The Northern Ireland Assembly is seeking the public’s views on its Conversion Practices (Criminalisation) Bill. This bill, if enacted as it stands, will criminalise certain types of consensual conversations, including criminalising parents who disagree with a child’s gender identity.
Please take action to respond to the consultation and tell the Northern Ireland Assembly not to progress this bill.
The deadline for responding is Thursday 1 October 2026
The full text of the bill can be found here: https://www.niassembly.gov.uk/globalassets/documents/legislation/bills/non-executive-bills/mandate-2022-2027/conversion-practices-criminalisation-bill/conversion-practices-criminalisation-bill—as-introduced—fpv.pdf
There is an Online Survey to respond to the consultation. There are questions on the ten clauses of the bill in this survey. Below is our guide to responding to the questions.
Please use your own words. There is a 2,500 character limit for most of the questions on the online form.
Do you support the overall purpose of the Conversion Practices (Criminalisation) Bill?
No.
Please explain your answer, including any areas where you believe the Bill should be amended.
- This bill would criminalise ordinary mainstream Christian pastoral work on personal transformation.
- This bill would criminalise consensual private conversations between clergy and/or counsellors and psychotherapists in the private sector on the one hand, and church members and/or clients on the other.
- There is no need for a new criminal law since there are already laws against verbal and physical abuse.
- There is a serious lack of evidence to support the need for new legislation in this area.
- This bill would criminalise parents who disagree with their child’s choice to self-identify as transgender or non-binary.
- This bill would criminalise adults who agree to help a child or teenager seeking help to deal with LGBT indoctrination from their parents and/or teachers.
- Ordinary responsible parenting such as discouraging sexual activity or restricting access to the internet could be criminalised.
- There is no defence of consent, meaning that consensual conversations will be criminalised.
Offence of providing conversion therapy — Clause 1
Clause 1 would make it an offence to provide or carry out conversion therapy where the person intends to change or suppress the victim’s sexual orientation or gender identity, and the victim suffers physical or psychological harm as a consequence. Do you support this approach?
No
- This bill will criminalise consensual conversations on sexual orientation and gender identity.
- This clause would criminalise parents or other relatives who take steps to try help a distressed child to live as a member of his or her sex.
- There is no defence of consent which means that helping someone who wants to be helped with a conversation could be a criminal offence.
- The threshold of ‘harm’ is very low, meaning that someone being upset of offended could be grounds for an offence being committed.
- The use of “suppress” will capture ordinary parenting or pastoral advice such as to abstain from sexual activity. Advising someone to live according to Biblical sexual ethics could be a criminal offence.
- No government should seek to criminalise consensual conversations between adults.
Are the elements of the offence sufficiently clear, including the requirements relating to intent, harm, the reasonableness defence, consent and penalties?
No
- Consent must be a defence in any case involving consensual conversations.
- The defence of “reasonable” is very unclear. There is no definition of what counts are “reasonable.” This means that people will be arrested and prosecuted and will not know whether they have committed an offence until the courts decide.
- Excluding a defence of consent means that courts are stripped of the primary objective measure of ‘reasonableness’.
- There is no definition of “suppress” which means that ordinary parenting or pastoral guidance could be a criminal offence.
Offence of engaging in coercive conversion behaviour — Clause 2
Clause 2 would make it an offence to engage in coercive conversion behaviour where the person intends to change or suppress the victim’s sexual orientation or gender identity, and the victim suffers physical or psychological harm as a consequence. Do you support this approach?
No
- This clause would criminalise parents or other relatives who take steps to try help a distressed child to live as a member of his or her sex.
- The consultation does not offer guidance as to how courts could isolate pastoral speech or relational accountability as the direct cause of psychological harm to an individual. It does not therefore provide the ability to prove harm beyond reasonable doubt, as would be required by the courts.
- It is unclear what would count as “reasonable” in any defence leaving people unsure whether a conversation would be criminal or not.
- Ordinary parenting includes encouraging children to abstain from sexual activity and to learn self-control which could fall foul of “suppression” in this bill.
- The threshold of ‘harm’ is far too low. People often feel ‘fear, alarm or distress’ when discussing sensitive issues in conversation, even when the other person is being helpful and supportive.
Are the elements of the offence sufficiently clear, including the requirements relating to intent, harm, the reasonableness defence, consent and penalties?
- The term ‘coercive conversion behaviour’ here is likely to capture language that is intended to convey religious moral authority, advice and guidance as inherently or tending to be coercive.
- Freedom of Religion (Article 9) and Freedom of Expression (Article 10) protect not merely mild, neutral, or agreeable speech, but the right to preach, persuade, advocate for moral standards, and teach voluntary self-restraint. Classifying non-violent, persuasive speech as inherently “coercive” weaponises the criminal law to suppress orthodox religious beliefs on marriage, sexuality, and gender.
- There is no defence of consent which means that a consensual conversation could be deemed ‘coercive. People must be able to have consensual conversations without fear of criminalisation.
- It is not clear what the defence of “reasonable” actually means.
- It is draconian and totalitarian to threaten to criminalise consensual conversations.
Clause 3 would make it an offence to cause or facilitate a person leaving Northern Ireland for the purposes of being subject to conversion therapy or coercive behaviour. Do you support this approach?
No.
- This will have a chilling effect on people who travel to the UK for Christian conferences. They could risk a criminal offence if one person in the party later complains they had a conversation which counts as conversion practice.
- The term “facilitate” is exceptionally broad in criminal jurisprudence. It could capture booking an airline ticket, providing transport to an airport, contributing to travel costs, or sharing information about a Christian conference, youth camp, or pastoral retreat outside Northern Ireland (whether in the Republic of Ireland, Great Britain, or further abroad).
- Parents have a well-established right under human rights law to guide their children’s upbringing and education in accordance with their religious and philosophical convictions. Threatening to criminalise parents who take or send their children to international Christian conferences violates fundamental rights to family life and religious upbringing.
- Someone going overseas is likely to go to a country without a conversion therapy ban. Such a country will likely refuse to comply with requests for evidence gathering, arrest and extradition.
- If a competent adult voluntarily requests help to travel abroad for religious ministry, prayer, or counselling aligned with their faith, a pastor or friend assisting them would be guilty of an offence. Because clause 3(3) of the Bill excludes consent as a defence, the adult’s explicit request offers no legal protection to the person assisting them.
Are the elements of the offence sufficiently clear, including the requirements relating to intent, recklessness as to harm, the reasonableness defence, consent and penalties?
No.
- Consent must be a defence for any offence of this kind.
- It is incoherent to allow the defence that ‘conversion therapy’ was ‘reasonable in the particular circumstances’ whilst denying consent as a defence.
- A broad statutory defence of ‘reasonableness’ does not provide any legal clarity for defendants.
- If the bill excludes consent as a defence, courts are stripped of the primary objective measure of reasonableness.
- Threatening criminal penalties for taking people to the UK for Christian activities is draconian.
Clause 4 defines conversion therapy as including counselling or any form of talking therapy, coaching or instruction, and treatment or purported treatment. Is this definition sufficiently clear and appropriate?
No.
- What counts as “talking therapy” is left undefined. It could be any form of consensual conversation.
- The fact that no payment is required will mean that informal conversations or counselling would be captured.
- Standard parenting or pastoral care could be captured as an offence.
- “Coaching or instructing” could include ordinary parenting.
Does Clause 4 provide sufficient clarity on the circumstances in which regulated healthcare professionals would fall outside the scope of the offence?
No.
- Exempting certain people from the offence undermines the need for any offence at all.
- Parents should also fall outside the scope of the offence.
- Clause 4 only exempts therapy provided or carried out by individuals registered by or subject to regulation by the listed professional bodies.
- This will mean that therapy conducted by regulated healthcare professionals intended to change a person’s sexual orientation to same-sex sexual orientation, or to change a person’s gender identity towards a transgender or non-binary identity, is exempt from criminalisation.
- A person being encouraged to identify as transgender by a regulated professional will have no recourse under the law for unethical and unscientific advice.
- Clause 4 undermines equality before the law with respect to potential victims of unethical healthcare professionals.
Clause 4 would allow the Department of Health, by order subject to Assembly approval, to amend the list of regulatory bodies whose registered professionals may fall outside the scope of the conversion therapy offence when acting in accordance with applicable standards and codes of ethics. Is this delegated power appropriate?
No.
- The Department of Health could add more bodies to the list, thus expanding the scope for conversion therapy in one direction (intending to change a person’s sexual orientation towards same-sex sexual orientation, or a person’s gender identity towards transgender or non-binary identity). This would create inequality before the law.
- If therapy or counselling with the goal of changing sexual orientation and/or gender identity is to be criminalised, it only makes sense to criminalise it in all cases including change towards same-sex sexual orientation and transgender/non-binary gender identities.
- Recognising that some people should be exempt from the offence shows that there is no real need for a new offence.
Clause 5 defines coercive behaviour for the purposes of the Bill. Is the definition sufficiently clear and workable?
No.
- “Monitoring” is normal parenting practice. It should not be criminalised.
- “Regulating” is also normal parenting practice.
- Teachers or pastoral assistants or social workers may also engage in regulating or monitoring a person’s behaviour.
- The definition of coercive behaviour relies on subjective feelings of the alleged victim, such as “feeling frightened”, or being “punished.” Parents routinely and legitimately punish children for bad behaviour.
- Parents should not be criminalised for protecting their children from harmful content online, for example.
Does the requirement that coercive behaviour must take place on two or more occasions provide an appropriate threshold for the offence?
No.
- Pastoral care, discipleship, confirmation classes, and spiritual mentoring are inherently recurring practices.
- Setting the threshold at ‘two or more occasions’ means routine weekly ministry or regular pastoral care automatically satisfies the frequency element of the offence, lowering the barrier to criminalising ordinary church life.
- Normal responsible parenting involves repeating certain conversations or instructions multiple times. This will be criminalised.
- There only needs to be two instances of a teenager feeling “distress” which is a very low threshold for a criminal offence.
- This bill risks criminalising repeated family disagreements or discussions.
Clauses 6 and 7 define sexual orientation and gender identity, and set out when there is, or is not, intent to change or suppress sexual orientation or gender identity. Are these provisions sufficiently clear?
No.
- These definitions are entirely subjective to the victim’s mind. The victim may change their mind at any given moment, and no one can know that this has happened.
- There is no actual definition of what “gender identity” means in law. It is purely subjective.
- Criminal law cannot be based on personal perception of identity at a point in time.
- Given that the clauses specify that sexual orientation and gender identity are as understood by the ‘victim’ and the person, and therefore stress personal agency in identification, it makes no sense for the bill as a whole to deny consent as a defence.
- The Bill creates a legal contradiction: it grants an individual total agency to define their identity, but strips them of Article 8 ECHR autonomy to seek spiritual counsel, prayer, or guidance to live in accordance with their religious convictions regarding that identity.
Do these clauses provide sufficient protection for legitimate expression of beliefs or opinions, and for support which affirms a person’s sexual orientation or gender identity?
No.
- These clauses do not provide sufficient protection for legitimate expression of beliefs or opinions.
- Stating a belief in a conversation is nearly always intended to change or influence the other person’s beliefs. Thus “intent to direct” will capture ordinary conversations.
- Christian ministry involves persuading people to live according to Biblical sexual ethics. This type of ordinary Christian ministry will be criminalised.
- Explaining to someone the Christian belief that marriage is between a man and a woman could be a criminal offence under this bill.
- Affirming someone in a transgender identity would not be an offence under this bill, while questioning a person’s transgender identity would be an offence. This will criminalise parents who question a child’s gender identity.
Clause 8 provides that psychological harm includes fear, alarm or distress. Is this definition appropriate and sufficiently clear for the purposes of the offences in the Bill?
No
- ‘Psychological harm’ is downgraded to the momentary emotions of fear, alarm or distress, which could lead to trivial malicious and vexatious reports to the police.
- The threshold is set at mere feelings of fear alarm or distress which is far to low for a criminal offence.
- The threshold is subjective. Anyone can claim they felt fear, alarm or distress after the fact and this is very hard to disprove.
- People often feel distressed when discussing sensitive topics. This should not make the conversation a criminal offence.
There may have been no intent to cause any harm, but if the victim claims they were distressed then this still counts as a criminal offence.
Clause 9 would amend the Magistrates’ Courts (Northern Ireland) Order 1981 so that there would be no right to claim trial by jury for offences under clauses 1, 2 or 3. Do you agree with this approach?
No
Trial by jury is a fundamental right. Criminalising consensual conversations needs to be properly assessed by a jury of ordinary citizens.
Clause 10 provides that the Act would come into operation 12 months after Royal Assent. Is this an appropriate period to allow for preparation and implementation?
We do not think there is a particular need to answer this question.