intended to provide a briefing for reporting in this complex area and to point to useful additional editorial resources. It is not a substitute for the Editorial Guidelines, or normal editorial processes, including referring up to a more senior colleague, or consulting Editorial Policy. It does not cover the BBC’s role and responsibilities as an employer. Debates, legislation and policies relating to transgender issues have been increasingly in the spotlight in recent years.

The BBC has been extremely slow to acknowledge the issues around reporting sex and gender, and has ignored major government consultations. We have found that it is still falling behind current research and public opinion.

2. Some of the issues are contested, with strongly held and sometimes incompatible views and no settled consensus.

There is a settled consensus around the central question - the existence and reality of binary, immutable sex. It is not a view, or opinion, that sex is impossible to change, and that there are two of them. It is a substantiated scientific fact. The BBC prepares the ground here for presenting it as an opinion.

There is a view, or opinion, that sex is mutable, and on a spectrum, and this view or opinion is scientifically unsubstantiated. No one has ever changed sex. It is empirically impossible. Thus the contention that it is changeable, or has been changed, should be presented as a view, opinion, or belief. Instead it is presented by the BBC as a fact.

In our view these two approaches should be changed, in order accurately to reflect reality.

The guidance is signalling that it will now finally set out the facts as a resource for its journalists to draw on. It does not.

Mr Munro had the opportunity here to consult developmental and evolutionary biologists - not feminists or campaigners of any kind - and launch this guidance

with a back-to-basics focus on the facts. Guidance about when and under what circumstances to ‘overlook’ the facts for the sake of kindness or when legally required would then be due. He misses the opportunity.

3. Individuals often feel they have a big personal stake in how these issues are reported. This can make it a challenging area for BBC journalism.

Here the focus is tied to emotionalism rather than facts. There are two primary issues here:

failure to focus on the facts

failure to support journalists who do try to report the facts but can face

overwhelming pressure from people who feel they have a ‘big personal stake’

What the guidance is saying, but does not spell out, is indeed extremely sensitive: that there are trans-identified staff members, or staff members with trans-identified family or friends, who are heavily personally invested in self-identification.

There are also some heavily invested gender identity activists within the BBC, including in HR, staff networks and editorial, and they can and do mobilise to complain internally about BBC reporting which challenges gender identity theory in any way.

We have members with experience of this: for example, accusations of making people they don’t work alongside feel ‘unsafe’, or of being afraid to speak up because parents of trans-identified children are present. Or an example would be the Justin Webb case: his accurate clarification that trans sports‘women’ are male was the subject of an insta-complaint, instantly upheld by a BBC Executive Complaints Unit showing signs of regulatory capture. This was the mildest possible deployment of accuracy, but no quarter was given.

The ‘other side’ (as it were - the sex realist side) is generally unlikely to make these kinds of emotional representations, and instead will focus on poverty of fact, one-sidedness, lack of impartiality and selective bias and so on. Greater maturity is needed within BBC editorial management to acknowledge and curate this mismatch.

4. As with any subject, care needs to be taken when researching stories, selecting contributors and examining claims and counter-claims.

This is without substance, purely because this guidance (see later pages) reaffirms self-identification as the BBC standard - the very definition of an unsubstantiated claim which remains unexamined by the BBC.

5. Some apparently credible sources of information can be highly partisan and misleading.

Much of this guidance seeks to ‘both sides’ every issue, implying that sex realists and gender identity activists are equally responsible for falsity, over reaction, over-emotionalism and so on.

In reality, the greatest purveyors of misinformation on sex and gender have been gender identity activist groups, many of whom were invited into the BBC (All About Trans, Mermaids, Stonewall, INvolve, Global Butterflies) and given serious roles in policy development, and much of whose advice appears on BBC documents.

Some of it is taking a very long time to extract, so it would be judicious of the BBC to acknowledge the one-sided nature of this problem.

6. We should have the need for audience understanding at the forefront of our reporting.

Again, empty words. We wish that this were true. The BBC has made it clear that anyone who seeks to enhance audience understanding on the biological sex of trans people will face disciplinary action.

7. Attitudes and levels of engagement vary widely among different sections of the audience. While these are debates that some people are immersed in, to the general audience they can appear opaque and the language unfamiliar.

This could be managed in a number of ways. Some suggestions:
Every story and programme on sex and gender links to a basic fact check on the reality of sex - that it is immutable and gamete-based

Every story and programme has a footnote that ‘trans women’ refers to males (born males, biological males) and ‘trans men’ refers to females (born females, biological females)

Relevant stories having a footnote explaining that no one is ‘in between’ the sexes

The Review team should ask BBC editorial leaders what is making this so hard to do, if it agrees that the audience is very badly confused, and the language so opaque.

Does the BBC find accuracy undesirable?

Is it afraid of activists?

Is it led by people who themselves hold gender beliefs?

Has it considered only the harm to trans advocates and no one else?

8. We need to consider the framing of stories, the language we use, the tone of coverage, the context we provide and the labels we apply to the views of contributors. For example, describing someone as either a women’s rights activist or an anti-trans activist is an editorial choice.

The BBC has made steps forward on story-framing. Historically it was inevitable that stories on sex and gender were framed around ‘trans rights’ - online, in story intros, by presenters in interviews, in programming. It does still happen, just less routinely. Important to remember these stories are never only about trans rights. Examples:

The issue of males in female spaces is always about women’s rights

The issue of child transition is as much about the right to grow up without

medical interventions as about accessing puberty blockers and opposite sex hormones

The BBC has also made progress in not framing as ‘trans children’ those minors who have been identified as trans by their parents, school or themselves. There has been a move towards the phrases ‘gender distressed’ and ‘trans-identified’, which should continue.

However Mr Munro makes his own framing mistake here - so subtle he may not have noticed it himself. He frames ‘anti-trans’ and ‘women’s rights’ as of equal

value - whereas ‘anti-trans’ is an obvious negative slur. The BBC has already had to correct headlines which used this phrase to describe women’s rights campaigners.

9. We may also need to challenge claims or assumptions by contributors. Care is needed, for example with use of the term ‘transphobic’ to describe people who would not themselves accept that label.

The BBC has a ‘tag’, a special page for stories about ‘Transphobia’. Stories like this, for example, and this story about a women’s rights event. It ought therefore - naturally - to be able to supply its own definition of transphobia: and if it can’t, should express extreme caution over using the term at all.

It could also point out that many people believe transphobia is simply rebranded homophobia, and fear that assumptions about transphobia actually ‘erase’ homophobic abuse.

10. This is a fast-moving area. Inevitably therefore, this is a snapshot of the current state of legislation, policy and public attitudes.

For the most part, this isn’t true. The condition of being male or female is not a fast-moving area. It does not change. Nor is it true that this guidance is a snapshot of either legislation or public attitudes, because it fully affirms self-identification of sex, which is not the law, nor do most people believe ‘trans women are women’.

The fact that it is a snapshot of much public policy, despite being out of skew with the condition of reality, legislation and public attitudes, is a news story which the BBC has struggled to cover.

11. We are used to reporting on controversial subjects. They are at the heart of the news agenda and the focus of much of our journalism. As with any contested subject, we need to be aware of the requirement for due impartiality set out in the Impartiality section of the Editorial Guidelines:

4.3.6 When dealing with ‘controversial subjects’, we must ensure a wide range of significant views and perspectives are given due weight and prominence, particularly when the controversy is active. Opinion should be clearly distinguished from fact.

These are empty words, as the BBC fails to make clear that impartiality naturally begins with establishing the facts, and moves on to curating a range of views around them.

Instead this December 2023 guidance tells journalists to adopt opinion and belief (self-identification of sex) as standard, over fact (biological sex). We cannot stress enough how easy it is to diagnose the BBC’s problem with accuracy and impartiality on this issue.

In all internal editorial conversations, the BBC treats the fact of biological sex as having the same weight as the opinion that being male or female is determined by gender identity/the brain.

In all outward-facing content, the BBC treats the fact of biological sex as an opinion, and treats the opinion that being male or female is determined by gender identity/the brain, as a fact.

This position is impossible for editorial leaders to justify. Its analysis does require critical thinking, but at a rather basic level.

12. The Guidelines set out what is meant by ‘due weight and prominence’:

4.3.2 Impartiality does not necessarily require the range of perspectives or opinions to be covered in equal proportions either across our output as a whole, or within a single programme, webpage or item. Instead, we should seek to achieve ‘due weight’. For example, minority views should not necessarily be given similar prominence or weight to those with more support or to the prevailing consensus.

This is well put, but until ‘due weight’ is given to the facts around sex (for example, there is no fact check or reality check on bio sex on the website) they are empty words.

13. We need to think about what we decide to leave out, as well as what we include:

4.3.3 There may be occasions when the omission of views or other material could jeopardise impartiality. There is no view on any subject which must be excluded as a matter of principle, but we should make reasoned decisions, applying consistent editorial judgement, about whether to include or omit perspectives.

This is one of the BBC’s major sources of bias: the exclusion of so many important stories. During the period under consideration, the BBC nominally had an LGBT Correspondent, an LGBT producer, a global gender correspondent, a full health team, an education team, science correspondents and social affairs correspondents and producers. However, dozens of stories were ignored and there is a dearth of informative factchecks. We supply examples in our other submissions.

14. Sex and gender: The distinction between sex and gender is at the core of many of the contested areas around trans. Indeed, the distinction itself is not universally accepted.

This guidance is written as if there were no facts at hand to settle some of the ‘contested areas’. It certainly doesn’t offer them. In reality, those facts are available but the BBC chooses not to lay them out, either internally or externally.

It is not ‘universally accepted’ that the earth is an oblate spheroid, for example, but we do not balance astronomers with those who imagine it to be flat. It is not ‘universally accepted’ that climate change is human-led, but we see no need to give equal weight to climate scientists and deniers.

Note that ‘gender’ here is used to mean ‘gender identity’, not sex. Much confusion arises because the BBC also uses ‘gender’ to mean the exact opposite - sex. The guidance is an opportunity to clear up this fudge but unfortunately makes it worse.

15. We need to take care to use the appropriate term in the context of a particular story. Gender identity is based on the feelings, behaviour, expectations and outward presentation typically considered to correspond to someone's sex.

The BBC builds this entire section on the unsubstantiated premise that gender identity is real and that everyone has one. Consequently the reasoning that follows is fatally flawed. But let’s plough on.

According to this, the BBC determines ‘gender identity’ to be based on stereotypes. It should probably say so, and a comprehensive guide would add that many people consider these stereotypes to be highly regressive - boys play with trucks, girls play with dolls, women wear makeup, men don’t have long hair, men can’t cry, women

can’t be rocket scientists and so on. Aer all, observing the differing social ‘expectations’ corresponding to sex (as the BBC puts it) would be a very good definition of basic sexism.

On the other hand, many people who identify as trans actually claim that gender identity is innate and not based on cultural factors at all. Or they may simultaneously say it is nothing to do with stereotypes while claiming they ‘always knew’ they were the opposite sex because they liked the colour pink, or wanted short hair. These are the types of contradictions that make the issue ‘opaque’ and ‘confusing’ for many ordinary people, so it’s the sort of thing the BBC should be both dissecting internally and explaining to the audience.

16. For example, a person whose sex is female might identify as male, or vice versa.

A good explainer would include the detail that ‘identify’ here means ‘say they are’, that the term ‘identify’ is hard to define, and that it doesn’t mean that people actually are what they say they are.

17. For most people, their sex and gender identity are the same.

This sentence could be drawn straight from a Stonewall playbook. There is no evidence that gender identity exists, or that everyone has one. The evidence that some people have one could be summarised as evidence only of certain feelings or desires, not of any innate identity. But the BBC has planted this activist belief in ‘gender identity’ right in the middle of important pan-BBC guidance on reporting sex and gender. It’s wrong.

18. The medical term for people who experience “unease or dissatisfaction” about a difference between their sex and gender is gender dysphoria.

Here Mr Munro elides ‘gender identity’ with ‘gender’. Aer exhorting staff to be careful with terms, he fudges these two, and lays out no definition of ‘gender’ - not even to say it should only be used to reference ‘gender identity’ in order to avoid confusion. It’s well known that gender is oen used as a substitute for ‘sex’ (including in this guidance) and this is where it could have come up with helpful advice such as - ‘when referencing sex, always use the word ‘sex’.’

There are various meanings of ‘gender’ - here are three, and they should have been laid out:

A euphemism for biological sex (journalistic and workplace convention)

‘Gender identity’ (the activist view)

The collections of stereotypes which arise from biological sex (the feminist

view)

This is not the sort of detail that might make it into a public explainer, but it should certainly be understood and discussed internally, particularly in specialised guidance.

19. There is a lack of consensus about the nature of gender dysphoria and some people do not accept that sex and gender are separate.

Again, the elision of terms, amounting to a fudge. Some people do not accept that gender exists at all, never mind being separate from sex. This section only prompts more questions.

What is meant by gender here?

Who does not accept that sex and gender are separate?

Who thinks they are the same?

Who disputes the nature of gender dysphoria - medics, activists, feminists?

Why is there no acknowledgement that the existence of gender identity (if

that is what is meant here by ‘gender’) is scientifically unsubstantiated?

It would also be useful to have a definition of sex (gamete-based), with guidance around the fact that ‘born’ and ‘biological’ are unnecessary qualifiers.

20. The NHS provides guidance on gender dysphoria and how people can seek help if they need it. A trans person's gender identity is not the same as the sex on their original birth certificate.

Again, the premise of gender identity being innate. There is no need for the words ‘on their original birth certificate’ - they deliberately imply that sex can change after being recorded, when it can’t. This is the point at which sex immutability can be made clear.

21. A baby’s sex is recorded as male or female, based on physical characteristics. There are a small number of people born with chromosomal or physical differences that can make this a complex judgement. These are known as differences in sexual development (DSD).

This is correct, but there is selective bias. All DSDs are diagnosed according to sex - no one is in between. We suggest it is spelt out, along with the advice that this is where the phrase ‘assigned at birth’ springs from and remains useful.

22. People who experience a difference between their sex registered at birth and their gender identity may describe themselves as transgender, or trans.

‘Registered at birth’ is redundant. Their sex, is their sex. This is internal guidance for journalists, not publication, and it promised to be clear. It is not clear.

Again, the assumption that universal ‘gender identity’ is real and substantiated runs through this guidance like Brighton through a stick of rock. It’s a very activist position.

23. Many transgender people live according to their gender identity, dressing and presenting to the world in a way matching that identity and being referred to by their chosen name.

These are stereotypes, but the sentence ‘live according to their gender identity’ is meaningless, and a journalist as senior as the News Deputy CEO should be aware of this. If you are not a man, it is impossible to live according to a male identity. Perhaps a ‘seek to live’ would be useful here. A female who says she’s male is living as a female who says she’s male, or wants to be male, or is seeking to live according to a male identity.

The BBC frequently uses the phrase ‘has been living as a woman since...’ when referring to men. It’s inaccurate. A more useful word might be ‘presenting’ as a woman.

24. We should use a person’s chosen name, unless there are good editorial reasons to use their birth name.

Why? No explanation is given. Mr Munro should make clear the editorial conditions which would qualify for use of a previous name. Examples to be discussed might be:

Crime/court cases

Missing people/suspects

Contributors to debates on women’s spaces

Trans rights/women’s rights campaigning

Professional developments

Sport

These are a few examples. Without outlining the conditions for the exceptions to this unexplained rule, it guarantees the rule will be broken only under the rarest circumstances, if at all. Senior managers have nothing to guide them when asked by their teams.

25. People who are non-binary do not consider themselves to have a solely male or female gender identity. In the UK, a person’s sex can only be legally registered as male or female. Some other countries, including Australia and Germany, legally recognise a non-binary gender.

Suggestion: ‘People who [say they] are non-binary do not consider themselves to have a solely male or female ‘gender identity’.’

26. Some people also decide to change their body physically to correspond to their gender identity.

‘Gender identity’ is an unsubstantiated concept. Suggestion: ‘Some people who identify as trans decide to change their body physically’.

27. This can involve, for example, taking hormone medication or having voice therapy. A small proportion go on to have surgery. Social, physical and legal changes are known as transitioning.

This is an extreme and irresponsible minimisation of medical interventions, particularly for children. Medical interventions can include:

Puberty blockers (a powerful cancer drug)

Cross sex hormones

Mastectomy

Castration

Penectomy

Hysterectomy

Removal of the vagina

Extraction of a large skin tube from the forearm to make a neo-penis

The BBC has never produced any fact check on the reality of medical transition and the long lasting side effects, nor has it carried the personal journey of a medical detransitioner, for example a male who regrets his complete castration. It’s an abrogation of responsibility. This guidance, with its reference to ‘voice therapy’, and absence of any detail, is part of the problem. The impression given to staff: ‘nothing to see here’. We suggest such a fact check be drawn up and published.

Further: a useful addition to the guide would be the estimated numbers of later male transitioners who take the most radical surgical option. It’s between five and ten per cent at most. This is vital context for the debate on males in female spaces. For some men claiming to have undergone surgery, it simply means breast implants.

28. People sometimes described as gender-critical emphasise that a person’s biological sex cannot be changed and think that biological sex is more important than gender identity.

Suggestion: ‘People sometimes described as ‘gender critical’ or ‘sex realist’ understand that sex cannot be changed and are willing to say so. They will campaign on the grounds that the difference between men and women is important politically, socially and for the safety of women and children. People who believe in gender identity think that this is what determines whether a person is male, female, or neither. There is no evidence to suggest that everyone has a gender identity.

‘People who say they have a ‘gender identity’ of the opposite sex, or neither sex, or other undefined ‘gender identity’, have not changed sex. They remain as they were born, male or female, throughout their lives.

‘Most countries allow people to change their birth certificates aer going through a legal process. Some countries allow self-identification, some require a medical diagnosis. Self-identification is not the law in the UK.

‘Some countries, including the UK, allow sex to be changed on legal documents such as a passport or driving licence, without a legal process of ‘gender reassignment’.’

29. The number of trans and non-binary people is small in relation to the overall UK population and estimates vary. For the first time in 2021, the census in England and Wales asked “Is the gender you identify with the same as your sex registered at birth?”. Of the responses, 262,000 people over 16 answered ‘no’ to the question. Of these, 96,000 identified as transgender, with half identifying as trans men and half as trans women. Comparable figures are not yet available for Scotland or Northern Ireland. A further 30,000 people identified as non-binary and 18,000 wrote in a different gender identity. The remainder gave no additional information. Following concerns about whether all respondents had interpreted the question as intended, the Office for National Statistics undertook further work to understand the data and compare it with other available sources. When referring to these figures in output we should make clear that there are uncertainties about the accuracy of the data.

Suggested addition

‘Little research has been conducted on the numbers of people who have detransitioned. We should not take on trust statements such as ‘the numbers are tiny’. There is one Reddit detrans forum which has >50,000 members, for example.

‘The word ‘detransition’ is generally used to refer to a person who has undergone medical intervention. The word ‘desist’ is generally used to refer to a person who socially transitioned without medical intervention.

‘Social transition: asking to be treated by those around you as if you were the opposite sex/an alternative ‘gender’. Usually involves a change of name, change of presentation and declaration of pronouns.’

30. Legal changes. Under the Gender Recognition Act 2004, UK adults are eligible for a Gender Recognition Certificate if they meet certain criteria. The certificate has the effect of changing a person’s legal sex. This will be recorded on their birth, marriage and death certificates.

Inaccurate.

Suggestion: ‘The certificate has the effect of changing a person’s legal sex for almost all purposes. With a GRC, you can update your birth or adoption certificate, and update your marriage or civil partnership certificate’.

31. The main requirements are:
A declaration that they will live permanently in their acquired gender Two medical reports, including a diagnosis of gender dysphoria
A medical report of any hormone treatment or surgery, or any planned treatments
Evidence they have lived full time in their acquired gender for at least two years, such as copies of their passport and driving licence
Applicants must be 18 or over and pay a fee

Suggested edits:
‘A medical report of any hormone treatment or surgery, or why none has taken place’ (no medical treatment is required for a GRC to be issued)
‘Applicants must be 18 or over and pay a fee of £5’
‘It has now been simplified to an online process’

32. Some trans people said they found the system costly, humiliating and bureaucratic. Fewer than 5,000 people had legally changed their sex in this way by 2019. This led the UK government to launch a public consultation on potential changes to the Act.

Suggestions:

‘Fewer than 5,000 people had changed their legal sex marker by 2019. Since then the number has risen by approximately 8,500’

‘Campaigning by activists led the UK government to launch a public consultation on potential changes to the Act in 2018’

33. There was speculation that the government might scrap the medical diagnosis requirement for England and Wales and allow people to change their legal sex through self-identification. When the government responded to the consultation in 2020, it said it believed the Gender Recognition Act contained proper checks and balances. It reduced the cost of applying to £5 and said it was moving the process online.

Suggestion: ‘This was widely considered to be a consultation on ‘self-identification’ of sex, removing the medical diagnosis. It was treated as such by campaigners on both sides, such as Stonewall and Fair Play for Women. The government responded in 2020 by reducing the cost and moving the process online. The medical diagnosis requirement was retained. Self-identification of sex is not the law in the UK.’

34. Scotland. The Scottish government wanted to make it easier for people born in Scotland, or classed as "ordinarily resident" there, to obtain a Gender Recognition Certificate. Gender recognition is devolved in Scotland, but not in Wales or Northern Ireland. The proposed reforms would speed up the process and lower the age people can apply to 16. No diagnosis of gender dysphoria or medical reports are required. The period for which applicants need to have lived in their acquired gender is cut to three months, or six months for under 18s.

Suggestion: ‘The Scottish government wanted to make it easier for people born in Scotland, or ordinarily resident there, to obtain a Gender Recognition Certificate. The changes they proposed would have amounted to self-identification of sex; removing the medical requirement, speeding up the process and reducing the eligible age to 16. Gender recognition is devolved in Scotland, but not in Wales or Northern Ireland. The legislation passed in the Scottish Parliament but did not become law.

35. The high profile case of Isla Bryson, a double rapist who changed gender while waiting to stand trial, had a significant impact on the debate. Bryson was convicted of attacking two women, while known as Adam Graham.

Note: this is exactly the fudged language use that this guidance was meant to prevent. ‘Changed gender’ could usefully be replaced by ‘self-identified as a woman’.

36. Bryson was initially jailed in a women's prison, in line with Scottish Prison Service policy, but was moved to a men's facility aer the decision met widespread opposition. The policy was subsequently changed so that transgender women are taken first to a prison matching their sex at birth.

The final sentence is soaked in activism. Suggestion:

‘The policy was subsequently changed so that male detainees who identify as women/claim a female identity are taken first to the male prison estate’

In a guide on impartiality and avoiding activist language, it’s really important that activist language itself can be avoided, if not expunged. It really starts with being able to identity the framing that produced it.

37. There were concerns that some of the consequences of the Bill could impact wider UK equality legislation, which is a ‘reserved’ matter outside the Scottish Parliament's powers. In December 2022, Scotland’s highest court, the Court of Session, ruled that a GRC changes someone's legal sex for the purpose of the Equality Act 2010. The Act is designed to protect people from being discriminated against because of certain characteristics, which include both sex and gender reassignment. The implications of the new Scottish legislation for the existing Equality Act led the UK government to use its powers to block the Gender Recognition Reform Bill. The Scottish government is challenging this decision in court. In December 2023, the Court of Session ruled in favour of the UK government.

Out of date, extremely unclear on the Equality Act and the Haldane ruling. Suggestion:

‘There were concerns that the Bill could have an impact on wider UK equality legislation, which is outside Scottish Parliamentary powers. In

December 2022, in a separate case, Scotland’s Court of Session ruled that a GRC changes someone's legal sex for the purpose of the Equality Act 2010 - effectively ruling that the protected characteristic of ‘sex’ in the EA included males with a GRC.

The EA2010 says it is illegal to discriminate on the grounds of a list of protected characteristics, which include ‘sex’ and ‘gender reassignment’. (Note: neither ‘gender’ nor ‘gender identity’ is a protected characteristic). The implications of the new Scottish legislation for the EA 2010 led the UK government to use its power, known as S35, to block the Scottish law.

The Scottish government challenged the decision in court, which in December 2023 ruled in favour of the UK government. Scotland said it would not appeal, and in May 2024 the plans for Gender Recognition reform were formally dropped by the SNP.’

38. Women-only spaces. Much of the debate about the rights of transgender people has focused on access to women-only spaces such as toilets, changing rooms, domestic violence refuges, as well as prisons.

After warning about framing, this guidance frames women’s spaces as about the ‘rights of transgender people’. Editors need to look with a wider lens. There are a small number of transgender people and a very large number of women. The issue is not so much ‘the rights of transgender people’ as

the rights of women

the lifelong medicalisation of children, young adults and other vulnerable people

Suggestion: ‘Much of the debate has focused on access to women-only spaces such as toilets, changing rooms, domestic violence refuges, as well as prisons.’

39. Under the Equality Act 2010, no-one should be discriminated against because they are transgender. A person does not need to have undergone any specific treatment or surgery to be protected.

There is an opportunity here to fact check the type of protection offered under the protected characteristic of ‘gender reassignment’. The BBC should take this opportunity.

Suggestion: ‘People who have undergone or propose to undergo gender reassignment are protected against discrimination in housing, employment and a range of other services. It does not mean that people with this protected characteristic are able to self-identify as the opposite sex. A man without a GRC, who ‘identifies as a woman’ has to be treated the same as a man who does not ‘identify as a woman’. He does not have to be treated as if he were a woman.’

The BBC needs to consult lawyers who do not work for gender identity captured organisations.

40. But single-sex service providers can choose to exclude transgender people where this is a ''proportionate means of achieving a legitimate aim'', including dignity, privacy or safety.

Again, the BBC should offer the required detail, including that ‘privacy and safety’ are considered a legitimate aim by the EHRC, and link to these EHRC guidelines issue in 2022. Many correspondents don’t seem to understand the type of discrimination protection offered by the EA2010. A link to the Equality Act is advisable.

Also: framed as ‘exclusion’. Could easily say ‘can choose to maintain single sex spaces’. The framing betrays the priorities of the writer of the guidance.

41. In 2023, the chair of the EHRC advised that clarifying the definition of “sex” in the Equality Act to “biological sex” is worth further consideration. This would make it easier for spaces to exclude people who are transgender, whether or not they have a Gender Recognition Certificate.

Here is the distinct and deliberate framing of exclusion again.

Suggestion: ‘This would make it easier for women to protect single-sex spaces even when a transgender male (‘person’, if they cannot bear to write male) has a Gender Recognition Certificate.’

42. In 2023, the MoJ announced that transgender women convicted of violent or sexual offences, or having male genitalia, would not serve sentences in the women’s prison estate unless there are “exceptional circumstances”, whether or not offenders have a Gender Recognition Certificate. Previously in England and Wales, transgender women prisoners were only placed in a women’s prison aer a risk assessment by a complex case board.

Although this guidance continually stresses how contested the issue is, and how journalists should not elevate opinion over fact, it’s not itself impartial, and lands on one side throughout - the side of affirmation. The MoJ announcement was about transgender males or men. Suggestion: ‘biologically male transgender people’ or ‘biological males’. The final sentence should be deleted: there’s evidence that male prisoners were automatically sent to a female prison and that the risk assessment was a captured process. In fact, this guidance itself says so in (37) - ‘Bryson was initially jailed in a women's prison, in line with Scottish Prison Service policy’. It contradicts itself.

43. Employment. Transgender employees have taken cases to employment tribunals, claiming workplace discrimination in contravention of the Equality Act 2010. There have also been high profile cases which arose from claims of employment discrimination against women with gender-critical views.

Again the framing: there have been extremely significant cases on both sides, and the more newsworthy and legally significant have been those brought by sex realists. (The Review team will probably struggle to think of a ‘trans’ case off the top of their heads, whereas the Maya Forstater case was the best known and most groundbreaking). But ‘trans’ cases are given primacy here.

44. In 2021, Maya Forstater won a High Court case against her employer, the Center for Global Development. She had not had her contract

renewed aer expressing her view on social media that “sex is immutable and not to be conflated with gender identity.”

Suggestion: Should say ‘stating that’ not ‘expressing her view’. Facts should not be presented as opinions. The BBC really struggles with subtle or ‘nudge’ bias.

45. This ruling overturned an earlier employment tribunal finding. The court found that her views were “a protected belief” under the Equality Act.

The guidance should explain here that the case was presented not on the grounds of truth, but of belief, for complex reasons. This is the kind of analysis in which the BBC has consistently failed to show interest. It should also explain that the ruling that they are protected as a ‘belief’ does not mean that they are not also true, and the weight of evidence remains in their favour.

46. However, the court also said that “the judgement does not mean that those with gender-critical beliefs can ‘misgender’ trans persons with impunity.” and “does not mean that trans persons do not have the protections against discrimination and harassment conferred by the Equalities Act. They do.”

The guidance needs to qualify its activist language here. ‘The judgement does not mean that people can ‘misgender’, or use sex-based pronouns and language, for trans persons..’ . The reference to protections is pointless without the full explanation of what the protections actually are, as we outlined in (39).

47. In 2022, barrister Allison Bailey won her case for discrimination against her chambers. An employment tribunal found that she had been discriminated against for her view that biological sex cannot be changed and that a woman is defined by her biological sex.

Correction: ‘found that she had been discriminated against for stating that biological sex cannot be changed’

48. Gender identity and children. Another contested area is the treatment of children who question their gender identity. These feelings are

"reasonably common", according to the NHS. For a small percentage they persist and may lead to a referral to the under-18s Gender Identity Development Service (GIDS) in England.

Another demonstration of the problem that this guidance is fully built on a belief in gender identity. The existence of gender identity itself is deeply contested, and the BBC should not be incorporating the belief in such a controversial concept into its editorial guidelines. If necessary, it can include an explanation that despite its contested nature, the NHS uses the phrase in its policy making.

49. The number of such referrals increased substantially in recent years.

This is meant to be a comprehensive backgrounder, so it should include the fact that referrals of girls in particular grew astronomically aer about 2014. This coincided with much greater media exposure and media activism by groups such as All About Trans and Press for Change. (programmes such as I Am Leo, I Am Jazz, Just a Girl, BBC Victoria Derbyshire features for example).

50. In some cases, the service referred children to be prescribed puberty blockers. These delay the onset of puberty, but the NHS says little is known about their long term side effects.

At this point the BBC needs to give more detail about puberty blockers. It has its own fact check that could be offered as a link, but describing them simply as a ‘delay’ without also referencing the lifelong impact will mislead its journalists and encourage them in copy to refer to them with this uncomplicated description as a pause. It can also explain that they are powerful cancer drugs, and are prescribed ‘off-label’ for gender dysphoria.

51. In 2023, NHS England announced that children would only be prescribed puberty blockers as part of clinical research. Cross-sex hormones cannot be prescribed until a young person is over the age of 16 and has been on puberty blockers for 12 months. Reassignment surgery is not legal for people under the age of 18. In Scotland, young people can be referred to the Sandyford Clinic. In Wales, referrals are to the Gender Identity Clinic. In Northern Ireland referrals are to the Knowing Our Identity service.

This needs updating in the light of developments in 2024 following the Cass Review.

52. Applicants must be over 18 to obtain a Gender Recognition Certificate.

Worth making clear here that this means children’s legal sex is always the same as their biological sex.

53. Keira Bell case. In 2021, the Court of Appeal overturned a judgement that children under the age of 16 considering gender reassignment are unlikely to be mature enough to give informed consent to be prescribed puberty blocking drugs.Tavistock and Portman NHS Foundation Trust, which ran NHS England’s only gender identity development service for children, had challenged a High Court ruling against the service by Keira Bell, a 24-year-old woman who began taking puberty blockers when she was 16, before later reverting to a female gender identity. This process is known as detransitioning. The Appeal Court judges ruled that it was established legal principle that “it was for clinicians rather than the court to decide on competence”.

Discussion of this case needs to make clear that Bell dropped any further challenge because of new NHS guidance that limited the prescription of GNrH analogues (puberty blockers) and the announcement of a review.

54. ‘..before later reverting to a female gender identity. This process is known as detransitioning’.

This is a deeply captured statement. People who detransition medically oen come to the conclusion that ‘gender identity’ is itself a flawed and harmful concept that doesn’t in reality exist at all. Many detransitioned people are available to attest to this but the BBC has resolutely failed to examine the issue with any focus. Many would simply not describe their detransition as reverting to a particular identity, and would find that description offensive.

Suggestion: ‘before leaving/dropping/reverting from her trans status/male identity and stopping medical treatment’ - but the BBC really needs to talk to detransitioned people about how they would describe it, and use their words.

55. Cass Review. The NHS announced in July 2022 that the Tavistock and Portman NHS Foundation Trust was to close aer it was criticised in an independent review, led by Dr Hilary Cass. The Independent Review of Gender Identity Services for Children and Young People (The Cass Review) was commissioned by NHS England and NHS Improvement in Autumn 2020. The interim report said the current model of care was leaving young people "at considerable risk" of poor mental health and distress, and having one clinic was not "a safe or viable long-term option". It said the service had “moved from a psychosocial and psychotherapeutic model to one that also prescribes medical interventions by way of hormone drugs’. It recommended setting up new regional centres.

This needs a complete update from April 10 2024 with the publication of the full review. It’s also much too wordy for the amount of information conveyed.

56. Conversion therapy tries to change or suppress someone's sexual orientation or stop them identifying as a different gender to their sex recorded at birth. It can include talking therapies and prayer, but more extreme forms can include exorcism, physical violence and food deprivation.

Delete ‘recorded at birth’ - it’s wordy, unnecessary and feeds into activist thinking.

For a comprehensive backgrounder this is remarkably short on the detail that the more ‘extreme forms’ listed are all already illegal acts. It also fails to inform that any evidence that ‘conversion therapy’ on the grounds of ‘gender identity’ is taking place in the UK is vanishingly rare. More importantly, it fails to explain that there is grave concern that talking therapies to help distressed patients could be criminalised by such a ban.

57. The government says it intends to bring forward legislation to ban all forms of conversion therapy in England and Wales, including practices aimed at transgender people. The ban would outlaw attempts to change

someone's sexuality or gender identity. The government had previously said transgender conversion therapy would not be included in the ban. It is not clear how the ban would affect religious practice or the kind of therapeutic support envisaged in the Cass Review as the appropriate medical approach for children and young people.

Again, the wording is predicated on the belief ‘gender identity’ is real and that everyone has one.

‘Therapeutic support’ should be briefly explained beyond ‘envisaged in the Cass Review’. The concern is that a ‘conversion therapy ban’ would render illegal every approach except automatic affirmation and medicalisation.

58. Sport. While there are a small number of elite trans athletes, the involvement of trans women in female categories has received increasing focus in recent years.

There are a considerably larger number of male athletes in grassroots female sport. Parkrun and football are huge areas of controversy. Allowing males into female categories also involves shower and change sharing: this needs a reference.

Suggestion: ‘The involvement of transgender males in female categories affects all women’s sport and has recently received much greater focus, as the number of males competing with or against females has risen’.

59. Trans women have to adhere to rules to compete in women’s categories in specific sports. This can include lowering their testosterone levels to a certain amount, for a set period of time, prior to competing. There are concerns, however, that athletes retain a biological advantage from going through male puberty that is not addressed by lowering testosterone.

Suggestion to remove activist phrasing: replace ‘trans women’ with ‘transgender males’ or ‘biological males’. Remove ‘there are concerns’ and replace with ‘there is evidence’. Write and link to BBC fact check (does not currently exist) explaining the skeletal, muscular, lung and haemoglobin advantages of being male.

60. The issue of trans competitors affects different sports to different degrees.

Suggestion: ‘The issue of biological males in female categories affects different sports to different degrees.’

61. Sports governing bodies have been drawing up their own policies, seeking to balance inclusion and fairness..

Activist framing. Allowing male competitors into female categories is an act of exclusion as much as inclusion. A female is excluded for every male that is included. Females are also more likely to be excluded from podiums, prizes and medals. Therefore it should not be described as ‘inclusion’. Suggestion: ‘seeking to maintain fairness’.

62. ..as well as the safety of competitors in contact sports. Several sports have tightened their rules aer previously allowing trans women to compete in women’s categories.

‘..aer previously allowing biological males to compete in women’s categories’

63. The International Olympic Committee (IOC) first permitted transgender women to take part in the female category of the Olympics in 2004, as long as they had undergone "appropriate surgery".

Irrelevant detail, and they should not be described as women.

64. Then, in 2015, the IOC stated athletes who had transitioned from male to female..

Nobody transitions from male to female. It is impossible. Suggestion: ‘the IOC said male athletes who adopt a female ‘identity’’

65. ..could compete in women's sport without requiring surgery, as long as they had declared their gender identity as female for at least four years, and kept their testosterone level below a certain level for at least 12 months.

Suggestion: ‘..as long as they had adopted a female identity for at least four years, and kept their testosterone level below 10 nmol/L for at least 12 months. This is approximately four times higher than the average female testosterone level at 0.5 to 2.4 nmol/L’.

66. A revised framework was issued after the Tokyo Olympics which said there should be no assumption that a transgender athlete automatically had an unfair advantage in female events. It said that the individual sports which come under its umbrella needed to set their own guidelines.

Very very common activist ‘mistake’: using ‘transgender’ when the word needed is ‘male’. (There is no problem with female transgender athletes so long as they are not taking testosterone or other enhancing substances).

67. The focus in athletics had been on testosterone levels, with most rules stating that transgender women had to lower and then maintain those levels in their body. However, in March 2023, World Athletics announced that trans women would no longer be allowed to compete in the female categories.

Repeated use of ‘trans women’ is

Inaccurate - they are not women of any kind. The Review team may need to examine how its own beliefs on this have been nudged by perpetual media bias

Activist language - when it’s a guiding principle of the BBC not to adopt activist language as its own

The BBC must start using ‘male’ or ‘biological male’.

68. Transgender cyclist Emily Bridges was due to compete in her first women's event in 2022 but was barred by cycling's world governing body. British Cycling suspended its transgender policy and in May 2023 said that transgender women could no longer compete in its elite female events. World Rugby has banned trans women from playing women’s rugby at elite level.

No reference needed to Emily Bridges, who is male. Suggestion: ‘In May 2023 British Cycling said biological males could no longer compete in its elite female events’.

69. Government advice and the curriculum. There has been considerable controversy about the appropriate approach for schools. The UK government says it will publish dra guidance for schools in England on issues around sex and gender. This could, for example, include policy on whether and when to inform parents of a pupil’s wish to change their gender identity. The Welsh government has also said it will publish guidance in the current academic year. Scotland and Northern Ireland have already published guidance.

‘Wish to change their gender identity’ is captured language. Suggestion: ‘express a wish to socially transition’. Section needs updating for developments in 2024.

70. In September 2020, the government updated the national curriculum for Relationships, Sex Education and Health in England. It is compulsory for schools to have classes about relationships at primary school, and relationships and sex education at secondary school. Here is the RSE curriculum and guidance published in 2020 to assist teachers in implementation: It includes this advice:

Ensuring content is appropriate “...We are aware that topics involving gender and biological sex can be complex and sensitive matters to navigate. You should not reinforce harmful stereotypes, for instance by suggesting that children might be a different gender based on their personality and interests or the clothes they prefer to wear. Resources used in teaching about this topic must always be age-appropriate and evidence based. Materials which suggest that non-conformity to gender stereotypes should be seen as synonymous with having a different gender identity should not be used and you should not work with external agencies or organisations that produce such material. While teachers should not suggest to a child that their non-compliance with gender stereotypes means that either their personality or their body is wrong and in need of changing, teachers should always seek to treat individual students with sympathy and support...”

This is fine.

71. Contributors. As the Editorial Guidelines make clear, we have to ensure a wide range of significant views are included in our output. This can be challenging as some contributors do not accept the legitimacy of views with which they disagree. This is sometimes framed as a conflict between free speech and hate speech.

This is bizarre. There is no reference to ‘truth’ and ‘facts’ here - which was deemed so important at the start of the guidance.

Suggestion: delete. Replace with: ‘A balance of views should be curated around the facts, and presenters and writers should be able to distinguish between opinion, and accurate descriptions of reality’.

72. We need to give appropriate time and space for contributors and the audience to engage with the complexity of the issues involved. This includes providing appropriate questioning of inaccurate factual assertions.

See above suggested wording.

73. Where possible we should include relevant voices speaking for themselves, rather than having others talk for them. This includes trans people, as well as those affected by the story, for example on single-sex refuges or women’s athletics.

The BBC Review team may start to see a pattern here of the extra mentions, the elevation and concern for trans voices, trans framing, trans rights. It speaks to the mindset of the BBC. There’s no need to say ‘this includes trans people’ as if to suggest their voices have been thin on the ground. The voices that have been excluded are those of women. (For example in the BBC coverage of the Cass Review, a trans-identified male was deployed almost every single broadcast hour to explain how medical transition had positively affected their life). For around a decade, trans personal journeys have made up the bulk of the BBC coverage of this issue. Suggestion: much better to say here ‘this includes women and detransitioned people’.

Further suggestion - add:

‘These issues are so controversial that our presenters can become targets when they are obliged to play Devil’s Advocate and present the ‘opposing’ opinion or explain certain facts. Having a good balance of contributors helps to eliminate this problem.’

74. We should consider the interests of contributors as part of our duty of care. We know from the Keira Bell court case and the interim Cass review that a high proportion of young people who identify as trans or non-binary have additional diagnoses, in particular autism and ADD/ADHD. They may also have issues with their mental health.

Striking absence here of any acknowledgement that women have suffered death and rape threats, job loss, blacklisting, financial repercussions, depression, and arrest because they spoke up on this issue.

Suggestion: ‘We also know that those who speak up for sex realism oen suffer serious personal repercussions and we need to respect their concerns and fears. We should not change the words they use and requests for anonymity should be given special consideration’.

77. Production teams. Output dealing with this subject, and interactions with potential contributors, can come under intense scrutiny on social media. The techniques set out above may also be helpful for staff in dealing with hostile or inappropriate posts. You can also direct people to BBC Action Line rather than deal with individuals direct. If you experience inappropriate pressure or abuse you should raise your concerns with your line manager.

This is fine but does not go far enough. Attention should be paid to internal campaigning. Suggestion: add ‘All our journalists are protected when they raise a concern. However sometimes colleagues can suffer inappropriate internal pressure from activists, which goes beyond helpful suggestions or ‘raising concern’. In these cases, please refer to your line manager with details.

‘You may also wish to discuss with your editors whether your byline should be attached to your article.’

78. Language. We should aim to make our own language clear and accessible and, where needed, clarify the language used by contributors. Careful and accurate use of language and appropriate attribution in our reporting are crucial. Some of the terms used, for example ‘cis-gender’ to identify a person who has the same sex and gender identity, are not familiar to many of our audience and may be considered offensive by some.

The word ‘cisgender’ is as offensive as t...y. If the Review team is offended by even the expurgated version of that word, it will understand. It must seriously consider placing the strongest possible warning over the use of c..gender.

79. The BBC News style guide has advice on reporting in this area, which was reviewed last year. It is included here for reference:

The reaffirmation of the News Style Guide renders almost pointless very large chunks of the December 2023 guidance that we’ve just read, as it simply reaffirms the activist language of self-identification.

80. gender/sex
Using appropriate language is an important part of how we portray people in our stories. Sexuality, race, ethnicity or disability should not be mentioned unless they are relevant to the subject matter. But when we do focus on one aspect of a person's character, we should ensure we do not define them by it.

The BBC should define ‘appropriate’ here with reference to its principle of ‘due accuracy’. This is where it can point out that although something may be true, it may not be relevant, and its inclusion may contribute to bias.

81. Gay/lesbian: Use gay as an adjective rather than a noun (eg: two gay men - but not "two gays"). It can apply to members of both sexes, but current preferred practice is to refer to "gay men and lesbians". For wider references, talk about LGBT people or the LGBT community (lesbian, gay bisexual, transgender). If this does not suffice, the preferred initialism is “LGBTQ”or“LGBTQ+” - the “Q” means questioning and/or queer, the “+” acknowledges not all people may feel represented by these initials. Where possible, however, initials should be avoided. The issues affecting lesbian, gay, bisexual and transgender people can be very different and the more specific we can be with our language, the better. If using LGBT+ or another formulation - for example in a quote – consider the likely audience of the story and whether the term needs explaining. Instead of “LGB”, for example, consider “lesbian, gay or bisexual”.

The BBC should consult the LGB Alliance for its opinion on this.

82. “Gender identity” means how people feel or present themselves, distinct from their biological sex or sexual orientation. We should be aware that the concept of a gender identity is contested by some.

Captured language. Suggested wording: ‘Some people believe that everyone has a gender identity and that this determines if they are male and female. This is a transgender advocate point of view. There is no evidence that everyone has a gender identity and we should not use language that implies this, but contributors must be allowed to express this view’.

83. Use sex to refer to a person’s physical development and gender to describe how they identify themselves. Sex is “recorded” or “observed” at birth. Use of “assigned at birth” should be attributed.

Suggestion: ‘Sex is never ‘assigned’, except in cases of DSDs, and the phrase should only appear in quotes. Sex is immutable and in most cases there is no need to include ‘recorded/observed at birth’.

Note: this is an excellent opportunity to explain to colleagues that confusion can arise because of the use of ‘gender’ to mean ‘sex’. Suggestion: ‘We know that ‘gender’ is oen used instead of ‘sex’ and this can be confusing. Make sure you always use ‘sex’ when you are referring to biological sex’.

84. Transgender, or trans, is an umbrella term for a person whose gender identity differs from their sex recorded at birth.

Captured language from an activist lexicon. Suggestion: ‘Transgender, or trans, is an umbrella term for a person who says they have a gender identity that differs from their sex’

85. A person born male who lives as a female, would typically be described as a “transgender woman” and would take the pronoun “she”. And vice versa.

Suggestion: a male person who adopts or seeks to adopt a female identity should be described as a ‘trans-identified male’, and vice versa. However if a quote includes the term ‘trans woman’ to mean male, or ‘trans man’ to mean female, we should not change it. If necessary, footnotes can be included to explain the terms accurately.’

86. We generally use the term and pronoun preferred by the person in question, unless there are editorial reasons not to do so.

This is the beating heart of the BBC’s adoption of self-identification of sex.

It is not the law, it is not likely to become the law, legislation on this has been rejected, it does not represent reality and it is not generally publicly accepted that male people can be female and vice versa. It is an activist point of view, and the adoption of trans pronouns is an activist or ally stance, as acknowledged by all organisations who encourage people to add pronouns to their email signatures or social media bios. This sentence is the main source of the BBC’s affirmative bias and probably ought to be dropped.

Suggestion: ‘There is no law against accurately describing a person’s sex, nor is it forbidden by Ofcom. However, once a person has been accurately identified as a male or female, man or woman, with a transgender identity - efforts can be made to avoid inaccurate pronoun use. In sports, crime and many policy areas, sex is always relevant and gender identity is not. Prioritise clarifying the sex of the person for the sake of public understanding. There may be no need to reference a person’s adopted ‘gender identity’ . See separate guidance on court proceedings.’

Suggestion: there is no guidance on court proceedings. Produce some and link it here. We have already made a submission on accurate language around court cases.

87. If that’s unknown – apply that which fits with the way the person lives publicly.

This is an activist framing. Suggestion: drop it completely.

88. If reporting on someone who is making their transition public, it may be appropriate to refer to their previous identity to help audience understanding. It may also be appropriate to refer to a transition to make sense of some stories.

See suggested wording above, and drop this.

89. We should not include “intersex” or people with differences of sexual development as part of this group.

This is fine.

90. Take care with the term “sex change”, unless referring specifically to the surgical element of a transition. It should not be used as a general description for a transgender person.

No one changes sex, ever, and no one ever has. Suggestion: ‘Do not use the term ‘sex change’. No one has ever changed sex’.

91. Queer is an adjective used by some people who find more specific terms, such as ‘lesbian’, ‘gay’, ‘bisexual’, ‘trans’ and ‘LGBT’, too limiting to describe their romantic or sexual orientation, gender identity and/or gender expression. Originally a pejorative term, more recently “queer” has been reclaimed by some in the LGBTQ+ community, to describe themselves. However, it is not universally accepted and has the potential to cause offence. Be careful when using the term. We should not apply the term to an individual or group unless they have already adopted it.

The warning against ‘queer’ should be much stronger. Many gay people find it disgustingly offensive. Please consult LGB Alliance. Additional suggestion: ‘The acronyms LGBT and LGBTQ+ should not be used when the story is only about gay and lesbian people’.

92. Non-binary is an adjective used to describe a person who does not identify as only male or only female, or who may identify as both.

Suggestions: ‘Non-binary is an adjective used to describe a person who says they do not identify as only male or only female.’ Delete the rest.

93. It is increasingly common for non-binary people to use the singular pronoun ‘they. We should not ascribe a gender to someone non-binary.

But we may need to explain any use of “they” as a singular pronoun to the audience for clarity. This could be without explicitly mentioning their gender, however (eg: [First name surname] - who uses "they" and "them" as personal pronouns - is...).

Suggestion: ‘It is increasingly common for people who say they’re non binary to request the pronoun ‘they’. Once the sex of the person has been made clear, where relevant, we can avoid activist language by working around pronouns to use names or other descriptors. We may need to explain why other people are using ‘they’.’

Note here: ‘This could be without explicitly mentioning their gender’ - is another example of muddle in the guidance. Presumably by gender the BBC means sex. Who knows. Delete it.

94. “Sexual preference” suggests a person chooses to be gay or bisexual. For the same reason, phrases such as “alternative lifestyle” should also be avoided where possible. Instead of “sexual preference” and “admits being gay”, consider “sexual orientation” and “is gay”.

Consult LGB Alliance but this seems fine.

Many of the BBC’s problems with bias stem directly from the News Style Guide which this Guidance does nothing to address. We would also strongly suggest that the BBC adds relevant links to the Gender Recognition Act 2004, the Equality Act 2010 and the Protection from Harassment Act 1997.