The EHRC says it exists to uphold dignity, fairness, and equality for all protected groups. But the internal emails and submissions we’ve now analysed tell a different story — one where trans people are routinely misgendered, dehumanised, and portrayed as threats, and the Commission never once speaks up to stop it.
We’ve gone line by line through the FOI disclosure from the EHRC’s correspondence with Sex Matters and Transgender Trend. What we found is systematic and deliberate framing of trans people — especially trans women — as deceptive, unsafe, and unfit to participate in public life.
And the worst part? The EHRC didn’t just receive these statements. It listened. It circulated them internally. It used them to inform guidance. It never challenged a single word.
Systematic Misgendering and Dehumanising Language
Let’s start with the basics. Trans women in these documents are never referred to as women. Instead, over and over again, we’re reduced to:
- “trans-identifying males”
- “men with certificates”
- “male-bodied people”
This isn’t accidental. These phrases are designed to erase legal recognition under the Gender Recognition Act and replace it with biological essentialism. They are rhetorical weapons dressed up as legal nuance.
Here are just a few examples from the FOI:
“Being a trans-identifying heterosexual male and being a lesbian are two quite separate material realities.”
— Sex Matters submission, Page 19
“A customer who is a trans-identified male.”
— Page 8
“Men use the women’s toilets… They haven’t been designated as gender neutral.”
— Page 8
“A boy remains a boy and a girl remains a girl.”
— Schools guidance commentary, Page 6
Even when discussing children, the language is rigid and dehumanising. Pronouns and affirmed identities are refused entirely. One submission says:
“A school should not pretend that a girl is a boy or that a boy is a girl.”
— Page 6
The word “pretend” is doing a lot of damage here.
Framing Us as a Danger — In Every Sphere
The FOI shows a consistent pattern: wherever trans people exist, we’re framed as a threat.
In schools, we’re a safeguarding risk. In Girl Guides, we’re “inappropriate” around girls. In prisons, our very presence is “unjust and absurd”. In offices, our colleagues claim to feel “unsafe” because of our identities or allies.
Let’s look at what was said — and what the EHRC let pass without objection.
In Schools
“A school must accurately recognise every child’s sex in order to carry out its duty of care.”
“No meaningful social transition is lawfully possible in schools.”
— Page 6
Translation? Affirming a trans child’s identity is framed as dangerous or unlawful.
In Youth Organisations
“This leads to Girl Guides putting men and boys into inappropriate situations with girls…”
— Page 14
Again, trans girls and women are reduced to “men and boys” and presented as a threat, with no evidence, no context, just bigotry repackaged as safeguarding.
In Law and Policy
“The result of a s.9(1) GRA reading… is that the class of ‘women’ includes people whose bodies are male… This produces unjust, absurd and anomalous results.”
— Page 3, legal briefing
Even where trans people have a full Gender Recognition Certificate, their legal gender is dismissed as an “absurdity”.
Language as a Tool of Erasure
All of this — the misgendering, the fearmongering, the endless invocation of “safety” — builds a clear narrative: that trans people, simply by existing, are a danger to women, children, workplaces, and society.
This is not just a series of offensive phrases. It is a framework designed to make our exclusion seem justified — even inevitable.
And yet in all of this correspondence, over years of engagement with these lobbying groups, the EHRC never once challenged this narrative.
Regulatory Silence is Complicity
The EHRC is supposed to be the body that protects people like us. It is legally bound to enforce the Equality Act 2010 and uphold rights under the Human Rights Act. But what these documents show is that it listened to anti-trans groups who framed us as predators, liars, and risks — and it said nothing.
Worse, it used that language in its own guidance. It adopted those framings in sport, in schools, in single-sex services. It gave private meetings to the people spreading this narrative and refused the same access to trans-led organisations.
We Have the Receipts
This isn’t just theory. It’s written in EHRC’s inbox.
This is how discrimination gets institutionalised: not with slurs, but with respectable language and polite emails full of “concern”.
It’s time to call this what it is: not consultation, not policy development, but complicity.