Two important organisations providing vital support for trans people have called for the Equality and Human Rights Commission (EHRC) to have its accreditation reconsidered. They describe the EHRC as an “activist organisation promoting gender critical ideology” that has “actively opposed any progress with human rights” and gives preferential treatment to anti-trans groups. These submissions are now public and showcase a dark but unsurprising devolution of an institution that in our opinion is not fit for purpose.
The first of the groups is Trans Exile Network (TEN), a mutual support network and information hub supporting trans, intersex and nonbinary people inside and outside of the UK. Their founder Dr. Victoria McCloud, a trailblazing lawyer and former Judge, is also challenging the UK following the highly controversial Supreme Court decision in the For Women Scotland case by filing with the European Court of Human Rights, represented by Trans Legal Clinic.
Alongside TEN in this submission is The Lemkin Institute for Genocide Prevention (LIGP). Last year, the Lemkin Institute issued a Red Flag Alert for the UK over the increasingly anti-trans developments in courts and government.
Together they revealed in a press statement this morning that on 6th January 2026 they made an official submission and later supplementary on 24th February 2026 to the Global Alliance of National Human Rights Institutions (GANHRI) and its Sub-Committee on Accreditation (SCA) regarding the EHRC’s A Grade rating being insufficient.
This is after submissions in October 2025 by TransActual, Amnesty International UK and Trans+ Solidarity Alliance requesting a special review, and a previous special review in 2024 that took place after the SCA had “serious concerns” regarding EHRC complying with Paris Principles the year before.
The cover letter attached to the first submission best sums up their argument succinctly in two quotes:
“The UK government and the EHRC have either actively opposed any progress aligned with civilised norms of respect for human rights, or have by wilful neglect allowed the UK’s NHRI (the EHRC) to become politically captured by a contested ideology (Gender Critical Ideology)”
And:
“It is the considered view of TEN and LIGP that the EHRC must not be allowed to continue in its present course as an organisation with the imprimatur of GANHRI and the SCA in any form. It has become an activist organisation promoting contested Gender Critical Ideology.”
The cover letter with the submission explains how EHRC chose to intervene in the April 2025 Supreme Court Case as a party to call for trans exclusion, and how since the ruling the EHRC have misrepresented the judgement to support their moves towards this goal. Similar argument has been raised by The Good Law Project (GLP).
The submission itself details the exact ways TEN and Lemkin see the EHRC failing in its duties to uphold the standards of GANHRI and the Paris Principles that the EHRC is subject to. Some of its arguments are here in brief.
Their submission claims the EHRC’s stance on Legal Gender Recognition is not up to required international standards. They reference focus on “biological sex” in the EHRC as well as the blocking of the Gender Recognition Reform Bill in Parliament which cited the EHRC’s concerns as a reason while the UN calls policy on self-determination an “urgent duty”.
Similarly the submission claims EHRC stance on conversion practices also fails international standards by advocating for the proposed conversion ban to exclude trans people, meanwhile multiple countries have successfully banned conversion practices for both orientation and gender identity in line with direct calls from the council of Europe.
The EHRC’s stance on data processing and protection are also under fire for both their lack of response to the Sullivan Report. A review whose recommendations raised concerns regarding trans people’s Right to Privacy as well as supporting a “biological sex” interpretation yet again in upcoming legislation on Hate Crime in Scotland.
The focus on definition of sex is part of what they argue is an adoption of Gender Critical Ideology. This is backed up by Kemi Badenoch’s admission that the puberty blockers ban required having gender critical people in government and equalities “holding the positions that mattered most”.
They also argue the EHRC gives “preferential treatment” to Sex Matters, evidenced by FOIs broken down by Trans Advocacy and Complaint Collective(TACC). Sex Matters are notorious for transphobia and currently in an ongoing case with the Charity Commission over its attempts to create a map tracking trans athletes in the UK.
The supplemental is an update to a point brought up in the initial submission, that the EHRC’s definition of sex following the Supreme Court ruling is being seen as a mandate for “blanket exclusion” of trans women from women’s prisons. This is because the EHRC have decided to intervene in a second case supporting For Women Scotland who are now arguing for that exact change in Scottish prisons which currently operate on a case by case basis.
We’ve reached out to the EHRC for comment and will update this article with if we receive one. TEN and Lemkin have said in the press release they will be issuing no further public comment at this time but will wait to assist GANHRI.
It is undeniable that the EHRC is facing more and more scrutiny from organisations as they continue down this path with what appears to be a disregard for the human rights they are designed to protect. The question is now if the SCA will recognise this worsening for what it is, which in our opinion is, again, that the EHRC is not fit for purpose.
