Consultation Submissions
Here we publish our submissions to Scottish and UK Government consultations, as well as any other consultations we feel it’s important for our voices to be heard.
EHRC
Code of practice for services, public functions and associations 2025
Remit: To provide feedback on the clarity of the update to the Code of Practice following the Supreme Court judgment that sex has a biological meaning in the Equality Act.
Date submitted: 30 June 2025
Submission: EHRC Code of Practice 2025
Police Scotland
Review of Sex & Gender Data Recording
Remit: To provide feedback on the terminology and recording practices Police Scotland proposes to collect data on sex and gender.
Date submitted: 22 June 2025
Submission: PDF
Scottish Parliament: Equalities, Human Rights and Civil Justice Committee
The operation of the Public Sector Equality Duty in Scotland
Remit: To give views on whether the proposed reforms will improve the delivery of the general public sector duty.
Date submitted: 28 February 2025
Submission: PDF
United Nations
Call for input to the addendum to the report of the Special Rapporteur on violence against women and girls to the HRC on the concept of consent in relation to violence against women and girls
Remit: To inform the Special Rapporteur’s addendum to her thematic report to the Human Rights Council at its 59th session in June 2025.
Date submitted: 30 January 2025
Submission: PDF
Scottish Government
Proposals to amend the legislation on religious observance and religious education in schools
Remit: To provide views on proposed changes to the current legislation on religious observance (RO) and religious education in schools. The proposed changes are thought to support the alignment of legislation with the United Nations Convention on the Rights of the Child by requiring that children and young people’s views are taken into account in relation to their participation in RO. The consultation document has more information and the questions asked are here.
Date submitted: 26 January 2025
Submission: PDF
Glasgow City Council
Public toilet provision consultation
Remit: The Council has adopted a ‘feminist town planning’ strategy in order to create public spaces – such as public toilets – that are safe and inclusive for women, and accessible for all members of the community. It is fundamental that women are central to all aspects of planning, public realm design, policy development and budgets. We are conducting a survey to assess the current state of public toilet facilities and identify areas for improvement. Your feedback is valuable and will help shape better services.
Date submitted: 22 January 2025
Submission: PDF
United Nations
List of Issues, International Covenant on Economic, Social and Cultural Rights (ICESCR), UK review
Remit: to provide a response to the UN List of Issues for the seventh periodic review of the covenant in the UK.
Date submitted: 13 January 2025
Submission: PDF
NHS Grampian
Equality Outcomes 2025-2029 (proposed)
Remit: to provide feedback on the proposed Equality Outcomes for 2025-2029 under the Public Sector Equality Duty in order to shape a more inclusive and equitable future for NHS Grampian workforce and healthcare. It will also help promote inclusive decision making, transparency, accountability and legal compliance on the Equality Act 2010.
Date submitted: 10 January 2025
Submission: PDF
EHRC
Code of practice for services, public functions and associations
Remit: To provide feedback on the completeness, accuracy and ease of understanding of the revised Code of Practice. The Code explains how the Equality Act 2010 works in relation to discrimination in associations and discrimination, harassment and victimisation in services and public functions and applies the legal concepts in the Act to everyday situations
Date submitted: 03 January 2025
Submission: PDF
Scottish Parliament: Private Members Bill
Proposed Prostitution (Offences and Support) (Scotland) Bill
Remit: To provide views on Ash Regan’s proposal for a Bill to create an offence of paying for sexual services, to repeal the offence of soliciting or importuning by prostitutes, to repeal previous convictions for soliciting or importuning by prostitutes and to support those in or exiting prostitution.
Date submitted: 10 September 2024
Submission: PDF
UK Government: Equality Hub, Minister for Women and Equalities
Incorrect guidance on single-sex spaces and gender self identification
Remit: Examples of policy or guidance in which public bodies – or organisations that advise public and private organisations – wrongly suggest that people have a legal right to access single-sex spaces and services according to their self-identified gender.
Date submitted: 25 June 2024
Submission: PDF
Outcome: Government response, EHRC response
Scottish Parliament: Standards, Procedure and Public Appointments Committee
Scottish Elections (Representation and Reform) Bill
Supplementary evidence submitted in response to Engender urging the Committee to adopt a gender quota for election candidates similar to the Senedd Cymru (Electoral Candidate Lists) Bill.
Date submitted: 12 June 2024
Submission: PDF
Scottish Government: Ending conversion practices in Scotland
Remit: To give views on the Government’s proposals for criminal and civil legislation to end conversion practices in Scotland.
Date submitted: 02 April 2024
Submission: PDF
UN Special Rapporteur on violence against women and girls
Call for inputs – country visit to the United Kingdom of Great Britain and Northern Ireland
Remit: In preparation for the visit, the Special Rapporteur invites all interested individuals and organisations, including civil society organisations, women’s rights activists, and academics to provide inputs on:
- Issues related to violence against all women and girls, based on intersecting grounds and including its different manifestations;
- Information on groups of women and girls particularly at risk of being exposed to gender based violence;
- Policies and legislation in place or being considered with a view to preventing and combating violence against women and girls.
Date submitted: 10 February 2024
Submission: PDF
Convention on the Elimination of all forms of Discrimination Against Women (CEDAW) Committee
Remit: To give views on issues and implications for women on the self-identification of sex and gender identity as a legal right.
Date submitted: 31 January 2024
Submission: PDF
Scottish Parliament: Equalities, Human Rights and Civil Justice Committee
Gender Representation on Public Boards (Amendment) (Scotland) Bill
Remit: To give views on the merits or otherwise of the Scottish Government’s specific proposal to remove the definition of “woman” in section 2 the Gender Representation on Public Boards (Scotland) Act 2018. This is the definition that the court ruled was unlawful in our judicial review win from February 2022 and issued an order for it to be removed from the Act.
Date submitted: 17 January 2024
Submission: PDF
All submissions published by the Committee on 30 January 2024
Scottish Parliament: Criminal Justice Committee
Scottish Prison Service policy on the management of transgender prisoners
Remit: Submit views on the policy recently updated by SPS on the management of transgender prisoners. The Criminal Justice Committee is meeting on 11th January to consider the policy.
Date submitted: 04 January 2024
Submission: PDF
Scottish Government: Delivery of relationships, sexual health and parenthood (RSHP) education in Scottish schools – draft statutory guidance
Remit: This consultation seeks views on draft statutory guidance on the delivery of relationships, sexual health and parenthood education in Scottish schools. Work to embed lesbian, gay, bisexual and transgender (LGBT) inclusive education across the curriculum and to review the delivery of Personal and Social Education (PSE) both recommended the existing guidance, dating from 2014, be updated.
Date submitted: 21 November 2023
Submission: PDF
Update 28 March 2025: All consultation responses have now been published by the Scottish Government; ours is here.
Scottish Government: A Human Rights Bill for Scotland
Remit: Embedding international human rights in Scotland will further emphasise the importance of all people being treated with dignity, and ensure that human rights play an even more central role in our strategies, policies and decision-making processes across all areas of government and the wider public sector. This consultation on the proposals for a Human Rights Bill to be introduced within this session of the Scottish Parliament seeks the views of everyone on that vision.
Date submitted: 05 October 2023
Submission: PDF
Submission published by the Scottish Government on 24 January 2024.
Scottish Government: Reforming the criminal law to address misogyny
Remit: Respond to the Misogyny Working Group’s final report which recommends the introduction of:
- A new offence of public misogynistic harassment of women;
- A new offence of issuing threats of, or invoking, rape or sexual assault or disfigurement of women and girls online and offline;
- A new statutory aggravation to relate to misogynistic behaviour where a crime such as assault, criminal damage/vandalism or threatening or abusive behaviour is aggravated by misogyny; and
- A new offence of stirring up hatred against women
Date submitted: 23 June 2023
Submission: PDF
Outcome: Published consultation responses, Consultation analysis
Government response: The Scottish Government has decided not to proceed with this Bill in this parliamentary session. They will lay an SSI by September 2025 to add the protected characteristic of sex to the Hate Crime and Public Order (Scotland) Act 2021.
Scottish Parliament: Citizen Participation and Public Petitions Committee
PE2001: Withdraw the ‘Supporting transgender young people in schools’ guidance from Scottish schools
Petition. Calling on the Scottish Parliament to urge the Scottish Government to withdraw the ‘Supporting transgender young people in schools: guidance for Scottish schools’ resource, and await the outcome of the Cass Review before developing a new resource.
Date submitted: 13 June 2023
Submission: PDF
United Nations CEDAW: Equal and inclusive representation of women in decision-making systems
Remit: On 22 February 2023 the Committee on the Elimination of Discrimination against Women will hold a half-day of general discussion on “Equal and inclusive representation of women in decision-making systems”. The Committee invited written submissions on the theme of the general discussion.
Date submitted: 17 February 2023
Submission: PDF
Scottish Government: Equality Evidence Strategy 2023-25
Remit: Seeking views to shape the draft plan to improve and strengthen Scotland’s equality evidence base. The development of Scotland’s next Equality Evidence Strategy, covering the years 2023 to 2025 will enable policy makers to develop sound and inclusive policies to improve service delivery and outcomes for people in Scotland.
Date submitted: 07 October 2022
Submission: PDF
Scottish Parliament: Witchcraft Convictions (Pardons) (Scotland) Bill
Remit: A proposed Member’s Bill seeking views on revisiting past injustices and pardon all those convicted under the Witchcraft Act 1563.
Date submitted: 15 September 2022
Submission: PDF
Scottish Government: Strategic Review of Funding and Commissioning of Violence Against Women and Girls Services: Call for Views
Remit: To inform the development of a new funding model that will ensure high quality, accessible specialist services across Scotland for those experiencing any form of violence against women and girls.
Date submitted: 15 August 2022
Submission: PDF
Additional information:
– 01 August 2022 Letter to review group requesting consultation withdrawn and reissued due to the unlawful redefinition of “woman”.
– 06 August 2022 Letter in response to the minutes of review group meeting.
– 12 August 2022 Email to Scottish Ministers
– 06 February 2023 Online meeting with the review group
– 06 June 2023 Violence Against Women and Girls – Independent Strategic Review of Funding and Commissioning of Services: report
Scottish Parliament: Constitution, Europe, External Affairs and Culture Committee
Inquiry into Scotland’s Census
Remit: To examine the outcome of the Census, focusing on the quality of the data collected, identifying any gaps and how they could be filled.
Date submitted: 12 August 2022
Submission: PDF
Scottish Parliament: Equalities, Human Rights and Civil Justice Committee
Gender Recognition Reform (Scotland) Bill: Call for Views
Remit: Provide comment on the Bill to help inform the scrutiny of the Committee.
Date submitted: 16 May 2022
Submission: PDF
Additional information:
– 27 May 2022 Joint letter to the committee re Scottish Government’s handling of the Bill development.
– 31 May 2022 Susan Smith, FWS giving evidence to the Equalities, Human Rights and Civil Justice Committee (Official Report and Video).
– 30 August 2022 Supplementary evidence re the impact of our second judicial review on Gender Representation on Public Boards (Scotland) Act.
– 30 August 2022: Supplementary evidence re the Cabinet Secretary’s comments on single-sex exceptions in the Equality Act.
Scottish Government
Public Sector Equality Duty review
Remit: The Scottish Ministers are seeking views on specific and detailed proposals within the Scottish Specific Duties which are aimed at improving the current regime. Further and general views from stakeholders are also invited.
Date submitted: 11 April 2022
Submission: PDF
United Nations Human Rights Council
Universal Periodic Review
Remit: The Universal Periodic Review (UPR) is a unique process which involves a review of the human rights records of all UN Member States. The UPR is a State-driven process, under the auspices of the Human Rights Council, which provides the opportunity for each State to declare what actions they have taken to improve the human rights situations in their countries and to fulfil their human rights obligations. The UK will be reviewed for its fourth cycle in November 2022. All relevant stakeholders can submit written information which is considered during the review.
Date submitted: 29 March 2022
Submission: PDF
UK Government
Banning Conversion Therapy
Remit: Gathering views on aspects of the policy including: targeting physical acts conducted in the name of conversion therapy; targeting talking conversion therapy with a new criminal offence; and producing a package of holistic measures, such as Conversion Therapy Protection Orders, new support for victims, restricting promotion, removing profit streams, and strengthening the case for disqualification from holding a senior role in a charity.
In some areas the questions are specific, to gather reactions to the preferred approach, while in others the questions are more open, to gather stakeholder views and further evidence.
Date submitted: 04 February 2022
Submission: PDF
Financial Conduct Authority
Remit: The FCA invited views on their consultation paper on diversity and inclusion on company boards and executive committees. This included setting a target for at least 40% of boards to be women (including individuals self-identifying as women).
Date submitted: 20 October 2021
Submission: PDF
Equality and Human Rights Commission
Remit: The EHRC invited views on their draft strategic plan for 2022-25.
Date submitted: 29 September 2021
Submission: PDF
Scottish Government
Views on ‘Accurately record the sex of people charged or convicted of rape or attempted rape’ petition
Remit: The Equalities, Human Rights and Civil Justice Committee invited views on a public petition, PE1876: Accurately record the sex of people charged or convicted of rape or attempted rape
Date submitted: 28 September 2021
Submission: PDF
Scottish Government
Views on the ‘End Conversion Therapy’ petition
Remit: The Equalities, Human Rights and Civil Justice Committee invited views on a public petition, PE1817: End Conversion Therapy.
Date submitted: 12 August 2021
Submission: PDF
Additional information:
– 14 March 2022 Our letter to the Committee published.
United Nations Commission on the Status of Women
Remit: Communications (complaints/appeals/petitions) to the Commission on the Status of Women containing information relating to alleged violations of human rights that affect the status of women in any country in the world. The Commission on the Status of Women considers such communications as part of its annual programme of work in order to identify emerging trends and patterns of injustice and discriminatory practices against women for purposes of policy formulation and development of strategies for the promotion of gender equality.
Date submitted: 01 August 2021
Submission: Our response covered the Gender Representation on Public Boards Act, All-Women Shortlists, Census, Hate Crime and Public Order Act, Prisons, and the Genuine Occupation Requirement.
Submission: PDF
Also published as stand alone chapters, starting here.
Working Group on Misogyny and Criminal Justice in Scotland
Remit: There is no agreed definition of misogyny in Scotland currently. The Working Group have agreed a working definition to help in identifying misogynistic behaviours – this is deliberately not a legal definition and is as follows:
‘Misogyny is a way of thinking that upholds the primary status of men and a sense of male entitlement, while subordinating women and limiting their power and freedom. Conduct based on this thinking can include a range of abusive and controlling behaviours including harassment and bullying. Misogyny can be conscious or unconscious, and men and women both can be socialised to accept it.’
Written Evidence Questions:
1. Which conduct do you consider to be covered by the term misogynistic behaviours?
2. Do you know of any Scottish laws that currently address misogynistic behaviours?
3. Do the current laws adequately protect women in Scotland from misogynistic behaviours?
4. Are there any gaps in the law in Scotland regarding misogynistic behaviours?
5. Do you think there should be a stand – alone offence to cover misogynistic behaviour in public spaces including the street, around schools, on public transport, online etc.?
6. Do you think that the characteristic of ‘sex’ should be added to hate crime legislation in Scotland?
7. Do you think that there should be an offence of stirring up of sexual hatred added to hate crime legislation in Scotland?
8. What non-legal measures are you aware of that have attempted to address misogynistic behaviours within Scottish society?
9. How effective, in your view, have these non-legal measures been in addressing these behaviours?
10. Should any of these non-legal measures be made mandatory?
Date submitted: 30 July 2021
Submission: PDF
UK Government
Toilet provision for men and women
Date submitted: 25 February 2021
Submission: PDF
Scottish Government
Hate Crime and Public Order (Scotland) Bill
Date submitted: 22 February 2021
Submission: PDF
Scottish Government
Sex and Gender in Data Working Group: Feedback on Draft Guidance
Date submitted: 12 February 2021
Submission: PDF
Additional information: Also a blog post
UK Government
Law Commission: Hate Crime
Date submitted: 24 December 2021
Submission: PDF
Scottish Government
Challenging Men’s Demand for Prostitution
Date submitted: 10 December 2020
Submission: PDF
Parliament of Canada
Federal Bill C-6 Conversion Therapy
Date submitted: 06 December 2020
Submission: PDF
Scottish Government
United Nations Convention on the Rights of the Child (Incorporation) (Scotland) Bill
Date submitted: 16 October 2020
Submission: PDF
Scottish Government
Post-legislative Scrutiny: The Lobbying (Scotland) Act 2016
Date submitted: 14 August 2020
Submission: PDF
Scottish Government: Justice Committee
Hate Crime and Public Order (Scotland) Bill: Call for Views
Date submitted: 19 July 2020
Submission: PDF
Additional information:
– 20 November 2020 Supplementary Evidence
– 24 November 2020 Susan Smith, FWS giving evidence to the Justice Committee (Official Report and Video)
– 30 November 2020 Supplementary Evidence
– 16 February 2021 Supplementary Evidence
– 22 February 2021 Freedom of Expression Amendments (Remit): Submission
Scottish Government
Forensic Medical Services (Victims of Sexual Offences) (Scotland) Bill
Date submitted: 26 June 2020 Letter to Health and Sport Committee
Additional information:
– Several blog posts
– 10 December 2020 Stage 3 Debate and Vote (Official Report and Video)
Scottish Government
Gender Recognition Reform (Scotland) Bill: A Consultation
Date submitted: 17 March 2020
Submission: PDF
Additional information: Also a blog post
Scottish Human Rights Commission
Scotland’s second National Action Plan for Human Rights (SNAP2)
Date submitted: 16 December 2019
Submission: PDF
National Advisory Council on Women and Girls
September 2019 Spotlight on Sport
Date submitted: 24 September 2019
Submission: PDF
Scottish Rugby
Transgender Policy: Non-Binary Players
Date submitted: 31 August 2019
Submission: PDF
Scottish Government: Equalities and Human Rights Committee
Draft Budget Scrutiny 2020-21: Call for Views
Date submitted: 23 August 2019
Submission: PDF
Additional information:
– 26 September 2019 Susan Smith, FWS giving evidence to the Equalities and Human Rights Committee (Official Report and Video)
– 26 September 2019 Supplementary Evidence
Scottish Government
Consultation on Implementation of the Gender Representation on Public Boards (Scotland) Act 2018
Date submitted: 04 August 2019
Submission: PDF
Scottish Government
Consultation on Scottish Hate Crime Legislation
Date submitted: 24 February 2019
Submission: PDF
Scottish Government: Culture, Tourism, Europe and External Affairs Committee
Census (Amendment) (Scotland) Bill: Call for Views
Date submitted: 23 November 2018
Submission: PDF
Additional information: 06 December 2018 Susan Smith, FWS giving evidence to the CTEEA Committee (Official Report and Video)