Consultation outcome

Equality impact assessment - proposed changes to the availability of puberty blockers consultation

Published 11 December 2024

Introduction

The general equality duty that is set out in the Equality Act 2010 requires public authorities, in the exercise of their functions, to have due regard to the need to:

• eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the act
• advance equality of opportunity between people who share a protected characteristic and those who do not
• foster good relations between people who share a protected characteristic and those who do not

The general equality duty does not specify how public authorities should analyse the effect of their existing and new policies and practices on equality but doing so is an important part of complying with the general equality duty.

Summary of policy or proposal

The proposal is to make a permanent order to prevent new patients aged under 18 from beginning to take puberty blockers for the purposes of gender incongruence and/or gender dysphoria, under the care of private prescribers.

Intended aims

The Medicines Act 1968 enables ministers to prohibit the sale or supply of medicines on safety grounds. The previous government used this power to introduce restrictions on the sale and supply of gonadotrophin-releasing hormone (GnRH) analogues (commonly known as puberty blockers). The Medicines (Gonadotrophin-Releasing Hormone Analogues) (Emergency Prohibition) (England, Wales and Scotland) Order 2024 (‘the emergency order’) was made on 29 May 2024, and came into force on 3 June 2024. A separate set of regulations was also introduced in parallel for England, permanently banning new prescribing of puberty blockers as a treatment option for gender incongruence and/or gender dysphoria to new patients within NHS primary care.

A second emergency order will be developed and introduced. This will continue current restrictions and allow time for this consultation to take place ensuring the is no gap in legislative provision.

The aim of the permanent order is to reduce and remove risks to patient safety through ensuring that a consistent approach to prescribing of GnRH analogues is taken by all prescribers.

The permanent order seeks to achieve this aim through:

1. Prohibiting the sale or supply of specified medicines against prescriptions from a UK private prescriber which would start a child or young person under the age of 18 on a medical pathway for gender incongruence and/or gender dysphoria.
2. Prohibiting sale or supply against prescriptions from an EEA or Switzerland registered prescriber for specified medicines to a child or young person under the age of 18.
3. Making exceptions for sale or supply against NHS prescriptions.

The sale or supply of GnRH analogues to a child or young person who is already on a medical pathway for gender incongruence and/or gender dysphoria before 3 June 2024 (when the emergency order came into force) or for purposes other than gender incongruence and/or gender dysphoria will be able to continue, where the prescription is from a UK registered prescriber and is appropriately endorsed with ‘SLS’ (Selected List Scheme) and the patient’s age.

The sale or supply of GnRH analogues under a prescription from an EEA or Switzerland registered prescriber which post-dates the emergency order coming into force is banned in all circumstances for patients aged under 18.

Those who were already on a course of treatment prescribed by an EEA or Switzerland registered prescriber can legally switch to a UK registered prescriber to continue their treatment.

For patients aged 18 or over, a prescription from an EEA or Switzerland registered prescriber will be dispensed in the UK providing verification of age and identity can be shown to the dispensing pharmacist.

A targeted consultation of representative organisations likely to be substantially affected by a potential permanent order is required under the Medicines Act 1968. The consultation seeks views on the restrictions, including on their impact and the benefits and risks of making them permanent.

The final report of the Cass Review (‘the report’) into children’s gender identity services was published on 10 April 2024. The report states that the rationale for early puberty suppression in cases of gender incongruence and/or gender dysphoria remains unclear, with weak evidence regarding the impact on gender incongruence and/or gender dysphoria, and mental or psychosocial health. The effect on cognitive and psychosexual development remains unknown.

Prior to the report’s publication, NHS England announced on 12 March 2024 the end of the routine prescribing of puberty blockers for children aged under 18 to treat gender incongruence and/or gender dysphoria. NHS Scotland announced a ‘pause’ to prescribing puberty blockers to children aged under 18 on 18 April 2024.

Children aged under 18 obtaining puberty blockers as a treatment for gender incongruence and/or gender dysphoria when the evidence is weak on its impact and/or benefit is a patient safety issue. In the wake of the Cass Review final report’s publication, some international providers stated their intention to continue prescribing puberty blockers to children in the UK, thus the risk to these children is high.

The restrictions are considered necessary to mitigate the acute risk that children unable to obtain puberty blockers through the NHS will seek them through alternative routes, including private providers and international providers. This poses a risk to their health and wellbeing. The consultation is required, under the Medicines Act 1968, when making a determination on whether a permanent order should be made.

Who will be affected

The following may be affected by the proposed permanent order:

• children aged under 18, or their families, obtaining puberty suppressing hormones through private and/or overseas providers for the treatment of gender incongruence and/or gender dysphoria
• healthcare providers, prescribers and dispensing pharmacists adhering to the permanent order or treating people who cannot obtain the medicines, or working with patients who need the medicines for other reasons to ensure the appropriate endorsement is provided
• patients of any age who are prescribed the listed medicines for any reason other than gender incongruence and/or gender dysphoria may be indirectly affected. Prescriptions for these patients also need to be appropriately endorsed or the patient may need to provide proof of age or identity at the point of dispensing

Evidence

The below is an example of evidence that has been gathered so far. This analysis will be developed further using responses to the consultation on a permanent order. This will involve a targeted consultation of representative groups as well as the Commission on Human Medicines (CHM).

The final report of the Cass Review into children’s gender identity services was published on 10 April 2024. The report states that the rationale for early puberty suppression remains unclear, with weak evidence regarding the impact on gender incongruence and/or gender dysphoria-related distress or on mental or psychosocial health. The report states that bone density is compromised during puberty suppression, and that the effect on cognitive and psychosexual development remains unknown. The findings of the report were informed through extensive research, including citing multiple studies, which are set out in the references section of the report (on pages 248 to 263).

NHS England’s national clinical policy on puberty suppressing hormones published on 12 March 2024 confirmed that puberty blockers are no longer available as a routine commissioning treatment option for treatment for children and young people under 18 who have gender incongruence and/or gender dysphoria. This policy was introduced following a careful review of the evidence and a 90-day public consultation. This concluded that there was not enough evidence to support the safety or clinical efficacy of puberty blockers to make them routinely available as a course of treatment.

The Scottish Government decided to pause puberty blockers for under 18s on 18 April 2024, following publication of the final report of the Cass Review. NHS Scotland confirmed it had paused prescribing puberty blockers to children referred by its specialist gender clinic.

Analysis of impacts

Disability

There is little data available on the number of children and young people (CYP) experiencing gender incongruence and/or gender dysphoria who also have a disability. However, written sources indicate that these individuals often present with other conditions.

According to NHS England’s equality and health inequalities impact assessment (EHIA) for their puberty suppressing hormones policy, a significant proportion of those presenting with gender incongruence and/or gender dysphoria have a diagnosis of autism spectrum disorder (ASD). Around 35% of young people referred to the NHS-commissioned specialised service for children and young people with gender incongruence present with moderate to severe autistic traits. Individuals with ASD are likely to share the protected characteristic of ‘disability’. Around 70% of people with autism also meet diagnostic criteria for at least one (often unrecognised) psychiatric disorder that further impairs psychosocial functioning, for example, attention deficit hyperactivity disorder or anxiety disorders. Intellectual disability (an IQ less than 70) coexists in approximately 50% of children and young people with autism.

There are also an increased prevalence of children and young people presenting to the current service with severe forms of mental health problems which may in some cases constitute a ‘disability’ for the purpose of the Equality Act 2010.

The UK government’s LGBT survey (2017) reported that 32.5% of respondents from the transgender and non-binary population self-identified as having a disability (respondents were aged 16 years and above).

Given the prevalence of disability among those presenting with gender incongruence and/or gender dysphoria, making the temporary prohibition order permanent will impact those with this protected characteristic who are accessing puberty blockers via EEA registered prescribers or UK registered private providers. New patients who may have been hoping to access puberty blockers may find it difficult to understand the change.  Existing patients who had accessed puberty blockers but whose route of access is not now available may need additional support. All of these patients may experience impacts on their mental health.

To mitigate this impact, extra guidance is being provided to NHS GPs and to the wider NHS to support patients presenting with gender incongruence and/or gender dysphoria. If they are already under the care of Childrens and Young People’s Mental Health Services (CYPMHS) or Child and Adolescent Mental Health Services (CAMHS) they can contact their team for advice. If they are not, their GP team should offer to see them, and private providers have a duty of care and will be responsible for sourcing appropriate psycho-social support and other alternatives if the prescribing is not continuing. For any new additions to the NHS waiting list prior to the new referral pathway, NHS England has committed to offering mental health support. For those already in NHS tertiary services, care will continue under NHS specialist supervision.

The regulatory tools for affecting prescriber behaviour in the independent or overseas sectors are limited, which is why legislation has been made. The emergency order is a reasonable and proportionate response to the report and NHS England clinical guidelines given the lack of evidence for efficacy of this course of treatment. The consultation will inform the Secretary of State as to whether the restrictions should be made permanent.

Sex

Of referrals to the commissioned service at Tavistock Gender Identity Development Service (GIDS), 69% were of natal females and 31% were of natal males.

The report showed that the final intervention patients received from the Tavistock clinic according to their natal gender, shows that a higher proportion of natal females (57.9%) ended up on both puberty blockers and cross-sex hormones compared to natal males (47.7%).

The policy may disproportionately impact individuals who are natal female based on this data. However, as set out above, mitigations will be put in place to make sure individuals are receiving psychosocial support and onward referral to the appropriate services if they can no longer obtain puberty blockers.

Sexual orientation

NHS England does not hold data on the sexual orientation of individuals who are referred to or seen by the NHS commissioned service. Therefore, we are not in receipt of evidence to appropriately assess the impact of this measure. The consultation for the proposed permanent order will be used to gather further evidence.

Race

The data below shows the ethnicity of children and young people referred to the current commissioned service between July and December 2022. The data was returned by the Tavistock and Portman NHS Foundation Trust in February 2023 and is taken from the NHS England equality impact assessment.

The ethnicity of the 498 patients referred to Tavistock GIDS between July and December 2022 was reported as:

• any other ethnicity - 3 (0.6%)
• Asian or Asian British (any other) - 5 (1.0%)
• Asian or Asian British (Indian) - 1 (0.2%)
• black or black British (Caribbean) - 2 (0.4%)
• mixed (any other background) - 15 (3.0%)
• mixed (white and Asian) - 1 (0.2%)
• mixed (white and black Caribbean) - 2 (0.4%)
• not known (not requested) - 1 (0.2%)
• not stated (client unable to choose) - 152 (30.5%)
• other ethnic group (Chinese) - 1       (0.2%)
• white (any other background) - 11 (2.2%)
• white (British) - 200 (40.2%)
• white (mixed white) - 2 (0.4%)
• white (Polish) - 2 (0.4%)
• did not respond - 100 (20.1%)

There is limited data as to the ethnicity of children referred to children’s gender identity services. Of the data available, a high proportion of individuals are ‘white’. It may be surmised that the permanent order would disproportionately impact individuals who are white because that is because a higher proportion of this populations are white. Mitigations will be put in place for those no longer able to access puberty blockers through their usual prescriber.

Age

The policy covers the prescribing and dispensing of puberty blockers for children aged under 18 suffering from gender incongruence and/or gender dysphoria. It will, therefore, necessarily impact children and young people disproportionately as compared to adults. The very nature of the products is such that they will have this impact.

We have concluded, however, that the fact the policy will mainly impact children and young people is inevitable given the nature of the medicinal product under consideration and does not result in unlawful discrimination. The emergency order is a proportionate response to the findings of the Cass Review that the rationale for early puberty suppression remains unclear, with weak evidence regarding the impact on gender incongruence and/or gender dysphoria, and mental or psychosocial health in this age group.

Using legislative means to prohibit prescribing is a necessary measure given the lack of other options available to government to limit prescribing by the independent sector and EEA registered prescribers. The consultation will inform whether the emergency order, currently in place, should be made permanent.

There may be an impact on patients aged 18 or over who are prescribed puberty suppressing hormones for reasons other than gender incongruence and/or gender dysphoria (around 80,000 prescriptions a year in England). They may be asked by pharmacists to provide additional evidence that the prescription is compliant with the requirements of the legislation, although the proposed permanent order does not apply to their treatment. There are mitigations in the drafting of the emergency order to protect legitimate use and clear guidance has been provided to make clear to pharmacists and patients about what and for whom the proposed permanent order does and does not cover. For example, a prescription for a patient aged 18 or over can be dispensed providing the patient can provide proof of age, whether or not the ‘SLS’ endorsement is present. Any permanent order, arising from the outcome of this consultation and the Secretary of State’s decision, would also include these mitigations.

Gender reassignment

A person has the protected characteristic of gender reassignment under the Equality Act 2010 if the person is proposing to undergo, is undergoing or has undergone a process (or part of a process) for the purpose of reassigning the person’s sex by changing physiological or other attributes of sex.

In their national clinical policy on puberty suppressing hormones EQIA, NHS England stated that considering the application of Equality Act 2010, section 7, to this service, the High Court in R (AA) v NHS Commissioning Board (2023) found that not every child or young person referred to a specialised gender incongruence service will have the protected characteristic of gender reassignment. The court held that children and young people who are referred to such a service do not - at the point of referral or while they remain on the waiting list - share the protected characteristic of ‘gender reassignment’ as a class or cohort of patients. The whole cohort of patients cannot be treated as “proposing to undergo” a process (or part of a process) for the “purpose of reassigning” their sex “by changing physiological or other attributes of sex” as a class. However, as the court found and as NHS England accepts, many children and young people in this position will, individually, have the protected characteristic of gender reassignment at this stage although determining that will involve a case-specific factual assessment.

Of the 45.7 million people (94.0% of the population aged 16 years and over) who responded to the 2021 census, a total of 262,000 people (0.5%) answered ‘no’ to the question ‘is the gender you identify with the same as your sex registered at birth’, indicating that their gender identity was different from their sex registered at birth. Within this group:

• 118,000 (0.24%) answered ‘no’ but did not provide a write-in response
• 48,000 (0.10%) identified as a transgender man
• 48,000 (0.10%) identified as a transgender woman
• 30,000 (0.06%) identified as non-binary
• 18,000 (0.04%) wrote in a different gender identity

The remaining 2.9 million (6.0%) did not answer the question on gender identity.

If data on those accessing medical treatment within the NHS is consistent with population data, it is likely that at least 0.2% of those accessing healthcare identify as a trans man or a trans woman.

Consideration must also be given as to whether direct or indirect discrimination arises in regard to individuals who share this protected characteristic, as GnRH analogues will continue to be routinely available through NHS protocols for children who present with central precocious puberty (CPP). This is a rare disease caused by premature reactivation of the hypothalamic-pituitary-gonadal axis, resulting in the premature development of pubertal pulsatile secretion of gonadotropins in childhood.

The use of GnRH analogues is standard of care as a response to CPP (where patients meet clinical criteria) and the clinical approach is not contested. The various available agents have been licensed for CPP in the UK and in many other countries for over 25 years following a consideration of the outcome of a number of clinical trials. By contrast, the use of GnRH analogues is not authorised for gender incongruence and/or gender dysphoria. GnRH analogues are in use ‘off-label’ for gender incongruence and/or gender dysphoria but there is limited evidence on treatment aims, benefits, risks and outcomes - and the clinical approach is contested. (Off-label means a medicine is used in a different way than that stated in its licence.)

In considering whether discrimination arises, it must be understood that the aetiology and epidemiology of CPP and treatment aims are quite different to that of gender incongruence and/or gender dysphoria. CPP is the early onset of puberty and secondary sexual characteristics (generally accepted as less than 8 years old in girls and less than 9 years old in boys) and it can range in seriousness from benign to malignant variants. The cause is often unclear, but it can be attributable to a number of conditions that may require specialist investigation (such as central nervous system (CNS) tumours, CNS head trauma, genetics, neurofibromatosis type 1, cerebral palsy). GnRH analogues for this cohort will be considered if the child has rapidly progressing symptoms or if bone age is significantly advanced beyond birth age. The physiological aims of GnRH analogues as a response to CPP are to halt pubertal progression and progressive physical development and to preserve or reclaim adult height potential.

NHS England has concluded that no direct discrimination occurs.

Eliminating unlawful (direct and indirect) discrimination

The use of GnRH analogues in this patient cohort for the purpose of blocking puberty is an off-label use and can be said to be an experimental course of treatment for which the evidence base is weak.

The report found that the use of GnRH analogues for this purpose had not been sufficiently studied. There should be rigorous clinical trials to test the efficacy and safety of a course of treatment or medicine before it is used. The review of evidence by the University of York as part of the report found no demonstration of changes in gender incongruence and/or gender dysphoria or body satisfaction as a result of using puberty blockers. 

The aim of the emergency order, any renewal and any permanent order arising out of the consultation will be to protect those seeking puberty blockers for gender incongruence and/or gender dysphoria from accessing puberty blockers from private and EEA registered prescribers. The changes to the Prescription of Drugs Regulations limit prescribing of puberty blockers in NHS primary care. Together these actions will close the routes which patients can legally access medicines which may be actively harmful for them.

Closing legal routes to access the products may mean that those with this protected characteristic may turn to unregulated, black market sources of puberty blockers. However, this type of sale or supply is also prohibited under the emergency order and will constitute a criminal offence. These actions will protect children from starting a course of treatment which may be unsafe and harmful and for which the evidence base is weak.

The impact on those wishing to access puberty blockers and any associated anxiety about not being able to do so will be mitigated by extra support being in place by NHS England. This action is a reasonable response to the report, the clinical guidelines introduced by NHS England, and the lack of evidence for efficacy of this course of treatment.

Advancing equality of opportunity

Equal opportunity is not applicable in this instance as those without this protected characteristic will not be wanting to access puberty blockers for the purposes of gender incongruence and/or gender dysphoria.

Fostering good relations

This is a policy issue with strong opposing views. The emergency order and the proposed regulations are likely to cause further negative reaction among certain groups. Communications and guidance have been developed to reinforce the message that these actions are being taken to restrict unsafe routes through which puberty blockers can currently be obtained, despite the risks and lack of evidence to support their use in this context.

Religion or belief

There is limited available evidence on the religious attitudes of transgender people in the UK, although a trans mental health study found that most people who took part stated that they had no religious beliefs (62%). A data collection exercise of adult gender dysphoria clinics undertaken by NHS England in 2016 reaffirmed the findings of this study but it is unclear as to the extent to which the findings may relate to children and young people.

Therefore, we are not in receipt of evidence to suggest otherwise and therefore are of the view that this potential permanent order does not have any significant impact on individuals who may share this protected characteristic.

Pregnancy and maternity

Data on pregnancy and maternity of transgender patients under the age of 18 is not available. We are of the view that this potential permanent order does not have any significant impact on individuals who may share this protected characteristic.

According to ONS data, the number of conceptions for women aged under 18 years in England and Wales was 13,131 in 2021.

Marriage and civil partnership

The legal age of marriage and civil partnership is 18 years in England and Wales and 16 years in Scotland. We are therefore of the view that this potential permanent order does not have any significant impact on individuals who may share this protected characteristic.

Engagement and involvement

Evidence and testing

The evidence driving this policy is the Cass Review, which emphasises that the rationale for early puberty suppression remains unclear, with weak evidence regarding the impact on gender incongruence and/or gender dysphoria, and mental or psychosocial health.

Since the emergency order came into force in June, we have held fortnightly meetings with NHS England, regulatory bodies, pharmaceutical bodies and royal colleges to understand the impact of the proposed permanent order. From this initial engagement, we have received limited feedback on the impact of the emergency order. We also formally requested written feedback from these groups to inform this advice.

Some concerns were raised around the risk of criminalisation of pharmacists who unknowingly break the law through no fault of their own. For example, if a patient could mislead the pharmacist about their clinical condition or identity. Concerns were also raised around the speed at which the emergency order was issued which could also mean there are some pharmacists who are not yet aware of it and inadvertently dispense a prescription.

The Secretary of State also met with LGBT+ representative groups to hear directly about the health and care issues that are most important to them. The restrictions were discussed, although the conversation was significantly broader and covered a range of topics. Concerns were raised around:

• access to these medicines for patients who were already prescribed a course of treatment by an EEA or Switzerland registered prescriber (on or before 3 June 2024) and ensuring continuity of care
• the impact the restrictions may have on mental health and wellbeing of children and young people with gender incongruence and/or gender dysphoria
• prescribers’ understanding of the new rules

This consultation provides a further opportunity to hear directly from affected stakeholders on what the impacts of the existing emergency order are and the benefits and risks of making the restrictions permanent. This will ultimately strengthen our evidence base.

Shaping policy or proposal

Parties engaged on the emergency orders include but are not limited to: NHS England, the devolved administrations, Community Pharmacy England, the chair of the Commission on Human Medicines, the General Medical Council and the General Pharmaceutical Council. Given the time constraints this has been done to support the delivery and implementation of the emergency order, specifically to support communications with relevant sectors. The BMA and CPE were engaged on changes to the Prescription of Drugs Regulations.

The targeted consultation for a permanent order will engage stakeholders across the health and care system (across the entirety of the UK) including patient representative groups, organisations representing prescribers and pharmacists, and organisations with an interest in child health, gender identity and mental health.

Summary of analysis

The evidence gathered demonstrates the potential for differential impact for those with the protected characteristics of gender reassignment, age, sex and disability. 

Continuation of the restrictions on a permanent basis (subject to consultation) is likely to deliver positive impacts to these groups, for example:

• reductions in clinical risk for all children and young people currently using EEA prescriptions to obtain puberty blockers in the UK, and those who would otherwise seek to do so via this route
• reductions in clinical risk for new patients seeking to use UK private prescribing to obtain puberty blockers for gender incongruence and/or gender dysphoria specifically
• reductions in clinical risk for new patients seeking to use NHS prescribing to obtain puberty blockers for gender incongruence and/or gender dysphoria specifically
• improved consistency of treatment

There are also likely to be some negative impacts (from both the existing temporary ban and making the restrictions permanent), including the following risks:

• a risk to physical or mental health where patients’ treatment is changed or disrupted
• a risk to mental health where patients are unable to get treatment that they were expecting, or which they believed might be beneficial despite limited evidence
• a potential bottleneck if treatment for significant numbers of patients is delayed until the age of 18
• a potential increase in demand for NHS care, if people stop using alternative providers
• a potential risk of patients seeking unsafe treatment and/or the creation of ‘black market’ demand

Overall impact

Restrictions on prescribing, sale and supply mainly effect under 18s, but also impact those over 18 who will need to provide proof of age and identity to receive their EEA prescriptions. With the exception of EEA prescriptions, the sale or supply of puberty blockers for children for reasons other than gender incongruence and/or gender dysphoria, and their use for gender incongruence and/or gender dysphoria among existing patients, will remain permissible subject to the conditions in the legislation.

A permanent order also offers the potential for health gains arising from more appropriate treatment being provided instead of puberty blockers. This consultation seeks to enhance the evidence base, including the effects of the temporary order.

The overall impact is therefore to move clinical practice in line with the recommendations of the Cass Review, with a consistent approach across all settings, such that children and young people presenting with gender incongruence and/or gender dysphoria are provided with a holistic assessment and individualised care plan that identifies and addresses all their needs. 

This change in approach will have a specific impact on patients who have previously accessed puberty blockers through routes that are now not recognised, or patients who had expected to be able to begin this treatment.  Mitigations have been put in place to provide additional support to patients who need it. 

Addressing the impact on equalities

Mitigations

The risks identified will be mitigated in part by the policy design. For the various cohorts involved this includes:

• allowing existing patients to continue their treatment, where they and their clinician consider this to be appropriate for them, or to access alternative support
• clear (clinically-led) communications to patients and all those potentially affected about the new rules
• providing all young people who are on the national waiting list for care in the new children and young people’s gender services with access to mental health services if they or their parents feel that is needed
• ensuring all GPs have clear information and guidance about their responsibilities to these young people and how best to support them and, where appropriate, refer them to specialist services
• ensuring all children and young people’s mental health service are informed about the impacts that these restrictions might have and implications for their services, and the need to ensure that services to be ready to receive any primary care referrals
• enabling the NHS 111 service, which has provision to deal with urgent mental health need, to provide appropriate support and advice to callers who may be impacted by these restrictions
• keeping patients, families and health services informed about these restrictions and the support available to those who need it, and act on feedback received
• ensuring any new additions to the waiting list prior to the new referral pathway will be offered mental health support
• clear signalling by NHS England of crisis support services in the NHS and voluntary sector, for example Samaritans and Papyrus Prevention of Young Suicide
• private providers have a duty of care and will be responsible for sourcing appropriate psychosocial support and other alternatives if prescribing is not continuing

Monitoring and evaluation

Alongside continuing the actions we have set out in the ‘Engagement and involvement’ section of this document, the consultation will enable to us to understand the evidence base further. The consultation specifically asks whether this equality impact assessment appropriately reflects the potential impact of making the restrictions permanent on the protected characteristics.

A second emergency order will be developed and introduced. This will continue current restrictions and allow time for this consultation to take place ensuring the is no gap in legislative provision.

Conclusion

This is an updated version of the equality analysis that was provided for the purposes of the decision to make the existing order.