The so-called ‘Independent Review of Data, Statistics and Research on Sex and Gender’ led by Professor Alice Sullivan is nothing more than a thinly veiled attempt to push a gender-critical agenda under the guise of academic neutrality. Framed as an objective evaluation of how data on sex and gender should be collected, the review instead advances a rigid, binary model of ‘biological sex’ that is both scientifically flawed and legally dubious.
Professor Alice Sullivan’s involvement with the anti-trans hate group Sex Matters – where she sits on the advisory group alongside a cohort of transphobic anti-trans activists – raises fundamental concerns about the credibility of this review. Sex Matters is an organisation that has actively campaigned to roll back trans rights in law, policy, and public life. That someone with such overt ideological bias was given the authority to shape government recommendations on sex and gender data collection is an affront to the principles of impartiality and evidence-based policymaking.
The Sullivan Review’s core premise – that legal recognition of gender identity should be deprioritised in favour of an unchangeable ‘biological sex’ – is not just ethically indefensible, but it is also legally questionable. The UK’s Equality Act 2010 (EqA2010) explicitly protects gender reassignment as a characteristic, meaning trans people have the right to be recognised and accommodated in law. The Gender Recognition Act 2004 (GRA2004) further provides legal recognition of a person’s affirmed gender, meaning any attempts to treat trans women as ‘male’ or trans men as ‘female’ in official records would directly conflict with statutory rights.
Moreover, the review’s recommendations run counter to the Human Rights Act 1998 (HRA1998), particularly in relation to the right to privacy under Article 8. Trans people have the right to live in accordance with their gender identity without undue interference by the state. A policy framework that mandates the recording of ‘biological sex’ above gender identity – especially in medical, workplace, and governmental records – would be a clear violation of this right.
The Sullivan Review’s insistence on centring ‘biological sex’ in data collection ignores decades of medical and sociological research that demonstrates the complexity of sex, gender, and health outcomes. It also fails to account for non-binary and intersex people, whose very existence undermines the binary model the review clings to.
For transgender people, the implications are far more severe. If the government were to adopt the recommendations in this report, it would actively endanger trans people’s access to healthcare, legal recognition, and protection from discrimination. Reducing individuals to their assigned sex at birth in official data would lead to systemic misrepresentation, improper medical treatment, and further barriers to legal equality.
While the Sullivan Review is a direct attack on trans people, its implications extend far beyond the trans community. The idea that a person’s ‘biological sex’ should be visually recorded based purely on observation poses significant risks for cisgender individuals as well. Women with polycystic ovary syndrome (PCOS), intersex people, men with gynecomastia, and those who simply do not conform to gendered expectations could find themselves misclassified or subjected to invasive scrutiny.
In medical settings, for example, a cis woman with higher testosterone levels or a cis man with atypical secondary sex characteristics could be flagged incorrectly, leading to inappropriate or delayed care. In employment or legal contexts, individuals who do not fit stereotypical notions of ‘male’ or ‘female’ could be forced to justify their identity based on arbitrary, outdated criteria.
A policy that reduces people to an ‘observed’ sex classification is not just unscientific – it is profoundly harmful to anyone who does not fit into narrow, regressive definitions of male and female. This will effect cisgender individuals more than transgender.
The Sullivan Review is not an objective or neutral document – it is a partisan, ideologically motivated report that reflects the biases of its lead author and her affiliations. Rather than implementing the review, the Government must reject it, and stop this attempt to smuggle gender-critical extremism into official policy. Instead, data collection should reflect reality: that gender identity matters, that trans people’s rights are protected in law, and that medical, legal, and social systems must accommodate the full diversity of human experience.
This review is not just flawed; it is an outright attack on trans people’s rights. It must be called out for what it is: bad science, bad ethics, and bad policy. The government must not allow this to shape future decisions on sex and gender data collection. To do so would not only be regressive, but it would put the UK in direct violation of its own equality and human rights framework.