UK research and trans inclusion threatened by Sullivan Review recommendations
Published: 3 February 2026
A UK Government-commissioned review's recommendations on research ethics and recording sex and gender data could undermine the quality of public institutions’ research, erode academic freedom, and threaten the rights of trans and gender diverse people if widely adopted, researchers have warned.
A UK Government-commissioned review's recommendations on research ethics and recording sex and gender data could undermine the quality of public institutions’ research, erode academic freedom, and threaten the rights of trans and gender diverse people if widely adopted, researchers have warned.
The ‘Independent review of data, statistics and research on sex and gender’, known as the Sullivan Review, was published across two reports in March and July last year. The Review recommended that all data and statistics on sex and gender should use and adhere to a single, binary model of what it calls ‘biological’ sex.
Today (Tuesday 3 February), researchers from the University of Glasgow have published the first peer-reviewed academic response to the Sullivan Review.
In the paper, Dr Jay Todd and Professor Felicity Callard argue that the Review implicitly promotes the systematic exclusion and erasure of trans and gender diverse people from research and data‑collection protocols across public bodies, including government, universities, the NHS, and research organisations. They argue that the Review wrongly portrays trans and gender diverse people’s self‑determination of sex and gender as incompatible with scientific truth and legitimacy.
The researchers argue that full implementation of the Review’s recommendations could lead to poorer research quality and inappropriate policy decisions. They highlight that the Review’s recommends that universities consider ‘paring back the scope and power of ethics committees’ in various ways, removing ethical oversight from some university-based research, and arguing that Equality, Diversity and Inclusion departments should not issue guidance on data collection.
They warn that compulsory attribution of ‘birth sex’ in research and administrative settings contravenes researchers’ academic freedom and their obligation to prioritise participant rights and autonomy.
They say that the recommendations could have consequences for the conduct of clinical research and the quality of research outcomes by making it impossible to properly account for people whose sex or gender does not conform to a binary definition of sex or align with the sex they were assigned at birth. They argue that the Review’s recommendation that descriptions of datasets and groups of people should not acknowledge sex or gender beyond a binary established at birth further entrenches its focus on trans exclusion.
Dr Todd, of the University of Glasgow’s School of Geographical & Earth Sciences, is the paper’s corresponding author. They said: “The UK Government’s Health Secretary Wes Streeting MP has claimed that the Sullivan Review ‘will lead to better, more inclusive and fairer outcomes for everyone, including the trans community’. We strongly disagree.
“The Sullivan Review promotes a harmful approach to research that systematically excludes trans and gender diverse people at a time when trans communities already face systemic erasure. It would reduce the ability of UK researchers to recognise and engage with the people involved in a wide range of studies in a dignified and accurate way.”
In the paper, Dr Todd and Professor Callard discuss how the Review misrepresents scientific understandings of sex. They say the Review does not seriously engage with the complexities of sex development and that a more expansive approach to sex can reduce risk of clinical harm. The authors also highlight how narrower definitions of sex foreclose possibilities for some intersex people and those with variations of sex characteristics, who would find it challenging to accurately respond to research that offers no options beyond a sex binary.
The paper also points out that the Review, although consistently appealing to the ‘clarity’ of science and ‘ordinary mainstream views’, discounts decades of social scientific and critical inquiry which has demonstrated that both sex and gender are socially as well as biologically produced. By rejecting significant bodies of medical and social science research, the paper’s authors maintain, the Review frames trans existence as illegitimate.
Professor Callard said: “We can find no evidence trans or gender diverse people were involved in the Review’s design, analysis, or writing. It uses what we see as dehumanising language, including by deploying culture wars about trans participation in sport to make key recommendations and by referring to trans women as ‘males who identify as women’. The Review includes recommendations that encourage researchers to record a person’s sex according to their own observation rather than participants’ self‑description, an approach that could miscategorise both trans and cisgender people. These proposals clearly do not align with basic ethics of participant dignity and autonomy.
“The Review’s recommendations raise serious questions about the independence of scientific inquiry, and we urge decision makers to consider the potential harms the Review could cause if widely taken up.”
The paper showcases how the Sullivan Review’s recommendations are already being used to justify actions which seek to deny trans people’s agency and autonomy. Dr Todd and Professor Callard note that the Review has been referenced in policy documents and reports in the United States and elsewhere that seek to remove concepts of gender and gender identity from research and healthcare frameworks.
Dr Todd added: “If the Sullivan Review’s recommendations are accepted and normalised, they could contribute to a wider rollback of trans inclusion and of the rights of marginalised people more broadly, and undermine critical scholarship internationally.
“We are calling upon researchers across the UK to reject the recommendations of the Sullivan Review and push back on the possibility of their implementation by government and our public institutions.”
The team’s paper, titled ‘A critical response to the UK’s ‘Sullivan Review’ into sex and gender in research and data’, is published in Transactions of the Institute of British Geographers.
First published: 3 February 2026